PRIVACY POLICY FOR THE TEAMTAILOR PLATFORM

By creating this account, we inform you that Keyrus Consultadoria Portugal, Unipessoal Lda will proceed to process your personal data in order to incorporate it into present and future selection processes that may be carried out, in accordance with the provisions of Regulation (EU) 2016/679 of the European Parliament and of the Council, of 27 April 2016, relating to the protection of natural persons with regard to the processing of personal data and the free movement of such data (hereinafter, "GDPR").

KEYRUS PORTUGAL may manage the application you make for a specific vacant position on the Teamtailor SaaS platform, or it may be included in future selection processes. Through the Teamtailor platform, we will profile the candidate that will allow us to identify their suitability for the positions offered.

In compliance with Article 13 of the GDPR, following the principles of lawfulness, fairness and transparency, we make this Privacy Policy available to you.

1. Who is responsible for the processing of your personal data?

RESPONSIBLE: Keyrus Consultadoria Portugal, Unipessoal Lda

NIF: 515 888 818

REGISTERED OFFICE: Avenida Defensores de Chaves, 4, 4º piso, Arroios, 1000-117 Lisboa, Portugal

CONTACT:

Internal DSPO: Raquel Alegre Jorge

Email: dpo.portugal@keyrus.com

Phone: 91 308 3380

DPO: Grupo Adaptalia Legal-Formativo, S.L.

Email: dpd@keyrus.es

2. For what purposes do we process your data?

From the Teamtailor platform, we inform you that KEYRUS PORTUGAL will process the information you provide us with for the following purposes:

DATA SUBJECTS

PURPOSE OF PROCESSING

Candidates

• Conduct selection tests
• Manage personnel selection processes.
• Assess the candidate's capabilities.
• Decision-making about available jobs.
• Be part of the KEYRUS PORTUGAL job bank
• Keep the curriculum vitae of the data subject for future selection processes.
• Communications regarding new job offers
• Preparation of statistical reports or lists of candidates to meet the company's hiring needs
• Identify candidates' needs

3. What is the lawfulness of processing of your data?

The legal basis for the processing of candidates' personal data shall be as follows:

DATA SUBJECTS

PURPOSSE OF PROCESSING

LAWFUL OF PROCESSING

Candidates

• Conduct selection tests

Article 6(1)(b) of the GDPR: application on request of pre-contractual measures

• Manage personnel selection processes.

• Assess the candidate's capabilities.

• Decision-making about available jobs.

• Be part of the KEYRUS PORTUGAL job bank.

Art. 6.1.a) GDPR: consent of the candidate.

• Keep the curriculum vitae of the interested party for future selection processes.

• Communications regarding new job offers.
• Preparation of statistical reports or lists of candidates to meet the company's hiring needs.

Art. 6.1.f) GDPR: Keyrus Portugal's legitimate interest in optimising its recruitment processes and ensuring the mobility of its employees.

• Identify candidates' needs.

The data we request from you is adequate, pertinent and strictly necessary, and in no case are you obliged to provide it to us, but their non-communication may affect the purposes indicated in the previous section.

4. What data is processed by KEYRUS PORTUGAL and from what sources do they come?

KEYRUS PORTUGAL may process personal data of the following types, depending on the relationship established with the user and the purposes specified in the previous section:

• Identification data (first name, last name, personal postal address, business email address, personal email address, business or personal phone number, photograph (optional), video (optional), country, LinkedIn account information);
• Professional data (seniority, position, grade, department, office), professional experience (skills, functions, information about the company, tasks of the employee), training (last year of training, name of the training course, name of the training organization), certification (year of certification, name of certification, type of certification), languages, CV and cover letter.
• Personal life (hobbies and customs indicated on your CV)
• ID and password.
• Data obtained by answering the questions asked during the selection process.

The data that KEYRUS PORTUGAL processes as a result of the interactions made by the candidate through the Teamtailor platform, come from the following sources:

• Data provided by the user by filling in the forms made available by KEYRUS PORTUGAL when registering and creating a user account.
• Data deduced from the candidate's assessment in the context of the selection process.
• Data collected from academic entities or companies in which you have provided services in case of requesting professional references.
• Data that you have provided us with from your LinkedIn profile in the event of making a direct request through this social network.
• Data provided through Infojobs, Monster or similar websites when requesting inclusion in a selection process related to an offer published on the website.

