Affinius Capital, its subsidiaries and affiliates, including Affinius Capital Europe B.V. (together, “Affinius Capital”), are committed to protecting the privacy and security of personal data provided as part of an application for employment. This Applicant Privacy Policy (“Policy”) explains what personal data we collect regarding employee recruiting, how we use that data, and your rights.

Personal Data That We Collect

 Personal data that you provide: To process your application, we ask you to provide certain personal data. You provide the information voluntarily, and you determine what information to provide. However, some information is required for us to complete our evaluation of your application, and without sufficient information we may have only a limited ability to evaluate you as a candidate. When you complete an employment application, we collect information about your education and employment history, contact information, job qualifications, eligibility, and job interests. You may provide additional information, such as your resume, transcripts, references, and compensation request.

 Data we receive from other sources: We may obtain information about you from other sources, to the extent permitted by applicable law, which sources include employment research firms, recruiters, identity verification services, and other Internet websites (for example, LinkedIn). In addition, where permitted by law, we use a third party to carry out a background check to determine your suitability for a position.

How We Use Personal Data

Affinius Capital uses your personal data collected in our recruiting process in the following ways:

(i) to process and evaluate your application and make hiring decisions (necessary to respond to your request that we process your application for employment);

(ii) to communicate with you and inform you of current and future career opportunities, pursuant to our legitimate interest in doing so (unless you tell us that you do not want us to keep your details for that purpose);

(iii) to manage and improve our recruiting and hiring processes, pursuant to our legitimate interest in doing so (unless you tell us that you do not want us to keep your details for that purpose);

(iv) to conduct reference and background checks where required or permitted by applicable local law or for compliance with corporate governance and legal and regulatory requirements.

When the applicable law is U.S. law or the law of another country outside the European Economic Area (“EEA”), processing of applicants’ information for compliance with legal and regulatory obligations is necessary for the legitimate interests of Affinius Capital in complying with those laws.

If you are hired, your personal data will be maintained and used as part of your employee record under our Employee Privacy Policy.

Sharing and Disclosure of Personal Data

We share your personal data only as necessary to evaluate your application and for legitimate business interests, as described below:

 Affinius Capital Affiliates: If you will be employed by an Affinius Capital affiliate, then Affinius Capital will share your personal data with that affiliate. Our affiliates will be required to treat your personal data in accordance with this Policy.

 Service Providers: Affinius Capital uses other companies and individuals to provide services on its behalf. For example, we use vendors to assist with recruiting, payroll employment consulting, legal matters, and background checking. These providers process or store personal data while performing their contractual duties to Affinius Capital. We require that the service providers process your data only pursuant to our instructions and solely to meet their contractual obligations in the performance of the specific functions described above, and have appropriate measures in place to protect that data. If these providers are located outside the EEA, then Affinius Capital will ensure protection of your personal data when transferring the data to those providers.

 Legal Requirements: Affinius Capital may disclose your data if required or permitted to do so by law (such as when part of a governmental agency action or litigation), governmental or quasi-governmental requests, or a regulatory organization, or to relevant third parties such as site technicians, brokers, auditors, lawyers, or professional advisors.

Storage and Retention of Personal Data

Personal data submitted as part of your application will be transferred to Affinius Capital in the United States as necessary to process your application for employment. The United States may have data protection laws less stringent than or otherwise different from the laws in effect in the country in which you are located. We will take steps to ensure that your personal data receives an adequate level of protection where it is processed. If you are hired, then your personal data will be transferred pursuant to standard contractual clauses for the transfer of personal data between Affinius Capital Europe B.V. and Affinius Capital.

Affinius Capital will retain personal data in accordance with our retention policy for that information (personal data obtained from employee candidates is kept for two years from the end of the calendar year in which it is received, unless you tell us that you do not want us to retain your data so we can inform you of current and future career opportunities, as described in this Policy). When we have no justifiable business need to process your personal data, we will either delete or anonymize it in a way that it can no longer be associated with any individual, so it is no longer personal data.

Protection of Personal Data

Affinius Capital understands the importance of securing personal data, and uses reasonable administrative, physical, and technological security measures to help prevent personal data from unauthorized use, access, or disclosure.

Rights in Relation to Personal Data

You may have certain rights with respect to your personal data under applicable data protection laws.

Pursuant to data protection laws in the EEA, you have the following rights in relation to your personal data:

 Right of access: If you ask us, we will confirm whether we are processing your personal data and, if we are, provide you with a copy of that personal data along with certain other details. If you require additional copies, we may need to charge a reasonable fee.

 Right of erasure: You may ask us to delete or remove your personal data.

 Right to object to processing: You may ask us at any time to stop processing your personal data, and we will do so when the legal basis of the processing is a legitimate interest (described under the “How we use personal data” section of this Policy), unless Affinius Capital demonstrates compelling, legitimate grounds for the processing.

 Right to data portability: You may obtain personal data from Affinius Capital when the legal basis of the processing is consent or the necessity of the processing to perform a contract.

 Right to rectification: You may require Affinius Capital to correct any inaccurate or incomplete personal data.

 Right to restrict processing: You may ask that Affinius Capital restrict processing of personal data in certain circumstances (for example, where you believe that the personal data is not accurate or lawfully held, or when you previously objected to the processing).

 Right to lodge a complaint with the data protection authority: If you have a concern about Affinius Capital’s privacy practices, including the way that Affinius Capital has handled your personal data, you can report it to the data protection authority authorized to hear those concerns.

Affinius Capital acts as a data controller for personal data under this Policy.

If you would like to exercise any of the above rights, please contact gdprinforequest@affiniuscapital.com so that we may consider your request under applicable law. To protect your privacy and security, we may take steps to verify your identity before complying with the request.

Transfer of Business

On a merger, consolidation, sale, or transfer of all or substantially all of the assets or business of Affinius Capital, we may need to transfer your personal data in our possession to the relevant successor to the business. Affinius Capital will advise those successors of the terms of this Policy and of our expectation that the successors will adopt and maintain this Policy until there is a notification of an amendment of this Policy.

Privacy Policy Changes

Affinius Capital and any successors may revise this Policy from time-to-time. If a material change is made to this Policy, then we will notify you of the change in accordance with the applicable law.

Contact

For more information about this Policy, please contact Affinius Capital's Human Resources department at Employment@affiniuscapital.com.