BALLUFF U.S. APPLICANT TRACKING SYSTEM PRIVACY POLICY

Effective date: July 1^st, 2025

At BALLUFF, INC. (“BALLUFF,” “we,” “us,” and “our”), we respect your privacy and are committed to protecting it through our compliance with privacy and data protection laws. This Balluff US Applicant Tracking System (“ATS”) Privacy Policy (otherwise referred to as the “Policy”) covers information we may collect from applicants and how we may use, retain, and secure such information through our use of the ATS operated via Paycom.

1. What data we may collect about you

We may collect the following categories of information about you when you apply for a position with us:

• Personal Identity Data which includes first name, last name.
• Contact Data which includes mailing address, email address, and telephone number.
• Employment Data which includes your current and or previous employers, job titles or positions, references, and whether you are legally authorized to work in the United States or if you require or anticipate requiring sponsorship to work in the United States.
• Other Academic, Professional, Training and Salary Related Data which includes academic degrees and professional qualifications.
• Resume/CV Data which may include details of any memberships or interests you may have, so please only share information that is directly related to your application for a position with us.
• Application Information which includes administrative information related to active or previous applications you have submitted to us and/or any previous employment history you may have with us.
• Demographic Information which includes about your ethnicity, disability status, and veteran status. You are not required to provide this information to apply for a position with us. We do not use this information to inform interview and/or hiring decisions, nor do we process this information to infer characteristics about you. Finally, this information is not shared with third parties.
• Reference Information which includes the reference’s name, relationship to you, title, and contact information.
• Correspondence Information which includes correspondence history related to your job application.
• Account Data which includes your ATS login ID and password.
• Internet or Other Electronic Network Activity Data which includes your device hardware information, operating system, platform information, browser type, language information, and browser plugin types.
• Usage Data which include information about how you use the ATS.
• Other Data which includes any other information you provide to us during the application process or through your use of the ATS, including from which career portal or third-party site you may have submitted your application.

2. How we collect your data

We may collect personal data in two ways:

• Directly from you. We will generally collect personal data directly from you as part of the recruitment and/or application process, using the ATS.
• Through technology and devices. This includes data we automatically collect using cookies and other technologies when you use your devices, software, or browser to access and use the ATS.

3. Reasons for processing your personal data

Balluff processes your personal data to fulfill our legal obligations which require compliance with applicable law, such as labor and employment and privacy laws. In addition, we process your personal data to fulfill your request to apply for a position with us. We may also process your personal data for our legitimate interests such as making hiring decisions.

4. How we use your personal data

Balluff may use your personal data for the following purposes:

• Administrative purposes which include registering individuals on the ATS, managing the ATS, and maintaining and updating our contact information and job applicant pool.
• Communication purposes which include contacting individuals who use the ATS through mail, phone calls, or email for human resources purposes such as to schedule an interview, request additional information, or notify of a hiring decision.
• Interview-related activities purposes which include providing your information to travel agencies, hotels, or other travel related services for interviews.
• Reporting purposes which include preparation of evaluations for offered compensation, legal compliance audits, and legal claims.
• Legal compliance purposes which include any legal correspondence with you, complying with applicable laws, or responding to court orders or government agency requests.

5. Disclosing your information

• Affiliates: We may disclose your personal data to individuals in our affiliates, specifically our parent company, subsidiaries, and affiliates if they participate in the interview or hiring process. When we disclosure your personal information to our affiliates, we will transfer your data in a manner consistent with this Policy and all applicable data privacy laws.
• Service providers: We may disclose your personal data to our service providers, consultants, and legal advisors to support our business. This includes IT infrastructure providers, HR solution service providers such as Paycom, and audit firms and law firms. These Service Providers are bound by contractual obligations to protect your personal data in accordance with our Policy and applicable privacy laws.
• Other Third parties for legal compliance: We may share your personal data with courts and government agencies when we have a good faith belief that disclosure is necessary to comply with a law, regulation, court order, or other legal processes.

6. Disclosures of your personal information

We allow access to personal information only to those who require such access to perform their tasks and duties and to third parties who have a legitimate purpose for accessing it. If we permit a third party to access personal information, we will do so only after implementing appropriate measures to ensure the information is used in a manner consistent with this Policy, including appropriate security and confidentiality safeguards.

7. Use of ATS

We may use ATS technology to automatically sort, rate, or filter candidates using criteria specified by us. However, any decision made with respect to interviewing and/or hiring a candidate for one of our positions will be made by our staff using all information available to them. We do not use ATS for automated decision-making purposes.

