Privacy Policy for Job Candidates at the Company

1. DIPLOMAT DISTRIBUTORS (D.D) CYPRUS LIMITED registered under the laws of the Republic of Cyprus with registration number 286543 (hereinafter: the “Company“) respects and protects the privacy of individuals who have submitted their candidacy for employment with the Company (hereinafter: “the Candidates“). The Privacy Policy, as detailed below, will clarify the sources through which the Company collects information about the Candidates, the purposes for which the Company collects the information, the types of information collected, the uses that the Company may make of the information, the ways in which the Company handles and stores the information it collects, as specified in this Privacy Policy.

2. The Job Candidate acknowledges that the details provided thereby as part of the recruitment process will be collected by the Company and stored in the Company’s systems and will be available to the Company and/or entities on its behalf, including companies in the Diplomat Group, for the purposes set forth in this Privacy Policy below.

3. This Privacy Policy is written in the masculine gender for convenience only, and should be read as referring to the feminine gender as well.

4. The Company will collect information about the Candidates from various sources, including information that the Candidate has provided and will provide to the Company and information that the Company has received and will receive from third parties during the Candidate’s recruitment and classification process.

We collect and process your personal data in accordance with the GDPR and applicable data protection laws. The lawful bases we rely on for processing your data during the recruitment process include:

5.1 Contractual Necessity – Processing your data is necessary to take steps at your request prior to entering into an employment contract (e.g., reviewing your application, arranging interviews).

5.2 Legal Obligation – We may be required to process certain data to comply with our legal and regulatory obligations (e.g., verifying your right to work, equal opportunity monitoring).

5.3 Legitimate Interests – We have a legitimate interest in processing your data to assess your suitability for the role, maintain recruitment records, and improve our hiring process. We ensure that our interests do not override your rights and freedoms.

5.4 Consent (if applicable) – In limited circumstances, we may request your consent (e.g., for retaining your CV for future roles or conducting certain background checks). Where consent is required, you have the right to withdraw it at any time.

During the recruitment process, the Company Candidate’s recruitment collects, stores, uses and process the following categories of personal data provided by the Candidate::

6.1 Identification and contact details: resume, full name, ID number, date of birth, telephone and mobile phone.

6.2 Information regarding education, employment experience, qualifications and professional experience including professional certificates and licenses, which are required for the recruitment process and the examination of your application to be hired as an employee of the Company.

6.3 Information regarding your professional performance including disciplinary offenses, professional assessments including documentation of conversations with recommenders and more.

6.4 As part of the recruitment process, you may voluntarily provide additional data, including sensitive data (for example, information about ethnic origin, political opinions, religious beliefs, physical or mental health, etc.). If you elect to provide such information, you do so voluntarily and with your consent to its use as described in this policy.

6.5 Interview summaries and internal evaluations of the interviewing parties, findings of assessment tests, English exams, security investigations and any other evaluation that will be performed regarding the candidate as part of the internal or external recruitment process.

7.1 The Company will retain the information about the job candidate for the purpose of managing the recruitment process and managing legal proceedings and defending against claims, demands and allegations in connection with the Company’s activities or in connection with engagements with third parties and compliance with the provisions of the law.

7.2 The Company may retain information about the Candidate for consideration for additional positions, where it has a legitimate interest in doing so and where such interest is not overridden by the Candidate’s rights and freedoms

The Company requires information about the Candidates for all or part of the following purposes:

8.1 For the purpose of examining the Candidate’s suitability for the company, for the proposed position and/or for the vacant positions;

8.2 To contact the candidate, including through direct mailing and to update him regarding changes in the recruitment process;

8.3 For the purpose of classification and placement of the Candidate;

8.4 To manage your candidacy profile, coordinate interviews,  assess your professional profile, and assess your suitability for the positions using automated tools, personal interviews or diagnostic and assessment tests;

8.5 To offer the candidate other positions;

8.6 For the purpose of statistics, research, analysis and conducting satisfaction surveys in relation to the recruitment process;

8.7 To preserve and protect the Company’s information, property and assets, including protection against the leakage of trade secrets, protection of the Company’s intellectual property and copyrights, protection of the Company’s information, protection of the interests of the Company and its employees, including economic, security and other interests;

8.8 For the purposes of defending against claims, demands and allegations in connection with the Company’s activities or in connection with agreements with third parties.

