DATA PRIVACY NOTICE - AGILEONE

What is the purpose of this document?

AgileOne is committed to protecting the privacy and security of your personal information.

This privacy notice describes how we collect and use personal information about you during and after your working relationship with us, in accordance with applicable laws.

It applies to all employees, workers and contractors.

ACT1 Group - Agile1 Switzerland GmbH c/o Premium Business Center 4-Towers GmbH, Turmstrasse 18, 6312 Steinhausen Switzerland ("AgileOne") is a "data controller". This means that we are responsible for deciding how we hold and use personal information about you.

This notice applies to current and former employees. This notice does not form part of any contract of employment or other contract to provide services. We may update this notice at any time.

It is important that you read this notice, together with any other privacy notice we may provide on specific occasions when we are collecting or processing personal information about you, so that you are aware of how and why we are using such information.

Data protection principles

We will comply with data protection law. This says that the personal information we hold about you must be:

1. Used lawfully, fairly and in a transparent way.
2. Collected only for valid purposes that are related to your employment and that we have clearly explained to you and not used in any way that is incompatible with those purposes.
3. Relevant to the purposes we have told you about and limited only to those purposes.
4. Accurate and kept up to date.
5. Kept only as long as necessary for the purposes we have told you about.
6. Kept securely.

The kind of information we hold about you

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 data).

There are "special categories" of more sensitive personal data which require a higher level of protection.

We collect, store, and use the following categories of personal information about you from time to time:

• Name, title, address, telephone number, personal email address.
• Date of birth.
• Job title.
• Gender
• Marital status and dependants.
• Next of kin and emergency contact information.
• Social security or national insurance numbers.
• Bank account details.
• Payroll records.
• Taxation information
• Salary, annual leave, pension and benefits information.
• Attendance
• Start date/termination date.
• Location of employment or workplace.
• Copy of driving licence/passport/utility bill.
• Recruitment information (including copies of right to work documentation, references and other information included in a CV or cover letter or as part of the application process when you joined).
• Compensation history.
• Training records
• Professional memberships
• Performance information.
• Disciplinary and grievance information.
• Information about your use of our information and communications systems.
• Photographs.
• Background screening and reference check information.

How is your personal information collected?

We collect personal information about employees through the application and recruitment process, either directly from candidates, a recruiter or online services such as LinkedIn and other job sites. We may sometimes obtain additional information from third parties including former employers, credit reference agencies or other background check agencies. Consent would be sought where local law requires.

We will collect additional personal information in the course of job-related activities throughout the period of you working for us.

How we will use information about you?

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

1. Where we need to perform the contract we have entered into with you or another party that you are a party to.
2. Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests.
3. Where we need to comply with a legal obligation.
4. We may also use your personal information where we need to protect your vital interests (or someone else's interests).

Situations in which we will use your personal information

We need the categories of information in the list above primarily to allow us to perform our contract with you and to enable us to comply with legal obligations. In some cases we may use your personal information to pursue legitimate interests of our own or those of third parties, provided your interests and fundamental rights do not override those interests. The situations in which we will process your personal information are listed below:

• Administering payroll
• Benefits and pensions
• Pre-employment recruitment and ascertaining suitability for employment/engagement
• Employment contract administration
• Taxation
• Insurance claims/admin
• Right to work assessment
• Business planning including accounting and auditing
• Performance reviews
• Salary reviews and compensation
• Customer/Supplier contract management and fulfilment
• Annual review
• Education, training and development requirements
• Work-related events attendance
• Dealing with legal disputes involving data subject, or other employees, workers and contractors, including accidents at work
• Ascertaining data subject fitness to work
• Managing sickness absence
• Complying with health and safety obligations
• Ensuring data subject wellbeing in an emergency situation
• To prevent fraud
• Gathering evidence for possible grievance or disciplinary hearings
• Making arrangements for the termination of the working relationship
• To monitor data subject use of our information and communication systems to ensure compliance with AgileOne IT security policies
• To ensure network and information security, including preventing unauthorised access to computer and electronic communications systems and preventing malicious software distribution

Change of purpose

We will only use your personal information for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If we need to use your personal information for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so.

Please note that we may process your personal information without your consent, in compliance with the above rules, where this is required or permitted by law.

How we use particularly sensitive personal information

"Special categories" of particularly sensitive personal information require higher levels of protection. We have in place an appropriate policy document and safeguards which we are required by law to maintain when processing such data.

Our obligations as an employer

We will use your particularly sensitive personal information in the following ways:

• We will use information relating to leaves of absence, which may include sickness absence or family related leaves, to comply with tax, employment and other laws.
• We will use information about your physical or mental health, or disability status, to ensure your health and safety in the workplace and to assess your fitness to work, to provide appropriate workplace adjustments, to manage sickness absence and to administer benefits.

Data sharing

We may have to share your data with third parties, including third-party service providers and other entities in the group.

We require third parties to respect the security of your data and to treat it in accordance with the law.

