Additudes policy for processing personal data

1.1 This privacy policy (”Privacy Policy”) describes how Additude AB, registration number 556806-8489, with its principal place of business at Stora Varvsgatan 11, 7 tr, 211 74 Malmö, Sweden, and its subsidiaries collect, use, disclose, store and otherwise process personal data. Subsidiaries are the following companies (with the same principal place of business as Additude AB): Additude Excellence AB (registration number 556972-9592), Additude Innovation AB (registration number 559136-5167), and Additude Industry AB (registration number 559152-7972)

1.2 We respect your right to privacy, and we are committed to comply with applicable data protection rules and to safeguard your rights. This Privacy Policy describes, amongst other things, which information we collect about you, how your personal data is processed and for what purposes we collect and use the personal data. This Privacy Policy also describes your rights and how you can contact us about the use of your personal data.

1.3 Personal data means all types of information which can, directly or indirectly, be used to identify a living physical person (“Personal Data”).

1.4 Each subsidiary of the Additude group of companies is the data controller with respect to the processing of Personal Data within framework of the business of such subsidiary and is thus responsible to ensure that such processing of Personal Data is made in accordance with applicable data protection legislation. Additude AB is the data controller with respect to all other processing of Personal Data within the Additude group of companies. If you have any questions regarding which company that is data controller with respect to the Personal Data processed about you, please do not hesitate to contact us at: Additude AB, Stora Varvsgatan 11, 7 tr, 211 74 Malmö, Sweden, or at our e-mail: personuppgifter@additude.se.

1.5 When reference below is made to “Additude”, it is to be understood as a reference to the company, within the Additude group of companies, that is the data controller with respect to the processing in question.

1.6 This Privacy Policy is layered and divided into sections based on the categories of data subjects, i.e. the individuals, whose Personal Data is processed by Additude. Therefore, you only need to read the section that is relevant to you and which refers to the category that you belong to. The final sections 6 to 8 cover general provisions regarding protection of your Personal Data, your rights and contact details, and apply to all categories of data subjects. 1.7 Section 2 covers processing of Personal Data performed within the business areas Headhunting and Client Solution (conducted by Additude AB) and is thus not relevant to any of the subsidiaries. The other sections are applicable to all companies with the Additude group.

2.1 General This section 2 applies if you are a candidate for a position/positions which Additude recruits on behalf of a client (either an employment with our client or a position as an external consultant).

2.2 What types of Personal Data do we process?

2.2.1 We will process personal and contact information about you, which have been requested by us or submitted by you in writing or communicated orally. We may also collect personal and contact information about you from a third party. Such third parties are primarily our partners, but to some extent we also use other sources like LinkedIn and open CVs on the Internet. The personal and contact information about you consists of name, address (incl. e-mail address), telephone number, current work position (if applicable), CV (including date of birth and photo if included on the CV), minutes of interviews (strict routines are applied with respect to the content and storage of such), competences (to a certain limited extent) and to which assignments you have been a candidate.

2.2.2 If we, on the basis of data collected from a third party, identify you as a suitable candidate for a position, we will contact you to check your interest in the position in question. If you tell us that you are not interested, or do not respond to us, we will not register any Personal Data about you in our systems.

2.3 Why do we process your Personal Data?

Additude processes Personal Data relating to you in order to assess and to determine whether we would like to propose you as a suitable candidate for the position at the client.

2.4 The legal grounds for processing the Personal Data

2.4.1 Collection of Personal Data from a third party

The processing of Personal Data which has been collected from a third party is based on our legitimate interest to provide our recruiting services. However, the processing will only be based on such legitimate interest until we have been in contact with you. After our contact with you, we will either erase your Personal Data (if you tell us that you are not interested in the position in question, or you do not respond to us) or base a continued processing on a consent given by you.

2.4.2 Processing of Personal Data after we have been in contact with you or you have submitted Personal Data to us on your own initiative In connection with the contact with you pursuant to section 2.4.1 above, we will (provided that you have expressed your interest) obtain a consent from you regarding our processing of your Personal Data. If our contacts instead are initiated by you voluntarily submitting your Personal Data to us, either due to your interest in a specific position or to your general interest in being a part of our register for future positions, we will in connection with your submission of Personal Data ask you to consent to our processing. If covered by your consent, we will continue the processing of your Personal Data also after the completion

of a recruitment process for a position which you have expressed your interest in.

2.5 For how long do we store your Personal Data?

2.5.1 Your Personal Data will be stored for as long as the recruitment process is ongoing and thereafter for a following period of three (3) years from our latest contact with you. During the said three year period, Additude will retain the Personal Data for the defense of any legal claims.

2.5.2 If our processing of Personal Data is based on your consent, we will retain your Personal Data until you withdraw your consent. However, we will under all circumstances delete your Personal Data if the purpose behind our processing of the data ceases.

