Candidate Privacy Notice

PLSI Technology Services (India) LLP and Polygon Labs Services (Delaware) Inc. take your data protection rights and our legal obligations seriously. The information that you provide to us in the course of your application for employment with us as well as other information that relates to you or other identified or identifiable individuals (“Personal Data”) will be treated in a secure and confidential manner as set out in this Privacy Policy (“Policy”).

PLSI Technology Services (India) LLP and Polygon Labs Services (Delaware) Inc. (together “Polygon Labs”, “we”, “us” or “our”) are the joint controllers of your Personal Data. This means that both entities will determine together how and why your Personal Data is processed, principally because our local entity does not have its own human resources department and therefore is working with its affiliate for certain processing activities. These entities have entered into a joint controller agreement by which they both are responsible for informing you about the processing of your Personal Data in this Policy. You may exercise your rights as a data subject with either entity as set forth below. In addition, where processing of Personal Data is undertaken by other affiliates of Polygon Labs for their own independent purposes, these affiliates may be controllers or joint controllers of your Personal Data and a separate privacy policy will be provided to you. 

Throughout this Policy we use the term “processing” to refer to all activities involving your Personal Data, including collecting, handling, storing, sharing, accessing, using, transferring, erasing and disposing of Personal Data.

This Policy is provided to you in compliance with data protection laws. This Policy does not constitute or form part of any contract nor is it an offer to contract or an offer of employment. This Policy does not confer any contractual right on you, or place any contractual obligation on us.

1. Personal Data

We may collect various types of Personal Data about you for the purposes described in this Policy:

• Data about you: full legal name, date of birth, age, home contact details (e.g., address and location, telephone number, e-mail), national ID and other governmental IDs and numbers, immigration and eligibility to work data; to the extent permissible by applicable law, records of your past criminal convictions, sex offender registry status, fraud convictions, other sanctions; and you and your family’s outside business activities relevant to Polygon Labs.
• Data about your employment history and qualifications: education and training, employment history, LinkedIn information, qualifications, references.
• Data about your application: CV/resume and application, interview data.
• Other information: Social media information such as Twitter handle or Github profile information; or other information you voluntarily provide us through the application process.

You may give us the Personal Data described above during the recruitment process, whether through your application, further communications, on the telephone or during interviews. 

We may also receive Personal Data about you from third parties: recruiters; references from a previous employer; business partners; sub-contractors providing recruiting or technical services; analytics providers; and background check and search information providers; as well as from publicly available sources such as social media where such Personal Data is proportionate to the position for which you are applying. We may also retain that Personal Data after you have been employed (where this is relevant and to the extent permitted by applicable law).

• We may also receive information (which may include your Personal Data) from our hiring manager, from our Human Resources staff, and, from time to time, from our other employees (for instance, in the course of conducting an interview). 

2. Why We Process Your Personal Data; Legal Bases

The Personal Data requested from you during the recruitment process is required by us in order to assess your application for employment with Polygon Labs. If you do not provide some or all of this Personal Data it may affect our ability to process your application and therefore to offer you employment. In some cases, it may mean that we are unable to continue with your application for employment as Polygon Labs will not have the Personal Data we believe to be necessary for the effective and efficient management of the recruitment process.

We collect the Personal Data described in Section 1 above for the purposes of managing Polygon Lab’s  recruitment related activities, namely: verification of qualifications and employment eligibility; the evaluation and selection of candidates; setting up and conducting interviews and tests; and conducting evaluations, assessments and otherwise as needed in the recruitment process, including if relevant, issuing employment offers; bringing successful candidates into Polygon Labs; dealing with queries or complaints relating to the recruitment process; for asserting or managing any kind of claims that we may bring or that may be raised against us; to comply with legal or regulatory obligations; and, where appropriate, retaining information relating to unsuccessful candidates for consideration in future relevant vacancies. 

We process your Personal Data for the purposes described above on the following legal bases:

• Legal obligations: the processing is necessary for compliance with a legal obligation to which Polygon Labs is subject (purposes of processing: verifying eligibility for employment or complying with obligations regarding non-discrimination; complying with other legal or regulatory obligations such as law enforcement requests or other); 
• Assessment of working capacity: the processing is necessary for us to assess your capacity to become one of our employees; or
• Contractual obligations / Pre-contractual steps: the processing is necessary to comply with the terms of our recruitment process, as disclosed to you prior or during the recruitment process or in order to take steps at your request prior to offering you employment (purposes of processing: communicating with you about your application); or 
• Consent: the processing is necessary for setting up and conducting interviews and tests; conducting evaluations and assessments; verifying your academic, work and other qualifications; verifying references; evaluating and selecting candidates for further consideration; to issue an employment offer; to deal with queries or complaints; asserting or managing any kind of claims that we may bring or that may be raised against us; and to consider unsuccessful candidates for future vacancies).     

3. With Whom Do We Share Your Personal Data?

As part of a multinational with affiliates in several countries, Polygon Labs may hire for its sites, and use resources, located outside the country where you live. Your Personal Data may be shared with affiliated companies where it is reasonable and necessary to do so, such as to ensure a consistent application of standards for candidate recruitment. Within Polygon Labs, your Personal Data can be accessed by or may be disclosed internally on a need-to-know basis to persons responsible for managing or making hiring decisions, Human Resources staff, system administrators and other support teams (such as IT and Finance).

Your Personal Data may also be accessed by third parties who provide us with services relevant to your recruitment, namely: recruiters; companies that host, support and/or maintain the IT systems supporting our recruitment system; and companies that verify your references, perform background checks solely to the extent permitted by applicable law or conduct vetting on our behalf.

If your application for employment with Polygon Labs is successful and you accept a job offer from us, your Personal Data may also be shared as described in our employee privacy policy, and notably with Human Resources management, payroll and benefits systems, and the Personal Data contained in such systems may be accessible by providers of those systems, their affiliated companies and sub-contractors; tax authorities; regulatory authorities; and our lawyers, auditors, investors, consultants and other professional advisors. 

Polygon Labs may also share your Personal Data if it becomes involved in a reorganization, merger, consolidation, acquisition, or any form of sale of some or all of its assets, with any type of entity, whether public, private, foreign or local.

Polygon Labs expects all third parties to process any Personal Data disclosed to them in accordance with applicable law and contract terms, including with respect to Personal Data confidentiality and security.  Where these third parties act as a “processor” (for example, by verifying your references at our request), they carry out their tasks on our behalf and upon our instructions for the above-mentioned purposes.  In this case, your Personal Data will only be disclosed to these parties to the extent necessary to provide the required services.  

4. Security of Personal Data

• We implement what we determine to be reasonable physical, technical and administrative security standards designed to protect your Personal Data from loss, misuse, alteration, destruction or damage.  
• We store your Personal Data on computers which we own or on our secure servers or secure servers of third-party affiliates, and provide for a fully compliant storage safety. We carefully manage and monitor such devices to ensure that complete security is maintained at all times. In compliance with the applicable Indian law, we strive to adhere to the International Standard IS/ISO/IEC 27001 on Information Technology - Security Techniques - Information Security Management System - Requirements.
• We may also store your Personal Data on secure servers of non-affiliate third parties, provided they are compliant with the applicable Indian data protection laws.

5. Where We Process and Store your Personal Data

From time to time your Personal Data will be transferred to persons/entities within or outside your country for the purposes described in this Policy. For example, your Personal Data may be transferred, among other purposes, to conduct the review of your application, the processing of your information, and the provision of support services by third parties.

Depending on the scope of your interactions with us, information about you, including personal information, may be stored in or accessed from multiple countries. For example, we may share your Personal Data with colleagues within Polygon Labs; with colleagues at Polygon Labs entities in the United States; and with third parties as described in this Policy. Those third parties may be located in the United States and other countries which have been determined to provide adequate protection to Personal Data.

Whenever we transfer personal information to other jurisdictions, we will ensure that the information is transferred in accordance with this Policy and as permitted by applicable data protection laws.  

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6. Retention of your Personal Data

• We will retain candidate Personal Data for a period of up to one year following the closure of the recruitment process relating to the role for which you applied in the event other job opportunities arise within Polygon Labs or an affiliate. In all cases, we will retain your Personal Data for a period of time corresponding to the applicable statute of limitations for any kind of claims that we may bring or that may be raised against us, or legal or regulatory obligations.

