RECRUITMENT PRIVACY NOTICE

Last updated September 12^th, 2022

Previan Technologies Inc. and its subsidiaries and affiliates, which include Eddyfi Technologies, Senceive, Pavemetrics, NDT Global, TSC Subsea and Dynamic Risk (collectively, “Previan") value and are committed to respecting your privacy and protecting your personal information. This Recruitment Privacy Notice (the "Notice") describes how Previan handles and protects your personal information in connection with Previan's recruitment processes and programs. In the event of a conflict between this Notice and applicable law, the applicable law shall prevail.

This Notice applies specifically to the personal information of job applicants, potential job applicants and individuals who participate in our recruitment programs and events.

WHAT IS PERSONAL INFORMATION?

Personal information is defined as any information about an identified or identifiable individual. An identifiable individual is a person who can be identified, directly or indirectly, by reference to an identifier such as a name, an identification number, location data, an online identifier or one or more factors specific to that individual.

Sensitive personal information is a subset of personal information that includes ethnicity, health, trade union membership, philosophical beliefs, as well as the processing of genetic data, biometric data for the purpose of uniquely identifying a natural person, as well as data concerning health or data the sex life or sexual orientation of a natural person.

WHAT DATA DO WE COLLECT?

The types of personal information that Previan requests from you and the ways that we process it are determined by the requirements of the country in which the role you apply for is located, and not the country in which you reside. Should you apply to more than one location or should the role to which you apply be available in more than one country, the types of personal information we request from you and the ways that we process it are determined by the requirements of all the countries in which the position is located.

We collect personal information directly from you when you apply for a role with Previan, such as your name, address, contact information, photographs and videos, certifications and diplomas, work and educational history, achievements, identity documents, and test results. This personal information is submitted directly to the relevant entity or organization within Previan through the online application process and follow-up communications and/or through alternative channels (e.g., via professional recruiting firms). If you receive an offer from Previan, we may then conduct a background check and, to the extent permitted by applicable law, we may also collect personal information related to criminal offences and proceedings. We also collect similar personal information about you from third parties, such as professional recruiting firms, your references, prior employers, Previan employees with whom you have interviewed or who recommended your candidacy, and, to the extent permitted by applicable law, employment background check providers. We may also collect personal information about you online to the extent that you have chosen to make this information publicly available. For example, we may find your profile on professional social media websites (such as LinkedIn) and contact you about suitable roles.

Previan may collect sensitive personal information about a candidate to the extent permitted to do so by applicable laws (e.g., U.S. equal opportunity laws) and to support our efforts to create an inclusive and diverse work environment. We may also collect sensitive personal information to the extent that a candidate chooses, without being asked, to voluntarily disclose it during the recruiting process. Under limited circumstances and to the extent permitted by applicable law, we may also collect sensitive personal information relating to health and medical characteristics, such as status of infection, test results, and vaccination status, to address our public health and workplace safety obligations and to protect Previan and its employees, clients, and third parties.

HOW DO WE PROTECT YOUR PERSONAL INFORMATION?

All personal information processed by Previan is stored on secure servers. Previan implements appropriate contractual, technical and organizational measures to protect the personal information it processes from loss, unauthorized access, use, disclosure or modification and to ensure the integrity of the personal information in accordance with our information security policy. In addition, Previan processes your personal information only for the purposes identified in this Privacy Notice and does not retain the data longer than as set forth in this Privacy Notice.

WHAT ARE THE PURPOSES OF OUR PROCESSING?

We collect and use your personal information for legitimate human resources and business management reasons, including:

identifying and evaluating candidates for potential employment, as well as for future roles that may become available;

maintaining records in relation to recruiting and hiring;

ensuring compliance with legal requirements, including those relating to public health and workplace safety;

fostering our diversity and inclusion programs and practices;

conducting background checks, including, to the extent permitted by applicable law, and if you receive an offer from us, criminal history checks; and

protecting the workplace and communicating with medical professionals, law enforcement, or other public authorities in the event of an emergency or public health event, such as when the health or safety of you or one or more individuals may be endangered, including, to the extent permitted by applicable law, sharing data about the status of an infection, test results, and vaccination status.

