Recruitment Privacy Notice

Introduction

Leaside Services Limited (we), a company registered in Cyprus, is committed to protecting your privacy and ensuring the fair and lawful processing of your personal data during the recruitment process. This consent form outlines how your personal information will be collected, used, and protected in compliance with international data protection regulations, including but not limited to the General Data Protection Regulation (GDPR), the UK GDPR, UK Data Protection Act 2018, the U.S. Office of Federal Contract Compliance Programs (OFCCP) requirements, and the California Consumer Privacy Act (CCPA).

1. Data Controller and Operator

The data controller is Leaside Services Limited, located at Office 21, 17 Georgiou Karaiskaki Str., 3032 Limassol, Republic of Cyprus. We may use Workable, an online application provided by Workable Software Limited, to assist with our recruitment process. If we use Workable to process personal information it becomes a data processor on our behalf. Workable is only entitled to process your personal data in accordance with our instructions. If you have any questions regarding the processing of your data or your rights under applicable laws, please contact us (see “Contact Information" below).

2. Purpose of Data Processing

Your personal data will be processed for the purpose of evaluating your application for employment with Leaside Services Limited or its affiliated companies. This includes:

• Considering your application for our available and/or possible positions.
• Assessing your qualifications, skills, and experience in relation to the position(s) you have applied for.
• Communicating with you throughout the recruitment process.
• Enhancing any information that we receive from you with information obtained from third party data providers.
• Finding appropriate candidates to fill our job openings.
• Helping our service providers (such as Workable and its processors and data providers) and partners (such as the job sites through which you may have applied) improve and develop their services.
• Ensuring compliance with equal employment opportunity (EEO) and anti-discrimination laws.

3. Types of Data Processed

The personal data (this includes information provided through an online job site, via email, in person at interviews and/or by any other method) we may collect from you and process includes:

• Your name, contact details (email address, phone number, etc.), date of birth, and address.
• Your resume/CV, cover letter, and any other documents you provide.
• Information about your education, employment history, experience, skills, and professional qualifications.
• Video, video interview (in case you choose special Workable features).
• Voluntary self-identification data (e.g., race, gender, disability status) for EEO reporting purposes, where applicable.
• Social media links or profile information from LinkedIn.

Providing self-identification data is entirely voluntary and will not affect your candidacy. This information is used solely for compliance with EEO reporting requirements and to ensure fairness in our recruitment practices.

4. Collection Channels

The personal data we may collect from following sources and process includes:

• Information provided directly by you when contacting us through any available communication channels (email, phone, social media, etc.), responding to our initial outreach or inquiries, or submitting information via our website or career portal (e.g., job applications, contact forms).
• Publicly available information about you that you have published on the Internet – this may include sources such as LinkedIn, public job boards databases, and other social media profiles (via Workable feature, if used).
• Personal information from various databases provided by Workable (both publicly available and not) to find possible candidates to fill our job openings.
• Personal data from a third party who recommends you as a candidate for a specific job opening or for our business more generally.

6. Data Sharing and International Transfers

Your personal data may be shared with:

• Authorized personnel involved in the recruitment process at Leaside Services Limited.
• Third-party service providers (e.g., Workable, Indeed) who assist in the recruitment process.
• Affiliated companies as part of the recruitment process:
  • Emerging Travel Inc., reg.no 4869611, USA
  • EMERGING TRAVEL UK LIMITED, Company number 12185384, Germany
  • Emerging Travel Kazakhstan LLP, BIN 191240026456, Republic of Kazakhstan
  • Smart Middle East Travel Agency L.L.C, Reg.no: 1803677, United Arab Emirates
  • Emerging Travel Asia PTE. LTD, Reg.no: 201927854K, Singapore
• Job sites or similar online service providers.
• Government agencies, where required by law (e.g., for EEO or OFCCP reporting).

Your data may be transferred to and processed in countries outside your country of residence, including countries outside the European Economic Area (EEA) or the United Kingdom (UK). Where such transfers occur, we ensure appropriate safeguards are in place to protect your data, such as Standard Contractual Clauses (SCCs) or other mechanisms approved under applicable laws.

Please note that the operations of the companies mentioned in this clause are subject to their own terms of service and privacy policies, as well as applicable laws and international standards. If applicable, your account preferences on the relevant platforms may also apply.

7. Automated Candidate Matching by Workable

As part of our recruitment process, we use the Workable platform, which may automatically match your profile with potential job opportunities based on your qualifications, skills, and experience. However, all such matches are reviewed manually by our recruitment team to ensure relevance and fairness. We do not use fully automated decision-making systems in our hiring process. Automated matching is used solely to assist in identifying potential candidates and does not replace human judgment in the recruitment process.

8. Data Retention

Your personal data will be retained for as long as necessary to fulfill the purposes outlined in this notice. Once it is no longer needed for these purposes, your data may be securely deleted or anonymized.

9. Your Rights Under Applicable Laws

Depending on your location and applicable laws, you may have the following rights regarding your personal data:

GDPR and UK GDPR:

• Right to Access: You can request a copy of the personal data we hold about you.
• Right to Rectification: You can request corrections to any inaccurate or incomplete data.
• Right to Erasure: You can request the deletion of your data under certain circumstances.
• Right to Restrict Processing: You can request that we limit the processing of your data.
• Right to Data Portability: You can request a copy of your data in a machine-readable format.
• Right to Object: You can object to the processing of your data under certain conditions.

CCPA (California Residents):

• Right to Know: You can request information about the categories and specific pieces of personal data we have collected about you.
• Right to Delete: You can request the deletion of your personal data.
• Right to Opt-Out of Sale: You can opt-out of the sale of your personal data (if applicable).
• Right to Non-Discrimination: You have the right to not be discriminated against for exercising your CCPA rights.

OFCCP (U.S. Applicants):

• Voluntary Self-Identification: You may voluntarily provide information about your race, gender, disability status, or veteran status for EEO reporting purposes. This information is used solely for compliance with federal regulations and will not affect your candidacy.

Other Jurisdictions:

If you are located in a jurisdiction not explicitly mentioned above (e.g., Kazakhstan, Singapore, etc.), you may have additional rights under local data protection laws. These may include:

• Right to Access: You can request a copy of the personal data we hold about you.
• Right to Rectification: You can request corrections to any inaccurate or incomplete data.
• Right to Erasure: You can request the deletion of your data under certain circumstances.
• Right to Object: You can object to the processing of your data under certain conditions.

To exercise any of these rights, please contact us (see “Contact Information" below).

10. EEO and Non-Discrimination Commitment

Leaside Services Limited is an equal opportunity employer. We do not discriminate on the basis of race, color, religion, sex, national origin, age, disability, genetic information, or any other characteristic protected by applicable law. All employment decisions are based on qualifications, merit, and business needs.

11. Data Security

Leaside Services Limited is committed to protecting the security of your personal data. We implement appropriate technical and organizational measures to safeguard your data against unauthorized access, disclosure, alteration, or destruction. These measures include encryption, access controls, and regular security audits.

12. Changes to This Consent Form

We may update this consent form from time to time to reflect changes in our practices or applicable laws. If we make significant changes, we will notify you and, where required by law, seek your renewed consent.

13. Contact Information

If you have any questions, concerns, or requests regarding your personal data or this consent form, please contact us at: