This Candidate Privacy Statement (“Statement”) informs you of how Vanpot Holdings Ltd (“Vanpot Holdings”/“we”/“our”/“us”) collects and uses personal information in the context of your candidacy for employment with Vanpot Holdings and its subsidiaries/affiliates (collectively referred to as “Vanpot”).

What kinds of personal information do we collect and process?

The types of personal information we may collect and process (for the purposes described in the next section), include:

• Your name, contact information (such as home address, phone number, email address), gender, work permit or visa information, your employment and education history, referrals or references, and whether you are subject to any prior employer obligations, and any other information you provide (such as information included in your resume, cover letter, or on your Career Profile)
• Desired salary, willingness to relocate, other job preferences
• Information that you make publicly available such as contact information, your education, and work experience information (e.g. when you share information via job search and career networking sites as far as it is relevant to consider you for career opportunities)
• Interview details, and outcomes of any recruiting exercises you complete
• If disclosed, any special needs or health condition and information relating to accommodations that you may request during the recruiting process
• If required, health information to monitor the spread of infectious diseases in the workplace (where appropriate)
• If you’re being referred, we process information that the person referring you provides about you
• We also receive information such as your education and work experience, contact information, and demographics, from third-party data providers who have the rights to provide us with your information. These partners collect your information from publicly available sources, or through third parties they work with

Note: We collect some personal information because we are required to collect it under applicable law, or need it to move forward with your application. We’ll tell you if the personal information is required when we ask you to provide it. We’ll use any personal information you submit in accordance with this Statement. If you choose not to submit such personal information, we may be unable to proceed with your application or engage with you in relation to your candidacy or your interest in employment opportunities at Vanpot.

How do we use this personal information?

We use your personal information (as set out above), for the purposes described below. We process your personal information as necessary to consider you for, and assess your suitability for, employment opportunities with us.

We process personal information:

• To receive, review and reply to your application
• To verify the information you or others provide, and to check your references
• To assess your suitability for the opportunity you applied for, and in certain cases, for other opportunities at Vanpot
• To facilitate the interview/recruiting process
• To prepare an offer letter, if your application is successful
• If you were referred, to inform the referrer of the status and final outcome of your application
• Where we have identified you as a potential candidate from information that we’ve collected from public sources, in order to suggest suitable opportunities for you at Vanpot

We process your personal information to stay in touch and engage with you.

In considering you for opportunities at Vanpot we may consider you for current and future opportunities. We may contact you from time to time, for example, to invite you to events we organize or sponsor, send you alerts or recommendations about opportunities at Vanpot, or ask you for updates. You can opt-out of these communications at any time.

We process your personal information to maintain and improve our recruiting processes, for internal planning and management reporting, and to comply with laws and regulations.

In more detail, we process your personal information:

• To manage and improve the Careers portal and our recruiting processes, for example, to make the application process easier and more efficient
• To prepare and perform management reporting and to perform analysis related to recruiting metrics, such as length of the recruiting process
• To create and submit reports as required by applicable law or regulation

If you accept a conditional offer from us, we process your personal information for background verification (to the extent permitted by applicable laws).

We’ll provide further information regarding this processing upon start of the background verification process.

We process your information in order to protect the safety and security of our workforce and others.

In more detail, we process your information:

• To protect the health and safety of our workforce and others in our facilities, to the extent permitted by applicable law
• To maintain the safety, integrity and security of the company, its workforce, and others as required or permitted by law, including but not limited to conducting background and security checks. As a job applicant, you also agree that we may review and use any information collected pursuant to our Data Policy to promote safety and security

How do the Vanpot companies work together?

The Vanpot Holdings group of companies share infrastructure, systems and technology to process your personal information (as outlined in the sections above), to ensure efficiency and security, as permitted by applicable law, and in accordance with this Statement. For example, Our recruiters collaborate globally to connect candidates with the right opportunities.

How do we work with vendors and service providers?

We work with third-party partners who help us manage and improve our recruiting process, including tools and systems we use for this purpose. These third parties include:

• Recruitment service providers
• Vendors facilitating interviews and tests
• Vendors facilitating interview travel booking and expenses
• Vendors facilitating relocation (where applicable)
• Immigration advisors including lawyers and consultants
• Reporting and analytics service providers
• Pre-employment screening services
• Vendors assisting us with the implementation of health and safety measures

We require these third parties to protect the personal information they receive with appropriate security measures and prohibit them from using the information for their own purposes or outside what is necessary to provide the service.

How do we respond to legal requests or prevent harm?