We may also use your personal information for Previan analytics purposes, including in aggregated and pseudonymized form, to improve our recruitment and hiring process and augment our ability to attract successful candidates.

WHAT ARE THE LEGAL BASES FOR OUR PROCESSING?

Our processing of your personal information for the purposes mentioned above is based:

in part, on Previan performing contractual and precontractual measures relating to our potential employment relationship with you;

in part, on Previan complying with applicable law with regard to personal information necessary to satisfy our legal and regulatory obligations, including with regard to public health and workplace safety;

in part, on the legitimate interest of Previan for recruitment, administrative management of employees, provision of information technology tools to employees, information security, work organization, career and mobility monitoring, training, management of social activities; and

in part, on your consent, if we offer you the opportunity to participate in our optional recruiting programs or if we collect sensitive personal information for legally permitted purposes other than compliance with our legal obligations regarding public health and workplace safety.

HOW WE HANDLE INTERNATIONAL DATA TRANSFER?

Your personal information may be accessed by recruiters and interviewers working in the country where the position for which you are applying is based, as well as by recruiters and interviewers working in different countries within the Previan global organization. Individuals performing administrative functions and IT personnel within Previan may also have limited access to your personal information to the extent necessary perform their jobs. In some countries, you may have fewer rights under local law than you do in your country of residence, but we have put in place legal mechanisms designed to ensure adequate data protection for your personal information when it is processed by Previan subsidiaries and affiliates within the Previan global organization and by Previan’s service providers, including the transfer of your personal information to countries other than the one in which you reside.

We use third-party service providers to provide a recruiting software system and data associated with such recruitment software system is hosted in third-party data centers located in Canada. We also share your personal information with other third-party service providers that may assist us in identifying and recruiting talent, administering and evaluating pre-employment screening and testing, and improving our recruiting practices.

Except to the extent necessary to accomplish the Previan uses and purposes described in this Privacy Notice, we do not disclose your personal information to third parties. We also prohibit our service providers from using your personal information for non-Previan purposes. We do not otherwise share or sell your personal information to third parties.

We maintain processes designed to help ensure that any processing of personal information by third-party service providers is consistent with this Privacy Notice and protects the confidentiality, availability, and integrity of your personal information in compliance with applicable law and our information security policy. Where required by law, we put in place additional legal mechanisms designed to help ensure adequate data protection for your personal information when transferred to another country. If you would like more information about these legal mechanisms, which may include the EU’s Standard Contractual Clauses, please contact us at the address provided at the end of this Privacy Notice.

In addition, we may disclose or transfer your personal information in the event of a re-organization, merger, sale, joint venture, assignment, or other transfer or disposition of all or any portion of any of Previan’s businesses.

WHAT ARE THE RETENTION PERIODS FOR YOUR PERSONAL DATA?

If you accept an offer of employment with Previan, any relevant personal information collected during your pre-employment period will become part of your personnel records and will be retained in accordance with specific country requirements and with the Previan’s general privacy policy and procedures, which will be provided during the on-boarding process.

If we do not employ you (including if you were not selected for an interview or if your candidacy was rejected), we may nevertheless continue to retain and use your personal information for a period of 2 years (unless country specific requirements for a longer retention period apply, in which case your personal information will be retained for the minimal amount of time to comply with such requirements) to consider you for potential future roles.

WHAT ARE YOUR RIGHTS?

You have:

The right to be informed about the processing of your personal information;

The right to access your personal information processed by Previan;

The right to rectification which allows you to modify and rectify the personal information that are processed about you by Previan;

The right to erasure which allows you under specific conditions to request the deletion of your personal information by Previan;

The right to restrict processing which allows you to control how your data is processed or to request that your personal information no longer be processed but only retained by Previan;

The right to object to the processing of your personal information, which means that you can require Previan to stop processing your personal information, when the processing does not meet a legal obligation, is not necessary for the performance of a contract or is based on the consent because you may withdraw your consent in this last case; and

The right to portability, which allows you to receive your data if it is not provided on the basis of consent or contract.

To exercise these rights or for any other question or request related to this Privacy Notice, please contact Previan’s group Data Protection Officer at dpo@previan.com.

You also have the right to file a complaint or claim with an appropriate privacy authority.