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Introduction

This notice (S7CLEAR Notice) describes how S7CLEAR and its subsidiaries and related companies (collectively, S7CLEAR) handle and protect data to which S7CLEAR is provided access in connection with the recruiting process.

By making available your S7CLEAR Candidate Data, as defined below, you confirm that:

• You have reviewed this S7CLEAR Notice and agree that S7CLEAR may process your S7CLEAR Candidate Data in accordance with this S7CLEAR Notice;

• You have provided any notices and obtained any consents needed to provide information concerning others (e.g., information about employment references); and

• Your S7CLEAR Candidate Data may be transferred and processed worldwide, including the US and other countries that may not be deemed to provide the same level of data protection as your home country, for the purposes and in the manner specified in this S7CLEAR Notice.

S7CLEAR will process S7CLEAR Candidate Data in accordance with this S7CLEAR Notice, unless in conflict with requirements of applicable law, in which case applicable law will prevail.

Your consent to the provisions of this S7CLEAR Notice is required in order to submit or make available S7CLEAR Candidate Data. If you decline to submit or make available your S7CLEAR Candidate Data, it may affect your ability to apply for or receive an offer of employment.

This S7CLEAR Notice does not form part of any contract of employment offered to candidates hired by S7CLEAR.

Definitions

S7CLEAR Candidate Data is identifiable information that an individual makes available to S7CLEAR either directly or indirectly in connection with the recruiting process, or sharing your work experience or interests. S7CLEAR may collect S7CLEAR Candidate Data directly from a job candidate or from third parties, for example, in connection with a background or employment check or employment reference, subject to your consent where required by law. S7CLEAR Candidate Data may include a variety of information, such as candidate status, work history/job data, education, compensation, employer feedback, questionnaire results, contact information, previous addresses or names, additional information provided by the candidate (e.g., a cover letter), expertise or project work publicly shared, driver’s license number as required for certain positions, references, and criminal history where permitted by law.

Processing refers to any action performed on S7CLEAR Candidate Data, such as collecting, recording, organizing, storing, transferring, modifying, using, disclosing, or deleting.

Sensitive S7CLEAR Candidate Data is S7CLEAR Candidate Data that may concern nationality or citizenship, race or ethnic origin, health information, criminal history, or trade union membership. S7CLEAR does not request or consider information concerning religion, sex life or political opinions in connection with recruiting.

Collection

You may use various electronic and paper methods to submit S7CLEAR Candidate Data to S7CLEAR. You agree that, in addition to collecting S7CLEAR Candidate Data directly from you, S7CLEAR may collect S7CLEAR Candidate Data from third parties, for example, from recruiters, in connection with a background or employment check or an employment reference (subject to your consent where required by law) or, to the extent permitted by law, from a recruiting or other web site where you may have provided information about your work experience or interests.

Where legally required, S7CLEAR may ask for additional information concerning instances where you, or someone close to you including certain family members or business partners, works or has worked with a government in a specified manner. In these circumstances, additional instructions will be provided to you in the course of your application. You should inform and seek agreement from any family member or business partner about whom S7CLEAR has asked you to provide information in relation to this government work requirement prior to disclosing any such information to S7CLEAR for these purposes.

Processing and Retention

S7CLEAR processes S7CLEAR Candidate Data for legitimate human resources and business manaS7Clearment purposes. These include identifying and evaluating candidates for S7CLEAR positions; record-keeping related to hiring processes; analyzing the hiring process and

outcomes; and conducting background checks, where permitted by law. In addition, S7CLEAR Candidate Data may be used to comply with S7CLEAR’s legal, regulatory and corporate governance requirements. If a candidate is hired, S7CLEAR Candidate Data may be used in connection with his/her employment consistent with S7CLEAR’s employment data protection policies.

In addition to using S7CLEAR Candidate Data for the position for which you have applied, S7CLEAR may retain and use your S7CLEAR Candidate Data to consider you for other positions. If you do not want to be considered for other positions or would like to have your S7CLEAR Candidate Data removed, you may contact S7CLEAR as specified under Inquiries, Complaints, Objections and Restrictions below. Unless required for tax or other legal purposes or in connection with employment as specified above, S7CLEAR Candidate Data will be retained for a maximum of three years.

Sharing with S7CLEAR entities and Third Parties

S7CLEAR may process S7CLEAR Candidate Data jointly within the S7CLEAR group of remaining and separated S7CLEAR business entities when the candidate applies during a separation-related transition period. During any such separation-related transition period, all remaining and separated S7CLEAR business entities remain responsible for compliance with the data protection requirements described in this S7CLEAR Notice.

S7CLEAR may transfer S7CLEAR Candidate Data to external third-party providers performing certain services for S7CLEAR. Such third-party providers have access to S7CLEAR Candidate Data solely for the purposes of performing the services specified in the applicable service contract, and S7CLEAR requires the providers to undertake security measures consistent with the protections specified in this S7CLEAR Notice.