2.6 How may your Personal Data be shared?

2.6.1 Only those of Additude’s employees and, if applicable, external consultants who are directly involved in a relevant recruitment process will have access to your Personal Data. Further, the Personal Data will be shared with our client in question. Also other companies within the Additude group of companies and certain service providers of Additude, incl. providers of IT-systems, may be given access to your Personal Data. Additude may engage a data processor for processing of Personal Data on behalf of Additude. Additude is responsible for ensuring that the data processor’s processing complies with the legal requirements applicable to the processing.

2.6.2 Additude will not sell, trade or lease your Personal Data to third parties.

2.6.3 Unless otherwise set out in any specific information regarding our processing of your Personal Data, Additude will not transfer your Personal Data to any country outside the EU/EEA.

2.6.4 Personal Data may be disclosed by Additude to comply with legal requirements or other requirements from official authorities, in order to safeguard Additude’s legal interests or to detect, prevent, or draw attention to frauds or other safety or technical problems.

3.1 General This section 3 applies if you are applying for job at Additude; either for an announced open position or by submitting an unsolicited application.

3.2 What types of Personal Data do we process?

We will process personal and contact information about you, which have been requested by us or submitted by you in writing or communicated orally. We may also collect personal and contact information about you from a third party. Such third parties could be Skatteverket, Polismyndigheten, Linkedin and Creditsafe. The personal and contact information consists of name, date of birth, address (incl. e-mail address), telephone number, current work position (if applicable) and CV (including photo if you have included your photo on the CV).

3.3 Why do we process your Personal Data?

Additude processes Personal Data relating to you in order to assess your job application and to determine whether we would like to offer you a position at Additude.

3.4 The legal grounds for processing the Personal Data

3.4.1 Application for an announced open position or if you proceed to a job interview

The legal basis for processing Personal Data which we receive in relation to a recruitment process regarding an announced open position, or if you proceed to a job interview following an unsolicited application, is that the processing is necessary in order to take steps prior to entering into a (employment) contract with you.

3.4.2 Unsolicited application and Personal Data stored for future recruitment processes

The legal basis for processing Personal Data which we receive through an unsolicited application where we currently do not have any open positions to offer, or which we store after a completed recruitment process (regarding a position which has been assigned to another applicant) is the consent given by you to such processing.

3.5 For how long do we store your Personal Data?

3.5.1 Your Personal Data will be stored for as long as the recruitment process is ongoing and thereafter for a following period of maximum three (3) years, during which Additude will retain the Personal Data for the defense of any legal claims.

3.5.2 If our processing of Personal Data is based on your consent, we will retain your Personal Data until you withdraw your consent. However, we will under all circumstances delete your Personal Data if the purpose behind our processing of the data ceases.

3.6 How may your Personal Data be shared?

3.6.1 Only those of Additude’s employees and, if applicable, external recruiters who are directly involved in a relevant recruitment process will have access to your Personal Data. Further, other companies within the Additude group of companies and certain service providers of Additude, incl. providers of IT-systems, may be given access to your Personal Data. Additude may engage a data processor for processing of Personal Data on behalf of Additude. Additude is responsible for ensuring that the data processor’s processing complies with the legal requirements applicable to the processing.

3.6.2 Additude will not sell, trade or lease your Personal Data to third parties.

3.6.3 Unless otherwise set out in any specific information regarding our processing of your Personal Data, Additude will not transfer your Personal Data to any country outside the EU/EEA.

3.6.4 Personal Data may be disclosed by Additude to comply with legal requirements or other requirements from official authorities, in order to safeguard Additude’s legal interests or to detect, prevent, or draw attention to frauds or other safety or technical problems.

4.1 General This section 4 applies if you are an employee of or otherwise represent a company that Additude has an ongoing contractual relationship with, or that Additude has established contact with for discussing the possibilities of such contractual relationship or for other purpose.

4.2 What types of Personal Data do we process?

We collect and process the following Personal Data about you: (i) contact details, i.e. name, e-mail address, phone number, (ii) employment details, i.e. employer, job title, job street address, and (iii) other data that you intentionally share, e.g. information about you that you voluntarily submit to us in free text fields or share in other contexts.

4.3 Why do we process your Personal Data?

We process your Personal Data for the following purposes:

(i) to send notifications or messages to you which are related to an agreement between your company and Additude;

(ii) to be able to otherwise execute, maintain and perform our obligations under an agreement with your company;

(iii) to discuss any future contractual relationship between your company and Additude; or

(iv) to provide you with information about Additude’s products or services, or to invite you to activities or events.

4.4 The legal grounds for processing the Personal Data

As applicable, the processing referred to under section 4.3 is made on the basis of our legitimate interest to:

(i) uphold, maintain and administrate a contractual relationship that we have with your company;

(ii) sustain the partnership with your company and to discuss product, solution and service offerings; and

(iii) market, promote and demonstrate our business, products, solutions, services, events and similar.

