Privacy Policy

NOVABASE GROUP

PRIVACY POLICY

In compliance with Portuguese Securities Market Commission (CMVM) Recommendations on the corporate governance of listed companies, and to foster a culture of responsibility and diligence, Novabase has adopted a system for communicating irregular practices (“SPI”) occurring within the Novabase Group.

PRIVACY POLICY NOVABASE GROUP

WHAT IS THIS PRIVACY POLICY FOR? The policy describes the types of personal information that we gather, how we use this information, with whom we share it and the rights and choices available to personal data subjects with regard to our use thereof. A description is also provided of the measures taken to protect information security and how you can get in touch with us about our privacy policies and the exercising of your rights.

WHAT DOES THIS PRIVACY POLICY COVER? We can gather the following types of personal information (when permitted by law): Job history and academic qualifications; Linguistic proficiency and other work-related skills; Social Security Number, civil identification number or other identification number issued by the government; Date of birth; Gender; banking information; Citizenship and work authorisation status; verification of criminal record and others; Information about benefits; fiscal information; phone contact; Information provided by references; information contained in your Curriculum Vitae (CV), information provided about your career interests and other information about your job qualifications. In addition, we can gather any information that you may wish to provide us with about other individuals, as well as information related with emergency contacts.

COLLECTION PURPOSES 1. We use the information described in this policy for activities related with the administration and management of the employment contract and the employment relationship between the Parties, namely, for the following purposes:

a) The calculation and payment of remunerations, additional payments, other allowances and bonuses;

b) The calculation, withholding at source and operations pertaining to discounts from remuneration, be they mandatory or optional, deriving from legal provisions;

c) The carrying out of non-nominal statistical operations related with wage processing in the context of the processing entity;

d) Compliance with the obligations to which NOVABASE is subject, namely in terms of employment, social security and fiscal legislation.

e) Other purposes related with staff management.

WHO IS THE DATA CONTROLLER? The personal data controller is Novabase Neotalent SA.

DATA COMMUNICATION TO OTHER ENTITIES (THIRD PARTIES AND SUBCONTRACTORS) AND DATA TRANSFER

NOVABASE, in the context of activities related with the administration and management of the employment contract and the employment relationship between the Parties, may communicate and/or transfer the personal data of the Employee to those entities identified below, not excluding any other entities not mentioned, but which are legally entitled to duly process the data in question:

  1. IGFSS – Financial Management and Social Security Institute;
  2. AT – Tax Authority;
  3. Banking and Insurance Institutions;
  4. INE - National Institute of Statistics;
  5. ACT - Working Conditions Authority;
  6. The entity responsible for the performance of duties pertaining to Safety, Hygiene and Medicine at work;
  7. Any other entity to which wage processing and/or other duties related with human resources’ management have been assigned.

We can share your personal information with clients and/or between Novabase Group companies. Novabase shall carry out all its data processing within the European Economic Area (EEA) and so it does not plan on carrying out any international data transfer.

WHAT IS THE PERSONAL DATA STORAGE PERIOD? NOVABASE will store personal data solely for as long as is necessary to achieve the purposes for which they are intended and to comply with its legal obligations. When defining this period, it shall bear in mind both the best practices and the legal obligations to which NOVABASE is subject, namely, in terms of employment, social security and fiscal legislation.

HOW DO WE USE “COOKIES”? "Cookies" are small software labels that are stored on your computer through the browser, retaining only information related to your preferences, not including, as such, your personal information. Similarly to the vast majority of web pages available, Novabase also uses cookie technology on its web pages. Cookies gather statistical data from users and Novabase uses this information solely and exclusively to increase the speed and usability of its web pages. The cookies used by Novabase do not gather any personal information from its users. They were not developed to follow you or track your behaviour online. Should you so wish, you may change the way in which your browser uses cookies, namely by blocking or eliminating cookies from web pages, thereby not allowing the storage of any information on your browser. Cookie management can be carried out on your browser settings.

RIGHTS OF DATA SUBJECTS The data subject may, at any time and free-of-charge, exercise its rights of access, rectification or elimination of data, opposition, restriction and portability of its data, subject to the limits foreseen by law, via the e-mail data.privacy@neotalent.pt or by sending a recorded delivery to the postal address Av. D. João II, n.º 34, 1998-031 Lisboa. When the lawfulness of processing derives solely from the consent of the data subject, acceptance by the user that its data may be processed or assigned shall always be of a revocable nature, without any retroactive effects. To revoke said consent, users may contact Novabase at the e-mail data.privacy@neotalent.pt.

PERSONAL DATA SECURITY Bearing in mind the great concern and commitment that Novabase demonstrates for defending privacy matters, various technical and organisational security measures were taken to protect the personal data provided to us from their dissemination, loss, improper use, alteration, processing or unauthorised access as well as from any other form of unlawful processing. The employees of Novabase, as well as those who render services to it, take on the commitment not to disclose to third parties or use for purposes contrary to the law, any personal information of the Clients which they have learned during the course of their duties. Novabase undertakes to respect the legislation on the protection of Client data privacy and to only process these data for those purposes for which they were gathered, as well as to ensure that these data are processed with suitable levels of security and confidentiality, under the terms of the applicable legislation and the conditions stipulated by the CNPD.

ALTERATIONS TO THE PRIVACY POLICY Novabase reserves the right to, at any time, make adjustments or alterations to the present Privacy Policy.

HOW TO GET IN TOUCH WITH US If you have any questions or comments about the general privacy policy, if you wish to exercise your rights or if you would like to update the information and preferences that we have about you, please write to the following postal address: Neotalent A/C Data Privacy Av. D. João II, n.º 34 1998-031 Lisboa

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