Privacy notice part 2:

Privacy policy on the processing of personal data

This Privacy Policy provides you with information about how we use your personal information and, perhaps more importantly, what your rights are in this regard (for example, you have the right at any time to request that we delete or confirm what information we hold about you, withdraw consent you have given, and/or file a complaint with the supervisory authority if you are not satisfied with something we have done).

The following is included in this Privacy Policy:

1. What types of personal data are collected?

2. How is your personal data collected?

3. How is your personal data used?

4. Who will your personal information be shared with?

5. How is your personal data protected?

6. How long will your personal data be stored?

7. How can you access, change or take back personal information you have given us?

This privacy statement also includes some defined terms, which is why we have included a glossary at the end of this document.

This Privacy Statement is divided into different subsections for each different category of person who needs to take notice of it (for example, in the "What types of personal information is collected?" section, there are subsections for "Candidates" and "Visitors to our website" as well as the other individuals to whom this Privacy Statement applies). The Privacy Policy contains different information depending on the section, so pay close attention to make sure you are in the correct section.

1. WHAT TYPES OF PERSONAL DATA ARE COLLECTED?

The information described below is of course in addition to the personal data that we are legally obliged to process in the respective situations.

CANDIDATE DATA: Depending on the governing conditions, we may collect some or all of the information listed below from you in order to offer you job opportunities tailored to your situation and interests.

• Name

• Age/Date of birth

• Birth number

• Gender

• Photography

• Marital status

• Contact details

• Training details

• Professional career

• Emergency contacts and information on dependents

• Contact details for a reference

• Work permit status

• Nationality/citizenship/place of birth

• Start date or availability date

• Diversity information (any race or ethnic origin, religious affiliation or similar beliefs, and physical and mental health, including any disability-related information)

• Details of any criminal record, if relevant to a position for which you are applying

• Details about your prior and current compensation, pension and benefit arrangements

• Sexual orientation (for example, if you disclose this by providing details of relatives).

• Information about your interests and aspirations for future employment; this is collected both directly and derived, for example, from job listings or articles you read on our website or links you clicked on in emails we send out

• Additional information that you provide to us on your own initiative

• Additional information that your contacts for a reference provide to us about you on their own initiative

• Additional information that our customers provide to us about you on their own initiative or that we receive from third parties, e.g. job portals

• IP address

• Date, time and frequency of your access to our services

• Video recording when you enter our premises.

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Please note that this is not an exhaustive list of the personal information we collect.

POTENTIAL CANDIDATE DATA: If we believe our services may interest or benefit you, we may collect limited data about you to evaluate how we might help you. This data will likely include your name and contact information so that we can get in touch with you. We may also collect other information about you, for example, if we found you in our search on LinkedIn or other job posting sites. In this case, we collect information such as your career history, education, qualifications, skills, and interests, as well as additional information that you have provided in a profile or resume that you have uploaded to one of these sites.

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CUSTOMER DATA: We collect data about our customers only to a very limited extent. Generally, we only need your contact information or the contact information of individual contacts within your organization (such as their names, phone numbers, and email addresses) to contact you regarding our services as well as to ensure a smooth business relationship. We also store information about your online use of candidate profiles and other materials published by ROQA Recruitment We use this to ensure that you receive appropriate promotional communications from us at the right time. We may also store additional information that someone from your organization has shared with us on their own initiative. If we need additional personal information from you for specific reasons, we will let you know.

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PERSONS WHO'S DATA WE GET FROM CANDIDATES AND EMPLOYEES, E.g. REFERENCE CONTACT, EMERGENCY CONTACT ETC: From reference contacts, we only need confirmation of the information about the candidate or prospective employee that you already have so that they can get the job they want. Of course, to ask someone for a reference, we need the contact details of the reference contact (such as name, email address and phone number). We also need these details if our candidate or one of our employees has listed you as an emergency contact so that we can notify you in the event of an accident or emergency.

