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MOD RECRUITMENT PRIVACY POLICY

1. Privacy Policy

Machines of Destiny Ltd. and its affiliates ("Machines of Destiny,” “MOD,” "we," "us," or "our") are committed to safeguarding the privacy of prospective employees, job applicants and candidates ("you/your") and the Personal Information you have entrusted to us. It is important for you to understand what Personal Information we will collect, how we will use it, and who may access it.


“Personal Information” means information about an identifiable individual. It includes information that you have provided to us or was collected by us from other sources. It may include details such as your name and address, age and gender, personal financial records, identification numbers including your Social Insurance Number, Identity Card Number, Passport Number, employment and educational history, professional affiliations and personal references, to the extent permitted by local laws.


This Privacy Policy applies only to prospective employees, job applicants and candidates. It governs the collection, use, access and processing of Personal Information submitted by or about such persons through MOD’s online application platforms, recruitment drives, third party platforms, recruiters and other contacts, or directly communicated to MOD. It also applies to employees of a potential acquisition target whose Personal Information is collected by MOD in the course of due diligence. This Privacy Policy does not apply to our employees, customers, suppliers, contractors or to Personal Information that MOD collects for other purposes.


Further notices highlighting certain uses we wish to make of your Personal Information together with the ability to opt in or out of selected uses may also be provided when we collect Personal Information from you.


Our websites may contain links to other third party websites. If you follow a link to any of those third party websites, please note that they have their own privacy policies and that we do not accept any responsibility or liability for their policies or processing of your Personal Information. Please check these policies before you submit any Personal Information to such third party websites.


This Privacy Policy is intended to explain our privacy practices in relation to recruitment and covers the following areas:


a.    what Personal Information about you we may collect;
b.    how we may use your Personal Information;
c.    who we may share your Personal Information with;
d.    how we protect your Personal Information;
e.    how to contact us, your ability to prevent marketing communications and how to access and update your Personal Information;
f.    our Cookies Policy; and
g.    how changes to this Privacy Policy and the Cookies Policy will be made.

2.    What Personal Information We May Collect
We will collect and process all or some of the following Personal Information about you, to the extent such collection and processing may be necessary in connection with the recruitment process relating to your candidacy:


a.    Information you provide to us: Personal Information that you provide to us when you apply for a role with us, including your name, contact details, home address, email address, work and educational history, professional affiliations, photograph, identity documents, identification number, and other details. This may also include sensitive Personal Information consisting of racial or ethnic origin, trade union membership, or data concerning health;
b.    Information about you provided to us by third parties or made publicly available: Personal Information about you provided by third parties such as recruitment agencies, prior employers, your references, (to the extent permitted by law) background check providers, as well as Personal Information which is publicly available;
c.    Our correspondence: We will typically keep a record of any correspondence between us;
d.    Device information: This will include information about your operating system, browser, software applications, IP address, geolocation, security status and other device information in order to improve your experience, to protect against fraud and manage risk; and
e.    Website and communication usage details of your visits to the websites and information collected through cookies and other tracking technologies: This will include, but not be limited to, your IP address and domain name, your browser version and operating system, traffic data, location data, web logs, posts on the MOD forum, other communication data, and the resources that you access.

3.    How We May Use Your Personal Information
In this section, we set out the purposes for which we use your Personal Information and, in compliance with our obligations under applicable laws, identify the "legal grounds" on which we rely to process the information.
These "legal grounds" allow companies to process personal data only when the processing is permitted by the specific "legal grounds" set out in applicable laws. They are:


a.    Consent: where you have consented to our use of your information;
b.    Contract performance: where your information is necessary to enter into or perform our contract with you;
c.    Legal obligation: where we need to use your information to comply with our legal obligations;
d.    Legitimate interests: where we use your information to achieve a legitimate interest and the reasons for using it outweigh any prejudice to your data protection rights; and
e.    Legal claims: where your information is necessary for us to defend, prosecute or make a claim against you, us or a third party. If you have consented to our use of information about you for a specific purpose, you have the right to change your mind at any time, but this will not affect any processing that has already taken place. Where we are using your information because we or a third party (e.g. your employer) have a legitimate interest to do so, you have the right to object to that use though, in some cases, this may mean no longer using the Services.

Please note that in addition to the disclosures we have identified below, we may disclose Personal Information for the purposes we explain in this policy to service providers, contractors, agents, advisors (e.g. legal, financial, business or other advisors) and affiliates of MOD that perform activities on our behalf, as well as other members of the MOD group.


The purposes for which we use your Personal Information and the "legal grounds" on which we rely to process the information are:


a.    To evaluate and communicate with prospective employees.

