This GDPR Privacy Notice (the "Privacy Notice") of Headlands Technologies, LLC applies for successful job applicants and/or website visitors from the EEA, Switzerland and/or the UK. Headlands Tech respects your privacy and is committed to protecting your personal data. This Privacy Notice aims to give you information on how Headlands Tech collects and processes your personal data throughout our job application process and use of this website.

This privacy notice is issued on behalf of Headlands Tech Holdings, LLC, Headlands Technologies Europe B.V., Headlands Technologies LLC, Headlands Tech UK Limited, and all of their affiliated companies (collectively, the "Headlands Tech Group") so when we mention the "Company", "Headlands Tech", "we", "us" or "our" in this Privacy Notice, we are referring to the relevant company in the Headlands Tech Group responsible for processing your data. Headlands Tech Holdings, LLC is the data controller of your personal data.

1. THE DATA WE COLLECT ABOUT YOU AND HOW WE COLLECT IT

Personal data, or personal information, means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymous or pseudonymised data).

We may collect the following data during the job application process:

• Data about your application and interviews includes forename and surname, citizenship status, date of birth, age, contact details (e.g., address, telephone number, e-mail), willingness to relocate, job preferences, salary information, educational qualifications, any contents of a curriculum vitae or resume, professional qualifications, employment, interview data, employment references
• Other information relevant to potential recruitment includes background checks, reference checks, candidate testing results, information relating to criminal convictions (as relevant and permissible), information from public social media sites.
• Any other information you provide us as part of the application process

We may collect this information from you, your references (details of whom you will have provided), your education provider and recruitment agencies (as applicable).

We may collect the following data after the shortlisting stage, and before making a final decision to recruit:

• Right to work information - which may include your nationality, immigration status and information from related documents, such as your passport or other identification and immigration information.
• Background check information - such as information about criminal convictions and offences, credit history, sanctions screening results, where legally permitted, government affiliation, political contributions, and fingerprints for certain locations (if you are offered a position of employment or an internship with us).

We may collect the following data through your use of this website:

• Technical Data includes internet protocol (IP) address, your login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform, and other technology on the devices you use to access this website.
• Usage Data includes information about how you use our website.
• Any other information you provide us as part of your use of this website

IF YOU FAIL TO PROVIDE PERSONAL DATA

Where we need to collect personal data by law, or under the terms of a contract we have with you and you fail to provide that data when requested, we may not be able to continue with the job candidacy process.

2. LEGAL BASIS FOR DATA PROCESSING

We will only use your personal data when the law allows us to. Most commonly, we will process your personal data in the following circumstances:

• where we need to comply with a legal or regulatory obligation;
• where it is necessary for our legitimate interests and your interests and fundamental rights do not override those interests;
• where necessary if we enter into an employment contract with you; or
• where you have provided consent.

We seek to ensure that our information collection and processing is always proportionate. We will notify you of any changes to information we collect or to the purposes for which we collect and process it.

PURPOSES FOR WHICH WE WILL USE YOUR PERSONAL DATA

Collection of Special Categories of Personal Data

We will only Process sensitive Personal Information if we have a lawful basis for doing so (as set out in the 'Legal Basis for Data Processing' above) and when provided voluntarily from you or by a third party with your consent. We will generally only use your particularly sensitive personal information in the following ways:

• We will use information about any disability or health condition you may have to consider whether we need to provide appropriate adjustments during the recruitment process, for example whether adjustments need to be made during a test or interview.
• We will use information about your race or national or ethnic origin, religious, philosophical or moral beliefs to ensure meaningful equal opportunity monitoring and reporting.
• We will use information about your unlawful or objectionable conduct, criminal charges, or convictions to evaluate fitness for a particular purpose.

We have in place an appropriate procedures and safeguards.

Headlands Technologies does not use automated decision-making in Processing Personal Data in a way that will have a significant impact on you.

COOKIES

A cookie is an element of data that a website can send to your browser, which is then stored on your system. A cookie is useful for having the browser remember specific information across several pages or between visits to a website. A cookie does not store personally identifiable information or any sensitive information. Also, our site does not read any information stored in cookies given to you from other websites, except in cases where the other website is a provider of information or functionality within our website and that cookie is necessary to make our website function correctly.