If any of your personal data is processed by these companies, we invite you to consult their privacy policy. Keyrus Portugal will not be held responsible for any violation of the regulations by any of these companies.

5. How long will we keep your personal data?

The data provided may be kept for 24 months (2 years) from the end of the selection process to which you apply or the last contact with the candidate. Subsequently, your data will only be kept if your consent has been obtained and may be duly blocked for the time necessary to comply with the applicable legal obligations. Once this period has elapsed, we will proceed to delete the personal data subject to processing. During this retention period, your personal data will be kept on the platform for the period necessary to fulfil the above purposes.

6. To which recipients will your data be disclosed?

KEYRUS PORTUGAL, in order to provide its services correctly, may communicate your data to:

1. KEYRUS, S.A., the parent company of the company, whose administrative control makes such communication necessary.
2. Third-party companies for the realization of projects and evaluation of the candidate. Sometimes, as a result of the outsourcing of services to third parties through the hiring of KEYRUS PORTUGAL, it will be necessary to communicate the candidate's CV for the assessment of the profile by those companies in whose projects he or she will participate.

Likewise, to have full transparency with you, we inform you that your personal data will be stored on the platform managed by Teamtailor AB with registered office at Östgötagatan 16 116 21 Stockholm, Stockholms län, contact telephone +46 (0)10 330 22 22 and contact email support@teamtailor.com in its capacity as data processor. In this regard, the corresponding data processor agreement has been formalized to guarantee the correct processing of data under the guidelines of KEYRUS, S.A., compliance with the mandates of the data protection regulations, as well as the adoption of sufficient legal, technical and organizational security measures, in compliance with article 28 of the GDPR and 28 of the PPDGDR. You can find out more about the processing of your data by Teamtailor at the following link: https://www.teamtailor.com/en/privacy-policy/.

7. Are there international data transfers?

KEYRUS PORTUGAL will not transfer your personal data to third countries that do not comply with data protection regulations. In the event that an international transfer of data may occur, the candidate will be duly informed and KEYRUS PORTUGAL undertakes to safeguard his/her personal data, as well as to adopt the necessary measures for its timely protection, including the signing of the corresponding Standard Contractual Clauses (SCC) in the event that the commission has not adopted an Adequacy Decision that guarantees the international transfer of data.

8. What are your rights when you provide us with your data?

In compliance with Articles 15 to 22 of the GDPR, you may exercise your data protection rights. The data protection rights that may be exercised, where applicable, are:

• The right to request access to personal data relating to the data subject.

• Right to rectification.

• Right to erasure.

• Right to object.

• Right to request the restriction of your processing.

• Right to data portability.

• The right not to be subject to decisions based solely on automated data processing.

The owners of the personal data obtained may exercise their personal data protection rights by sending a written communication to the registered office of KEYRUS PORTUGAL, Avenida Defensores de Chaves, 4, 4º piso, Arroios, 1000-117 Lisboa, Portugal; or to the email address provided for this purpose, dpo.portugal@keyrus.com.

You can consult more information on the exercise of rights on the official website of the Portuguese “Comissão Nacional de Proteção de Dados” (hereinafter, "CNPD"), at the following link.

9. Can I withdraw consent?

You have the possibility and the right to withdraw consent for any specific purpose granted at the time, without affecting the lawfulness of the processing based on consent prior to its withdrawal.

10. Where can I complain if I believe that my data is not being processed correctly?

If any candidate considers that data is not being processed correctly by KEYRUS PORTUGAL or that requests to exercise rights have not been satisfactorily addressed, can file a complaint with the corresponding data protection authority, with the Portuguese “Comissão Nacional de Proteção de Dados” being the one indicated in the Portuguese national territory. More information on their website, accessible here.

11. Security and updating of your personal data.

In order to safeguard the security of your personal data, we inform you that it has adopted all the technical and organizational measures necessary to guarantee the security of the personal data provided. All this to prevent its alteration, loss, and/or unauthorized processing or access, as required by the regulations, although absolute security does not exist.

It is important that, in order for us to keep your personal data up to date, you inform us whenever there is a change to your personal data.

12. Confidentiality.

KEYRUS PORTUGAL informs you that your data will be processed with the utmost zeal and confidentiality by all personnel involved in any of the phases of the processing. We will not transfer or communicate your data to any third party, except in the cases provided for by law, or unless the candidate has expressly authorized us.