9.1 The information that is held in the Company’s databases may be disclosed to third parties for the purposes of the recruitment process (for example: an assessment institute) in accordance with the terms of the Privacy Policy.

9.2 The transfer of information to third parties will include only relevant information that does not exceed the purposes as detailed above and will be carried out in a manner proportionate to a defined, explicit and legitimate purpose.

9.3 The Company may transfer information about Candidates to the following third parties:

Third parties that provide various services to the Company, including, among others, recruitment and placement services, assessment institutes, lawyers or other external professional consultants, providers of security and support services for information technology (IT) systems, providers of support and storage services and other third parties that provide services to the Company in connection with the recruitment process.

In accordance with the provisions of the law applicable to the Company, including tax authorities and other government authorities and bodies.

The Company may also transfer information to subsidiaries, business partners or potential business partners, among others, in the framework of a reorganization, transfer and/or sale and/or assignment and/or acquisition, of the Company and/or its assets and/or any part thereof, for consideration or not, to third parties, including but not limited to, in the event of a merger of the Company and/or its operations with third parties, in cases of a change of control, whether full or partial, in the Company, and for the purpose of examining the feasibility of the events mentioned above.

In cases where the candidate’s data is transferred to a country outside the EU/EEA, the Company will ensure that appropriate safeguards are in place to protect the data in compliance with the GDPR and relevant applicable data protection laws.

The Company takes technical and physical measures regarding privacy and information security in accordance with accepted standards. As known, the storage and transmission of information by electronic means, including through the internet, can never be completely secure and whenever the candidate provides information to the Company, in particular through the internet, the candidate does so with full consent and subject to the risks involved in transmission of information in this manner.

Any candidate has the following rights regarding the processing of their personal data subject to restrictions according to the provisions of any law and the Company’s procedures:

• Request access to your personal data. This enables you to receive a copy of the personal data we hold about you as well as information about how your personal data will be processed and the legal basis for the processing.

• Request correction of the personal data that we hold about you.

• Request deletion of your personal data. You can ask us to delete or remove personal data. We may not be able to fulfil your request if we have other legal reasons that require us to hold your data.

• Right to object to processing of your personal data where we are relying on a legitimate

• Request restriction of processing of your personal data. This enables you to ask us to suspend the processing of your personal data for the following reasons:

(a) If you want us to establish the data’s accuracy.

(b) Where our use of the data is unlawful but you do not want us to erase it.

(c) Where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims.

(d) You have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.

• Request the transfer of your personal data to you or to a third party.

• Withdraw consent at any time where we are relying on consent to process your personal data. If you withdraw your consent, we may not be able to provide certain products or services to you.

If you want to exercise any of these rights, please contact ddcprivacy@diplomat-global.com.

12. Right to Complaint

If you have any concerns or complaints regarding the processing of your personal data, or our compliance with the GDPR and other applicable legislation you have the right to complaint to the Office of the Commissioner for Personal Data Protection at:

Office address:

Kypranoros 15, Nicosia 1061 , Cyprus

Postal address

P.O.Box 23378, 1682 Nicosia, Cyprus

Tel: +357 22818456

Fax: +357 22304565

Email: commissioner@dataprotection.gov.cy

13. We would appreciate the opportunity to address your concerns first, so please contact us in the first instance, and we will do our best to resolve any issues.

14. This Privacy Policy shall be governed by Israeli law, excluding its defaults. Jurisdiction in connection with any dispute and/or claim that may arise in connection with or related to this Privacy Policy is vested exclusively with the courts in Tel Aviv-Yafo.

15. The Company reviews the Privacy Policy regularly and reserves the right to make changes at any time at its sole discretion, inter alia, in order to take into account changes in the management of its activities, legal requirements, the needs of the Company, etc., without providing notice or warning. The Company will update candidates regarding material changes to this Privacy Policy on the Company’s website. The candidate’s continuation in the recruitment process will constitute his consent to the updated Privacy Policy, including any changes or amendments that may be made

Last updated: February 2025