7. Your Rights

• Subject to conditions set forth in applicable data protection legislation, you have the following rights. Note that the rights set out are not absolute and are each subject to certain exceptions:     
• Right to Information – Whilst Polygon Labs aims to provide you with as much information as possible with respect to our processing of your Personal Data within this Policy, you may be able to request certain additional information from us. Specifically, information with respect to the procedures to be taken in the event of a breach or infringement of your Personal Data, especially if the breach or infringement poses a direct and serious threat to the privacy and confidentiality of your Personal Data.  
• Right to Correct (Rectification) - Polygon Labs aims to ensure that all of your Personal Data is correct. You are entitled to have any inadequate, incomplete or incorrect Personal Data corrected (that is, rectified). 
• Right to Withdraw Consent - In the event your Personal Data is processed on the basis of your consent, you have the right to withdraw consent at any time, without affecting the lawfulness of processing based on consent before its withdrawal.
• Right to Request Personal Data and Right to Data Portability - If we rely upon your consent as the legal basis for processing, or where processing is necessary to perform a contract to which you are party, and the Personal Data is processed by automated means, you have the right to receive all such Personal Data which you have provided to us in a structured and machine-readable format, and also to require us to transmit it to another controller where this is technically feasible.
• Right to Erasure - You are entitled to have your Personal Data erased under specific circumstances, such as where you have withdrawn your consent, where you object to our processing of your Personal Data and where we have no legitimate reason to continue processing it, where your Personal Data is no longer required for the purpose for which it was collected and / or where our processing of your Personal Data is not in line with applicable laws and where erasure is necessary for us to comply with those laws.

• Right to Restriction of Processing - You have the right to restrict our processing of your Personal Data (that is, allow only its storage) where: 
  - you contest the accuracy of the Personal Data, until we have taken sufficient steps to correct or verify its accuracy; 
  - where the processing is unlawful;
  - where the processing exceeds the purposes set out within this Policy.

• Right to Request Continued Processing – You have a right to request that we continue to process your Personal Data once we have fulfilled our purposes for processing where such Personal Data relates to a legal proceeding. 
• Right to Stop Processing – You have a right to object to, and stop, our processing of Your Personal Data where we use it for direct marketing purposes, where we conduct statistical surveys, and in the event that we process it other than in accordance with the Personal Data Processing Controls set out under Indian data protection laws.‍
• Right to lodge a complaint - You may lodge a complaint with the supervisory authority of your country of residence, place of work or place of alleged infringement.‍
• Right to Nominate - You have a right to nominate any other individual, who shall, in the event of your death or incapacity, exercise your rights hereunder.‍
• Right of Grievance Redressal - You have a right to seek redressal if you have any complaints about a possible breach of applicable laws, for which we have appointed a grievance officer.  You may direct your questions or concerns to Andy LeGolvan (alegolvan@polygon.technology), the grievance officer.

8. How to Contact Us; How to Exercise Your Rights 

To obtain further information regarding your rights, to exercise any of your rights (other than to lodge a complaint), or to ask any questions regarding the processing of your Personal Data, please contact privacy@polygon.technology. To lodge a complaint, please contact the relevant Data Protection Supervisory Authority.

9. Changes to this Policy

We may update this Policy from time to time. If we make any changes, we will change the Last Updated date above. We encourage you to periodically review the Policy for the latest information on our privacy practices.‍

10. Consent

If and to the extent to which an alternative lawful basis for processing is not available for any purpose for processing described within this Policy, I hereby consent to Polygon Labs’ processing of my Personal Data for such purposes. Where Polygon Labs does rely on my consent, I understand that I have the right to withdraw my consent at any time. The withdrawal of my consent will not affect the lawfulness of Polygon Labs’ processing of my Personal Data up until the date at which I withdrew my consent. 

This California Applicant Privacy Notice (“ApplicantNotice”) describes our information practices relating to applicants and candidates for employment with PolygonLabs Services (Delaware) Inc., or our affiliates or subsidiaries (“Polygon Labs,” “we,” “our,” “us,” or the “Company”) who are California residents (each an “Applicant” or “you”). This Applicant Notice is intended to satisfy the requirements of the California Consumer Privacy Act (as amended by theCalifornia Privacy Rights Act of 2020) (collectively “CCPA”).

1. Scope and Relation to Other Policies

This Applicant Notice applies to the Personal Information we collect about our Applicants. This Policy supplements other agreements, including anyNon-Disclosure Agreement(s), if applicable. This Applicant Notice applies to any information that identifies, relates to, describes, is reasonably capable of being associated, or could reasonably be linked, directly or indirectly,with you (subject to some exemptions under the CCPA) (“Personal Information”). Note, our information practices may vary depending upon the circumstances, such as the location or role for which you are applying.

This Applicant Notice does not address or apply to our information practices that are not subject to the CCPA, such as:

• Business Information. Company or business information that constitutes trade secrets, proprietary information,intellectual property, company property, information that includes or affects the rights of other employees, privileged or investigative materials, or information that helps ensure security and integrity of company assets.
• Publicly Available Information. Information that is lawfully made available from government records, information we have a reasonable basis to believe is lawfully made available to the general public by you or by widely distributed media, or by a person to whom you have disclosed the information and not restricted it to a specific audience.
• Deidentified Information. Information that is deidentified in accordance with applicable laws.
• Aggregated Information. Information that relates to a group from which individual identities have been removed.
• Protected Health Information. Information governed by the Health Insurance Portability and Accountability Act or California Confidentiality of Medical Information Act.
• Activities Covered by the Fair Credit Reporting Act. This includes information we receive from consumer reporting agencies that are subject to the Fair Credit Reporting Act, e.g., information contained in background check reports we obtain as part of our vetting process.

This Notice also does not apply to the Personal Information we collect from our  contractors, employees, Applicants, or any developers in the context of their personal use of our websites or the Polygon Labs blockchain technology, which are subject to different notices. For additional information on our general privacy practices, please visit our website Privacy Policy.

Our information practices may vary depending upon the circumstances, such as the location or the role for which you are applying. Also in some cases (such as where required by law), we ask for your consent or give you certain choices prior to collecting or using certain Personal Information. We may also provide Applicants additional notices about our information practices that are covered by other laws (e.g., if we conduct a background check).

2. Personal Information We Collect

The following identifies the categories of Personal Information we may collect about Applicants (and may have collected in the last 12 months).

• Identifiers. Such as your name, alias, address, personal email address, and personal phone number. Additionally, we also collect Personal Information such as your social security number, driver’s license or ID number, passport number or governmental identifiers to verify your identity and authorization to work. 
• Protected Classifications. Such as , racial or ethnic origin, gender, citizenship,  disability status, veteran or military status and other characteristics of protected classifications under California or federal law. This information is generally collected on a voluntary basis and is used in support of our equal opportunity and diversity and inclusion efforts, as well as any reporting obligations or where otherwise required by law.
• Professional or Employment-Related Information. Such as outside business activities relevant to Polygon Labs, and prior employment history, qualifications, licensing, disciplinary record, assessment records, resumes, cover letters, conduct information (including disciplinary and grievance records), and termination data.
• Education Information. Such as education records, including degrees earned, continued education, or any other information about education history or background that is not publicly available personally identifiable information you choose to provide.
• Internet or Other Electronic Network Activity Information. Such as network activity information or usage data including, browsing history, search history, clickstream data, as well as interactions with our portals, websites, applications, and platforms, and other network activity information related to your interactions with us.
• Geolocation Data. Such as precise location data derived from a device.
• Financial Information. Such as current salary or salary range.
• Audio, Electric, Visual, or Similar Information. Such as photographs if you choose to provide to us. 
• Sensitive Personal Information. To the extent required by law and/or voluntarily provided by you, we collect information like social security number, driver’s license number, state identification card, racial or ethnic origin or sexual orientation (e.g., on a voluntary basis to support of our equal opportunity and diversity and inclusion efforts and reporting obligations, or where otherwise required by law, or union membership), and health information (e.g., as necessary to provide reasonable accommodations).

3. Where We Get Your Personal Information

We generally collect the categories of Personal Information identified above from the following categories of sources:

• Directly from you; 
• Recruiters and recruiting platforms;
• Former employers (with your prior permission);
• Our service providers, representatives, and agents; and
• Any references you provide.

4. Why We Collect Personal Information

We generally collect Personal Information as reasonably necessary for the following business or commercial purposes, as permitted by applicable laws:

• Recruiting and Hiring. We use Personal Information from your application and through the interview process to evaluate your qualifications and eligibility for employment. This includes identifying Applicants, scheduling interviews, conducting background checks, evaluating qualifications, extending offers, communicating with Applicants, maintaining Applicant information for future consideration, and supporting our equal opportunity employment practices.