Use justifications: consent, legitimate interests (to enable us to evaluate your candidacy and manage our relationship with you).
b.    To conduct background checks and other due diligence procedures on prospective employees, where applicable.

Use justifications: consent, legal obligation, legitimate interests (to enable us to evaluate your candidacy and ensure due diligence is performed on candidates).
c.    To maintain recruitment records.

Use justifications: consent, legal obligation.
d.    To reorganize or make changes to our business in the event that we: (i) are subject to negotiations for the sale of our business or part thereof to a third party; (ii) are sold to a third party; or (iii) undergo a re-organization, we may need to transfer some or all of your Personal Information to the relevant third party (or its advisors) as part of any due diligence process for the purpose of analyzing any proposed sale or re-organization. We may also need to transfer your Personal Information to that re-organized entity or third party after the sale or reorganization for them to use for the same purposes as set out in this policy.

Use justifications: legitimate interests (in order to allow us to change our business).
e.    In connection with legal or regulatory obligations, or legal proceedings. We may process your Personal Information to comply with our regulatory requirements, dialogue with regulators, or in connection with legal proceedings, which may include disclosing your Personal Information to third parties, the court service and/or regulators or law enforcement agencies in connection with enquiries, proceedings or investigations by such parties anywhere in the world or where compelled to do so. Where permitted, we will direct any such request to you or notify you before responding unless to do so would prejudice the prevention or detection of a crime.

Use justifications: legal obligations, legal claims, legitimate interests (to cooperate with law enforcement and regulatory authorities and to enforce our rights or defend ourselves).
f.    Retention of Personal Information upon employment. If you are employed by us, any Personal Data provided to us during the recruitment process will form part of your personnel file and will be retained in accordance with our privacy policies applicable to MOD employees.

Use justifications: consent, legitimate interests (to maintain personnel records).
g.    Specifically in relation to sensitive Personal Information, we may process such Personal Information for any purposes to which your explicit consent has been obtained, for compliance with environmental, social and governance obligations imposed by applicable law and regulations (such tracking diversity in our workforce), or to the extent required by law or contractual obligations.

Use justifications: explicit consent, necessary for the carrying out of obligations under employment law, social security or social protection law, or a collective agreement.


b)    Sharing Your Personal Information (and Cross-Border Transfers)
.    Sharing outside the MOD group: Personal Information may be provided to third parties, including background check service providers, anti-fraud organisations, legal, regulatory or law enforcement authorities in cases of suspected criminal activity or contravention of law, for the detection and prevention of fraud, or when required to satisfy the legal or regulatory requirements of governments, regulatory authorities or other self-regulatory organizations, or to comply with a court order or in connection with a legal or regulatory process.
a.    Sharing within the MOD group: We may share your Personal Information within the MOD group, including locations outside of your country of residence or the European Economic Area (“EEA”), for recruitment and hiring purposes, for legal and regulatory purposes, to manage business risks, to perform analytics, to ensure we have correct or up to date information about you (such as your current address or date of birth) and for administrative and IT purposes.
b.    Business sale or reorganization: Over time, we may buy new businesses or sell some of our businesses. Accordingly, Personal Information associated with the business being purchased or sold will be reviewed as part of the due diligence process and subsequently transferred as a business asset to the new business owner. We may also transfer Personal Information as part of a corporate reorganization or other change in corporate control.
c.    Sub-contractors and agents: We may use affiliates or other companies to provide services on our behalf such as data processing, human resources management and fraud prevention and detection. Such companies will be given only the Personal Information needed to perform those services and we do not authorize them to use or disclose Personal Information for their own marketing or other purposes. We have contracts in place holding these companies to the same standards of confidentiality by which we are governed.


4.    EEA Rights to Personal Information / General Data Protection Regulation (“GDPR”)
EEA individuals have the right, under certain circumstances, to:

 

Access their personal information;


a.    Correct inaccurate personal information;
b.    Request erasure of their personal information without undue delay;
c.    Request the restricted processing of their personal information;
d.    Receive the personal information that they have provided us with, in a structured, commonly used and machine-readable format and you have the right to transmit that information to another controller without hindrance or ask us to do so; and
e.    Object to the processing of their personal information.


Such individuals may request access to their personal information and modify or remove most information associated with their candidacy at any time by emailing us at dpo@MOD.com.
EEA individuals also have the right to lodge a complaint with a supervisory authority, in particular in the EU Member State of their habitual residence, place of work or place of the alleged infringement if they consider that our processing of their personal information infringes the applicable data protection laws. Please contact us at
info@machinesofdestiny.net and we will provide you with detailed information regarding the contact details of the respective competent supervisory authority.


