RECRUITMENT PRIVACY NOTICE

This Notice lets you know how WunderLand Group collects and uses your personal information when you apply (both online and offline) for a position with WunderLand Group.

The data controller

The “data controller” of the personal information collected and processed about you is WunderLand Group, who is responsible for deciding how and why your personal information is used and ensuring that your personal information is handled lawfully.

WunderLand Group, and its affiliate, Advanced Personnel, Inc. (“Advanced Personnel”), each of which is based in the USA, are responsible for managing recruitment activities. This means that, wherever you are based, the US Affiliates will process your personal information in the USA. WunderLand Group will remain the data controller and Advanced Personnel will act as data processor on behalf of the data controller.

WunderLand Group may engage another affiliate, Advanced RPO LLC, to help manage the recruitment process. Advanced RPO is also based in the USA and acts as a data processor on behalf of WunderLand Group.

WunderLand Group may use the services of an “employer of record” agency (the “Agency”) to hire employees and other workers. If this is the case, and you are successful in your application for a position, your contract will be with the Agency. The Agency will therefore also be a data controller of the data the Agency holds to administer your employment.

Where we use the terms “we” in this policy, we mean WunderLand Group and/or Advanced Personnel acting as a data processor on behalf of WunderLand Group.

Collecting Personal Information.

You may provide personal information directly to WunderLand Group. We ask for certain data, including educational and employment background, contact information and preferences,jobqualifications,andjobsforwhichyou would like to submit an application. You also may choose to provide WunderLand Group additional information, such asyourCV,resume,transcripts,employmentreferencesandrelatedinformation,andcompensationrequests.

In addition, WunderLand Group may collect information from third parties. For example, we may ask previous employers for a reference and, if we conduct background checks, we will receive data from third parties in connection with those background checks. We might also obtain information about you from LinkedIn if we have used LinkedIn to search for appropriate candidates or if we have connected with you or viewed your profile on LinkedIn, or if you apply for a position via LinkedIn.

WunderLand Group's web sites, including our recruitment systems, may use cookies and other electronic communication protocols. For further information, please consult the WunderLand Group Privacy Policy at www.wunderlandgroup.com/privacy-policy/

Sensitive Personal Information.

WunderLand Group does not request or require sensitive personal information concerning religion, health, sexual orientation, or political affiliation in connection with recruiting. We collect and process other sensitive personal data in the following circumstances:

If you have a disability and would like WunderLand Group to consider any accommodation, you may provide that information (health data) during the recruiting process.
In some countries we ask for information such as race or ethnicity for the purpose of monitoring equal opportunity; however, we do not require applicants to provide race or ethnicity information, and if you provide this information it will not be viewable in the hiring or selection

Voluntary Disclosure.

Your provision of personal information in connection with recruiting is voluntary, and you determine the extent of information you provide to WunderLand Group. For applicants outside of the United States, if you decide not to provide information, it may affect our ability to consider you for employment.

Using Personal Information.

The personal data you are submitting is used exclusively for the purposes set out below. Our use of your personal data is based on different legal justifications (“lawful bases”) depending on the purposes for use. These lawful bases are also set out below:

Purpose	Lawful basis
1) Recruitment purposes: assessing your application, qualifications and experience to determine whether to offer you a role (whether as an employee, contractor or other worker) and notifying you of whether your application has been successful.	· Processing is necessary to take steps at your request to enter into a contract with you for your engagement with WunderLand Group;· Processing is necessary in our legitimate interests – we have a legitimate interest in ensuring that applicants that are interviewed and hired are suitable for work that will be required of them.
2) If we decide to offer you a role, managing your ongoing engagement (further information about this purpose is available in our Employee Privacy Notice).	· Processing is necessary to perform your contract and for the reasons detailed in the Employee Privacy Notice.
3) If we do not decide to offer you a role, keeping your details on file to ensure we can respond to any queries that you might have about the selection process and to inform you of future job openings (unless you have told us that you don’t want us to do this).	· Processing is necessary in our legitimate interests. We have a legitimate interest in ensuring that we can provide comprehensive answers to any questions you have and that we have a clear audit trail of decision-making processes in the event of any challenge. We also have a legitimate interest in ensuring that we can notify you of upcoming opportunities that we think will be suitable for you so that we can engage the most appropriate candidates.· This is also in your interests as it ensures that you are informed of appropriate opportunities. You will be able to let us know at the time we inform you that your application has been unsuccessful, or at any time afterwards, if you do not want us to keep your information for these purposes.
4) Making reasonable adjustments to consider any disabilities that you make us aware of.	· Processing is necessary for compliance with legal obligations in the sphere of employment law; we are required to make reasonable adjustments for disabilities.
5) Diversity and equal opportunities monitoring.	· Processing is necessary in our legitimate interests. We have an interest in ensuring that our organization is diverse and that all individuals are given equal opportunities to progress. Processing of this data is required to keep equal opportunities under review.

