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Privacy Policy

v1.0 from 3/16/2023

Dear candidate,

We, Namox International Limited (hereinafter referred to as “we”, “our”, “us” or the
“Company”) incorporated under the laws of Hong Kong with the company number
3125513, with the place of business at Office 4, 10/F., Kwan Chart Tower No 6,
Tonnochy Road, Wanchai, Hong Kong, value your privacy and are committed to
protecting your personal information. This Candidate Privacy Policy (the “Policy”) is
intended to inform you about how we collect, process, use, and disclose your personal
data in connection with your application for employment with our organisation, in
compliance with the General Data Protection Regulation (GDPR) and other applicable
data protection laws.

Personal data means any information relating to you that identifies you or could
reasonably be used to identify you, and that is recorded in any form, as referred to in
the Policy sections which follow.

We collect and process your personal data you submit to us directly via our websites
and websites of the third parties we work with, LinkedIn, recruitment agencies/search
firms for the purposes of processing your application as described further.

We may also collect and process your personal data from the following publicly
available sources, provided collection of the data is necessary and relevant to the
performance of the job which you apply for and provided we are permitted to do so
according to national laws (“direct search”): LinkedIn, Facebook, Twitter and other social
media platforms, Google, Xing, Telegram.

Background Checks

Before making a final decision to recruit you, we may collect and process information
relating to your criminal record in order to satisfy ourselves that there is nothing in your
criminal convictions history which makes you unsuitable for the role. We seek to ensure
that our information collection and processing is always proportionate. Background
checks are carried out by a background check provider.

What we need

  • Your name, contact information (address, phone number, email address, social
    profile, messenger ID, Telegram), date of birth, nationality, gender, location,
    citizenship status, residency and work permit status, and passport data.
  • Your educational and professional background, including your resume,
    certificates, cover letter, references, and other application materials you provide.
  • Your employment history, including your job title, employer name, and dates of
  • Information about your skills, experience, and qualifications relevant to the job
    you are applying for.

We use your personal information for the following purposes:

  • To evaluate your suitability for the position you have applied for and to
    communicate with you regarding your application.
  • To conduct background checks, reference checks, and other pre-employment
    screenings as necessary.
  • To comply with our legal obligations, such as employment eligibility verification,
    equal opportunity monitoring, and health and safety requirements.
  • To maintain our records and manage our recruitment processes.
  • To improve our recruitment processes and services.

Legal basis for processing

Any personal data you provide to us will be used to process your application for the
specific position you have applied for. In accordance with applicable law, your personal
data may be retained and used to process your application for other open positions
within our companies, unless you object to such processing in which case they will be

The processing of your personal data is based on Article 6(1)(b) of the GDPR. We need
your personal data in order to conduct the recruitment process, and we will not be able
to consider you for a job offer when you do not provide us with your personal data.
Any processing from other sources is based on Article 6(f) of the GDPR.

When we retain your personal data for other open positions, we do this based on Article
6(1)(f) of the GDPR and in order to give you the possibility to work with us in the future
even though we are currently unable to offer you a position.

We will delete your personal data as soon as it becomes clear that an offer of
employment will not be made to you or is not accepted by you, unless we believe that
you might be suitable for other future open positions and you have not objected to this,
or unless we need to retain your personal data for the preparation, filing or defence of
legal claims. If we retain your personal data for other open positions, filing or defence of
legal claims, we will not store your personal data for this purpose for longer than three
(3) years from the last contact with you or last open position we consider you for.

We rely on the following legal bases for processing your personal information:

  • Our legitimate interests in evaluating your job application and assessing your
    suitability for the position.
  • Compliance with our legal obligations, such as employment eligibility verification
    and equal opportunity monitoring.
  • Performance of a contract with the data subject or to take steps at the request of
    the data subject prior to entering into a contract.

Security of your personal data

We use adequate administrative, technical, personnel, and physical measures to protect
your personal data. Only selected authorised individuals shall have access to the
information about your personal data. Your personal data is also protected through
confidentiality undertakings entered into by all persons processing your personal data.

Who do we share your information with

We may share your personal information with the following categories of third parties:

  • Service providers and suppliers who process personal information on our behalf,
    such as recruitment agencies, background check providers, and HR software
  • Regulatory authorities and other governmental bodies, where required by law.
  • Potential or actual employers, where we are assisting with your job placement.
  • Professional advisors, such as lawyers and auditors, where necessary for legal
    or compliance purposes.

Transfer of your personal data to a third country or to an international organisation

Your personal information may be transferred to countries outside of the European
Economic Area (EEA) where our service providers are located. We ensure that
appropriate safeguards are in place to protect your personal data, such as using
standard contractual clauses or ensuring that the recipient is located in a country with
an adequate level of data protection.

How long we keep your personal information for

We will retain your personal data for as long as necessary to fulfil the purposes for
which it was collected as referred to above, unless a longer retention period is required
by law or necessary to establish, exercise, or defend legal claims.

If you request us to cease procession of your personal data or for the personal dataerasure, we shall retain it within the aforementioned term to establish, exercise, or
defend legal claims. We shall make sure that neither of our representatives shall reach
out to you in relation to job opportunities within the said retention period.

Your data protection rights

Under the GDPR, you have the following rights in relation to your personal information:

  • The right to access your personal information and obtain a copy of it.
  • The right to rectify inaccurate or incomplete personal information.
  • The right to erasure (‘right to be forgotten’).
  • The right to restrict the processing of your personal information.
  • The right to object to the processing of your personal information.
  • The right to data portability.
  • The right to withdraw your consent to the processing of your personal

If you wish to exercise any of these rights, please contact us using the contact details
provided below.

In case you would like to remove your personal data from our recruitment system,
please send your request to the [email protected] email.

In the event that you wish to complain about how we handled your personal data,
please contact our DPO by the following email address: [email protected].

If after complaining to the DPO you still feel that your Personal Data has not been
handled appropriately, according to the law, you can lodge a complaint with the Cyprus
Data Protection Authority regarding the Processing of your Personal Data by us or on
our behalf:

Office of the Commissioner for Personal Data Protection
1 Iasonos str., 1082 Nicosia
P.O.Box 23378, 1682 Nicosia
Tel: +357 22818456
Email: [email protected]

Changes to the Policy

We may modify or amend this Policy from time to time.
We will notify you appropriately when we make changes to this Policy and we will
amend the revision date at the top of this page.