4.5 For how long do we store your Personal Data?

4.5.1 If your company has a contractual relationship with us, we will store your Personal Data in our database until the contractual relationship with your company ceases and for a limited time thereafter (not exceeding three years). However, your Personal Data will (if included in the contract text) continue to be processed as a part of the contract text, as long as the contract is retained for the purpose of safeguarding Additude’s legal interests.

4.5.2 If we have discussions with your company but such discussions do not result in that any contract is concluded, we will delete your Personal Data from our databases when it is no longer needed for the said discussions.

4.5.3 If we have neither a contractual relationship with your company nor have any ongoing discussions with your company regarding such relationship, but we are interested in providing your company with marketing material and other information about our business, products, solutions, events etc., we will process your Personal Data during three (3) years whereafter we will delete the Personal Data (as long as no discussions regarding a future cooperation have been initiated). Further, we will delete your Personal Data processed for direct marketing purposes if you object to processing for such purposes.

4.6 How may the Personal Data be shared?

4.6.1 Additude may share your Personal Data with our trusted subcontractors to the extent necessary for the performance of the contract we have entered into with your company. They may need access to the Personal Data in their assignment for us, but they will not be allowed to use the Personal Data for any other purpose. Further, other companies within the Additude group of companies and certain service providers of Additude, incl. providers of IT-systems, may be given access to your Personal Data. Additude may engage a data processor for processing of Personal Data on behalf of Additude. Additude is responsible for ensuring that the data processor’s processing complies with the legal requirements applicable to the processing.

4.6.2 Additude will not sell, trade or lease your Personal Data to third parties.

4.6.3 Unless otherwise set forth in any specific information regarding our processing of your Personal Data, Additude will not transfer your Personal Data to any country outside the EU/EEA.

4.6.4 Personal Data may be disclosed by Additude to comply with legal requirements or other requirements from official authorities, in order to safeguard Additude’s legal interests or to detect, prevent, or draw attention to frauds or other safety or technical problems.

5.1 General This section 5 applies if you, either as a private individual or as a representative of your company, have sent e-mails to an employee or other representative of Additude.

5.2 What types of Personal Data do we process?

We collect Personal Data in the form of your name, e-mail address and other information which you voluntarily share in e-mails that you send to us.

5.3 How do we process Personal Data received in an e-mail?

Upon our receipt of an e-mail, we will consider whether we have any reason and legal ground pursuant to section 2, 3 or 4 above to store or otherwise continue to process the received Personal Data. If we determine that such reason and legal ground exist, we will continue to process the received Personal Data in accordance with section 2, 3 or 4, as applicable. Otherwise, we will delete the Personal Data received through the e-mail.

6.1 You should always feel secure when you provide your Personal Data to us. We have employed a wide range of security measures to help protect your Personal Data against undue access, modification and deletion.

6.2 Personal Data is processed in a strictly controlled IT and office environment. We protect your Personal Data using commercially reasonable safeguards to prevent loss, misuse, unauthorized access, disclosure, alteration, and destruction. These measures include e.g. data encryption, firewalls, personal logins, threat detection, change logs, camera surveillance and electronic tags. Therefore, you can rest assure that your Personal Data is in safe hands.

7.1 Access, Corrections

You are always entitled to ask us whether we process any of your Personal Data, and if so, access a copy of such Personal Data. Further, you have the right to request that we correct or update your Personal Data if something is wrong or missing.

7.2 Deletion, Restriction of use and Data portability

Under certain circumstances (expressed in applicable data protection legislation), you may request that Additude restricts the use of your Personal Data or delete your Personal Data. If you have provided us with Personal Data, you also have the right to have your Personal Data resubmitted to you, in a structured and accessible format, for transfer to another user/processor.

7.3 Withdrawal of consent

If Additude processes Personal Data based on your consent, you have the right to withdraw the consent at any time through a written notice sent to Additude.

7.4 Requests and Complaints

7.4.1 If you wish to exercise any of the abovementioned rights or if you have any questions regarding Personal Data held by us or this Privacy Policy, please do not hesitate to contact us (for contact information, please see section 8 below).

7.4.2 Should you be dissatisfied with our processing of your Personal Data, please let us know, and we will do our best to meet your complaints. Your integrity is very important to us, and we always strive to protect and secure your Personal Data in the best possible way. Should we nevertheless, in your opinion, fail in this ambition, please note that you are also entitled to lodge a complaint with the Swedish Data Protection Authority (Sw. Datainspektionen), or such other authority as may be determined in the future.

You can contact us at: Additude AB, Stora Varvsgatan 11, 7 tr, 211 74 Malmö, Sweden, or at our e-mail: personuppgifter@additude.se.