• Defending and Protecting Rights. To protect and defend our rights and interests and those of third parties, including to manage and respond to Applicant and other legal disputes, to respond to legal claims or disputes, and to otherwise establish, defend or protect our rights or interests, including without limitation, Polygon Labs’ trade secrets and other intellectual property, and protecting the rights, property, and reputation of Polygon Labs and its workforce, or the rights, interests, health or safety of others, including in the context of anticipated or actual litigation with third parties.
• Compliance with Legal Obligations. Related to our compliance with applicable legal obligations (such as determining hiring eligibility or responding to subpoenas and court orders) as well as assessments, reviews and reporting relating to such legal obligations, including under employment and labor laws and regulations, Social Security and tax laws, environmental regulations, workplace safety laws and regulations, and other applicable laws, regulations, opinions and guidance.
• Use of Sensitive Personal Information. Our collection, use, and disclosure of sensitive personal information is limited to what is reasonable and proportionate to employ you for example, complying with our legal, regulatory and reporting obligations.
• Securing Our Premises. We also may use Personal Information to secure our offices, premises, and physical assets, including using electronic access systems if Applicants visit a Polygon location for interviews and screening.

5. Disclosure of Personal Information

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We may disclose the categories of Personal Information we collect for the purposes described above and for the following business purposes.

A. Purposes for Disclosing Personal Information 

• Evaluate Candidacy. We may disclose Personal Information when it is necessary to provide services you request and where it is necessary to identify Applicants, schedule interviews, and otherwise evaluate your qualifications and eligibility for employment.
• Compliance and Legal Obligations. If required to do so by law or subpoena, or if we reasonably believe such action is necessary to comply with the law, judicial proceeding, court order, or the reasonable requests of regulators, law enforcement or other public authorities. 
• Protection of Us and Others. We may disclose Personal Information if required to do so by law, to protect rights, property, or safety of our other associates, workers and contractors, our owners, members, and guests, ourselves or others; or where we have a legitimate interest in doing so. 
• Corporate Transactions. As we continue to develop our business, we may buy, merge, or partner with other companies, or obtain or extend financings, and we may disclose Personal Information as part of those transactions (including in contemplation of such transactions, e.g., due diligence).
• Other Disclosures. We may disclose Personal Information to others and in ways not described above if we give you notice and/or obtain your consent. 

B. Categories of Recipients

We may disclose Personal Information to the following categories of recipients: 

• Affiliates, Subsidiaries and Business Partners. We may disclose Personal Information to our corporate affiliates, subsidiaries and business partners where necessary to evaluate administer the working relationship, conduct our business. or for business operations purposes.
• Service Providers. We may disclose Personal Information to our service providers who perform services on our behalf, such as recruiters or recruitment platform providers. Our service providers are required to take appropriate security measures to protect your Personal Information in line with our policies and are not permitted to use Personal Information for their own purposes. 
• Regulatory and Government Entities. To comply with our legal obligations and where otherwise required by law, we may disclose the following categories of Personal Information to applicable regulatory and government entities: identifiers, characteristics of a protected classifications, and employment-related information. 
• Internet Providers, Operating Systems, and Platforms. If you sign in to or access Company platforms in connection with your application, we may disclose the following categories of Personal Information to Internet service providers, operating, systems and platforms for security and integrity purposes: identifiers and Internet and network activity information.

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6. Retention of Personal Information

We store your Personal Information for as long as needed, or permitted, based on the reason we obtained it (consistent with applicable law). When deciding how long to keep your Personal Information, we consider whether we are subject to any legal obligations (e.g., any laws that require us to keep records for a certain period of time before we can delete them) or whether we have taken any legal positions that require data retention (e.g., issued any legal holds or otherwise need to preserve data). From time to time, we may also deidentify your Personal Information, retain it and use it in compliance with CCPA.

7. Your California Privacy Rights

A. Applicant Privacy Rights 

The CCPA provides California residents with specific rights regarding Personal Information. This section describes your rights under the CCPA and explains how to exercise those rights. Subject to certain conditions and exceptions, Applicants have the right to make the following requests:

• Right to Know/Access. You have the right to request (subject to certain exemptions):
  
  - The categories of Personal Information we collected about you;
  - The categories of Personal Information we collected about you;
  - The categories of sources from which the Personal Information is collected;
  - Our business or commercial purposes for collecting, selling, or sharing that Personal Information;
  - The categories of third parties to whom we disclosed Personal Information; and
  - A copy of the specific pieces of Personal Information we have collected about you.

• Right to Correct. You have the right to request that we correct inaccuracies in your Personal Information. Applicants seeking to update their information may do so at any time by using our recruitment platform. 
• Right to Delete. You have the right to request we delete your Personal Information. Please note, Polygon Labs is not obligated to delete Personal Information that it is necessary to provide services you request or to comply with applicable laws. 
• Right to Opt-Out. You have the right to opt-out of “sales” and “sharing” of your Personal Information, as those terms are defined under the CCPA. While we do not “sell” Personal Information, our use of certain third-party analytics and advertising cookies may constitute “sharing” under the CCPA. To exercise your right to opt-out of the “sharing” of your Personal Information, please use the Do Not Sell or Share My Personal Information link at the bottom of our website. We do not sell or share “sensitive personal information,” nor do we sell or share the Personal Information of individuals under who we know are under sixteen (16) years old. 

You also have the right to opt-out of “sales” and “sharing” of your Personal Information through the use of an opt-out preference signal. If we detect that your browser or device is transmitting an opt-out preference signal, such as the “global privacy control”—or GPC—signal, we will opt that browser or device out of cookies that result in a “sale” or “sharing” of your Personal Information. If you visit our website from a different device or from a different browser on the same device, you will need to opt-out, or use an opt-out preference signal, for that browser and/or device as well.

• Right to Limit Use and Disclosure. We do not disclose “sensitive personal information” for purposes except as described in this Applicant Notice or as otherwise authorized by the CCPA.
• Right to Non-Discrimination. We will not discriminate against you for exercising any of the rights described in this section.

B. Exercising Your California Privacy Rights

To exercise any of these CCPA rights, please use one of the following methods:

• Email:   privacy@polygon.technology
• Mailing: Polygon Labs Services (Delaware) Inc.
  8605 Santa Monica Blvd., #42857
  West Hollywood, CA 90069

Polygon Labs may require additional information to confirm your identity before fulfilling the request such as your full name, telephone number, and the email address you used to communicate with us. In some cases, we may request additional information to verify your identity, or where necessary to process your request. If we are unable to verify your identity after a good faith attempt, we may deny the request and, if so, will explain the basis for the denial.

You may designate someone as an authorized agent to submit requests and act on your behalf. To do so, you must provide us with written permission to allow the authorized agent to act on your behalf. We may also ask you directly to verify that you have authorized your authorized agent to act on your behalf.

8. Contact Us

If you have questions or concerns regarding this Applicant Notice or the handling of your Personal Information, please contact us at:

Polygon Labs Services (Delaware) Inc.
8605 Santa Monica Blvd., #42857
West Hollywood, CA 90069
privacy@polygon.technology

Polygon Labs Services (Canada) Ltd. and its affiliate Polygon Labs Services (Delaware) Inc. take your data protection rights and our legal obligations seriously. The information that you provide to us in the course of your application for employment with us as well as other information that relates to you or other identified or identifiable individuals (“Personal Data”) will be treated in a secure and confidential manner as set out in this Privacy Policy (“Policy”).

Polygon Labs Services (Canada) Ltd. and Polygon Labs Services (Delaware) Inc. (together “Polygon Labs”, “we”, “us” or “our”) are the controllers of your Personal Data, determining why Personal Data is processed and how it is processed. In addition, where processing of Personal Data is undertaken by affiliates of Polygon Labs for their own independent purposes, these affiliates may be controllers or joint controllers of your Personal Data and a separate privacy policy will be provided to you to the extent required under applicable laws.

Throughout this Policy we use the term “processing” to refer to all activities involving your Personal Data, including collecting, handling, storing, sharing, accessing, using, transferring, erasing and disposing of Personal Data.

This Policy is provided to you in compliance with data protection laws. This Policy does not constitute or form part of any contract nor is it an offer to contract or an offer of employment.  This Policy does not confer any contractual right on you, or place any contractual obligation on us.

1. Personal Data

We may collect various types of Personal Data about you for the purposes described in this Policy:

• Data about you: full legal name,  date of birth, age, home contact details (e.g., address and location, telephone number, e-mail), national ID and other governmental IDs and numbers, immigration and eligibility to work data, salary/wage expectations; to the extent permissible by applicable law, records of your past criminal convictions, sex offender registry status, fraud convictions, other sanctions; and, where permitted by applicable law and subject to obtaining any required consent, ‎you and your family’s outside business activities relevant to Polygon Labs.
• Data about your employment history and qualifications: education and training, employment history, LinkedIn information, qualifications, references.
• Data about your application: CV/resume and application, interview data.
• Other information: Social media information such as Twitter handle or Github profile information; or other information you voluntarily provide us through the application process. 

