Data Privacy Policy

1.1 PERSONAL INFORMATION

“Personal information” is information that can be associated with a specific person and could be used to identify that specific person whether from that data or from that data and other information that Opcom has or is likely to have access to. We do not consider personal information to include information that has been made anonymous or aggregated so that it can no longer be used to identify a specific person, whether in combination with other information or otherwise.

1.2 CHANGES TO THIS PRIVACY POLICY

We may amend this Privacy Policy at any time by posting the amended terms on this site. All amended terms automatically take effect 30 days after they are posted. We will announce any material changes to this Privacy Policy on the Website or via email.

2.1 CANDIDATE PERSONAL DATA

The personal information we collect includes the following information: – Name; – Age; – Sex/gender; – Profile picture; – Marital status; – Contact details; – Education details; – Employment history; – Languages; – Personal goals; – Salary expectations; – Referee details; – Immigration status (whether you need a work permit); – Nationality/citizenship/place of birth; – Social security number (or equivalent in your country) and any other tax-related information; – Details about your current remuneration, pensions and benefits arrangements; – Information on your interests and needs regarding future employmen; – Extra information that you choose to tell us; – Extra information that your referral contact chooses to tell us about you; – Extra information that our Clients may tell us about you, or that we find from other third party sources such as job sites; – IP address;

2.1.1 WE COLLECT CANDIDATE PERSONAL DATA IN THE FOLLOWING WAY:

Personal information you give us – Personal information from other sources – Mailing your CV to Opcom – From our web site where you leave your contact details – From third party researcher, recruiting agencies and by analysing online and offline media. From our employees to the extent that they provide us with your details to act as a referral If you give us personal information about someone else, you must do so only with their explicit and prior consent. You have to inform them how we collect, use, disclose and retain their personal information according to our Privacy Policy.

2.2 CUSTOMER PERSONAL DATA

The personal information we collect includes the following information: – Name, – Sex/gender, – Position, – Company, – Contact details, – Employment history, – Information on your interests and needs; – Extra information that you choose to tell us; – IP address;

2.3 EMPLOYEE AND ALUMNI PERSONAL DATA

The personal information we collect includes the following information: – Name, – Sex/gender, – Position, – Company, – Contact details, – Employment details – Account Information, – Social contribution information, – Employment history, – Timesheets including all booking types such as sick leave, annual leave, performance time – Extra information that you choose to tell us; – Information discussed in Dialogs – The dates, times and frequency with which you access our systems – Pictures – Information on your interests and needs.

2.3.1 WE COLLECT EMPLOYEE PERSONAL DATA IN THE FOLLOWING WAY:

Personal information you give us – Personal information we collect automatically – Personal information from other sources- in appointments, Dialogs – in personal discussions with your superior or with other business related roles. Customer feedback about mandate performance Pictures from events. If you give us personal information about someone else, you must do so only with their explicit and prior consent. You have to inform them how we collect, use, disclose and retain their personal information according to our Privacy Policy.

2.4 SUPPLIER PERSONAL DATA

The personal information we collect includes the following information: – Name, – Sex/gender, – Position, – Company, – Contact details, – Extra information that you choose to tell us;

2.4.1 WE COLLECT SUPPLIER PERSONAL DATA IN THE FOLLOWING WAY:

Personal information you give us – Personal information from other sources. If you give us personal information about someone else, you must do so only with their explicit and prior consent. You have to inform them how we collect, use, disclose and retain their personal information according to our Privacy Policy.

2.5 WEBSITE VISITOR DATA

The personal information we collect includes the following information: – Name, – Last Name, – Contact details including email address – Extra information that you choose to tell us;

2.5.1 WE COLLECT VISITOR PERSONAL DATA IN THE FOLLOWING WAY:

Personal information you give us – Personal information from other sources. If you give us personal information about someone else, you must do so only with their explicit and prior consent. You have to inform them how we collect, use, disclose and retain their personal information according to our Privacy Policy.

3.1 Personal Data

3.1.1 CANDIDATE PERSONAL DATA

We use personal information we collect for: – Recruiting Activities – Marketing Activities

3.1.2 CUSTOMER PERSONAL DATA

We use personal information we collect for: – Recruiting Activities – Marketing Activities – Providing our Services

3.1.3 EMPLOYEE PERSONAL DATA

We use personal information we collect for: – Recruiting Activities – Marketing Activities – HR related Activities – Providing our Services

3.1.4 WEBSITE VISITORS PERSONAL DATA

We use personal information we collect for: – Marketing Activities – Provide, improve and personalize our Websites

3.2 MARKETING ACTIVITIES

The following describes our use of personal data for marketing purposes: – Targeted E-mail – – Combining and Analysing Personal Data

3.2.1 TARGETED E-MAIL

We send commercial e-mail to individuals at our client or other companies with whom we want to develop or maintain a business relationship in accordance with applicable marketing laws. Our targeted e-mail messages typically include . Targeted e-mails from Opcom may include additional data privacy information, as required by applicable laws.