If you are hired, the information may be used in connection with your engagement and for managing our organization. This will be subject to our Employee Privacy Notice and (if you are employed by our Agency) the Agency’s own privacy policy.

Data Recipients and Sharing with Third Parties.

WunderLand Group will share your personal information with the following recipients:

WunderLand Group’s affiliated company as detailed in the introduction to this policy;
service providers and other third parties as necessary in connection with recruiting, background checks (as applicable), pre-employment/onboarding processes, corporate governance, acquisitions and legal or regulatory requirements, including our primary human resources service providers. If you want to know more information about the identity of the specific service providers we use, please contact us at privacy@advancedgroup.com. WunderLand Group requires that its service providers and such other third parties keep your personal information confidential and that they only use the personal information in furtherance of the specific purpose for which it was disclosed;
clients of WunderLand Group to enable them to comply with obligations to provide information to regulatory authorities about individuals working on projects for them;
our Agency, if we hire you and you are employed by the Agency, to enable the Agency to manage your employment.

Security and Confidentiality.

Except as otherwise stated in this Notice or as required for legal or regulatory purposes, WunderLand Group treats your personal information as confidential and will not disclose it to third parties without your consent. WunderLand Group maintains, and requires its service providers to maintain, reasonable administrative, physical, and technical controls designed to protect the confidentiality and security of your personal information. WunderLand Group employees who may have access to personal information are required to keep that information confidential.

Retention.

If you are hired, we will keep your personal data processed in connection with your recruitment for the duration of your employment and the period thereafter as set out in our Employee Privacy Notice. If you are employed by the Agency, they will keep your personal data for the period detailed in their own privacy policies.

If you are not hired, will retain your information for a reasonable period of time (not to exceed 12 months) to ensure that we can respond to any queries, complaints or claims in relation to our decision not to hire you.

Your rights.

You have certain rights under data protection laws over your personal data. These include the following rights:

A right to ask us to correct any personal data we hold about you that is inaccurate;
A right to access a copy of your personal data (subject to some exceptions);
A right to have certain personal information provided to you in a common electronic format so that you can transfer it to a third party if possible;
A right to request deletion of personal data in certain circumstances, for example if we no longer need it or if we have processed it unlawfully (please note that we may not always be legally obliged to delete your information if we can demonstrate why we need it);
A right to object to certain processing of personal information, where our “lawful basis” set out above is our “legitimate interests”. If you object, we will stop processing your personal information for these purposes unless we can show that we have a compelling reason to continue doing so;
A right to ask us to restrict the processing of your personal information in some circumstances, for example if you think information is not accurate and we need time to check whether it is accurate, or if we have processed information unlawfully but you don’t want us to delete it. In these circumstances, we will do nothing but store your information unless and until you consent to us continuing to process it, we have verified its accuracy, or where there are other overriding justifications for continuing to process the information.

We will respond to any valid requests to exercise any of the above rights within one month, or within three months if the request is complex or if you have made several different requests. To exercise any of these rights, please contact us as specified under Inquiries, Complaints and Objections below.

Automated Decisions.

WunderLand Group generally does not make recruiting or hiring decisions based solely on automated processing of personal data. In the event that WunderLand Group relies solely on automated decision-making that could have a significant impact on you, WunderLand Group will provide you with an opportunity to express your views and will provide any other safeguards required by law.

Inquiries, Complaints & Objections.

You may submit inquiries, complaints and/or objections to the processing of your personal information, or requests to exercise your rights set out above, by sending a request in writing to privacy@advancedgroup.com.

Your Responsibilities.

You are responsible for the information you provide or make available to WunderLand Group, and you must ensure it is honest, truthful, accurate and not misleading in any way. If you provide any information concerning any other person, such as individuals you provide as references, you are responsible for providing any notices and obtaining any consents necessary for WunderLand Group to collect and use that information for the purposes described in this Notice.

Cross Border Transfers.

As detailed above, wherever you are based, WunderLand Group and Advanced Personnel will handle your personal data for recruitment purposes. Our online system that we use for recruitment is also hosted in the USA and some of our other suppliers may also transfer personal data to countries other than your home country. WunderLand Group has developed global data practices designed to assure your personally identifiable information is appropriately protected. Where required, we have agreements in place incorporated required contractual clauses to ensure that your personal data remains protected when it is transferred overseas to affiliates. We also ensure that the Clauses are incorporated into arrangements with our suppliers who transfer personal data outside the UK and the EEA.

General.

WunderLand Group may update this Notice from time to time, and the current version will be available on WunderLand Group’s job search page. If you have any questions or concerns about this Notice or its application, or if you believe your personal information has been used in a way that is not consistent with this, please contact us at privacy@advancedgroup.com.

WunderLand Group will process applicant personal information in accordance with this Notice, unless in conflict with requirements of applicable law, in which case applicable law will prevail.

Effective Date: February 19, 2023