Our website may make use of cookies for the following purposes:

• website administration and personalization;
• completing your request;
• authentication purposes;
• analysis of page and website information that does not identify specific individuals.

You can set your browser to notify you when you receive a cookie, or to alert you when websites set or access cookies, giving you the chance to decide whether to accept it. Browsers may also be set up to display a warning when a cookie is used. You may even disable your browser from accepting cookies. In order to provide you with the best possible experience while visiting our website, please enable cookies within your browser. Many parts of our site do not function properly if you disable cookies. Logging off, however, will delete the cookies. Additionally, when a session times out, the cookie expires and is removed on close of browser or when new session is initiated.

3. WITH WHOM DO WE SHARE YOUR PERSONAL DATA?

Your personal data may be shared with affiliated companies where it is reasonable and necessary to do so, such as to ensure a consistent application of standards for candidate recruitment. Within the Company, your personal data can be accessed by or may be disclosed internally on a need-to-know basis to persons responsible for managing or making hiring decisions and Human Resources staff.

Your personal data may also be accessed by third parties who provide us with services relevant to your recruitment, namely recruiters; companies that host, support and/or maintain the IT systems supporting our recruitment system; regulators, law enforcement and other government agencies; companies that verify your references, undertake background checks or conduct vetting on our behalf (where this is relevant and to the extent permitted by applicable law); and/or other third parties where we determine the disclosure is necessary to protect health and safety, our business interests, our regulatory or legal obligations, pursuant to a court order, government request or other demand, or as otherwise required by law.

If your application for employment with the Company is successful and you accept a job offer from us, your personal data may also be shared as described in our employee privacy notice, which will be provided at the time of employment.

The Company expects all third parties to process any personal data disclosed to them in accordance with applicable law and contract terms, including with respect to personal data confidentiality and security. Where these third parties act as a "processor", they carry out their tasks on our behalf and upon our instructions for the above-mentioned purposes. In this case, your personal data will only be disclosed to these parties to the extent necessary to provide the required services.

4. SECURITY OF PROCESSING

We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorized way, altered or disclosed. In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal data on our instructions, and they are subject to a duty of confidentiality.

We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of such a breach where we are legally required to do so.

5. INTERNATIONAL TRANSFERS

We share your personal data within the Headlands Tech Group. Accordingly, in the ordinary course of business, your personal data may be accessed, transferred, or otherwise Processed by our personnel and by third parties outside the European Economic Area (EEA).

Whenever we share your personal data out of the EEA, we ensure a similar degree of protection is afforded to it by ensuring at least one of the following safeguards is implemented:

• We may transfer your personal data to countries that have been deemed to provide an adequate level of protection for personal data by the European Commission. For further details, see European Commission: Model contracts for the transfer of personal data to third countries.

We may use specific contracts approved by the European Commission which give personal data the same protection it has in Europe. For further details, see European Commission: Model contracts for the transfer of personal data to third countries.

If you apply for a position at Headlands Technologies, your Personal Information may be Processed by Headlands Technologies in the United States or in one of our other locations. You understand that in some locations, the information you submit may not be subject to the same legal protection as is mandated in your home country and that the laws regarding privacy, data protection, and confidentiality of Personal Information may not be accorded the same protection as in your home country. Headlands Technologies will ensure that any Personal Information it transfers will be handled in accordance with good practice and any relevant law and/or regulations, including the standard contractual clauses, as applicable.

Please contact us at dataprotection@headlandstech.com if you want further information on the specific mechanism used by us when transferring your personal data out of the EEA.

6. DATA RETENTION

We will only retain your personal data for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements.

• For successful job applicants who become employees of Headlands Tech, any retention protocols that apply to employees will apply.
• For unsuccessful EEA, Switzerland, and/or UK job applicants who apply for a position in any of our offices, we will retain your personal data for as long as is necessary to fulfill the above purposes and for the retention period required in compliance with applicable laws and regulations.