You may give us the Personal Data described above during the recruitment process, whether through your application, further communications, on the telephone or during interviews. 

We may also receive Personal Data about you from third parties: recruiters; references from a previous employer; business partners; sub-contractors providing recruiting or technical services; analytics providers; and background check and search information providers; as well as from publicly available sources such as social media where such Personal Data is proportionate to the position for which you are applying. We may also retain that Personal Data after you have been employed (where this is relevant and to the extent permitted by applicable law).

We may also receive information (which may include your Personal Data) from our hiring manager, from our Human Resources staff, and, from time to time, from our other employees (for instance, in the course of conducting an interview). 

2. Why We Process Your Personal Data

The Personal Data requested from you during the recruitment process is required by us in order to assess your application for employment with Polygon Labs. If you do not provide some or all of this Personal Data it may affect our ability to process your application and therefore to offer you employment. In some cases, it may mean that we are unable to continue with your application for employment as Polygon Labs will not have the Personal Data we believe to be necessary for the effective and efficient management of the recruitment process.

We collect the Personal Data described in Section 1 above for the purposes of managing Polygon Lab’s  recruitment related activities, namely: verification of qualifications and employment eligibility; the evaluation and selection of candidates; setting up and conducting interviews and tests; and conducting evaluations, assessments and otherwise as needed in the recruitment process, including if relevant, issuing employment offers; bringing successful candidates into Polygon Labs;  dealing with queries or complaints relating to the recruitment process; for asserting or managing any kind of claims that we may bring or that may be raised against us; to comply with legal or regulatory obligations; and, where appropriate, retaining information relating to unsuccessful candidates for consideration in future relevant vacancies. 

3. With Whom Do We Share Your Personal Data?

As part of a multinational with affiliates in several countries, Polygon Labs may hire for its sites, and use resources, located outside the jurisdiction where you live. Your Personal Data may be shared with affiliated companies where it is reasonable and necessary to do so, such as to ensure a consistent application of standards for candidate recruitment. Within Polygon Labs, your Personal Data can be accessed by or may be disclosed internally on a need-to-know basis to persons responsible for managing or making hiring decisions, Human Resources staff, system administrators and other support teams (such as IT and Finance).

Your Personal Data may also be accessed by third parties who provide us with services relevant to your recruitment, namely: recruiters; companies that host, support and/or maintain the IT systems supporting our recruitment system; and companies that verify your references, perform background checks solely to the extent permitted by applicable law or conduct vetting on our behalf.

If your application for employment with Polygon Labs is successful and you accept a job offer from us, your Personal Data may also be shared as described in our employee privacy policy, and notably with Human Resources management, payroll and benefits systems, and the Personal Data contained in such systems may be accessible by providers of those systems, their affiliated companies and sub-contractors; tax authorities; regulatory authorities; and our lawyers, auditors, investors, consultants and other professional advisors. 

Polygon Labs may also share your Personal Data if it becomes involved in a reorganization, merger, consolidation, acquisition, or any form of sale of some or all of its assets, with any type of entity, whether public, private, foreign or local.

Polygon Labs expects all third parties to process any Personal Data disclosed to them in accordance with applicable law and contract terms, including with respect to Personal Data confidentiality and security.  Where these third parties act as a “processor” (for example, by verifying your references at our request), they carry out their tasks on our behalf and upon our instructions for the above-mentioned purposes.  In this case, your Personal Data will only be disclosed to these parties to the extent necessary to provide the required services.  

4. Security of Personal Data

We implement what we determine to be reasonable physical, technical and administrative security standards designed to protect your Personal Data from loss, misuse, alteration, destruction or damage.  

5. Where We Process and Store your Personal Data

From time to time your Personal Data will be transferred outside your jurisdiction for the purposes described in this Policy. For example, your Personal Data may be transferred, among other purposes, to conduct the review of your application, the processing of your information, and the provision of support services by third parties.

Depending on the scope of your interactions with us, information about you, including personal information, may be stored in or accessed from multiple jurisdictions. For example, we may share your Personal Data with colleagues within Polygon Labs; with colleagues at Polygon Labs entities in the United States, a country which has not received a decision of the European Commission confirming that it provides adequate protection to Personal Data; and with third parties as described in this Policy. Those third parties may be located in the United States and  other countries which have been determined to provide adequate protection to Personal Data. Applicable ‎‎laws in those ‎other jurisdictions might permit foreign governments, courts, law ‎enforcement ‎or ‎‎regulatory agencies to ‎access the information in those jurisdictions.‎ In these ‎cases, we will ‎comply with local law requirements relating to the conditions for disclosure ‎of personal information. ‎

Whenever we transfer personal information to other jurisdictions, we will ensure that the information is transferred in accordance with this Policy and as permitted by applicable data protection laws. Where applicable, you are entitled, upon request sent to privacy@polygon.technology, to receive information regarding steps that have been taken to protect your Personal Data in connection with such transfer.  

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6. Retention of your Personal Data

We will retain candidate Personal Data for a period of up to one year following the closure of the recruitment process relating to the role for which you applied in the event other job opportunities arise within Polygon Labs or an affiliate. In all cases, we will retain your Personal Data for a period of time corresponding to the applicable statute of limitations for any kind of claims that we may bring or that may be raised against us, or legal or regulatory obligations.

7. Your Rights

Subject to conditions set forth in applicable data protection legislation, you have the following rights:

• Right to Access - You have the right to request access to any Personal Data concerning you, subject to limited exceptions that may be prescribed by applicable law.
• Right to Correct (Rectification) - Polygon Labs aims to ensure that all of your Personal Data is correct. You are entitled to have any inadequate, incomplete or incorrect Personal Data corrected (that is, rectified). 
• Right to Withdraw Consent - In the  event your Personal Data is processed on the basis of your consent, you have the right to withdraw consent at any time, without affecting the lawfulness of processing based on consent before its withdrawal.
  
  Where your Personal Data is subject to restriction we will only process it with your consent or for the establishment, exercise or defense of legal claims.

• Right to lodge a complaint - You may lodge a complaint with the supervisory authority of your jurisdiction of residence, place of work or place of alleged infringement.

8. How to Contact Us; How to Exercise Your Rights 

To obtain further information regarding your rights, to exercise any of your rights (other than to lodge a complaint), or to ask any questions regarding the processing of your Personal Data, please contact privacy@polygon.technology. To lodge a complaint, please contact the relevant Data Protection Supervisory Authority.

9. Changes to this Policy

We may update this Policy from time to time. If we make any changes, we will change the Last Updated date above. We encourage you to periodically review the Policy for the latest information on our privacy practices.

Polygon Labs Services (Delaware) Inc. (“Polygon Labs”, “we”, “our” or “us”) takes your data protection rights and our legal obligations seriously. The information that you provide to us in the course of your application for employment with us as well as other information that relates to you or other identified or identifiable individuals (“Personal Data”) will be treated in a secure and confidential manner as set out in this Privacy Policy (“Policy”).

Polygon Lab is the controller of your Personal Data, determining why Personal Data is processed, and how it is processed. In addition, where processing of Personal Data is undertaken by affiliates of Polygon Labs for their own independent purposes, these affiliates may be controllers of your Personal Data and a separate privacy policy will be provided to you.

Throughout this Policy we use the term “processing” to refer to all activities involving your Personal Data, including collecting, handling, storing, sharing, accessing, using, transferring, erasing and disposing of Personal Data.

This Policy is provided to you in compliance with data protection laws. This Policy does not constitute or form part of any contract nor is it an offer to contract or an offer of employment. This Policy does not confer any contractual right on you, or place any contractual obligation on us.

1. Personal Data

We may collect various types of Personal Data about you for the purposes described in this Policy, with your consent wherever required by applicable law:

• Data about you: full legal name, date of birth, age, home contact details (e.g., address and location, telephone number, e-mail), national ID and other governmental IDs and numbers, immigration and eligibility to work data, salary/wage expectations; to the extent permissible by applicable law, records of your past criminal convictions, sex offender registry status, fraud convictions, other sanctions; and you and your family’s outside business activities relevant to Polygon Labs.
• Data about your employment history and qualifications: education and training, employment history, LinkedIn information, qualifications, references.
• Data about your application: CV/resume and application, interview data.
• Other information: Social media information such as Twitter handle or Github profile information; or other information you voluntarily provide us through the application process. 

You may give us the Personal Data described above during the recruitment process, whether through your application, further communications, on the telephone or during interviews. 

