Candidate's Privacy Notice

Updated November 10, 2023

CANDIDATE'S PRIVACY NOTICE

This Job Candidate Privacy Notice (“Notice”) describes what Personal Data (as defined below) we, Liquidity Capital M. C Ltd., together with our affiliates and subsidiaries, (collectively “Company”, “we” or “us”) collect and process on job candidates and applicants (“Candidates”, “you” or “your”) during their the recruitment process and thereafter, if applicable. This Notice applies to Candidates in the territory where we offer job opportunities, and is subject to applicable data protection laws (“Data Protection Laws”).

This Notice applies to the processing, sharing, and storing of Personal Data (as defined below) during, or after, the hiring process, and is in addition to, and does not replace the Privacy Policy governing the use of the website.

Please note that you are not obliged by law to provide us with Personal Data. However, we must obtain certain types of Personal Data to process and examine your job application. Also, if following the recruitment process a Candidate is hired or otherwise engaged by the Company, the Personal Data collected through the course of recruitment will be subject to the Company’s internal privacy policies, as provided to its employees and staff members.

The Company is considered the “data controller”or “database owner” (or any equivalent definition under Data ProtectionLaws) of the Personal Data collected fromCandidates. This means that we are responsible for deciding how we process, hold, and use Personal Data about you, as well as to implement applicable measures in order to secure the Personal Data we store, and where applicable, enable you to exercise your rights.

It is important that you read this Notice, together with any other notices that might be provided on specific occasions when we are collecting Personal Data about you so that you are aware of how and why we are collecting and using such Personal Data. For any questions or concerns you might have regarding your Personal Data please contact our Data Protection Officer at: privacy@liquiditygroup.com.

1) THE TYPES OF PERSONAL DATA WE COLLECT AND THE PURPOSE

“Personal Data” refers to information that identifies, relates to, or could reasonably be linked with an individual by reasonable means. For example, it could include your name, email address, and other contact information (address, telephone number), etc. Personal Data may further include types of information defined under applicable Data Protection Laws as “Sensitive Data” or “Sensitive Personal Information” which may include information such as governmental identification number or certificate, professional qualifications, financial information, health-related information, etc.

We will collect, store, and use various types and categories of Personal Data about Candidates, which may further include Sensitive Data. Those Categories are detailed in the table below.

Please note that the specific categories or types of Personal Data collected may vary depending on the position and legal requirements.

This table represents the Personal Data collected by the Company:

TYPES OF PERSONAL DATA

PURPOSE OF COLLECTION AND USE

LAWFUL BASES (APPLICABLE FOR CANDIDATES LOCATED IN THE EEA OR UK*)

Personal identification information:
‍such as name, date of birth, government-issued identification number, and copy of identification certificate (e.g., ID, passport, SSN).

Job Application evaluation:
to assess the Candidate's qualifications, skills, and suitability for the position applied for, and to identify potential matches with other open positions within the Company.

The lawful bases depend on the purpose for which we collect, use, and retain Personal Data. We mainly collect and use the Personal Data under our legitimate interest, as needed to decide if to appoint a Candidate to a certain job position. We may further retain certain types of Personal Data, under our legitimate interest, for the purpose of record keeping, compliance with applicable laws, evaluating our recruiting processes, and addressing potential disputes or legal claims. Where required under applicable Data Protection Laws, we will obtain your consent in order to retain and further use Personal Data for future job opportunities. You have the right to withdraw consent at any time.

Contact information:
such as email address, phone number, and address.

Communication:
to facilitate our correspondence with the Candidate during the recruitment process, including scheduling interviews, providing updates, and addressing inquiries.

Employment history:
such as previous employers, job titles, dates of employment, responsibilities, achievements, etc.

Verification and reference checks:
‍to verify the accuracy of the information provided by the Candidate, including employment history, education, and professional references, as well as conducting background checks where necessary.

Education and qualifications: such as information on educational institutions attendance and dates, degrees or certifications obtained, fields of study, etc.

Compliance with legal requirements: to ensure adherence to relevant employment laws, regulations, and industry standards.

Skills, abilities, and expertise: such as information related to the Candidate's relevant competencies, skills, language proficiency, and any other expertise that may be pertinent to the position being applied for.

Eligibility to work: to confirm the Candidate's legal right to work in the relevant country and comply with immigration requirements, if applicable.

Assessment results: information gathered from tests, interviews, or assessments conducted during the recruitment process to evaluate the Candidate's suitability for the role.

Decision-making and selection: to facilitate the decision-making process, compare Candidates, and ultimately select the most suitable individual for the position.

Background check information: information obtained through background checks, subject to applicable laws, such as verification of employment and education history.

Record-keeping and documentation: to maintain a record of the recruitment process, including Candidate evaluations, assessments, and decisions, which may be used for future reference or to address potential disputes or legal claims.

