WIZELINE’S PRIVACY NOTICE

Effective Date: August 3rd, 2023

Wizeline, Inc. together with its subsidiaries (“Wizeline”, “we”, “us”, “our”) values individual privacy and is strongly committed to protecting the confidentiality and security of your personal data.

We have created this Privacy Notice (this “Notice”) to inform you which personal data we collect from you when you interact with us in connection with the Covered Activities (as defined below) and how we use such personal information, where we store it and which are your rights with respect to it. We encourage you to read this Notice carefully and contact us if you have any questions.

Index

What is covered by this Notice
Which Personal Data we collect
Who is the Controller
For What purpose we use your Personal Data
The legal basis for data processing
How long do we keep your Personal Data
Disclosure of your Personal Data
How we protect your Personal Data
Your rights
Notice for residents in California
Appendix A: Talent Page and Recruiting Activities
Appendix B: Academy Page and Academy Services

What Is Covered by this Notice?

This Notice covers personal data about you that we collect (your “Personal Data”) in the context of the following activities (collectively, the “Covered Activities”):

Your use of our Website (our “Website”) and any services of our Website, including but not limited to developing and tracking sales leads.
Your registration in Wizeline’s talent page on our Website (our “Talent Page”) and your participation in a recruitment or hiring process in connection with a job opening in Wizeline (our “Recruiting Activities”). Please refer to Appendix A (“Appendix A”) for more information about the processing of Personal Data for recruiting processes.
Your registration in Wizeline Academy’s mailing list on our Website (our “Academy Page”) and your participation in or registration for any Wizeline Academy event or service through the Website or any other means available (our “Academy Services”). Please refer to Appendix B (“Appendix B”) for more information about the processing of Personal Data for Wizeline Academy’s services.

This Notice does not apply to Personal Data we collect by other means, such as Personal Data collected from or concerning our own employees, our customers in the context of performing any services under a professional services agreement, our vendors, interns, consultants and contractors.

1. Which Personal Data we collect.

Wizeline may request and you may choose to provide Personal Data for business and marketing purposes, including to enhance our offerings and your customer or user experience. The Personal Data we collect in the context of this Notice is information or pieces of information that could allow you to be identified, such as for example:

biographical information, such as first and last name;
contact information, such as address, phone number, location, e-mail address, username, password;
location Information (i.e., Information derived from device information associated with your IP address, country code, or address) for limited services and/or region-specific offerings;
device and other technical information, such as information about your hardware, operating system, browser type, browser settings, your mobile carrier or Internet Service Provider, and unique identifiers associated with your device, including IP address;
any other type of Personal Data you choose to submit to us in the context of the Covered Activities as further described in the Appendix A and Appendix B.

When navigating our Websites, Wizeline will collect and store Cookies. If you would like more information, please review Section 8 below.

We do not automatically collect Personal Data when you visit our Website, including our Talent Page, nor will we make any attempt to identify anyone visiting our Website. If we do want to collect personally identifiable information through our Website we will make it clear upfront and we will explain the purposes of collecting such information.

2. Who is the Controller.

Unless otherwise stated in this Notice, Wizeline is the data controller of the Personal Data which we collect and/or process about you in the context of the Covered Activities.

3. For what purpose we use your Personal Data.

We may process your Personal Data collected according to Section 1 above, for the purposes of:

enabling the use of our Website;
improving our Website and the services offered under our Covered Activities;
responding to your requests or questions;
administering contests, promotions, or surveys related to our services;
processing your transactions;
developing and tracking sales leads;
communicating with you and answering your questions, or sending you information about new events;
complying with applicable laws and to maintain appropriate records for internal administrative purposes, and to comply with applicable legal and regulatory obligations and respond to lawful government requests, as needed;
fulfilling any other business or commercial purposes at your direction or with your consent.
additional purposes as further described in the Appendix A and Appendix B.
ensuring the safety of our offices when we host visitors.

To achieve the above purposes, we need to perform different types of processing activities on your Personal Data, such as storage, access, transmission, consultation, adaptation or alteration, and combination.

We may process your Personal Data for our online marketing campaigns, including promotions sent by email, invitations to events and conferences, and other sales and marketing communications sent by Wizeline (the “Marketing Activities”), including the processing of your Personal Data in our customer relationship management software for purposes of the Marketing Activities.

4. The legal basis for data processing.

Within the scope of this Notice, we may process your Personal Data pursuant to the following legal basis:

Category of personal data	Legal basis for the processing
Identification data	You have provided your consent or the processing is necessary for: the performance of a contract and to take steps prior to entering into a contract; our legitimate interests, namely identifying and preventing illegal conduct such as fraud.
Contact data	You have provided your consent or the processing is necessary for: the performance of a contract and to take steps prior to entering into a contract; our legitimate interests, namely identifying and preventing illegal conduct such as fraud.
Electronic records	The processing is necessary for: the performance of a contract and to take steps prior to entering into a contract; our legitimate interests, namely providing internal computer systems and ensuring the security of such systems among others; compliance with a legal obligation to which we are subject.
Data about third parties	You have provided your consent or the processing is necessary for: the performance of a contract and to take steps prior to entering into a contract; compliance with a legal obligation to which we are subject.

When we rely on legitimate interests as a lawful basis of processing, you have the right to ask us more about how we decided to choose this legal basis. To do so, please use the Contact Us details below.

Where we process your Personal Data based on your consent, you may withdraw it at any time. However, this will not affect the lawfulness of our processing before you withdrew your consent. It will also not affect the validity of our processing of Personal Data performed on other lawful grounds.

5. How long do we keep your Personal Data.

We process Personal Data only for so long as is necessary for the purposes for which it was originally collected, after which it will be deleted or archived except to the extent that it is necessary for us to continue to process it for the purpose of compliance with legal obligations to which we are subject or for another legitimate and lawful purpose.

When the purposes of processing are satisfied, we will delete the related Personal Data within six months, or upon receipt of a verified request.

We may maintain your contact information (name, e-mail, and phone number) for the purposes of reviewing future service opportunities with you, maintaining historical records of commercial activities, or exercising your privacy rights as requested.

In the context of our Recruiting Activities, we may maintain your contact information for the purpose of sending you relevant information about our job openings or future events.

The data retention periods may be extended, if necessary, in the event of any claims and court proceedings – for the duration of these proceedings and their settlement.

6. Disclosures of your Personal Data.

We may share Personal Data with our subsidiaries and affiliates, as well as with our service providers, who assist us in operating our Website, conducting our business, providing our services, or as required by law. However, we enter strict data processing agreements with these third parties to ensure that they keep your Personal Data confidential, only use it for the services they provide to Wizeline, and treat your Personal Data with the same level of protection that we do. The categories of third parties to which we may disclose your Personal Data include those providing:

application hosting services;
project management and content collaboration services;
team communication services;
software development services;
e-mail software;
customer relationship management (CRM) software;
recruiting software and application tracking system;
web analytics services;
marketing partners;
payment services providers.

Some of these third parties may be located outside of your country of residence. The authorities of the country where you reside may have determined that in some countries, their data protection laws provide a level of protection equivalent to your jurisdiction. As an example, you can see here the list of countries that the European Commission has recognized as providing an adequate level of protection to Personal Data. We will only transfer your Personal Data to third parties in countries not recognized as providing an adequate level of protection to Personal Data when there are appropriate safeguards in place. These may include the EU standard contractual clauses (an agreement approved by the European Commission which gives Personal Data the same protection it has in the EU for data processing in non-EU countries), international data transfer agreements that meet the requirements of the applicable personal data protection laws, binding corporate rules, an approved code of conduct or your consent.

Sales of Personal Data: Wizeline generally does not directly sell your Personal Data. Like many companies, however, we use services that help deliver interest-based ads to you or analyze our website traffic, and may transfer Personal Data to business partners for their use. Making Personal Data (such as online identifiers or browsing activity) available to these companies may be considered a “sale” under the California Consumer Privacy Act (“CCPA”). If you would like to opt out of the sales of your Personal Data that take place via cookies, you can learn how under the Cookies section below.

Other Disclosure of Your Personal Data: We may disclose your Personal Data (i) to the extent required by law or if we have a good-faith belief that such disclosure is necessary in order to comply with official investigations or legal proceedings initiated by governmental and/or law enforcement officials, or private parties, including but not limited to: in response to subpoenas, search warrants, or court orders; or (ii) if we sell or transfer all or a portion of our company’s business interests, assets, or both, or in connection with a corporate merger, consolidation, restructuring, or other company change; or (iii) to our subsidiaries or affiliates only if necessary for business and operational purposes as described in the section above.

If we must disclose your Personal Data in order to comply with official investigations or legal proceedings initiated by governmental and/or law enforcement officials, we may not be able to ensure that such recipients of your Personal Data will maintain the privacy and security of your Personal Data.

We reserve the right to use, transfer, sell, and share aggregated, anonymous data, which does not include any Personal Data, about individuals whose Personal Data we process in connection with providing our services, as a group, for any legal business purpose, such as analyzing usage trends and seeking compatible advertisers, sponsors, and customers.

This Privacy Notice does not address, and we are not responsible for, the privacy, information or other practices of any third parties, including any third party operating any site to which the Wizeline Covered Activities contain a link. The inclusion of a link on any of the Covered Activities does not imply endorsement of the linked site by us or by our affiliates.

Please note that any information that you provide through any third party site is governed by the applicable third party’s privacy policy, and not by this Privacy Notice. We have no control over, and shall not be responsible for, any use of information that you provide through any third party site.

7. How we protect your Personal Data.

The security and confidentiality of your Personal Data is extremely important to us. Wizeline has implemented and will maintain technical, administrative, and physical measures that are reasonably designed to help protect Personal Data from unauthorized processing such as unauthorized access, disclosure, alteration, storage or destruction.

All of the information collected by Wizeline through the Website is stored on secured servers, to protect against unauthorized use and access.

8. Cookies.

A “cookie” is a small file stored on your device that contains information about your device. We use cookies for authentication (session management) purposes, which are deleted when you close your browser. Those cookies are first-party cookies, since they are placed directly by us.

We also use third-party cookies which are placed by our third-party service providers to track your browsing activity when you use our Website and for our Sales and Marketing Systems.

For more information about the cookies practices, please visit our Cookie Policy at https://www.wizeline.com/cookie-notice/.

You may also set your browser to send a Do Not Track (DNT) signal. For more information, please visit https://allaboutdnt.com/. Please note that our Services do not have the capability to respond to “Do Not Track” signals received from various web browsers.

9. Your Rights.

You have specific rights regarding your Personal Data collected and processed by us. In this section, we first describe those rights and then we explain how you can exercise those rights.

Right to know what happens to your Personal Data

This is called the right to be informed. It means that you have the right to obtain from us all information regarding our data processing activities that concern you, such as (i) the categories of Personal Data we have collected about you; (ii) the categories of sources from which the Personal Data is collected; (iii) the business or commercial purpose for collecting, selling, or sharing such Personal Data; (iv) the categories of third parties with whom we have disclosed Personal Data; and (v) the specific pieces of Personal Data we have collected about you. We are informing you of how we process your Personal Data with this Notice.

Right to know what Personal Data Wizeline has about You

This is called the right of access. This right allows you to ask for full details of the Personal Data we hold about you.

You have the right to obtain from us confirmation as to whether or not we process Personal Data concerning you, and, where that is the case, a copy or access to the Personal Data and certain related information. Once we receive and confirm that the request comes from you or your authorized agent, we will disclose to you:

● The categories of Personal Data we collected about you;

● The categories of sources for the Personal Data we collected about you;

● Our purposes for processing that Personal Data;

● Where possible, the envisaged period for which the Personal Data will be stored, or, if not possible, the criteria used to determine that period;

● The categories of third parties with whom we share that Personal Data;

● The specific pieces of Personal Data we collected about you;

● If we disclosed your Personal Data for a business purpose, two separate lists laying out the:

○ categories of Personal Data shared, and the categories of recipients who received the Personal Data; and

○ categories of Personal Data disclosed for a business purpose, identifying the categories of recipients who obtained the Personal Data;

● If we rely on legitimate interests as a lawful basis to process your Personal Data, the legitimate interests pursued by us or by a third party; and

● The appropriate safeguards for transferring data to a third country that does not have adequate legislation on data protection, if applicable.

Please take into account that the applicable personal data protection regulations, including the European Union General Data Protection Regulation (“GDPR”) allows us not to satisfy your access request when:

● you already have the information;

● providing such information proves impossible or would involve a disproportionate effort, or in so far providing such information is likely to render impossible or seriously impair the achievement of the objectives of that processing; and

● that Personal Data must remain confidential subject to an obligation of professional secrecy regulated by Union or Member State law or the applicable regulation in the relevant country including a statutory obligation of secrecy.

The CCPA prohibits us from disclosing account passwords or security questions and answers. We can inform you that we have this information generally, but we may not provide the specific items to you for security and legal reasons.

Right to correct your Personal Data

This is called the right to rectification. It gives you the right to ask us to correct anything that you think is wrong with the Personal Data we have on file about you and to complete any incomplete Personal Data.

Right to delete your Personal Data

This is called the right to erasure, right to deletion or the “right to be forgotten”. This right means you can ask for your Personal Data to be deleted.

If there is any Personal Data you would like deleted, you can ask us to do so using the contact information listed in this Notice. Sometimes we can delete your information, but other times it may not be possible, such as when the law tells us we cannot do so. If that is the case, we will consider if we can limit how we use it. There may also be circumstances where we deny your request to delete your information under applicable law, such as if we or our service providers need to retain the Personal Data to:

● Complete the transaction for which we collected the Personal Data;

● Provide a good or service that you requested, take actions reasonably anticipated within the context of our ongoing business relationship with you, or otherwise perform our contract with you;

● Detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity, or prosecute those responsible for such activities;

● Debug products to identify and repair errors that impair existing intended functionality;

● Enable solely internal uses reasonably aligned with your expectations based on your relationship with us;

● Comply with a legal obligation, including (but not limited to) obligations from the California Electronic Communications Privacy Act; or

● Make other internal and lawful uses of that information that are compatible with the context in which you provided it.

Right to ask us to change how we process your Personal Data

This is called the right to restrict processing. It is the right to ask us to only use or store your Personal Data for certain purposes.

You have this right in certain occasions, such as where you believe the data is inaccurate or the processing activity is unlawful. This right enables you to ask us to suspend the usage of Personal Data about you, for example if you want us to establish its accuracy or the reason for processing it.

Right to ask us to stop using your Personal Data

This is called the right to object. This is your right to tell us to stop using your Personal Data. You have this right where we rely on a legitimate interest of ours (or of a third party). Also, you have the right to object at any time to the processing of your Personal Data for Marketing Activities.

We will stop processing the relevant Personal Data unless: (i) we have compelling legitimate grounds for the processing that override your interests, rights, or freedoms; or (ii) we need to continue processing your Personal Data to establish, exercise, or defend a legal claim.

Right not to be subject to Automated Decision Making

You have the right not to be subject to decisions with a significant impact on you in any automated decision-making process. You will not be subject to decisions that will have a significant impact on you based solely on automated decision-making. There will always be human intervention into decisions based on automated processing, including automated analytics, testing, and profiling. If this position changes, or there is a need and lawful basis to do so, we will inform you.

Right to port or move your Personal Data

This is called the right to data portability. It is the right to ask for and download Personal Data about you that you have given us, so that you can:

● move it;

● copy it;

● keep it for yourself; or

● transfer it to another organization.

We will provide your Personal Data in a structured, commonly used, and machine-readable format. When you make a data portability request electronically, we will provide you a copy in electronic format.

Right to withdraw your consent

Where we rely on your consent as the legal basis for processing your Personal Data, you may withdraw your consent at any time. If you withdraw your consent, our use of your Personal Data before you withdraw is still lawful.

If you have given consent for your Personal Data to be shared with a third party, and wish to withdraw this consent, please also contact the relevant third party in order to change your preferences.

Right not to be discriminated against for exercising your privacy rights

We will not discriminate against you for exercising any of your privacy rights, meaning we will not:

● deny you goods or services;

● charge you different prices or rates for goods or services, including through granting discounts or other benefits, or imposing penalties; or

● provide you a different level or quality of goods or services.

Right to opt out of the sale of your Personal Data

You have the “right to opt out”, which means you have the right to ask us to not sell your Personal Data at any time.

As our use of some of the cookies that we use for statistical purposes and Marketing Activities is the only sale of your Personal Data that Wizeline may be engaging in, the only way to opt out of sales of Personal Data is to change your cookie preferences through our cookie consent management platform. In particular, you need to choose not to allow the following categories of cookies:

● Statistics

● Marketing

Please consider that the preferences you submit through the cookie consent management platform, including your requests to opt out from the sale of Personal Data, may be stored in cookies or similar technologies that are specific to your browser. If this browser is configured to block cookies or similar technologies, our tool may not be able to store your preferences. In addition, deleting cookies on this browser may result in your preferences being removed. If your preferences are removed after you delete cookies from this browser, you will have to update these preferences again. Also, remember that private browsing technologies (such as incognito mode) automatically delete all local storage and cookies when the browsing session ends, preventing us from recording your choice made during the session; and preventing us from accessing any local storage created outside of the current session, which does not enable us to access the choice you made during a normal or previous private browsing session.

We will only store your preferences in this browser. Because some companies may not connect information about this browser with other web browsers or devices you may use (such as a web browser on another computer you may use, or one on a mobile device), you need to update your preferences through the cookie consent management platform to set your preferences separately for other browsers or devices you may use.

Your right to opt into the sale of your Personal Data

As our use of some of the cookies that we use for statistical purposes and Marketing Activities purposes is the only sale of your Personal Data that Wizeline may be engaging in, the only way to opt into sales of Personal Data is to change your cookie preferences through our cookie consent management platform. In particular, you need to choose to allow the following categories of cookies:

● Statistics

● Marketing

Right to lodge a complaint with a Supervisory Authority

If the GDPR applies to the processing of your Personal Data with us, the GDPR grants you the right to lodge a complaint with a supervisory authority if you are not satisfied with how we process your Personal Data. In particular, you can lodge a complaint in the Member State of the European Union of your habitual residence, place of work, or of the alleged violation of the GDPR. If you are based in a non-European Union country, you may also be entitled to lodge a complaint with the relevant data protection authorities pursuant to the applicable data protection regulations.

How Can You Exercise Your Privacy Rights? To exercise any of the rights described above, please submit a request by contacting us by email at privacy@wizeline.com.

Verification of Your Identity Bear in mind that to evaluate your privacy rights requests, we need to be sure it was you who made the request. Consequently, we may need some information to confirm that you are who you say you are.

For requests submitted via password-protected accounts, your identity is already verified. For requests sent by other means, you will need to provide us with sufficient information that allows us to reasonably verify you are the person about whom we process Personal Data. Generally, we will request only information that we may have about you to confirm your identity, but under some circumstances we may require additional information or documentation to complete your request. We cannot respond to your request or provide you with Personal Data if we cannot verify your identity or authority to make the request. Making a request does not require you to create an account with us.

We will only use the Personal Data you provide us in a request to verify your identity or authority to make the request.

Please note that you may only make a consumer request to know or data portability twice within a 12-month period under the CCPA.

Verification of Authority If you are submitting a request on behalf of somebody else, we will need to verify your authority to act on behalf of that individual. When contacting us, please provide us with proof that the individual gave you signed permission to submit this request, a valid power of attorney on behalf of the individual.

Alternatively, you may ask the individual to directly contact us by using the Contact Us information below to verify their identity with us and confirm with us that they gave you permission to submit this request. We will only use the Personal Data you provide us in a request to verify your authority.

Response Timing and Format of Our Responses We will confirm the receipt of your request within ten (10) days and, in that communication, we will also describe our identity verification process (if needed) and when you should expect a response, unless we have already granted or denied the request.

Please allow us up to thirty (30) days to reply to you from the day we received your request. If we need more time (up to 60 days in total), we will inform you of the reason why, and the extension period, in writing.

If we cannot satisfy a request from you, we will also explain why in our response.

We will not charge a fee for processing or responding to your requests unless we determine that your request is excessive, repetitive, or manifestly unfounded. In those cases, we will tell you why we made that determination and provide you with a cost estimate before completing your request.

Non-discrimination for exercising privacy rights: In accordance with applicable law, we will not discriminate against you for exercising any of your privacy rights.

10. Notice to California Residents.

If you are a California resident, you may have certain additional privacy rights. Visit our Notice for residents in California, Exhibit A, for more information.

11. Privacy of Children

We do not knowingly process Personal Data of children under the age of 16.

12. When visiting our offices

Your rights as a visitor to our offices, in relation to your Personal Data, are similar to your rights as a visitor on our Website, as set out in this Notice, unless otherwise specified by local law.

13. Changes to this Notice.

From time to time, we may amend this Notice and post the updated Policy here. We will provide notice to you about material changes and, where required by applicable law we will obtain your consent. We will notify you about material changes to this Notice by email, when applicable. We encourage you to periodically check back and review this Policy so that you always know our current privacy practices. Latest updates to this Notice were made as of July 31, 2023.

14. EU Data Protection Representative

VeraSafe has been appointed as Wizeline’s representative in the European Union for data protection matters, pursuant to Article 27 of the General Data Protection Regulation of the European Union. If you are in the European Economic Area, VeraSafe can be contacted in addition to privacy@wizeline.com, only on matters related to the processing of personal data.

To make such an inquiry, please contact VeraSafe using the following contact form: click here or via telephone at: +420 228 881 031.

Alternatively, VeraSafe can be contacted at:

VeraSafe
Plaza de la Solidaridad 12, Floor 5
29006, Malaga
Malaga
Spain

15. UK Data Protection Representative

VeraSafe has been appointed as Wizeline’s representative in the United Kingdom for data protection matters, pursuant to Article 27 of the United Kingdom General Data Protection Regulation. If you are located within the United Kingdom, VeraSafe can be contacted in addition to or instead of privacy@wizeline.com, only on matters related to the processing of personal data.

To make such an inquiry, please contact VeraSafe using this contact form: click here or via telephone at: +44 (20) 4532 2003.

Alternatively, VeraSafe can be contacted at:

VeraSafe United Kingdom Ltd.
37 Albert Embankment
London SE1 7TL
United Kingdom

16. Contact Us.

If you have any questions about this Notice or our processing of your Personal Data, please write to our Data Privacy Officer by e-mail at privacy@wizeline.com or by postal mail at:

Wizeline, Inc.
50 California St, Suite 1500,
San Francisco, CA 94111
Please allow up to four weeks for us to reply.

Exhibit A: Notice for residents in California

This section of our Notice applies solely to individuals who reside in the State of California.

Categories of personal information collected: We may have collected the following categories of personal information from you within the last twelve (12) months:

1. Identifiers, such as name, address, online identifier, internet protocol address, email address, account name, social security number, driver’s license number, passport number, or other similar identifiers;
2. Additional personal information described in Cal. Civ. Code Section 1798.80, such as signature, physical characteristics or description, telephone number, state identification number, insurance policy number, bank account number, credit card number, debit card number, or any other financial information, medical information, health insurance information, employment, and employment history;
3. Characteristics of protected classifications under California or federal law;
4. Geolocation data;
5. Audio, electronic, visual or similar information;
6. Professional or employment-related information;
7. Education information;
8. Inferences drawn from other personal information; and
9. Sensitive personal information.

Categories of sources from which personal information is collected: The categories of sources from which Wizeline may have collected personal information about you are described in the “Means through which we obtain your personal data” section of this Notice.

Business or commercial purposes for collecting personal information: The business or commercial purposes for which we collect your personal information are described in the “For what purpose we use your Personal Data” section of this Notice.

Categories of personal information “sold” or “shared” to third parties: Wizeline does not “sell” or “share” your personal information that is subject to this Notice. We do not knowingly “sell” or “share” personal information of consumers under sixteen (16) years of age. Therefore, we do not offer the right to opt-out of “sale” or “sharing” of your personal information. Under the CCPA, “sell”, “selling,”, “sale”, or “sold” means selling, renting, disclosing, disseminating, making available, transferring, or otherwise communicating orally, in writing, or by electronic or other means, your personal information to a third party for monetary or other valuable consideration. Under the CCPA, “share”, “shared”, or “sharing” means sharing, renting, releasing, disclosing, disseminating, making available, transferring, or otherwise communicating orally, in writing, or by electronic or other means your personal information to a third party for cross-contextual behavioral advertising.

Categories of personal information disclosed to third parties: Wizeline may have disclosed all of the categories of personal information from you listed in the “Categories of personal information collected” portion of this Notice for California to the categories of third parties listed in the “Disclosures of your Personal Data” section of this Notice within the last twelve (12) months.

Personal information retention: The criteria used to determine how we retain personal information is set forth in the “Personal Data Retention” section of this Notice.

Use and disclosure of sensitive personal information: Wizeline does not use or disclose your sensitive personal information except to facilitate our relationship and other compatible uses, such as resisting malicious, deceptive, fraudulent, or illegal actions directed at us, or to ensure the physical safety of other persons.

APPENDIX A: Talent Page and Recruiting Activities

The purpose of this Appendix A is to inform you which Personal Data we collect from you when you interact with us in connection with the Talent Page and in the context of Recruiting Activities. Please note that this Appendix A supplements the provisions of this Notice.

1. Which Personal Data we collect.

The following Personal Data we collect in the context of this Appendix A is the one you choose to provide when you register in our Talent Page and when you participate in our Recruiting Activities:

Information that allows us to keep in touch with you, such as your address, work address, tax address, email, home phone number or other contact phone number.
Information that allows us to identify you, such as your name, gender, nationality, date of birth, personal photograph, tax identification number, among others.
Information regarding your previous employment or current employment, title or position; job performance, professional experience, information regarding training you have taken, evaluations, professional profile, among others.
Information that allows us to know your professional career, such as your schooling, educational background, titles, certificates, recognitions, professional license number, among others.
Information that you provide in resumes/CVs, letters, writing samples, or other written materials.
Data regarding your current or future health status and conditions, as well as information regarding your vaccination status, subject to legal limits on the timing of collection of such data and other applicable limitations.
Where applicable, criminal records and credit bureau reports or other data revealed during background screenings.
Information generated by interviewers and recruiters, based on their interactions with you.
Information provided by third-party placement companies, applicant matching platforms, recruiters, or job-search websites, where applicable.Images, photographs, and audio or video recordings captured in the course of physical or virtual recruitment events or interviews.

2. Sensitive Personal Data

Some of the Personal Data described in Section 1, Appendix A above, are or may be considered as “sensitive personal data” or “special categories of personal data”. We will obtain and treat this kind of Personal Data where: (i) its processing is necessary for the purposes of carrying out the obligations and exercising specific rights in the field of employment and social security law; (ii) the processing is necessary for the establishment, exercise or defense of legal claims (iii) the processing is necessary for the purposes of preventive or occupational medicine, for the assessment of the working capacity of the employee, or (iv) you have given your explicit consent to the processing. Therefore, your acknowledgement and execution of this Notice constitutes a valid and explicit such consent.

3. Means through which we obtain your Personal Data.

Wizeline may obtain Personal Data from you through various means, including:

Personally, from you throughout your recruitment process;
From third-party recruiters, applicant matching platforms, staffing companies.
From former or current employers;
Indirectly, for example, by receiving reports, background checks or any other information that are delivered to us by companies that we hire to carry out tests or examinations of various types with respect to our employees (e.g., psychometric tests) or when we obtain data that are stored in publicly accessible sources.

4. For what purpose we use your Personal Data.

We may process your Personal Data collected in accordance with Section 1 of this Appendix A for the following purposes:

providing our recruitment services and facilitating the recruitment and/or hiring process;
enabling you to submit your resume, applying for jobs or subscribing to alerts about jobs we think may be of interest to you;
communicating with you and answering your questions, or sending you information about new events or open positions; and
for the purposes mentioned above in Section 3 of this Notice.

5. The legal basis for data processing.

Within the scope of this Appendix, we may process your Personal Data pursuant to the following legal basis:

Category of personal data	Legal basis for the processing
Identification data	You have provided your consent or the processing is necessary for: the performance of a contract and to take steps prior to entering into a contract; our legitimate interests, namely identifying and preventing any illegal conduct such as fraud.
Contact data	You have provided your consent or the processing is necessary for: the performance of a contract and to take steps prior to entering into a contract; our legitimate interests, namely identifying and preventing any illegal conduct such as fraud.
Employment data	The processing is necessary for: the performance of a contract and to take steps prior to entering into a contract; our legitimate interests, namely managing our human resources and fulfillment of our obligations; compliance with a legal obligation to which we are subject. exercising specific rights in the field of employment insofar as it is authorized by EU law, EU Member State law, or other applicable laws.
Electronic records	The processing is necessary for: the performance of a contract and to take steps prior to entering into a contract; our legitimate interests, namely providing internal computer systems and ensuring the security of such systems among others; compliance with a legal obligation to which we are subject.
Data about third parties	You have provided your consent or the processing is necessary for: the performance of a contract and to take steps prior to entering into a contract; compliance with a legal obligation to which we are subject.

Where we process your Personal Data based on your consent, you may withdraw it at any time. However, this will not affect the lawfulness of our processing before you withdraw your consent. It will also not affect the validity of our processing of Personal Data performed on other lawful grounds.

6. Disclosures of your Personal Data.

In addition to the provisions of Section 6 of this Notice, Wizeline may send all or part of your Personal Data in connection with our Talent and Recruitment Activities to our service providers. These service providers include, but are not limited to: (i) companies that provide us with recruitment and selection services; (ii) application tracking software and systems; (iii) companies or laboratories that perform psychometric, psychological, technical or behavioral assessments, medical, clinical studies; (iv) companies that support us in accounting, tax, legal and immigration matters; (v) companies that perform background and socio-economic checks; (vi) other companies when necessary to comply with contractual or legal obligations.

APPENDIX B: Academy Page and Academy Services

The purpose of this Appendix B is to inform you which Personal Data we collect from you when you interact with us in connection with the Academy Page. Please note that this Appendix B supplements the above provisions of this Notice.

1. Which Personal Data we collect.

The following Personal Data we collect in the context of this Appendix B is the one you choose to provides when you join our Academy Page mailing list or decide to participate in or register for a Wizeline Academy event or services (“Academy Services”):

Information that allows us to differentiate you from other individuals, such as your name, gender, nationality, date of birth, personal photograph, among others.
Information that allows us to keep in touch with you, such as your address, work address, email, mobile number or other contact phone number.
Account information, such as your name, user name, profile picture, or social media account ID.
Where applicable, Information that allows us to know your professional career, such as your schooling, educational background, titles, certificates, recognitions, among others.
Images, photographs, and audio or video recordings captured in the course of physical or virtual Academy events.
Preferences and consumer habits (e.g. shopping habits, preferred educational courses).
Processing payment information.

2. For what purpose we use your Personal Data.

We may process your Personal Data collected in accordance with Section 1 of this Appendix B above, for the following purposes:

Authorize and manage the access to the Academy Page, verify your identity, authenticate your visits and provide you with the Academy Services;
Manage, analyze, develop, customize and improve our Academy Page and the Services;
Process the payment of the Academy Services (if applicable);
Send you notifications and news about Wizeline Academy Page, the Academy Services and events by any means, even when the relationship has ended, unless the person concerned states otherwise;
Obtain the diagnosis of possible connection problems that may exist between the Academy Page and you, improving the quality of the Academy Services.
For the purposes mentioned in Section 3 of this Notice.

3. The legal basis for data processing.

Within the scope of this Notice, we may process your Personal Data pursuant to the following legal basis:

Category of personal data	Legal basis for the processing
Identification data	You have provided your consent or the processing is necessary for: the performance of a contract and to take steps prior to entering into a contract; our legitimate interests, namely identifying and preventing any illegal conduct such as fraud.
Contact data	You have provided your consent or the processing is necessary for: the performance of a contract and to take steps prior to entering into a contract; our legitimate interests, namely identifying and preventing any illegal conduct such as fraud.
Academic data	You have provided your consent or the processing is necessary for: the performance of a contract and to take steps prior to entering into a contract; compliance with a legal obligation to which we are subject; our legitimate interests, namely managing our human resources or offering the possibility to use our Academy Page.
Electronic records	The processing is necessary for: the performance of a contract and to take steps prior to entering into a contract; our legitimate interests, namely providing internal computer systems and ensuring the security of such systems among others; compliance with a legal obligation to which we are subject.
Data about third parties	You have provided your consent or the processing is necessary for: the performance of a contract and to take steps prior to entering into a contract; compliance with a legal obligation to which we are subject.