PrimeConduct - GDPR & DPO Services

(B) Processing your Personal Data

Collection of Personal Data: We may collect Personal Data about you, such as your name, address and contact details. Examples of sources from which we may collect Personal Data include the following:

• We may obtain your Personal Data when you provide it to us (e.g., where you contact us via email or telephone, or by any other means).

• We may collect your Personal Data in the ordinary course of our relationship with you.

• We may collect Personal Data that you manifestly choose to make public, including via social media (e.g., we may collect information from your social media profile(s), to the extent that you choose to make your profile publicly visible).

• We may collect or obtain Personal Data when you visit any PrimeConduct website (a “Site”) or use any features or resources available on or through a Site. When you visit a Site, your device and browser will automatically disclose certain information (such as device type, operating system, browser type, browser settings, IP address, language settings, dates and times of connecting to a Site and other technical communications information), some of which may constitute Personal Data.

Creation of Personal Data: We may also create Personal Data about you, such as records of any meetings you attend. We collect, process and store information when you send, receive, or engage with messages in connection with our Services. This includes information such as the number of messages you’ve sent and received, details of who you’ve chatted with and when and which messages were responded to ("Message Data").This Personal Data helps us to conduct our operations and manage our workforce.

We also may use automatic scanning technology on messages to allow us to recognize patterns on our messaging platform. These patterns may help us make your professional communications more efficient and informed and contribute to a safer and more secure job search experience. For example, our software may do the following:

Look for text that indicates a web link (e.g. ends with ".com" or similar) to generate a clickable link

Provide auto-complete options when it anticipates who the receiver of the message may be

Look for content to provide quick actions such as a scheduling tool

Look for content to provide quick replies based on context

Check links shared in messages for malicious sites and looks for blacklisted keywords to detect spam and fraud.

Relevant Personal Data: The categories of Personal Data about you that we may Process include:

• Personal details: given name(s); preferred name; job title; employer.

• Contact details: work address; work telephone number; work mobile number; personal mobile telephone number; work email address.

Lawful basis for Processing Personal Data: In Processing your Personal Data in connection with the purposes set out in this Policy, we may rely on one or more of the following legal bases:

• we have obtained your prior express consent to the Processing (this legal basis is only used in relation to Processing that is entirely voluntary – it is not used for Processing that is necessary or obligatory in any way);

• the Processing is necessary in connection with any contract that you may enter into with us;

• the Processing is required by applicable law;

• the Processing is necessary to protect the vital interests of any individual; or

• we have a legitimate interest in carrying out the Processing, which is not overridden by your interests, fundamental rights, or freedoms. Where we rely on this legal basis, our legitimate interests are:

• our legitimate interest in the management and operation of our business;

• our legitimate interest in the promotion of our business; and

• our legitimate interest in the provision of services to our Clients.

Processing your Sensitive Personal Data: We do not seek to collect or otherwise Process your Sensitive Personal Data, except where:

• the Processing is required or permitted by applicable law (e.g., to comply with our diversity reporting obligations);

• the Processing is necessary for the detection or prevention of crime;

• the Processing is necessary for the establishment, exercise or defence of legal rights; or

• we have, in accordance with applicable law, obtained your prior explicit consent before Processing your Sensitive Personal Data (as above, this legal basis is only used in relation to Processing that is entirely voluntary – it is not used for Processing that is necessary or obligatory in any way).

Purposes for which we may Process your Personal Data: The purposes for which we may Process Personal Data, subject to applicable law, include:

• Provision of services to you: providing our Sites and other services to you; attending meetings with you; attending telephone calls with you; and otherwise communicating with you in relation to those services.

• Our Sites: operating and managing our Sites; providing content to you; displaying advertising and other information to you; and communicating and interacting with you via our Sites.

• Training: providing you with training and preparation for compliance with Data Privacy regulation.

• Newsletters and other marketing communications: communicating with you via any means (including via email, telephone, text message, social media, post or in person) news items and possible opportunities in which you may be interested.

• Communications and IT operations: management of our communications systems; operation of IT security; and IT security audits.

• Health and safety: health and safety assessments and record keeping; and compliance with related legal obligations.

• Financial management: sales; finance; corporate audit; and vendor management. • Surveys: engaging with you for the purposes of obtaining your views on relevant issues and topics.

• Improving our services: identifying issues with existing services; planning improvements to existing services; creating new services.