We collect these types of Personal Data subject to your consent. You have the right to withdraw consent at any time. We may further retain certain types of Personal Data, under our legitimate interest, for the purpose of record keeping, compliance with applicable laws, evaluating our recruiting processes, and addressing potential disputes or legal claims.

Eligibility to work: information regarding the Candidate's legal right to work in the relevant country, such as citizenship or visa status.

Administration and performance of human resources related duties, obligations, and procedures.

Subject to law enforcement or a competent authority request.

* Where the EU or UK General DataProtection Regulations apply, and as required under these regulations.

Communication and internal records: such as correspondence, and records of phone calls or other interactions between the Candidate and the Company during the recruitment process.

Continuous improvement: to analyze and refine our recruitment strategies,practices, and processes.

Any additional information voluntarily included by the Candidate in its resume (CV), and supporting documents submitted by the Candidate.

Record-keeping and documentation: to maintain a record of the recruitment process, which may be used for internal and external reporting responsibilities (e.g., legal and regulatory requirements), future reference or to address potential disputes or legal claims.

Sensitive Data, Equal opportunity data: information provided voluntarily by the Candidate related to gender, race, ethnicity, national origin and citizenship, disability and medical or health condition, veteran or military status.

Equal opportunity monitoring: We may ask for such information for the purpose of monitoring equal opportunity and ensuring diversity and inclusion.

Administration and performance of human resources related duties, obligations, and procedures. Note that, the Company does not discriminate, either directly or indirectly, on the grounds of sex, sexual orientation, gender, ethnic origin, religion, belief, marital status, nationality, national origin, color, age, or similar protected characteristics.

2) CATEGORIES OF SOURCES OF PERSONAL DATA

We typically collect Personal Data about Candidates, as follows:

‍Provided directly by the Candidate – this includes information you share when you submit your application, such as your name, email address, postal address, telephone number, age, education history, etc.; and‍
Information provided by third parties – recruitment agencies or your references former employers, etc.

3) WITH WHOM WE SHARE YOUR PERSONAL DATA

We share your Personal Data with third parties, including within our corporate group and with our employees, contractors, consultants, and service providers that help us with our business operationas well as administration and performance of human resources related duties,obligations, and procedures, including where needed to establish therecruitment process. We take applicable measures to ensure your Personal Data will be accessed only by those who really need to in order to perform their tasks and duties, and to third parties who need such access in order toprovide their services as required by the Company and in accordance with our instructions.

Below you can find information about the categories of such third-party recipients.

CATEGORY OF RECIPIENT

CATEGORY OF PERSONAL DATA

PURPOSE OF SHARING

The Company Group

All types of Personal Data

We may share Personal Data within our Company group to allow us to manage our recruitment process as a business, at the organizational level, and for human resources management. This will include information shared with a third party including by way of merger, acquisition, or purchase of all or part of its assets, your Personal Data may be shared with the parties involved in such event.

Contractors and Service Providers

All types of Personal Data

In the event of legal and law enforcement, we may disclose certain Personal Data, such as in response to verified requests relating to criminal investigations or alleged illegal activity, or any activity that may expose us, you, or any other third party to legal liability, and solely to the extent necessary to comply with such purpose

Governmental agencies, or authorized third parties

Subject to law enforcement or a competent authority request.

We may further share Personal Data where and to the extent needed to protect you, or third parties; enforce our policies and agreements or defend our rights, including the investigation of potentialviolations, alleged illegal activity, or addressing fraud or security issues;as well as in response to disputes, claims, demands, or legal proceedingsinvolving you and us or any third party as required to defend our legitimateinterests and as permitted under law. In addition, we may disclose Personal Data to third parties, in the event you request us to do so. In such event, the provision of yourPersonal Data will be subject to such third parties' policies and practices only.

4) INFORMATION SECURITY & CROSS BORDER DATA TRANSFER

We take great care in implementing and maintaining the security of your Personal Data. We employ industry-standard procedures and policies to ensure the safety of your Personal Data and prevent unauthorized disclosure or use of any such. In addition, we limit access to your Personal Data to those employees, agents, contractors, and other third parties who have the “need to know”. They will only process your Personal Data on our instructions. We have implemented technical, physical, and administrative security measures to protect the Personal Data we collect and store, including procedures to detect and manage suspected or actual security breaches.

Although we take reasonable steps to safeguard information, we cannot be responsible for the acts of those who gain unauthorized access or abuse of systems and network, and will not always be able to prevent such access.

Subject to applicable Data Protection Laws requirements, we will notify you and the appropriate authorities in the event that we discover a security incident or breach related to your Personal Data.