We access, preserve and share your personal information with regulators, law enforcement or others:

• In response to a legal request, if we have a good-faith belief that the law requires us to do so. We can also respond to legal requests when we have a good-faith belief that the response is required by law in that jurisdiction, affects individuals in that jurisdiction, and is consistent with internationally recognized standards.
• When we have a good-faith belief it is necessary to: detect, prevent and address fraud, unauthorised use of our systems or products; violates our terms or policies or other harmful or illegal activity; to protect ourselves (including our rights, property and products), you or others, including as part of investigations or regulatory inquiries; or to prevent death or imminent bodily harm.
• When we are under a legal obligation to do so, we may provide your personal information to law enforcement.

Personal information we process about you can be accessed and preserved for an extended period when it is the subject of a legal request or obligation, governmental investigation, or otherwise to prevent harm.

We may take these actions pursuant to our legal obligations, where necessary in our legitimate interests and the legitimate interests of others and where necessary to protect the vital interest of individuals.

How do we secure your personal information?

We have put in place appropriate security measures and controls to prevent your personal information from being accidentally lost, used, accessed, altered or disclosed in an unauthorised way.

We limit access to your personal information to those employees, agents, contractors or third parties who have a business need to know, and are subject to a duty of confidentiality.

For how long do we retain your personal information?

We’ll retain personal information (as set out in the preceding section), for as long as is required in order to comply with our legal obligations, to resolve disputes and to enforce our contractual agreements, or as necessary for our legitimate interests, such as to consider you for other current and future employment opportunities at Vanpot Holdings.

If you’re successful in your application for a position at Vanpot Holdings, we retain the personal information you provide during the application process, and information about your application process, as part of your employee records.

What is our legal basis for processing personal information?

We process the personal information that we have in the ways described above:

• As necessary to prepare and enter into an employment contract with you
• Consistent with specific consents, which you may withdraw at any time
• As necessary to comply with our legal obligations
• To protect your vital interests, or those of others
• As necessary for our (or others’) legitimate interests, including our interests in considering candidates for current and future employment opportunities, and in managing and improving our recruitment and hiring processes, unless those interests are overridden by your interests or fundamental rights and freedoms which require protection of personal information

Special personal information: We may process your special information where necessary for the establishment, exercise or defence of a legal claim by us, where necessary for the purpose of carrying out our obligations, or for the exercising of our rights or your rights in the context of employment or social security law. For example, we may need to process information about your health to accommodate any special needs you have when you come onsite for an interview.

We do not need your explicit consent if we use your special personal Information in accordance with one or more of the lawful bases set out above. In limited circumstances, we may approach you for your explicit consent to allow us to process special personal information for certain processing activities. If we do so, we will provide you with full details of the information that we would like and the reason we need it, so that you can carefully consider whether you wish to consent. You should be aware that it is not a condition for your candidacy or application with us that you agree to any request for consent from us. You are free to withdraw your consent by contacting us at PRIVACY EMAIL ADDRESS. Where you do so, we may be unable to proceed with your application or engage with you in relation to employment opportunities at Vanpot Holdings.

How can you exercise your rights provided under the POPIA?

Under the Protection of Personal Information Act, 2013 and its regulations (“POPIA”), subject to applicable exemptions or restrictions, you have the following rights in relation to your personal information:

• Right to be notified of when your personal information is collected
• Right to be aware if your personal information has been accessed or acquired by an unauthorised person
• Right to request access to your personal information, and request a copy, to the extent we hold your personal information
• Right to request deletion of your personal information
• Right to request correction of your personal information; and
• Right to object to or restrict the processing of your personal information under certain circumstances

For more information on your rights and how to exercise them, contact email LEGALEMAILADDRESS.

How do we operate and transfer personal information as part of our global business?

Any personal information you provide to us or we collect due to the contractual relationship you maintain with us may be transferred to or stored in a geographic region that imposes different privacy obligations than Mauritius.

We share information globally, both internally within the Meta companies, and externally with relevant third party partners (as set out above). Personal information we collect and process will be transferred or transmitted to, or stored and processed in the Mauritius for the purposes as described in this Statement. These information transfers are necessary for our recruitment operations.

Your personal information will be transferred abroad according to the standards and requisites provided by POPIA, and third parties with which your personal information will be shared shall assure the level of protection established by POPIA.

How can you contact us with questions?

The responsible party in relation to your personal information is Meta Platforms, Inc. Please contact us at EMAILADDRESSHERE or by mail at:

VANPOT

ADDRESS

HERE

You also have the right to submit a complaint to the Information Regulator or institute civil proceedings in relation to your personal information.

How can you learn about changes to this Statement?

We reserve the right to change this Statement from time to time. If we make changes to the Statement that are material, we’ll prominently post these changes to the Statement on this page.

Date of Last Revision: June 2, 2022