We may also receive Personal Data about you from third parties: recruiters; references from a previous employer; business partners; sub-contractors providing recruiting or technical services; analytics providers; and background check and search information providers; as well as from publicly available sources such as social media where such Personal Data is proportionate to the position for which you are applying. We may also retain that Personal Data after you have been employed (where this is relevant and to the extent permitted by applicable law).

We may also receive information (which may include your Personal Data) from our hiring manager, from our Human Resources staff, and, from time to time, from our other employees (for instance, in the course of conducting an interview). 

2. Consent; Why We Process Your Personal Data

Where required by applicable law, we rely on your consent to use your Personal Data. When we do so, we provide you with full details of the data that we would like and the reason we need it. You can withdraw your consent at any time. You will also have the option to not provide your Personal Data when requested. Once we have received notification that you have withdrawn your consent, we will no longer process your Personal Data except to the extent permitted by law. Where required by applicable law, we will also obtain your consent to process your sensitive Personal Data, as defined under applicable law, which may include passwords; data that reveals racial or ethnic origin, political opinions, religious or philosophical beliefs or trade union membership; financial information (such as bank account details, credit or debit card details, or other payment instrument details); government identifiers; genetic data; biometric data for the purpose of uniquely identifying a natural person; or data concerning health or a natural person’s sex life or sexual orientation.

The Personal Data requested from you during the recruitment process is required by us in order to assess your application for employment with Polygon Labs. If you do not provide some or all of this Personal Data, or if you withdraw your consent to process your Personal Data, it may affect our ability to process your application and therefore to offer you employment. In some cases, it may mean that we are unable to continue with your application for employment as Polygon Labs will not have the Personal Data we believe to be necessary for the effective and efficient management of the recruitment process.

We collect the Personal Data described in Section 1 above for the purposes of managing Polygon Lab’s  recruitment related activities, namely: verification of qualifications and employment eligibility; the evaluation and selection of candidates; setting up and conducting interviews and tests; conducting evaluations, assessments and otherwise as needed in the recruitment process, including if relevant, issuing employment offers; bringing successful candidates into Polygon Labs;  dealing with queries or complaints relating to the recruitment process; for asserting or managing any kind of claims that we may bring or that may be raised against us; to comply with legal or regulatory obligations; and, where appropriate, retaining information relating to unsuccessful candidates for consideration in future relevant vacancies. 

3. With Whom Do We Share Your Personal Data?

As part of a multinational with affiliates in several countries, Polygon Labs may hire for its sites, and use resources, located outside the country where you live. Your Personal Data may be shared with affiliated companies where it is reasonable and necessary to do so, such as to ensure a consistent application of standards for candidate recruitment. Within Polygon Labs, your Personal Data can be accessed by or may be disclosed internally on a need-to-know basis to persons responsible for managing or making hiring decisions, Human Resources staff, system administrators and other support teams (such as IT and Finance).

Your Personal Data may also be accessed by third parties who provide us with services relevant to your recruitment, namely: recruiters; companies that host, support and/or maintain the IT systems supporting our recruitment system; and companies that verify your references, perform background checks solely to the extent permitted by applicable law or conduct vetting on our behalf. 

If your application for employment with Polygon Labs is successful and you accept a job offer to work with us, your Personal Data may also be shared as described in the privacy policy of your employer of record, and/or our employee privacy policy, and notably with Human Resources management, payroll and benefits systems, and the Personal Data contained in such systems may be accessible by providers of those systems, their affiliated companies and sub-contractors; tax authorities; regulatory authorities; and our lawyers, auditors, investors, consultants and other professional advisors. 

Polygon Labs may also share your Personal Data if it becomes involved in a reorganization, merger, consolidation, acquisition, or any form of sale of some or all of its assets, with any type of entity, whether public, private, foreign or local.

Polygon Labs expects all third parties to process any Personal Data disclosed to them in accordance with applicable law and contract terms, including with respect to Personal Data confidentiality and security.  Where these third parties provide us services on our behalf (for example, by verifying your references at our request), they carry out their tasks upon our instructions for the above-mentioned purposes. In this case, your Personal Data will only be disclosed to these parties to the extent necessary to provide the required services.  

4. Security of Personal Data

We implement what we determine to be reasonable physical, technical and administrative security standards designed to protect your Personal Data from loss, misuse, alteration, destruction or damage.  

5. Where We Process and Store your Personal Data

From time to time your Personal Data will be transferred outside your country for the purposes described in this Policy. For example, your Personal Data may be transferred, among other purposes, to conduct the review of your application, the processing of your information, and the provision of support services by third parties.

Depending on the scope of your interactions with us, information about you, including personal information, may be stored in or accessed from multiple countries. For example, we may share your Personal Data with colleagues within Polygon Labs; with colleagues at Polygon Labs entities in the United States; and with third parties as described in this Policy. Those third parties may be located in the United States and other countries which have been determined to provide adequate protection to Personal Data. Applicable ‎‎laws in those ‎other countries might permit foreign governments, courts, law ‎enforcement or ‎‎regulatory agencies to ‎access the information in those jurisdictions.‎ In these cases, ‎we will comply with local law requirements relating to the conditions for disclosure of personal ‎information outside of your jurisdiction.

Whenever we transfer personal information to other jurisdictions, we will ensure that the information is transferred in accordance with this Policy and as permitted by applicable data protection laws. 

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6. Retention of your Personal Data

We will retain candidate Personal Data for a period of up to one year following the closure of the recruitment process relating to the role for which you applied in the event other job opportunities arise within Polygon Labs or an affiliate. In all cases, we will retain your Personal Data for a period of time corresponding to the applicable statute of limitations for any kind of claims that we may bring or that may be raised against us, or legal or regulatory obligations.

7. Your Rights

Depending upon applicable law, and subject to any specific conditions provided under such law, you may have the following rights in respect of your Personal Data:

• Right to Access - the right to request access to any of your Personal Data that Polygon Labs may hold, and to obtain information about the processing of that data.  
• Right to Rectify -  will take steps in accordance with applicable legislation to keep your Personal Data accurate, complete and up-to-date.  You may be entitled to have any inadequate, incomplete or incorrect Personal Data corrected (that is, rectified). You also have a responsibility to ensure that changes in personal circumstances are notified to Polygon Labs so that we can ensure that your Personal Data is up-to-date.

• Right to Erasure - you may have your Personal Data erased under specific circumstances.
• Right to Restriction of Processing - you may have the right to restrict our processing of your Personal Data. 
• Right to Withdraw Consent - in the event your Personal Data is processed on the basis of your consent, the right to withdraw consent at any time, without affecting the lawfulness of processing based on consent before its withdrawal.
• Automated Decision-making: the right not to be subject to a decision based on automated processing, including profiling which has legal or similar significant affects.‍
• Data Portability - the right to receive all such Personal Data which you have provided to Polygon Labs in a structured, commonly used and machine-readable format, and also to require us to transmit it to another controller where this is technically feasible.‍
• Right to Object to Processing - the right to object to the processing of your Personal Data.

If appropriate, we may ask you for additional information to verify your identity. Each of the rights listed above may be subject to exemptions under applicable data protection laws. 

You may also have the right to file a complaint with the relevant authority.

8. How to Contact Us; How to Exercise Your Rights 

To obtain further information regarding your rights, to exercise any of your rights (other than to lodge a complaint), or to ask any questions regarding the processing of your Personal Data, please contact privacy@polygon.technology. To lodge a complaint, please contact the relevant authority.

For individuals in Australia, if you remain unsatisfied with the way in which we have handled a privacy issue, you may approach an independent advisor or contact the Office of the Australian Information Commissioner (www.oaic.gov.au) for guidance on alternative courses of action which may be available. 

9. Changes to this Policy

We may update this Policy from time to time. If we make any changes, we will change the Last Updated date above. We encourage you to periodically review the Policy for the latest information on our privacy practices.

Polygon Labs Services (Delaware) Inc. (“Polygon Labs”, “we”, “us” or “our”) takes your data protection rights and our legal obligations seriously. The information that you provide to us in the course of your application for employment with us as well as other information that relates to you or other identified or identifiable individuals (“Personal Data”) will be treated in a secure and confidential manner as set out in this Privacy Policy (“Policy”).

Polygon Lab is the controller of your Personal Data, determining why Personal Data is processed, and how it is processed. In addition, where processing of Personal Data is undertaken by affiliates of Polygon Labs for their own independent purposes, these affiliates may be controllers of your Personal Data and a separate privacy policy will be provided to you.

Throughout this Policy we use the term “processing” to refer to all activities involving your Personal Data, including collecting, handling, storing, sharing, accessing, using, transferring, erasing and disposing of Personal Data.