Due to our global operation, your Personal Data may need to be processed or accessed in countries other than your jurisdiction, including, for example, when shared or accessed by our service providers or other affiliates. This may include the transfer of Personal Data from and to the State of Israel, the US, or the EEA. The Company only transfers Personal Data to another country in accordance with applicable Data Protection Laws. We take appropriate measures to ensure that your Personal Data receives an adequate level of protection, including by using contractual obligations or other data transfer mechanisms that were pre-approved by applicable data protection authorities to ensure your Personal Data is protected.

5) DATA RETENTION

In general, we will only retain your Personal Data for as long as necessary to fulfill the purposes we collected it for, including for the purposes of satisfying any legal, administrative, recordkeeping, or reporting requirements.

The criteria used by us to determine the retention periods are as follows:

● The type of Personal Data and purpose of the collection – we consider the scope, nature, and sensitivity of the Personal Data, the potential risk of harm from unauthorized use or disclosure of your Personal Data, the purposes for which we process your Personal Data and whether we can achieve those purposes through other means. If and where we no longer have a legal justification for retaining Personal Data, we will delete it or de-identify it so it can no longer be associated with you by reasonable means.

● Compliance with our legal obligations – we are required to retain certain types of Personal Data in order to comply with our obligations under applicable laws. In addition, we may retain certain types of Personal Data in the event we are required to do so subject to a binding legal request or a court order.

● Dispute, claims, and legal proceedings – if you have a dispute with us, we may retain certain types of Personal Data as necessary and applicable to your claims, including any legal proceedings between you and us until such dispute is resolved, and following, if we find it necessary, in accordance with applicable statutory limitation periods. In addition, in the event you request to exercise your rights, we will maintain the applicable correspondence for as long as needed to demonstrate compliance, usually in accordance with applicable statutory limitation periods.

We may further retain your Personal Data where you were not hired, to allow us to reconsider your application for alternative or future positions at the Company, and where required under applicable Data Protection Laws, we will obtain your consent. In addition, we may retain limited Personal Data as a reference for any future applications submitted.

6) YOUR RIGHTS RELATED TO YOUR PERSONAL DATA AND HOW TO EXERCISE THEM

We respect your privacy and your rights to control your Personal Data. You have the right to control and request certain limitations or rights to be imposed with regard to the Personal Data we hold and process. Depending on the applicable Data Protection Laws, these rights may include one or more of the following principal rights:

● The right to know what Personal Data we collect about you, the purpose of collection, with whom we share your Personal Data, and additional information such as the categories of sources from which the Personal Data is collected – as provided under this Notice;

● The right to request access and inspect your Personal Data. This right entitles you to review or receive a copy of certain Personal Data we hold about you;

● The right to correct inaccuracies in your Personal Data (also known as “rectification”). This right entitles you to have any incomplete or inaccurate Personal Data we hold about you corrected;

● The right to request deletion of your Personal Data. This right entitles you to request us to delete Personal Data where there is no good reason for us to continue processing it (as permitted under applicable Data Protection Laws);

● The right to request to restrict processing of Personal Data. This right entitles you to request to limit the purposes for which we process your Personal Data if one of the conditions set forth under applicable Data Protection Laws is satisfied;

● The right to object to the processing of your Personal Data. This right entitled you to object to our processing of your Personal Data if one of the conditions set forth under applicable Data Protection Laws are satisfied;

● The right to request the transfer of your Personal Data to another party (commonly known as "data portability");

● The right to withdraw consent, where we have collected your Personal Data or otherwise processed it based on your consent;

● Exercise your privacy rights without receiving discriminatory treatment by the Company.

● The right to right to appeal or lodge a complaint. If we decline to take action on your request, we will inform you without undue delay as required under applicable Data Protection Laws. The notification will include a justification for declining to take action and where required under applicable Data Protection Laws, instructions on how you may appeal to us or to an applicable authority. For EEA/UK Candidates*, you have the right to lodge a complaint with the applicable Data Protection Authority in the EU or the Information Commissioner in the UK.

For detailed information on your rights and how to exercise your rights, please seethe Data Subject Request (“DSR”) form available HERE, and send it to our privacy team at: privacy@liquiditygroup.com.

If you are an EU resident, you may also submit the request to exercise your right to our EU Data Protection Representative, Prighter Group, at https://prighter.com/q/13356608436

We sometimes need to request specific information from you to help us confirm your identity and ensure the requested rights apply to you. This is another appropriate security measure to ensure that Personal Data is not disclosed to any person who has no right to receive it. Information provided in connection with such request will be processed only for the purpose of processing and responding to your request, and it may be shared with our legal and administrative teams.

7) AMENDMENTS

We reserve the right to periodically revise this Notice, which will have immediate effect upon posting of the revised Notice. We recommend you review this Notice periodically to ensure that you understand our privacy practices and to check for any amendments.