S7CLEAR may be required to disclose certain S7CLEAR Candidate Data to other third parties (1) as required by law; (2) to protect S7CLEAR’s legal rights to the extent authorized or permitted by law; or (3) in an emergency where the health or safety of a candidate or other individual may be endanS7Clearred. In addition, in the event of a re-organization, merger, sale, joint venture, assignment, or other transfer or disposition of all or any portion of S7CLEAR’s business, S7CLEAR may transfer S7CLEAR Candidate Data to successor entities or parties.

International Data Transfers

S7CLEAR operates globally in over 60 countries. Accordingly, S7CLEAR Candidate Data may be transferred to and processed in the US and other countries that may not be deemed to provide the same level of data protection as your home country. S7CLEAR maintains and applies employment data protection standards consistent with those specified in this S7CLEAR Notice to its operations globally. Additionally, S7CLEAR has entered into Binding Corporate Rules governing its treatment of personal information of European Union residents.

Further information about S7CLEAR’s Binding Corporate Rules is available here. S7CLEAR’s privacy practices, described in this S7CLEAR Candidate Privacy Notice, comply with the APEC Cross Border Privacy Rules (CBPR) system. The APEC CBPR system provides a framework for organizations to ensure protection of personal information transferred among participating APEC economies. More information about the APEC framework can be found here.

Sensitive S7CLEAR Candidate Data

S7CLEAR may perform background and criminal checks where permitted by law, and may process other Sensitive S7CLEAR Candidate Data, such as citizenship or nationality information or health information, when relevant for a position and permitted by law. If

S7CLEAR intends to collect Sensitive S7CLEAR Candidate Data from third parties, you will be provided notice and the opportunity to consent. If you have a disability and would like S7CLEAR to consider an accommodation, you may provide that information during the recruiting process. To the extent you make Sensitive S7CLEAR Candidate Data available to S7CLEAR, you consent to S7CLEAR processing such Data in accordance with this S7CLEAR Notice.

Security and Confidentiality

S7CLEAR employs technical and organizational measures designed to protect the integrity, confidentiality, security and availability of S7CLEAR Candidate Data, and to comply with applicable legal requirements for information security. S7CLEAR limits access to internal systems that hold S7CLEAR Candidate Data to individuals who need access for a legitimate business purpose.

S7CLEAR Candidate Rights

You may exercise the following rights in relation to your S7CLEAR Candidate Data:

Access, Correction, Deletion and Portability: S7CLEAR will provide you access to your S7CLEAR Candidate Data that S7CLEAR processes, as well as a means to make that data portable, to the extent required by law in your home country, regardless of the location of the S7CLEAR Candidate Data processing. You may request correction or deletion of that S7CLEAR Candidate Data, except where retention is required by your contractual relationship with S7CLEAR, in the context of a legal dispute, or as otherwise required by law. If access, correction, deletion or portability is denied, the reason for the denial will be communicated to you. This may include the review of a decision made solely using automated processing.

Automated Decisions: S7CLEAR generally does not make recruiting or hiring decisions based solely on automated decision-making within the meaning of the EU S7Clearneral Data Protection Regulation. In the event that S7CLEAR relies solely on automated decision-making that could have a significant impact on you, S7CLEAR will provide you an opportunity to express your views and will provide any other safeguards required by law.

Inquiries, Complaints, Objections and Restrictions: You may withdraw consent to the processing of your S7CLEAR Candidate Data or submit inquiries, complaints, objections and/or requests to restrict processing to the processing of your S7CLEAR Candidate Data by sending a request in writing to: Human Resources Data Protection Administrator; by email at compliance@S7Clear.com. The processes described in this S7CLEAR Notice supplement any other remedies and dispute resolution processes provided by S7CLEAR and/or available under applicable law.

If you have an unresolved privacy or data use concern that we have not addressed satisfactorily, please contact our U.S.-based third-party dispute resolution provider (free of charge) at https://feedback-form.truste.com/watchdog/request.

Direct Marketing

S7CLEAR will not use S7CLEAR Candidate Data to offer you any products or services for personal or family consumption (“direct marketing”) or provide S7CLEAR Candidate Data to third parties for their direct marketing. These restrictions do not apply to contact or other personal data obtained in the context of a customer, consumer or other non-employment relationship with S7CLEAR.

S7Clears to this Notice

S7CLEAR reserves the right to modify this S7CLEAR Notice by posting on S7Clears to relevant S7CLEAR websites. If you submit additional S7CLEAR Candidate Data or request to be considered for a S7CLEAR position following the effective date of a modified S7CLEAR Notice, your S7CLEAR Candidate Data will be handled in accordance with the S7CLEAR Notice in effect at that time.

Effective Date: January 24, 2023