‍

This Policy is provided to you in compliance with data protection laws. This Policy does not constitute or form part of any contract nor is it an offer to contract or an offer of employment. This Policy does not confer any contractual right on you, or place any contractual obligation on us.

1. Personal Data

We may collect or receive various types of Personal Data about you for the purposes described in this Policy:

• Data about you: full legal name, date of birth, age, home contact details (e.g., address and location, telephone number, e-mail), national ID and other governmental IDs and numbers, immigration and eligibility to work data, , salary/wage expectations.
• Data about your employment history and qualifications: education and training, employment history, LinkedIn information, qualifications, references.
• Data about your application: CV/resume and application, interview data.
• Other information: Social media information such as Twitter handle or Github profile information; or other information you voluntarily provide us through the application process. 

You may give us the Personal Data described above during the recruitment process, whether through your application, further communications, on the telephone or during interviews. 

We may also receive Personal Data about you from third parties: recruiters; references from a previous employer; business partners; sub-contractors providing recruiting or technical services; analytics providers; and background check and search information providers; as well as from publicly available sources such as social media where such Personal Data refers to professional matters and is proportionate to the position for which you are applying. We may also retain that Personal Data after you have been employed (where this is relevant and to the extent permitted by applicable law).

1.1 We may also receive information (which may include your Personal Data) from our hiring manager, from our Human Resources staff, and, from time to time, from our other employees (for instance, in the course of conducting an interview). 

2. Why We Process Your Personal Data; Legal Bases

The Personal Data requested from you during the recruitment process is required by us in order to assess your application for employment with Polygon Labs. If you do not provide some or all of this Personal Data it may affect our ability to process your application and therefore to offer you employment. In some cases, it may mean that we are unable to continue with your application for employment as Polygon Labs will not have the Personal Data we believe to be necessary for the effective and efficient management of the recruitment process.

We may collect some of the Personal Data described in Section 1 above for the purposes of managing Polygon Lab’s recruitment-related activities, namely: verification of qualifications and employment eligibility; the evaluation and selection of candidates; setting up and conducting interviews and tests; conducting evaluations, assessments and otherwise as needed in the recruitment process, including if relevant, issuing employment offers; bringing successful candidates into Polygon Labs; dealing with queries or complaints relating to the recruitment process; for asserting or managing any kind of claims that we may bring or that may be raised against us; to comply with legal or regulatory obligations; and, where appropriate, retaining information relating to unsuccessful candidates for consideration in future relevant vacancies. 

We process your Personal Data for the purposes described above on the following legal bases:

• EEA legal obligations: the processing is necessary for compliance with an EEA legal obligation to which Polygon Labs is subject (purposes of processing relying on this legal basis: verifying eligibility for employment or complying with obligations regarding non-discrimination; complying with other legal or regulatory obligations such as law enforcement requests or other); or
• Contractual obligations / Pre-contractual steps: the processing is necessary to comply with the terms of our recruitment process, as disclosed to you prior or during the recruitment process or in order to take steps at your request prior to offering you employment (purposes of processing relying on this legal basis: communicating with you about your application); or 
• Legitimate interests: the processing is necessary for the legitimate interests pursued by Polygon Labs in hiring qualified and appropriate persons (purposes of processing relying on this legal basis: setting up and conducting interviews and tests; conducting evaluations and assessments; verifying your academic, work and other qualifications; verifying references; evaluating and selecting candidates for further consideration; to issue an employment offer; to deal with queries or complaints; asserting or managing any kind of claims that we may bring or that may be raised against us; and to consider unsuccessful candidates for future vacancies), except if in light of particular circumstances our interests are overridden by your interests or fundamental rights and freedoms that require protection of Personal Data. 

3. With Whom Do We Share Your Personal Data?

As part of a multinational with affiliates in several countries, Polygon Labs may hire for its sites, and use resources, located outside the country where you live. Your Personal Data may be shared with affiliated companies where it is reasonable and necessary to do so, such as to ensure a consistent application of standards for candidate recruitment. Within Polygon Labs, your Personal Data can be accessed by or may be disclosed internally on a need-to-know basis to persons responsible for managing or making hiring decisions, Human Resources staff, system administrators and other support teams (such as IT and Finance).

Your Personal Data may also be accessed by third parties who provide us with services relevant to your recruitment, namely: recruiters; companies that host, support and/or maintain the IT systems supporting our recruitment system; and companies that verify your references, perform background checks solely to the extent permitted by applicable law or conduct vetting on our behalf.

If your application for employment with Polygon Labs is successful and you accept a job offer to work with us, your Personal Data may also be shared as described in the privacy policy of your employer of record, and/or our employee privacy policy, and notably with Human Resources management, payroll and benefits systems, and the Personal Data contained in such systems may be accessible by providers of those systems, their affiliated companies and sub-contractors; tax authorities; regulatory authorities; and our lawyers, auditors, investors, consultants and other professional advisors. 

Polygon Labs may also share your Personal Data if it becomes involved in a reorganization, merger, consolidation, acquisition, or any form of sale of some or all of its assets, with any type of entity, whether public, private, foreign or local.

Polygon Labs expects all third parties to process any Personal Data disclosed to them in accordance with applicable law and contract terms, including with respect to Personal Data confidentiality and security.  Where these third parties act as a “processor” (for example, by verifying your references at our request), they carry out their tasks on our behalf and upon our instructions for the above-mentioned purposes.  In this case, your Personal Data will only be disclosed to these parties to the extent necessary to provide the required services.  

4. Security of Personal Data

‍We implement what we determine to be reasonable physical, technical and administrative security standards designed to protect your Personal Data from loss, misuse, alteration, destruction or damage.  ‍
‍

5. Where We Process and Store your Personal Data

From time to time your Personal Data will be transferred outside your country for the purposes described in this Policy. For example, your Personal Data may be transferred, among other purposes, to conduct the review of your application, the processing of your information, and the provision of support services by third parties.

Depending on the scope of your interactions with us, information about you, including personal information, may be stored in or accessed from multiple countries. For example, we may share your Personal Data with colleagues within Polygon Labs; with colleagues at Polygon Labs entities in the United States, a country which has not received a decision of the European Commission confirming that it provides adequate protection to Personal Data; and with third parties as described in this Policy. Those third parties may be located in the United States and other countries which have been determined to provide adequate protection to Personal Data.

Whenever we transfer personal information to other jurisdictions, we will ensure that the information is transferred in accordance with this Policy and as permitted by applicable data protection laws. Where applicable, you are entitled, upon request sent to privacy@polygon.technology, to receive a copy of the relevant contract (Standard Contractual Clauses or Binding Corporate Rules) showing that appropriate safeguards have been taken to protect your Personal Data in connection with such transfer.  

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6. Retention of your Personal Data

We will retain candidate Personal Data for a period of up to one year following the closure of the recruitment process relating to the role for which you applied in the event other job opportunities arise within Polygon Labs or an affiliate. In all cases, we will retain your Personal Data for a period of time corresponding to the applicable statute of limitations for any kind of claims that we may bring or that may be raised against us, or legal or regulatory obligations.
‍

7. Your Rights

Subject to conditions set forth in applicable data protection legislation, you have the following rights:

• Right to Access - You have the right to request access to any Personal Data concerning you, subject to limited exceptions that may be prescribed by applicable law.
• Right to Correct (Rectification) - Polygon Labs aims to ensure that all of your Personal Data is correct. You are entitled to have any inadequate, incomplete or incorrect Personal Data corrected (that is, rectified). 
• Right to Withdraw Consent - In the event your Personal Data is processed on the basis of your consent, you have the right to withdraw consent at any time, without affecting the lawfulness of processing based on consent before its withdrawal. We generally do not rely on consent for processing candidates’ Personal Data. 
• Right to Data Portability - If we rely upon your consent as the legal basis for processing, or where processing is necessary to perform a contract to which you are party or to take steps at your request prior to entering a contract, and the Personal Data is processed by automated means, you have the right to receive all such Personal Data which you have provided to us in a structured, commonly used and machine-readable format, and also to require us to transmit it to another controller where this is technically feasible.
• Right to Erasure - You are entitled to have your Personal Data erased under specific circumstances, such as where you have withdrawn your consent, where you object to processing based on legitimate interests and we have no overriding legitimate grounds or where Personal Data is unlawfully processed.‍
• Right to Restriction of Processing - You have the right to restrict our processing of your Personal Data (that is, allow only its storage) where: 
  - you contest the accuracy of the Personal Data, until we have taken sufficient steps to correct or verify its accuracy; 
  - where the processing is unlawful but you do not want us to erase the Personal Data;
  - where we no longer need your Personal Data for the purposes of the processing, but you require such Personal Data for the establishment, exercise or defense of legal claims; or 
  - where you have objected to processing justified on legitimate interest grounds (see below), pending verification as to whether we have compelling legitimate grounds to continue processing.
  - where your Personal Data is subject to restriction we will only process it with your consent or for the establishment, exercise or defense of legal claims.