We collect your date of birth, contact information and, if applicable, certain information about your medical condition if one of our employees has designated you as a dependent or otherwise eligible for a benefit in connection with his or her employment, or if one of our employees exercises certain employment rights. We may also receive limited information (through inferences drawn) about your sexual orientation if one of our employees, by identifying you as a dependent, relative or emergency contact, identifies you as a spouse or partner.

2. HOW IS YOUR PERSONAL DATA COLLECTED?

CANDIDATE DATA - We collect personal data from our candidates in the following ways:

• Personal data that you provide to us as a candidate

• Personal data we receive from other sources

• Personal information that we collect automatically.

Personal data that you share with us

ROQA Recruitment needs certain information about you in order to provide a goal-oriented service for you. In this way, we can provide you with optimal opportunities. In addition, you will probably save time because you will not have to search through information about jobs and services that are not relevant to you.

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You can share information with us in a variety of ways, depending on what suits you best. This may include that you:

• Enter your data as part of the application process on the ROQA Recruitment website or in an application form;

• Submit a hard copy resume at a ROQA Recruitment recruiting event, job fair, or branch office;

• Email your resume or other information to or interview with a ROQA Recruitment consultant;

• Apply for jobs through a job search engine, which will then direct you to ROQA Recruitment website;

• Enter your personal information on a ROQA Recruitment microsite; or

• enter a contest via a social network such as Facebook or Twitter (or similar).

Personal data we receive from other sources

We also receive personal data about candidates from other sources. Depending on the relevant circumstances, this may include personal data received in the following situations:

• Your reference contact may disclose personal information about you;

• Our clients and candidates may share personal information about you with us;

• When you click "Like" on our Facebook/Instagram page or "Follow" us on Twitter, we receive personal information about you from these sites;

Personal information collected automatically by us

If you access our website or read or click on an e-mail from us, we will also collect your data automatically or by you providing it to us.

DATA OF POTENTIAL CANDIDATES - We receive personal data about potential candidates from third parties when we:

• Search for potential candidates through third-party sources such as LinkedIn, Xing, and other job posting sites from which we receive your personal information

• Receive your personal information from Facebook, Instagram or Twitter when you 'like' our Facebook page or 'follow' us on Twitter (or engage in a similar interaction with us on social media)

Personal data we receive from other sources

We also obtain personal information about you from other sources. Depending on the circumstances, this may include personal information obtained in the following situations:

• If you are referred to us by recruiting agencies or other employment agencies that have shared personal information about you with us

• Your colleagues may share personal information about you with us

CUSTOMER DATA - We collect personal data from customers in the following ways:

• Personal data we receive from you

• Personal information we collect or receive from other sources

• Personal information that we collect automatically.

Personal data that we receive directly from you

We receive data directly from you in two ways:

• if you contact us on your own initiative, usually by telephone or e-mail, and/or

• When we contact you by phone, email or more generally as part of the business development activities of one of our consultants.

Personal data we receive from other sources

We try to obtain information about you and your colleagues through other sources, usually using due diligence or market research, about:

• Third-party market research and analysis of online and offline media (we will conduct this ourselves or commission other companies to do so)

• Lists of participants at corresponding events

• Other limited sources and third parties (e.g., from candidates when they share your information with us to provide you with a reference or when they provide feedback to us on a specific task).

Personal information we collect through our website or links in emails

If you access our website or read or click on an e-mail from us, we will collect your data automatically or by you providing it to us.

3. HOW IS YOUR PERSONAL DATA USED?

When we have data about you, we use it in different ways.

CANDIDATE DATA - In general, we use data about our candidates in five ways:

• Recruitment efforts;

• Advertising measures

• Equal opportunity monitoring; and

• assertion, exercise or defense of legal claims.

• In appropriate circumstances, we also use data from candidates to create a personality profile.

More details about each species:

Recruitment measures

Recruitment is the main area of our work. We have listed below selected ways in which we process your personal data for this purpose. Please note that this list is not exhaustive.

• Collecting your data from you and from other sources, e.g. LinkedIn, Xing

• Storing (and updating, if necessary) your data in our database so that we can contact you in connection with the recruitment process

• Providing recruitment services and facilitating the recruitment process.

