EFFECTIVE DATE: JULY 6, 2020

MODIFIED: NOVEMBER 07, 2022

LAST MODIFIED: August 24, 2023

VERSION: 1:3

Preliminary

TRAFFIC STARS LTD is committed to protecting your personal data and your privacy. The personal data we collect depends on the service requested and agreed in each case by Traffic Stars Ltd and/or its Affiliates and/or related companies (collectively referred to as “Traffic Stars” or “Company” or “we” or “us” or “our” in this privacy policy). For all purposes of this Privacy Policy, Affiliate means any entity directly or indirectly, through one or more intermediaries, controlling, controlled by or under common control with Traffic Stars or by each other.

This Privacy Policy explains how we collect, use and processes your personal data, how we comply with our legal obligations to you and informs you about your privacy rights under the Processing of Personal Data (Protection of individuals) Law 125 (I)/2018) as may be amended from time to time (the “Law”) and Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 on the protection of natural persons with regard to the processing of personal data and on the free movement of such data, and repealing Directive 95/46/EC as may be amended from time to time (the “GDPR”).

This Privacy Policy is directed to the candidates/job applicants.

Who we are:

TRAFFIC STARS LTD is a company duly registered in the Republic of Cyprus under registration number HE 335138 having its registered address and head office at Arch. Makariou III, 124, AGROTIS COURT, Floor 1, 3021, Limassol, Cyprus.

We have appointed a DPO who is responsible for overseeing questions in relation to personal data protection issues. Any questions about this Privacy Policy or any requests to exercise your legal rights shall be addressed to the DPO using the below details:

Email address: dpo@trafficstras.com

Postal address: Arch. Makariou III, 124, AGROTIS COURT, Floor 1, 3021, Limassol, Cyprus

Collection and Use of Your Personal Data

Personal data means any information relating to you that identifies you or could reasonably be used to identify you, and that is recorded in any form.

We may collect the following personal data:

a) Identity data such as first name, maiden name, last name, ID number, passport number, title, date of birth (city and country) and gender. In case your job application is successful, we may collect the same identity data of your dependents for subsequent travel arrangements.

b) Children’s data: We understand the importance of protecting children’s privacy. We may collect personal data in relation to children, only provided that your job application is successful and that we have first obtained your consent or unless otherwise permitted under the law solely for relocation purposes, in case your job application will be successful.

c) Contact data such as residential address, email address and telephone numbers, emergency contact details.

d) Additionally, we may collect marital status, IP address, insurance information, family member information, nationality, credit reference agency data, immigration status (to determine whether you need a work permits), copy of your work permit (if applicable), current employment position, educational background, employment history, tax information (e.g. tax identification number, tax residency), details about your current remuneration, pensions and benefit arrangements, information on your interests and needs regarding future employment.

e) any other personal data contained in your CV and/or cover letter or any other personal data you freely choose to send us.

f) copy of your passport details and the passport details of your dependents in case your job application is successful.

The above list of categories of personal data is not exhaustive and we may request to collect additional data. In such a case, you will be informed of the additional personal data required and of the purpose for which we require such data.

We collect and process different types of personal data, which we receive from you directly or from our contractors in person or via their representative in the context of the contractual relationship we have with you.

To the extent permitted by the law and for the fulfillment of our contractual or potential contractual relationship, we may collect and process personal data which has been lawfully obtained from third parties e.g. public authorities or companies that introduce you to us and/or from publicly available sources.

Additionally, Traffic Stars may collect and process your personal data from the following publicly available sources, provided collection of the data is necessary and relevant to the performance of the job which you apply for and provided we are allowed to do so by national laws (“direct search”): LinkedIn, Facebook, Twitter and other social media platforms, Google, Xing, Telegram.

Background Checks

Before making a final decision to recruit you, we may collect and process information relating to your criminal record in order to satisfy ourselves that there is nothing in your criminal convictions history which will prevent us from hiring you or entering into a contractual relationship with you. We seek to ensure that our information collection and processing is always proportionate.

Purposes of Processing Your Personal Data

In holding and processing your personal information, we comply with the GDPR and the) Law.

We will use your personal data for one or more of the following reasons:

a) To conduct the recruitment process.

b) To perform the contract we are about to enter into or have entered into with you.

c) For our legitimate interests.

d) To comply with a legal or regulatory obligation.

e) Where disclosure is necessary for a competent authority.

f) You have provided your consent. Please be informed that you have the right to revoke your consent at any time.

Any personal data you provide to Traffic Stars will be used to process your application for the specific position you have applied for. In case you wish us to retain and use your personal data to process your application for other open positions within Traffic Stars which may be suitable, you should reply to the automated email you will receive upon submission of your CV. If you do not reply to the automated email within the prescribed timeframe, we will consider that you object to such processing in which case all your personal data will be deleted from our records and therefore, you will not be contacted for any future job openings.

The processing of your personal data is based on Article 6(1)(b) of the GDPR.

We need your personal data in order to conduct the recruitment process, and we will not be able to consider you for a job offer when you do not provide us with the personal data described herein above.