We retain your Personal Information for that period in case there are further job opportunities in the near future or so that we can show, in the event of a legal claim, that we have not discriminated against candidates on prohibited grounds and that we have conducted the recruitment exercise in a fair and transparent way. After this period, we will securely destroy your Personal Information.

Details of retention periods for different aspects of your personal data are available in our retention policy which you can request from us by contacting us at dataprotection@headlandstech.com.

7. YOUR RIGHTS

Under certain circumstances, you have the following rights under data protection laws in relation to your personal data:

Request access, correction, or deletion you may request access, updating, deletions and corrections of inaccuracies in other personal information we have in our custody or control by emailing or writing to us at the contact information set out below.

Object to processing you can object to the processing of your personal information in some circumstances (in particular, where we don't have to process the data to meet a contractual or other legal requirement).

Request restriction of processing of your personal data. This enables you to ask us to suspend the processing of your personal data in the following scenarios: (a) if you want us to establish the data's accuracy; (b) where our use of the data is unlawful but you do not want us to erase it; (c) where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims; or (d) you have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.

Request the transfer of your personal data to you or to a third party. We will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.

Automated individual decision making entails the right not to be subject to a decision based solely on automated Processing (including profiling) that produces legal effects concerning you or similarly significantly affects you.

Withdraw consent at any time where we are relying on consent to process your personal data. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. Please click on the links below to find out more about these rights:

If you want to review, verify, correct or request erasure of your Personal Information, object to the processing of your personal data, or request that we transfer a copy of your Personal Information to another party, please contact the Data Protection Officer in writing. Additionally, if you have a concern about any aspect of our Privacy Policy, including the way we have handled your personal data, you can report it to your local data protection regulators.

If you are an EEA or UK resident, you have the right to bring complaints with any relevant data protection or privacy authority. You have a right to lodge a complaint with the UK Information Commissioner's Office at ico.org.uk/concerns/. Alternatively, you have the right to contact the relevant data protection supervisory authority in the EEA state of your habitual residence, place of work or of an alleged infringement of data protection laws in the EEA. In the Netherlands, the data protection regulator is the Dutch Data Protection Authority (Dutch DPA). You can contact the Dutch DPA using the following website: https://autoriteitpersoonsgegevens.nl/en/contact-dutch-dpa/contact-us.

TIME LIMIT TO RESPOND

We try to respond to all legitimate data subject access requests within one month. Occasionally it may take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.

8. CONTACT US

If you have any questions or comments about this Policy, the ways in which we collect and use your personal information, your choices, and rights regarding such use, or wish to exercise your rights, please do not hesitate to contact us at:

9. CHANGES TO THIS NOTICE

We may make changes to this Privacy Notice to reflect any changes to our use of your Personal Information or if required to comply with changes in applicable law or regulatory requirements. We encourage you to visit this Privacy Notice to review any updates.

10. GLOSSARY

Comply with a legal or regulatory obligation means processing your personal data where it is necessary for compliance with a legal or regulatory obligation that we are subject to.

External Third Parties means

• Service providers acting as processors based in the USA, the Netherlands, the United Kingdom and the European Union who provide IT and system services.
• Internal Revenue Service, Tax and Customs Administration (Belastingdienst), Inland Revenue Authority of Singapore, regulators and other authorities acting as processors or joint controllers based in the USA, the Netherlands, and Singapore require reporting of processing activities in certain circumstances.

Internal Third Parties means other companies in the Headlands Tech Group acting as joint controllers or processors and who are based in the Netherlands, the United Kingdom, France, Switzerland, Hong Kong and Singapore, and provide IT and system and administrative services.

Legitimate Interest means the interest of our business in conducting and managing our business. We make sure we consider and balance any potential impact on you (both positive and negative) and your rights before we process your personal data for our legitimate interests. We do not use your personal data for activities where our interests are overridden by the impact on you (unless we have your consent or are otherwise required or permitted to by law). You can obtain further information about how we assess our legitimate interests against any potential impact on you in respect of specific activities by contacting us at dataprotection@headlandstech.com.

Performance of a Contract means processing your data where it is necessary for the performance of a contract to which you are a party or to take steps at your request before entering into such a contract, such as an employment contract.

Updated: October 2024