• Matching data about you with vacancies that we consider suitable

• Sending your information to customers to apply for jobs or evaluate your suitability for jobs

• Allow you to submit your resume, apply for jobs online, or receive notifications of jobs we think may interest you

• Allow you to use the interactive features of our services, if desired

• Conduct customer satisfaction surveys

• Verify information you have provided or request information (e.g., references, qualifications, or possible criminal history, as appropriate and permitted by local law)

• Complying with our legal obligations related to the detection of crime or the collection of taxes or duties

• Process your information so that we can send you targeted, relevant promotional materials or other communications that we believe will be of interest to you

• Conduct assessment and development activities (e.g., psychometric assessments or testing of skills).

We will use your personal data for the purposes described above if we consider this necessary for our legitimate interests. If you do not agree, you have the right to object under certain circumstances.

Advertising measures

We may periodically send you information that we believe will be of interest to you or ask for your help in referring other candidates. In particular, if you request, we may use your information for the purposes listed below. Please note that this list is not exhaustive. To:

• Develop and promote other products and services;

• Promote our full range of recruitment services to you;

• Send you details of reports, promotions, offers, networking and customer events and, more generally, information about industries that we think may be of interest to you;

• Display extracts of your data for promotional purposes on ROQA Recruitment website as a success story (only if we have your explicit consent to do so); and

• Inform you of certain offers to which you are entitled as a result of your business relationship with ROQA Recruitment.

For some aspects of these activities that are not covered by our legitimate interests (in particular for data collection using cookies and direct advertising of our services to you via our digital channels), we require your consent. Depending on the situation, we will ask you to provide this explicitly by "opt-in" or implicitly by "soft opt-in".

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Soft opt-in consent is a specific type of consent that applies when we have received your contact information when you previously dealt with us (e.g., by submitting an application for a job or a resume, or reporting a vacancy) and we advertise other of our services online in connection with recruitment. In the case of "soft opt-in" consent, we will consider your consent given as long as you do not object or withdraw it (and we will remind you of your right to do so in any e-marketing message we send you). For most people, this is helpful because it allows us to provide you with information we think you might be interested in, as well as suggest jobs in addition to the one you applied for. This greatly increases the likelihood that we will find a new job for you.

For other types of e-marketing, we are required to obtain your explicit consent. If you do not agree with our marketing approach, you can withdraw or revoke your consent at any time.

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All of our advertising is based on things that we think will be particularly helpful to our clients and candidates. However, we realize that we cannot always get everything right for every individual. We will use your information to display ROQA Recruitment advertisements and other content to you on other websites, such as Facebook. If you do not want us to use your data in this way, disable the "advertising cookies" option (please consult our Cookie Policy). Even if you have disabled advertising cookies, it is possible that you will be shown advertisements from ROQA Recruitment. In this case, however, this is not done specifically for you personally, but for an anonymous target group.

Equality monitoring and other sensitive personal data

We want to ensure that our recruitment processes are consistent with our approach to equality. Some of the data we collect about you falls within the scope of "diversity information". This may be information about your ethnic background, gender, disabilities, age, sexual orientation, religion or similar beliefs, and/or socio-economic background. This diversity information is considered "sensitive" or "specially categorized" personal information and is subject to stricter privacy protections.

Where appropriate, we will use this information in anonymized form to monitor whether we are complying with our Equality Policy. We will also provide this data (anonymized as appropriate) to customers (including their internal or external auditors) if contractually agreed or if the customer specifically requests this information to comply with its own recruitment process.

We may collect other sensitive/special categorization personal information about you, such as health information or religious affiliation. In these circumstances, we will use this information to comply with employment rights and obligations, such as calculating annual leave entitlement or making appropriate adjustments for candidates or part-time employees.

We may also collect details of any criminal convictions. In these circumstances, we need your explicit consent to use them. We ask for this consent by offering you an "opt-in". This means that you must explicitly and unambiguously tell us that you consent to us collecting and using this information.

Assertion, exercise or defense of legal claims

In more unusual cases, we will also use personal information about you to assert, exercise or defend legal claims.