5.    Transfers Outside of the EEA
This section applies to EEA individuals.
Your Personal Information may be accessed by staff, suppliers or other persons in, transferred to, and/or stored at, a destination outside the EEA in which data protection laws may be of a lower standard than in the EEA. We will, in all circumstances, safeguard personal information as set out in this Privacy Policy.
Where we transfer Personal Information from inside the EEA to outside the EEA, we may be required to take specific additional measures to safeguard the relevant Personal Information. Certain countries outside the EEA have been approved by the European Commission as providing essentially equivalent protections to EEA data protection laws and therefore no additional safeguards are required to export Personal Information to these jurisdictions. In countries which have not had these approvals (see the full list here http://ec.europa.eu/justice/data-protection/international-transfers/adequacy/index_en.htm), we will establish legal grounds justifying such transfer, such as EU Commission-approved model contractual clauses, or other legal grounds permitted by applicable legal requirements.
If you live outside the EEA, we will undertake best efforts to give you a similar degree of control over your privacy.


6.    Security of Your Personal Information
.    We use physical, electronic and procedural safeguards to protect against unauthorized use, access, modification, destruction, disclosure, loss or theft of your Personal Information in our custody or control.
a.    We have agreements and controls in place with third party service providers requiring that any information we provide to them must be safeguarded and used only for the purpose of providing the service we have requested the company to perform.


7.    Security Over the Internet
.    No data transmission over the Internet or website can be guaranteed to be secure from intrusion. However, we maintain commercially reasonable physical, electronic and procedural safeguards to protect your Personal Information in accordance with data protection legislative requirements.
a.    All information you provide to us is stored on our or our subcontractors' secure servers and accessed and used subject to our security policies and standards. Where we have given you (or where you have chosen) a password which enables you to access certain parts of our websites, you are responsible for keeping this password confidential and for complying with any other security procedures that we notify you of. We ask you not to share a password with anyone.


8.    Retention of Your Personal Information
Our retention periods for personal data are based on business needs and legal requirements, which will differ depending on the jurisdiction or regulatory status of the MOD unit to which your candidacy relates. We retain your Personal Information for as long as is necessary for the processing purpose(s) for which the information was collected, and any other permissible, related purpose. When Personal Information is no longer needed, we either irreversibly anonymise the data (and we may further retain and use the anonymised information) or securely destroy the data.
If you have provided Personal Information to us via the MOD Careers website, you may also request for your Personal Information to be destroyed by clicking on the “Delete My Information” option under “Account Settings”.


9.    Updating Information
We will use reasonable endeavours to ensure that your Personal Information is accurate. In order to assist us with this, you should notify us of any changes to the Personal Information that you have provided to us by contacting us as set out in the "Contacting Us" section below.

 

10.    Your Rights
If you have any questions in relation to our use of your Personal Information, you should first contact us as per the "Contacting Us" section below. Under certain conditions, you may have the right to require us to:
.    provide you with further details on the use we make of your information;


a.    provide you with a copy of information that you have provided to us;
b.    update any inaccuracies in the Personal Information we hold;
c.    delete any Personal Information the we no longer have a lawful ground to use;
d.    where processing is based on consent, to withdraw your consent so that we stop that particular processing;
e.    object to any processing based on the legitimate interests ground unless our reasons for undertaking that processing outweigh any prejudice to your data protection rights; and
f.    restrict how we use your information whilst a complaint is being investigated.
Your exercise of these rights is subject to certain exemptions to safeguard the public interest (e.g. the prevention or detection of crime) and our interests (e.g. the maintenance of legal privilege). If you exercise any of these rights, we will check your entitlement and respond in most cases within a month.


11.    Contacting Us
If you have any questions or concerns about our privacy practices, the privacy of your Personal Information or you want to change your privacy preferences, please let us know.
To contact or get in touch with our team at contact@machinesofdestiny.net. Policy
We use cookies on our websites. To find out more about how we use cookies, please see our Cookies Policy at http://www.machinesofdestiny.net/legal.


12.    Changes to Our Privacy Policy and/or Cookies Policy
We may change the content of our websites and how we use cookies and consequently our Recruitment Privacy Policy and our Cookies Policy may change from time to time in the future. If we change this Recruitment Privacy Policy or our Cookies Policy, we will update the date it was last changed below. If these changes are material, we will indicate this clearly on our website.


13.    General
The provisions of this Privacy Policy supersede all other policies, contracts, agreements or arrangements, whether oral or written, express or implied, between us and you in respect of the subject matter herein. This Privacy Policy prevails over any other terms contained in or referred to in any other applicable policy or implied by trade, custom or course of dealing.

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