We may transfer your personal information outside Switzerland and the EU.

If we do, you can expect a similar degree of protection in respect of your personal information.

Why might you share my personal information with third parties?

We will share your personal information with third parties where required by law, where it is necessary to administer the working relationship with you or where we have another legitimate interest in doing so.

Which third-party service providers process my personal information?

"Third parties" includes third-party service providers (including contractors and designated agents) and other entities within our group. The following activities are carried out by third-party service providers: pension administration, benefits provision and administration, accounting and tax.

How secure is my information with third-party service providers and other entities in the AgileOne group?

All our third-party service providers and other entities in the group are required to take appropriate security measures to protect your personal information in line with our policies. We do not allow our third-party service providers to use your personal data for their own purposes. We only permit them to process your personal data for specified purposes and in accordance with our instructions.

When might you share my personal information with other entities in the AgileOne group?

We share your personal information with our parent company ACT1 Group Inc. dba AgileOne because ACT1 provides corporate support functions processing, and as part of our regular reporting activities on company performance. The support functions are: HR, Payroll, Finance & Accounting, Legal, Sales, Billing, & MIS.

What about other third parties?

We may share your personal information with other third parties, for example in the context of the possible sale or restructuring of the business or for payroll processing. We may also need to share your personal information with a regulator or to otherwise comply with the law.

Transferring information outside Switzerland and the EU

As just stated we will transfer the personal information we collect about you to ACT1 Group Inc. (AgileOne's parent company) in the USA in order to perform our contract with you and to further our legitimate business interests. There is not an adequacy decision by the European Commission in respect to the USA. This means that the USA is not deemed to provide an adequate level of protection for your personal information.

However, to ensure that your personal information does receive an adequate level of protection we have put in place the following appropriate measures to ensure that your personal information is treated by those third parties in a way that is consistent with and which respects the EU and Swiss laws on data protection:

Model Agreements/Standard Clauses with ACT1 Group Inc.

If you require further information you can contact the Data protection Officer.

Data security

We have put in place measures to protect the security of your information. Details of these measures are available.

Third parties will only process your personal information on our instructions and where they have agreed to treat the information confidentially and to keep it secure.

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

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

Data retention

How long will you use my information for?

We will only retain your personal information 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. To determine the appropriate retention period for personal data, we consider the amount, nature, and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal requirements.

In some circumstances we may anonymise your personal information so that it can no longer be associated with you, in which case we may use such information without further notice to you. Once you are no longer an employee, worker or contractor of the company we will retain and securely destroy your personal information in accordance with our applicable laws and regulations.

The AgileOne data retention policy is currently under review but will be derived from the above principles. The policy will be made available once completed.

Rights of access, correction, erasure, and restriction

Your duty to inform us of changes

It is important that the personal information we hold about you is accurate and current. Please keep us informed if your personal information changes during your working relationship with us.

Your rights in connection with personal information

Under certain circumstances, by law you have the right to:

• Request access to your personal information (commonly known as a "data subject access request"). This enables you to receive a copy of the personal information we hold about you and to check that we are lawfully processing it.
• Request correction of the personal information that we hold about you. This enables you to have any incomplete or inaccurate information we hold about you corrected.
• Request erasure of your personal information. This enables you to ask us to delete or remove personal information where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal information where you have exercised your right to object to processing (see below).
• Object to processing of your personal information if there is something which makes you want to object to processing on this ground. If you object to the processing, we will review your request and determine if we can cease processing it or if we need to continue the processing for the purposes we collected it for

If you want to review, verify, correct or request erasure of your personal information or object to the processing of your personal data, please contact HR or the Data Protection Officer in writing.

No fee usually required

You will not have to pay a fee to access your personal information (or to exercise any of the other rights). However, we may charge a reasonable fee if your request for access is clearly unfounded or excessive. Alternatively, we may refuse to comply with the request in such circumstances.

What we may need from you

We may need to request specific information from you to help us confirm your identity and ensure your right to access the information (or to exercise any of your other rights). This is another appropriate security measure to ensure that personal information is not disclosed to any person who has no right to receive it.

Right to withdraw consent

Should you have provided your consent to the collection, processing and transfer of your personal information for a specific purpose, you have the right to withdraw your consent for that specific processing at any time. To withdraw your consent, please contact your manager. Once we have received notification that you have withdrawn your consent, we will no longer process your information for the purpose or purposes you originally agreed to, unless we have another legitimate basis for doing so.

Data protection officer

We have appointed Nicholas Wills as Head of Privacy to act as data protection officer (DPO) and oversee compliance with this privacy notice. If you have any questions about this privacy notice or how we handle your personal information, please contact the Head of Privacy at privacy@agile1.com.

Changes to this privacy notice

We reserve the right to update this privacy notice at any time, and we will provide you with a new privacy notice when we make any substantial updates. We may also notify you in other ways from time to time about the processing of your personal information. If you would like a copy of this Privacy Notice in your local language please let us know.

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