Right to Object to processing justified on legitimate interest grounds - Where we are relying upon legitimate interest to process Personal Data, you have the right to object to that processing based on grounds related to your particular situation. If you object, we must stop that processing unless we can demonstrate compelling legitimate grounds for the processing that override your interests, rights and freedoms, or we need to process the Personal Data for the establishment, exercise or defense of legal claims. Where we rely upon legitimate interest as a basis for processing, we believe that we can demonstrate such compelling legitimate grounds, but we will consider each case on an individual basis.

• Right to lodge a complaint - You may lodge a complaint with the supervisory authority of your country of residence, place of work or place of alleged infringement.

8. How to Contact Us; How to Exercise Your Rights 

To obtain further information regarding your rights, to exercise any of your rights (other than to lodge a complaint), or to ask any questions regarding the processing of your Personal Data, please contact privacy@polygon.technology. To lodge a complaint, please contact the relevant Data Protection Supervisory Authority.

9. Changes to this Policy

We may update this Policy from time to time. If we make any changes, we will change the Last Updated date above. We encourage you to periodically review the Policy for the latest information on our privacy practices.

Uniclau S.L. and its affiliate Polygon Labs Services (Delaware) Inc. take your data protection rights and our legal obligations seriously. The information that you provide to us in the course of your application for employment with us as well as other information that relates to you or other identified or identifiable individuals (“Personal Data”) will be treated in a secure and confidential manner as set out in this Privacy Policy (“Policy”).

Uniclau S.L. and its affiliate Polygon Lab Services (Delaware) Inc. (together, “Polygon Labs”, “we”, “us” or “our”) are the joint controllers of your Personal Data. This means that both entities will determine together how and why your Personal Data is processed, principally because our local entity does not have its own human resources department and therefore is working with its affiliate for certain processing activities. These entities have entered into a joint controller agreement by which they both are responsible for informing you about the processing of your Personal Data in this Policy. You may exercise your rights as a data subject with either entity as set forth below. In addition, where processing of Personal Data is undertaken by other affiliates of Polygon Labs for their own independent purposes, these affiliates may be controllers or joint controllers of your Personal Data and a separate privacy policy will be provided to you.

Throughout this Policy we use the term “processing” to refer to all activities involving your Personal Data, including collecting, handling, storing, sharing, accessing, using, transferring, erasing and disposing of Personal Data.

This Policy is provided to you in compliance with data protection laws. This Policy does not constitute or form part of any contract nor is it an offer to contract or an offer of employment.  This Policy does not confer any contractual right on you, or place any contractual obligation on us.

1. Personal Data

We may collect various types of Personal Data about you for the purposes described in this Policy:

• Data about you: full legal name, date of birth, age, home contact details (e.g., address and location, telephone number, e-mail), national ID and other governmental IDs and numbers, eligibility to work data, salary/wage expectations.
• Data about your employment history and qualifications: education and training, employment history, LinkedIn information, qualifications, references.
• Data about your application: CV/resume and application, interview data.
• Other information: Social media information such as Twitter handle or Github profile information; or other information you voluntarily provide us through the application process.

You may give us the Personal Data described above during the recruitment process, whether through your application, further communications, on the telephone or during interviews.

We may also receive Personal Data about you from third parties: recruiters; references from a previous employer; business partners; sub-contractors providing recruiting or technical services; analytics providers; and background check and search information providers; as well as from publicly available sources such as social media where such Personal Data refers to professional matters and is proportionate to the position for which you are applying. We may also retain that Personal Data after you have been employed (where this is relevant and to the extent permitted by applicable law).

• We may also receive information (which may include your Personal Data) from our hiring manager, from our Human Resources staff, and, from time to time, from our other employees (for instance, in the course of conducting an interview).

2. Why We Process Your Personal Data; Legal Bases

The Personal Data requested from you during the recruitment process is required by us in order to assess your application for employment with Polygon Labs. If you do not provide some or all of this Personal Data it may affect our ability to process your application and therefore to offer you employment. In some cases, it may mean that we are unable to continue with your application for employment as Polygon Labs will not have the Personal Data we believe to be necessary for the effective and efficient management of the recruitment process.

We collect the Personal Data described in Section 1 above for the purposes of managing Polygon Lab’s  recruitment related activities, namely: verification of qualifications and employment eligibility; the evaluation and selection of candidates; setting up and conducting interviews and tests; and conducting evaluations, assessments and otherwise as needed in the recruitment process, including if relevant, issuing employment offers; bringing successful candidates into Polygon Labs;  dealing with queries or complaints relating to the recruitment process; for asserting or managing any kind of claims that we may bring or that may be raised against us; to comply with legal or regulatory obligations; and, where appropriate, retaining information relating to unsuccessful candidates for consideration in future relevant vacancies.

We process your Personal Data for the purposes described above on the following legal bases:

• EEA legal obligations: the processing is necessary for compliance with an EEA legal obligation to which Polygon Labs is subject (purposes of processing relying on this legal basis: verifying eligibility for employment or complying with obligations regarding non-discrimination; complying with other legal or regulatory obligations such as law enforcement requests or other); or
• Contractual obligations / Pre-contractual steps: the processing is necessary to comply with the terms of our recruitment process, as disclosed to you prior or during the recruitment process or in order to take steps at your request prior to offering you employment (purposes of processing relying on this legal basis: communicating with you about your application); or
• Legitimate interests: the processing is necessary for the legitimate interests pursued by Polygon Labs in hiring qualified and appropriate persons (purposes of processing relying on this legal basis: setting up and conducting interviews and tests; conducting evaluations and assessments; verifying your academic, work and other qualifications; verifying references; evaluating and selecting candidates for further consideration; to issue an employment offer; to deal with queries or complaints; asserting or managing any kind of claims that we may bring or that may be raised against us; and to consider unsuccessful candidates for future vacancies), except if in light of particular circumstances our interests are overridden by your interests or fundamental rights and freedoms that require protection of Personal Data; or
• Consent: processing is based on your prior explicit consent.

3. With Whom Do We Share Your Personal Data?

As part of a multinational with affiliates in several countries, Polygon Labs may hire for its sites, and use resources, located outside the country where you live. Your Personal Data may be shared with affiliated companies where it is reasonable and necessary to do so, such as to ensure a consistent application of standards for candidate recruitment. Within Polygon Labs, your Personal Data can be accessed by or may be disclosed internally on a need-to-know basis to persons responsible for managing or making hiring decisions, Human Resources staff, system administrators and other support teams (such as IT and Finance).

Your Personal Data may also be accessed by third parties who provide us with services relevant to your recruitment, namely: recruiters; companies that host, support and/or maintain the IT systems supporting our recruitment system; and companies that verify your references, perform background checks solely to the extent permitted by applicable law or conduct vetting on our behalf.

If your application for employment with Polygon Labs is successful and you accept a job offer from us, your Personal Data may also be shared as described in our employee privacy policy, and notably with Human Resources management, payroll and benefits systems, and the Personal Data contained in such systems may be accessible by providers of those systems, their affiliated companies and sub-contractors; tax authorities; regulatory authorities; and our lawyers, auditors, investors, consultants and other professional advisors.

Polygon Labs may also share your Personal Data if it becomes involved in a reorganization, merger, consolidation, acquisition, or any form of sale of some or all of its assets, with any type of entity, whether public, private, foreign or local.

Polygon Labs expects all third parties to process any Personal Data disclosed to them in accordance with applicable law and contract terms, including with respect to Personal Data confidentiality and security.  Where these third parties act as a “processor” (for example, by verifying your references at our request), they carry out their tasks on our behalf and upon our instructions for the above-mentioned purposes.  In this case, your Personal Data will only be disclosed to these parties to the extent necessary to provide the required services.  

4. Security of Personal Data

• We implement what we determine to be reasonable physical, technical and administrative security standards designed to protect your Personal Data from loss, misuse, alteration, destruction or damage.  

5. Where We Process and Store your Personal Data

From time to time your Personal Data will be transferred outside your country for the purposes described in this Policy. For example, your Personal Data may be transferred, among other purposes, to conduct the review of your application, the processing of your information, and the provision of support services by third parties.

Depending on the scope of your interactions with us, information about you, including personal information, may be stored in or accessed from multiple countries. For example, we may share your Personal Data with colleagues within Polygon Labs; with colleagues at Polygon Labs entities in the United States, a country which has not received a decision of the European Commission confirming that it provides adequate protection to Personal Data; and with third parties as described in this Policy. Those third parties may be located in the United States and other countries which have been determined to provide adequate protection to Personal Data.