3.2.2 COMBINING AND ANALYZING PERSONAL DATA

As described above, we may combine data from publicly available sources, and from our different e-mail, website, and personal interactions with you (this includes information collected across website. We combine this data to better assess your experience with Opcom and to perform the other activities described throughout our privacy policy.

3.2.3 YOUR RIGHTS

You can exercise your right to discontinue marketing communications to you at any time by using our Contact Us form. In such cases, we will retain minimum personal data to note that you opted out in order to avoid contacting you again.

3.3 RECRUITING ACTIVITIES

Recruiting Activities includes the following processes: – Validation of the candidate in order to check whether the candidate suits one or multiple vacancies (based on the screenings by recruiters, line managers and domain experts of Opcom). – Keeping the candidate in a candidate pool for later consideration up to three years after receiving the candidate’s personal data. – Linking personal data, which has been submitted via above defined sources, and information which were provided by the candidate during the screening/interview process (including technical exercises, email correspondence, written telephone protocols and similar data). – In case of employment, the personal data may be forwarded to external partners for work contract preparation and work permit organization.

3.4 HR RELATED ACTIVITIES

HR Activities includes the following processes: – Entry & leave process – Performance review – Employee development – HR Administration processes including pay-rolling

3.5 PROVIDING OUR SERVICES

Providing our Services includes the following processes: – Winning Mandates (submitting CV to Customers) – Project Performance Reviews

3.6 PREVENT, DETECT, MITIGATE AND INVESTIGATE FRAUDULENT OR ILLEGAL ACTIVITIES

Prevent, detect, mitigate and investigate fraud, security breaches, potentially prohibited or illegal activities Enforce our Privacy Policy, our User Agreement or other policies

3.7 DATA RETENTION

We retain your personal information as long as it is necessary and relevant for our operations, in general 10 years. In addition, we may retain personal information from closed accounts to comply with national laws, prevent fraud, collect any fees owed, resolve disputes, troubleshoot problems, assist with any investigation, enforce our User Agreement and take other actions permitted or required by applicable national laws. After it is no longer necessary for us to retain your personal information, we dispose of it in a secure manner according to our data retention and deletion policies.

3.7.1 RETENTION CANDIDATE DATA

The personal data of the candidate will be saved up to two years. Afterwards, the personal data of the candidate will get deleted manually. However, saving the personal data of the candidate for a longer time range than three years can be agreed between the candidate and Opcom in a written form (where applicable; depending on legal situation of the corresponding country). The candidate will always be able to request a deletion of her/his personal data via email or via post (see imprint for further

4.1 WITHDRAW CONSENT

If you wish to withdraw your consent, please send us an email to [email protected]. Please consider, that if you withdraw your consent for the use or disclosure of your personal information for purposes set out in this Privacy Policy, you may not have access to all our Services and we might not be able to provide you all of the Services and customer support offered to our users and authorized under this Privacy Policy.

6.1 OPCOM CUSTOMERS

Submitting CV of our employees and partner CVs towards Customers to verify the expertise level

6.2 SERVICE PROVIDERS AND FINANCIAL INSTITUTION PARTNERS

Third party service providers who help us to provide our Services, payment processing services, to assist us with the prevention, detection, mitigation and investigation of potentially illegal acts, violations of our User Agreement, fraud and/or security breaches, bill collection, and other business operations – Third party service providers who provide us Cloud Services and Cloud Storage

6.3 LAW ENFORCEMENT, LEGAL PROCEEDINGS AND AS AUTHORIZED BY LAW

To comply with our legal requirements, respond to claims that a listing or other content violates the rights of others, or protect anyone’s rights, property or safety. – to law enforcement or governmental agencies, or authorized third-parties, in response to a verified request relating to a criminal investigation or alleged or suspected illegal activity or any other activity that may expose us, you, or any other of our users to legal liability. We will only disclose information we deem relevant to the investigation or inquiry, such as name, city, state, postcode, telephone number, email address, fraud complaints – to third parties involved in a legal proceeding, if they provide us with a subpoena, court order or substantially similar legal procedure, or we otherwise believe in good faith that the disclosure of information is necessary to prevent imminent physical harm or financial loss or to report suspected illegal activity.