Creation of a personality profile

Personality profiling is a type of processing that uses information we collect about you to create your "personality profile". This allows us to better assess your personality and your interests, likes and dislikes, and then provide you with the best possible service.

This is how we use the personality profile:

A. Personalization

We want to ensure that we communicate with you in the best possible way and optimize the information provided to you through our services, our website and our online presence. To do this, we use personality profiling methods where we analyze your personal data to better understand your personality and your interests, habits and preferences. (An example of this: When you click on an element on our website, we consider this as a possible sign of what you are looking for). We use personality profiling methods to place you and your candidate in groups or segments with other candidates based on your interests, habits, traits and/or preferences in order to:

• Send you personalized emails (reflecting, for example, what we have identified as your possible preferences)

• Provide recommendations for editorial content that we think may be of interest to you (e.g., reports on developments in your industry)

• Send you more tailored or accurate advertisements (the content of which may, for example, reflect how you have responded to or interacted with our previous advertisements).

B. Shortlisting and ranking

We may use personality profiling methods that analyze your personal data and/or place you and your candidate profile into groups or segments based on your interests, habits, characteristics, and/or preferences to help our consultants make decisions. For example, we may run your personal data through our systems to find out as efficiently as possible how suitable you are for a vacancy. In this way, we optimize the match of candidate profiles with positions and improve the effectiveness and efficiency of the recruitment cycle.

More specifically, we can use these personality profiling methods to:

Shortlist you and other suitable candidates for specific positions based on prescribed criteria to enable our consultants to identify the most suitable candidates for positions in a more efficient manner and to recommend positions to you based on how your interests, habits, characteristics and/or preferences rank relative to other candidates.

Recommend positions to you based on how your interests, habits, attributes, and/or preferences rank relative to other candidates.

We will use personality profiling methods in connection with your personal data if we consider it necessary for our legitimate interests. If you do not agree with this, you have the right to object under certain circumstances.

DATA OF POTENTIAL CANDIDATES: We use data about potential candidates to determine whether you are interested in or might benefit from our services and to evaluate whether and how we might be able to help you. If we believe we can help you, we will use your contact information to contact you regarding our services (usually by email).

For this we can:

• Capture your personal data

• Store (and update, if necessary) your information in our database in order to contact you regarding our services

• Review your information to determine if and how our services could help you; and

• Contact you regarding our services.

CUSTOMER DATA - We use information about our customers for the following purposes:

• Recruitment efforts;

• Advertising measures: and

• assertion, exercise or defense of legal claims.

Recruitment measures

Recruitment is the main area of our work. This is done through the placement of candidates. Below we have listed the various ways in which we can use your data for this purpose:

• Storing (and updating, if necessary) your data in our database so that we can contact you in connection with recruitment activities.

• Conduct customer satisfaction surveys.

• Process your data in order to be able to address appropriate advertising campaigns to you for our services.

If you do not agree with this, you have the right to object under certain circumstances.

Advertising measures

Where compatible, we will not necessarily ask for your consent when sending you promotional materials to a business mailing address or email address.

If you do not agree, you have the right to opt out of receiving promotional materials from us.

Assertion, exercise or defense of legal claims

In more unusual cases, we will also use personal information about you to assert, exercise or defend legal claims.

PERSONS WHOSE INFORMATION WE RECEIVE FROM CANDIDATES AND EMPLOYEES, E.G. CONTACT PERSONS FOR REFERENCES, EMERGENCY CONTACTS AND SUBSIDIARIES - We will only use the information that our candidates or employees provide to us about you for the following purposes:

• If candidates or employees have listed you as an emergency contact on our form, we will contact you if they are involved in an accident or emergency; or

• If you have been designated by an employee as a dependent or other beneficiary, we will retain your personal information to ensure that that employee's personnel information is accurate and will use your personal information where necessary to provide employee benefits and to pay compensation, and will make your information available to the appropriate benefit providers.

• If a candidate or prospective employee has indicated you as a contact for a reference, we will contact you to obtain a reference or give your information to a third party to do so on our behalf. If you are asked to provide a reference based on a candidate's professional experience and we believe you may be interested in becoming our client, we may also use your information to contact you about this alternative opportunity.