8. Cookies and Automatic Data Collection Technologies

ATS may use the following automatic data collection technologies:

• Cookies (or browser cookies). A cookie is a small file placed on the hard drive of your computer. You can set your browser to refuse all or some browser cookies, or to alert you when websites set or access cookies. However, if you disable or refuse cookies, some parts of these websites may become inaccessible or not function properly.
• Web Beacons, Pixel Tags, Clear Gifs. Our website, the ATS, and our emails may contain small transparent embedded images or objects known as web beacons (also referred to as clear gifs, pixel tags, and single-pixel gifs) that permit us, for example, to compile other similar statistics such as tracking website content popularity or verifying system and server integrity.
• ATS. We use Paycom ATS analytics service. More information about how Paycom collects and processes data, and your rights regarding Paycom’s processing of your data can be found at Paycom Privacy Policies.

9. Retention of Your Information

All personal data is treated confidentially and retained in compliance with applicable laws and regulations. Your personal data will only be retained if we need it to fulfill contractual, legal, or internal process obligations. As soon as these obligations cease to apply, we will delete your data, unless legal retention obligations (e.g. commercial or tax retention obligations) prevent deletion. We may retain your application data for future relevant job opportunities with us.

10. Third-Party Processing

ATS is a cloud-based Human Resource Information System provided by Paycom that provides different services to manage the job application lifecycle. We use ATS to manage our application lifecycle. We do not control Paycom’s systems. Paycom has its own privacy policies and terms for processing your personal data. We encourage you to read those policies and terms before interacting with ATS.

11. Children

The ATS is not intended for children under 18 years of age. We will not knowingly solicit or collect personal data from children under 18, or the relevant minimum age under applicable local legal requirements, except as permitted under applicable law. If we learn that we have received information directly from a child under 18 without his or her parent’s or legal guardian’s consent, we will make commercially reasonable efforts to delete such information.

12. Your Rights and Choices

Your rights may vary depending on where you are located. Contact us as set forth below to request access to, correction of, deletion of, data portability of personal data that you have provided to us. Please note that many state privacy laws do not provide consumer privacy rights to individuals in the job applicant/employment context.

If processing is based on your consent, you have the right to withdraw your consent at any time. You can send the withdrawal to angela.wind@balluff.com. You can also delete the relevant data yourself within the ATS. The lawfulness of processing pursuant to consent until your withdrawal is not affected by revocation of your consent.

As noted above, depending on in which U.S. state you reside, you may have rights under certain U.S. state consumer privacy laws. However, these rights are not absolute, and in certain cases, we may decline your request as permitted by law. These rights may include:

• Right to know about the personal information we collect about you and how it is used and shared
• Right to delete personal information collected from or about you (with some exceptions)
• Right to correct inaccuracies in your personal data
• Right to obtain a copy (“portability”) of the personal data you previously shared with us
• Right to non-discrimination for exercising your data subject rights
• Right to opt out of the sale or sharing of your personal data ( as defined under applicable U.S. state privacy law),
• Right to obtain a list of the categories of third parties to which we have disclosed personal data (as permitted by applicable law)
• Right to limit use and disclosure of sensitive personal data (as permitted by applicable law)

How to Exercise Your Rights To exercise your rights, you can contact us by submitting a data subject access request via email to angela.wind@balluff.com, or by using other contact methods provided below.

Under certain U.S. state data protection laws, you may designate an authorized agent to make a data subject request on your behalf. We may deny a request from an authorized agent that does not submit written proof that they have been validly authorized to act on your behalf in accordance with applicable laws.

Request Verification Upon receiving your verifiable request, we may need to verify your identity to determine you are the same person about whom we have information in our system. If you have submitted a request to opt-out of the sale of your information, to opt-out of targeted advertising, or to opt-out of certain processing we will comply with such a request without any additional verification. For all other requests, we will make all commercially reasonable attempts to only use personal information provided in your request to verify your identity or authority to make the request. However, if we cannot verify your identity from the information already maintained by us, we may request that you provide additional information, consistent with applicable law.

If you submit the request through an authorized agent, we may need to collect additional information to verify your identity before processing your request, and, as noted above, the agent will need to provide written and signed permission from you to submit such request on your behalf. As noted above, requests submitted through an authorized agent to opt-out of the sale of your information, to opt-out of targeted advertising, or to opt-out of certain processing do not require verification.

13. Data Security

We use physical, electronic, and administrative safeguards to endeavor to protect your personal data from loss, misuse and unauthorized access, use, alteration, or disclosure. However, the Internet environment is not 100% secure, and we cannot guarantee that information we process will never be accessed in an unauthorized way.

14. Changes to our privacy policy

Changes to this Policy will be posted to the ATS, along with information on any material changes. We reserve the right to update or modify this Policy at any time and without prior notice.

15. Contact Us

If you have any questions about data protection at Balluff, we will be pleased to assist you. If you have any complaints or wish to assert your rights, please contact us at angela.wind@balluff.com.

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