Any processing of personal data from other sources is based on Article 6(f) of the GDPR.

When we retain your personal data for future job opening (please see below the Section Data Retention), we do this based on Article 6(1)(a) of the GDPR and we do so in order to give you the possibility to work with us in the future, even though we are currently unable to offer you a position.

Transfer of Your Personal Data

In the course of the performance of our contractual and statutory obligations, your personal data may be provided to different departments within Traffic Stars and/or to third parties providing services to us. If it is necessary to share your personal data with a third party service provider so we may perform our services and/or legal obligations, we enter into a contractual agreement with such third party to ensure that they comply with the data protection law and GDPR and they observe confidentiality. We require all third party service providers to respect the security of your personal data and to treat it in accordance with the law. We only permit our third-party providers to use your personal data for specified purposes and in accordance with our instructions and we only provide the necessary information they need to perform their specific services.

Traffic Stars do not at present transfer candidates’ personal data outside the European Economic Area.

Security for Your Personal Data

Traffic Stars uses appropriate administrative, technical, personnel, and physical measures to protect your personal data. Authorised personnel and third parties service providers may have limited access to your personal data, and they will only process your data according to our instructions.

We also have a data breach procedure in place, and we commit to notify you and the competent authority for any breach or any suspected personal data breach where we are obliged by the law to do so.

Automated decision making

You will not be subject to decisions that will have a significant impact on you based solely on automated decision-making. There will always be human intervention into decisions based on automated processing, including automated analytics, testing, profiling

Use of Third-Party Service Providers

Traffic Stars may engage third-party service providers, such as recruitment agencies/search firms and providers of recruiting software and applicant tracking system with whom Traffic Stars contracts as part of its normal business operations to carry out recruitment-related functions. Traffic Stars diligently selects such service providers and enters into written agreements with them ensuring that such providers (i) have adopted adequate data protection and security measures to safeguard your personal data; (ii) only use your data as instructed by Traffic Stars and for no other purposes; and (iii) store your personal data only within the terms of the agreement. Each third-party service provider guarantees an adequate level of personal data protection, including but not limited to, by entering into standard data protection clauses adopted by the European Commission.

Data Retention

We will retain your personal data for as long as necessary, to fulfil the purposes we collected it for, and to comply with a regulatory or statutory obligation.

The criteria used to determine our retention periods include:

• The length of time we have an ongoing relationship with you and provide the services to you.
• Whether there is a legal obligation to which we are subject.
• Whether retention is advisable considering our legal position (such as litigation or regulatory investigations).

In case your job application is successful and subject to the signing of your employment offer and then of your employment contract, your will be considered as employee of Traffic Stars and our Employee Privacy Policy and Data Retention Policy will apply.

In case your job application is unsuccessful, or the employment offer we made you is not accepted by you, but you have provided us with your consent to retain your personal data for future job openings, your personal data will be kept for 2 (two) years from the date such consent has been obtained.

In case your job application is unsuccessful, or the employment offer we made you is not accepted by you, and you have not provided us with your consent to retain your personal data for future job openings, your personal data will be deleted immediately from our records.

As per Article 4(11) of the GDPR such consent shall be “any freely given, specific, informed and unambiguous indication of the data subject’s wishes by which he or she, by a statement or by a clear affirmative action, signifies agreement to the processing of personal data relating to him or her.”

Your Legal Rights

Traffic Stars at all times balance your fundamental rights with the purposes of the processing of your personal data.

We have already explained to which cases your personal data is being processed, to what purpose and if the processing is based on your consent, we always explain what you are consenting to. Where the processing of your personal data is based on your consent, you have the right to withdraw your consent at any time by sending an email to dpo@trafficstars.com, but this will not affect the lawfulness of processing based on your consent before its withdrawal.

You have the right to:

• request access to your personal data
• request correction of your personal data
• request erasure of your personal data
• Object to processing of your persona data
• Request restriction of your personal data
• Request transfer of your personal data
• Request withdrawal of the consent that you gave us
• lodge a complaint with a supervisory authority

If you wish to exercise any of your rights, please contact us at support@trafficstars.com or dpo@trafficstras.com.

We would appreciate the chance to deal with your concerns and address your queries before you approach the supervisory authority.

In order to meet your request, we may need to request specific information from you to help us confirm your identity and ensure your right to access the information (or to exercise any of your other rights). This is another appropriate security measure to ensure that personal information is not disclosed to any person who has no right to receive it.

Exercising your rights is free of charge. However, we have the right at our sole discretion to refuse to fulfil or charge a reasonable fee for fulfilling several similar consecutive requests or requests that are manifestly unfounded or excessive. We are also entitled to decline requests on statutory grounds in which cases we will inform you of such decline including the grounds for the decline. We will provide you with information in the due course of exercising your above-mentioned rights at the latest within one month.

Changes to the privacy policy

This version was last updated on 24 August 2023. This Privacy Policy may be amended from time to time. We do encourage you to review this statement periodically so as to be always informed about how we are processing and protecting your personal information.