We will use your personal data for these purposes if this corresponds to our legitimate interests or applicable labor law. If you do not agree with this, you have the right to object.

4. TO WHOM WILL YOUR PERSONAL DATA BE DISCLOSED?

We may disclose your personal information in numerous ways and for numerous purposes to the following categories of people:

• All Group companies

• Suitable colleagues at ROQA Recruitment

• Individuals and organizations who, in order to work with us, have information related to the reference or application, such as current, previous or prospective employees, trainers and review boards, and employment and recruiting agencies

• Tax, audit or other authorities if we believe in good faith that we are required by law or other regulation to disclose such information (for example, because there is a request from a tax authority or in connection with anticipated litigation)

• Service providers (whether third parties or our group companies) who perform services on our behalf (including external consultants, business partners and professional advisors such as lawyers, auditors and accountants, administrative functions, technical support functions and IT consultants who perform development and testing work on our Company's technology systems)

• Providers of externally contracted IT services and storage providers, if a corresponding order processing agreement (or comparable safeguard) is in place

• Marketing technology platforms and suppliers

• In the case of candidates: potential employers and other human resource service agencies/organizations to improve your chances of finding employment

• In the case of candidates: external partners, job portals, job platforms, job search engines, software developers and cloud-based databases, if we believe this will increase the chance of finding the right job for you or improve the recruitment process in general

• In the case of candidates and contacts for references of our candidates and prospective employees: third parties we have engaged to provide services such as checking references, qualifications and criminal records, where such checks are appropriate and permitted by local law

• In the case of candidates and the contacts for references of candidates: internal and external auditors of our clients, if we need to share this data with them upon request in order to comply with our contractual or regulatory obligations

• In the case of candidates: Third parties who help us by developing services and procedures to optimize the candidate selection process and thus improve the quality and efficiency of recruitment services.

• If ROQA Recruitment were to merge with or be acquired by another company or corporation in the future (or meaningful discussions about such a possibility exist), then we may share your personal information with the (future) new owners of the company or corporation.

5. HOW IS YOUR PERSONAL DATA PROTECTED?

We will take all reasonable and appropriate measures to protect the personal information we store from misuse, loss or unauthorized access. To this end, we have taken a number of technical and organizational measures. This includes measures to deal with any suspected data breaches.

If you suspect that your personal information has been misused, lost or accessed without authorization, please let us know as soon as possible. Please contact us at datenschutz@roqa-recruitment.com.

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6. HOW LONG WILL YOUR PERSONAL DATA BE STORED?

If you are a customer, we store your personal data in order to provide services to you or receive services from you, or to provide you with information about our services that we think may be of interest to you. If you have specifically indicated that you do not want us to process your personal data, we will delete it from our systems unless we have a good faith belief that we are required by law or other regulation to retain it (for example, because of a request from a tax authority or a connection with anticipated litigation).

If you are a potential candidate or a candidate and we will delete your personal data from our, systems when we have had no relevant contact with you (or, where applicable, with the company you work for or with) for two years (or for a longer period if we believe in good faith that we are required by law or other regulation to retain your data). After this time, your data will presumably no longer be relevant for the purpose for which it was collected.

As with customers, if you are a potential candidate or prospect and have specifically indicated that you are not interested in our services, we will delete your personal information from our systems unless we have a good faith belief that we are required by law or other regulation to retain it (for example, because there is a request from a taxing authority or a connection to a prospective lawsuit).

If you are a potential candidate, we will assume that a relevant contact exists when we first contact you in connection with our services. If you are a candidate, we will assume that a relevant contact exists when you upload your updated resume to our website. In addition, if you communicate with us regarding potential positions, this will be considered relevant contact. This may be in the form of verbal or written communication or clicks within one of our promotional messages. If you receive, open or read an email or other digital message from us, this is not considered relevant contact. This is only the case if you click on something in it or respond directly.

In determining the appropriate retention period for different types of Personal Data, we consider the amount, nature and sensitivity of the Personal Data involved, the potential risk of harm from unauthorized use or disclosure of that Personal Data, the purposes for which we need to process it, and whether we can fulfill those purposes in other ways (while, of course, ensuring that we comply with our legal, regulatory and risk management obligations as described above).

7. HOW CAN YOU ACCESS, CHANGE OR WITHDRAW PERSONAL DATA THAT YOU HAVE GIVEN US?

One of the main objectives of the GDPR is to protect and clarify the data protection rights of EU citizens and individuals within the EU. This means that you still have various rights with regard to your data, even if you have already provided it to us. These rights are described in more detail below.

If you wish to contact us in connection with these rights, please contact us. We will endeavor to respond to your request as soon as possible, in any case within one month (extensions may be applied that we are entitled to by law).

Right to object: Based on this right, you may object to us processing your personal data if we do so for one of the following four reasons: (i) our legitimate interests, (ii) so that we can perform a task in the public interest or exercise official authority, (iii) so that we can send you direct marketing materials, and (iv) for scientific, historical, statistical or research purposes.

The "legitimate interests" and "direct marketing" categories above are those most likely to apply to our website visitors, candidates and clients. If you object to us processing your personal data because we consider it necessary for your legitimate interests, we must stop the relevant activities based on your objection, unless:

• we can demonstrate that we have overriding legitimate grounds for processing which override your interests, or

• we process your data to assert, exercise or defend a legal claim.

• If you object in connection with direct marketing, we must stop this activity as a result.

Right to withdraw consent: If you have given us your consent to process your personal data for certain activities (for example, to use cookies in certain jurisdictions), you may withdraw that consent at any time. We will cease the activity to which you had previously consented unless, in our opinion, there is an alternative reason that justifies our continued processing of your data for that purpose. Should this be the case, we will inform you of this.

Data Subject Request for Access to Personal Data (DSAR): You may request confirmation from us at any time about what information we hold about you and ask us to amend, update or delete that information. We may ask you to confirm your identity or ask you for more information about your request. If we grant you access to the information we hold about you, we will not charge you for it unless your request is "manifestly unfounded or excessive." If you request additional copies of this information from us, we may charge you reasonable administrative costs where permitted by law. We may deny your request if permitted by law. If we deny your request, we will provide reasons for doing so in each case.

Right to Erasure - Under certain circumstances, you may request that we erase your personal information. Typically, the information must meet one of the following criteria:

• The data is no longer needed for the purpose for which we originally collected and/or processed it;

• You have revoked your previously given consent for us to process your data and there is no other valid reason to continue the processing;

• the data have been processed unlawfully (i.e. in a manner contrary to the GDPR);

• the data must be deleted in order for us to comply with our obligations as data controller; or

• You object to the processing and we cannot demonstrate overriding legitimate grounds for us to continue processing if we process the data because we consider it necessary for our legitimate interests.

We may deny your request only for one of the following reasons:

• to exercise the right to freedom of expression and information;

• to comply with legal obligations, to perform a task in the public interest or to exercise official authority;

• When it is in the public interest to do so for public health reasons;

• for archival, research and statistical purposes; or

• to exercise or defend a legal claim.

• If we comply with a valid request to delete data, we will delete the data in question.

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Right to restrict processing: In certain circumstances, you may request that we restrict the processing of your personal data. This means that we will only store your data in the future and cannot carry out any further processing activities until: (i) one of the conditions listed below has been resolved, (ii) you give your consent, or (iii) further processing is necessary to assert, exercise or defend legal claims, to protect the rights of others, or if it is necessary due to legitimate public interest of the EU or a member state.

You may request that we restrict the processing of your personal data in the following circumstances:

• If you dispute the accuracy of the personal data we process about you. In this case, the processing of your personal data by us will be restricted until the accuracy of the data has been verified.

• If you object to us processing your personal data for our legitimate interests. In this case, you may request that the data be restricted while we review our reasons for processing your personal data.

• If the processing of your data by us is unlawful, but you prefer to restrict the processing by us instead of having the data deleted.

• When there is no longer a need for us to process your personal data, but you need the data to assert, exercise or defend legal claims.

If we have disclosed your personal data to third parties, we will inform them about the restricted processing if this is possible and does not require a disproportionate effort. We will of course inform you before we lift any restrictions on the processing of your personal data.

Right to rectification: You may also request that we rectify inaccurate or incomplete personal data that we have stored about you. If we have disclosed this personal data to third parties, we will inform them of the correction, provided this is possible and does not require disproportionate effort. Where appropriate, we will inform you of the third parties to whom we have disclosed the inaccurate or incomplete personal data. If we consider it inappropriate to comply with your request, we will explain the reasons for this decision.

Right to complain to a supervisory authority: You have the right to file a complaint with the competent local supervisory authority.

The Bavarian State Commissioner for Data Protection:
Prof. Dr. Thomas Petri

P.O. Box 22 12 19 
80502 Munich 
or:
Wagmüllerstr. 18 
80538 Munich

Phone: 089/21 26 72-0

E-mail: poststelle@datenschutz-bayern.de

Homepage: https://www.datenschutz-bayern.de

If you wish to exercise any of these rights or withdraw your consent to the processing of your personal data, please contact us via datenschutz@roqa-recruitment.com.

You can unsubscribe from notifications of open jobs or other of our promotional communications at any time.

It is important that the personal information we hold about you is accurate and up to date. Please keep us informed if your personal information includes changes during the period we store data.

GLOSSARY

• Candidates: This term describes applicants for all positions advertised or sponsored by ROQA Recruitment or individuals ROQA Recruitment reasonably considers to be interested in positions, including (un)temporary and part-time positions, as well as individuals who have submitted a speculative application to ROQA Recruitment without applying for a specific position. Individual contractors, freelancers or other third parties are also considered candidates for the purposes of this Privacy Policy.

• Customers: This category, as the term suggests, includes our customers, clients and other parties for whom ROQA Recruitment provides services in the course of its business or whom ROQA Recruitment reasonably considers to be persons who may be interested in our services.

• Deletion: In this day and age, it is nearly impossible to ensure the permanent and irretrievable deletion of electronic data. In addition, as set forth in this Privacy Policy, we are required by law or regulation, or for risk management reasons, to maintain the ability to access certain elements of Personal Data. However, we commit to you that at the end of the nominal storage period of your personal data, or when we are reasonably requested by you to delete it, we will implement specific operational and system measures to ensure that your data is rendered unusable. This means that while the data technically continues to exist in an archival system, we will ensure that neither our operating systems, processes, nor employees can easily access it. Only an extremely (i.e., extraordinarily) small number of senior staff will be able to recover your personal data in extremely (i.e., again, extraordinarily) limited and carefully prescribed situations so that it can be accessed for such lawful purposes. Once we have determined that all relevant legally required retention periods have expired (which we currently anticipate will be after a period of seven years), we will proceed to the next and final step and perform a so-called "hard", i.e., final, erasure, after which even this extremely small number of senior staff will not be able to recover your Personal Data.

• General Data Protection Regulation (GDPR): A European Union legal regulation harmonizing European data protection law. It enters into force on May 25, 2018, and all references to it should be interpreted to include related national data protection laws.

• Potential Candidates: Individuals with whom ROQA Recruitment has not previously had contact, but whom ROQA Recruitment reasonably considers to be interested in its services and, in particular, considers to be applicants for positions advertised or sponsored by ROQA Recruitment, including (un)temporary and part-time positions.

• Employees: this term describes current and former employees and interns who are directly involved in ROQA Recruitment's business (or who have accepted an offer to be involved) and certain other workers who are or have been involved in the business by providing services to ROQA Recruitment (even if not classified as employees).

• Systems: This term describes telephone, computer, Internet and wireless systems, software and portals, accounts and/or networks owned or controlled or used by ROQA Recruitment to transmit, create and/or receive communications or otherwise used in the course of ROQA Recruitment business, including candidate portal software and CRM systems.

Note: In order to simplify the reading flow, we have deliberately chosen specific terms such as "employment", "employer", "job", etc. and refrained from mentioning the equivalent for project assignments of our specialists at the same time.