Whenever we transfer personal information to other jurisdictions, we will ensure that the information is transferred in accordance with this Policy and as permitted by applicable data protection laws. Where applicable, you are entitled, upon request sent to privacy@polygon.technology.com, to receive a copy of the relevant contract (Standard Contractual Clauses or Binding Corporate Rules) showing that appropriate safeguards have been taken to protect your Personal Data in connection with such transfer.

6. Retention of your Personal Data

• We will retain candidate Personal Data for a period of up to one year following the beginning of the recruitment process relating to the role for which you applied within Polygon Labs or an affiliate. In all cases, we will retain your Personal Data for a period of time corresponding to the applicable statute of limitations for any kind of claims that we may bring or that may be raised against us, or legal or regulatory obligations.

7. Your Rights

Subject to conditions set forth in applicable data protection legislation, you have the following rights:

• Right to Access - You have the right to request access to any Personal Data concerning you, subject to limited exceptions that may be prescribed by applicable law.
• Right to Correct (Rectification) - Polygon Labs aims to ensure that all of your Personal Data is correct. You are entitled to have any inadequate, incomplete or incorrect Personal Data corrected (that is, rectified).
• Right to Withdraw Consent - In the event your Personal Data is processed on the basis of your consent, you have the right to withdraw consent at any time, without affecting the lawfulness of processing based on consent before its withdrawal.
• Right to Data Portability - If we rely upon your consent as the legal basis for processing, or where processing is necessary to perform a contract to which you are party or to take steps at your request prior to entering a contract, and the Personal Data is processed by automated means, you have the right to receive all such Personal Data which you have provided to us in a structured, commonly used and machine-readable format, and also to require us to transmit it to another controller where this is technically feasible.
• Right to Erasure - You are entitled to have your Personal Data erased under specific circumstances, such as where you have withdrawn your consent, where you object to processing based on legitimate interests and we have no overriding legitimate grounds or where Personal Data is unlawfully processed.
• Right to Restriction of Processing - You have the right to restrict our processing of your Personal Data (that is, allow only its storage) where:

• you contest the accuracy of the Personal Data, until we have taken sufficient steps to correct or verify its accuracy;
• where the processing is unlawful but you do not want us to erase the Personal Data;
• where we no longer need your Personal Data for the purposes of the processing, but you require such Personal Data for the establishment, exercise or defense of legal claims; or
• where you have objected to processing justified on legitimate interest grounds (see below), pending verification as to whether we have compelling legitimate grounds to continue processing.

Where your Personal Data is subject to restriction we will only process it with your consent or for the establishment, exercise or defense of legal claims.

Right to Object to processing justified on legitimate interest grounds - Where we are relying upon legitimate interest to process Personal Data, you have the right to object to that processing based on grounds related to your particular situation. If you object, we must stop that processing unless we can demonstrate compelling legitimate grounds for the processing that override your interests, rights and freedoms, or we need to process the Personal Data for the establishment, exercise or defense of legal claims. Where we rely upon legitimate interest as a basis for processing, we believe that we can demonstrate such compelling legitimate grounds, but we will consider each case on an individual basis.

• Right to lodge a complaint - You may lodge a complaint with the supervisory authority of your country of residence, place of work or place of alleged infringement (in the case of Spain, check www.aepd.es).

8. How to Contact Us; How to Exercise Your Rights

To obtain further information regarding your rights, to exercise any of your rights (other than to lodge a complaint), or to ask any questions regarding the processing of your Personal Data, please contact privacy@polygon.technology.com. To lodge a complaint, please contact the relevant Data Protection Supervisory Authority.

9. Changes to this Policy

We may update this Policy from time to time. If we make any changes, we will change the Last Updated date above. We encourage you to periodically review the Policy for the latest information on our privacy practices

Polygon Labs Services (Switzerland) AG and its affiliates Catenable AG and Polygon Lab Services (Delaware) Inc. take your data protection rights and our legal obligations seriously. The information that you provide to us in the course of your application for employment with us as well as other information that relates to you or other identified or identifiable individuals (“Personal Data”) will be treated in a secure and confidential manner as set out in this Privacy Policy (“Policy”).

Polygon Labs Services (Switzerland) AG and its affiliates Catenable AG and Polygon Lab Services (Delaware) Inc. (together “Polygon Labs”, “we”, “us” or “our”) are the joint controllers of your Personal Data. This means that all three entities will determine together how and why your Personal Data is processed, principally because our local entity does not have its own human resources department and therefore is working with its affiliate for certain processing activities. These entities have entered into a joint controller agreement by which they both are responsible for informing you about the processing of your Personal Data in this Policy. You may exercise your rights as a data subject with either entity as set forth below. In addition, where processing of Personal Data is undertaken by other affiliates of Polygon Labs for their own independent purposes, these affiliates may be controllers or joint controllers of your Personal Data.

In any case, if you have questions regarding this Policy or the processing of your Personal Data, please contact us via: privacy@polygon.technology. Throughout this Policy we use the term “processing” to refer to all activities involving your Personal Data, including collecting, handling, storing, sharing, accessing, using, transferring, erasing and disposing of Personal Data.

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This Policy is provided to you in compliance with data protection laws. This Policy does not constitute or form part of any contract nor is it an offer to contract or an offer of employment.  This Policy does not confer any contractual right on you, or place any contractual obligation on us.‍

1. Personal Data

We may collect various types of Personal Data about you for the purposes described in this Policy:

• Data about you: full legal name, date of birth, age, home contact details (e.g., address and location, telephone number, e-mail), national ID and other governmental IDs and numbers, immigration and eligibility to work data, to the extent permissible by applicable law, records of your past criminal convictions, sex offender registry status, fraud convictions, other sanctions; and your outside business activities relevant to Polygon Labs.
• Data about your employment history and qualifications: education and training, employment history, LinkedIn information, qualifications, references.
• Data about your application: CV/resume and application, interview data.
• Other information: Social media information such as Twitter handle or Github profile information; or other information you voluntarily provide us through the application process.

You may give us the Personal Data described above during the recruitment process, whether through your application, further communications, on the telephone or during interviews. 

We may also receive Personal Data about you from third parties: recruiters; references from a previous employer; business partners; sub-contractors providing recruiting or technical services; analytics providers; and background check and search information providers; as well as from publicly available sources such as social media where such Personal Data is proportionate to the position for which you are applying. We may also retain that Personal Data after you have been employed (where this is relevant and to the extent permitted by applicable law).

We may also receive information (which may include your Personal Data) from our hiring manager, from our Human Resources staff, and, from time to time, from our other employees (for instance, in the course of conducting an interview). 

2. Why We Process Your Personal Data; Legal Bases

The Personal Data requested from you during the recruitment process is required by us in order to assess your application for employment with Polygon Labs. If you do not provide some or all of this Personal Data it may affect our ability to process your application and therefore to offer you employment. In some cases, it may mean that we are unable to continue with your application for employment as Polygon Labs will not have the Personal Data we believe to be necessary for the effective and efficient management of the recruitment process.

We collect the Personal Data described in Section 1 above for the purposes of managing Polygon Lab’s  recruitment related activities, namely: verification of qualifications and employment eligibility; the evaluation and selection of candidates; setting up and conducting interviews and tests; and conducting evaluations, assessments and otherwise as needed in the recruitment process, including if relevant, issuing employment offers; bringing successful candidates into Polygon Labs;  dealing with queries or complaints relating to the recruitment process; for asserting or managing any kind of claims that we may bring or that may be raised against us; to comply with legal or regulatory obligations; and, where appropriate, retaining information relating to unsuccessful candidates for consideration in future relevant vacancies. 

We process your Personal Data for the purposes described above on the following legal bases to the extent such legal basis is necessary for our processing of your Personal Data:

• Legal obligations: the processing is necessary for compliance with an EEA or Swiss legal obligation to which Polygon Labs is subject (purposes of processing: verifying eligibility for employment or complying with obligations regarding non-discrimination; complying with other legal or regulatory obligations such as law enforcement requests or other); or
• Contractual obligations / Pre-contractual steps: the processing is necessary to comply with the terms of our recruitment process, as disclosed to you prior or during the recruitment process or in order to take steps at your request prior to offering you employment (purposes of processing: communicating with you about your application); or 
• Legitimate interests: the processing is necessary for the legitimate interests pursued by Polygon Labs in hiring qualified and appropriate persons (purposes of processing: setting up and conducting interviews and tests; conducting evaluations and assessments; verifying your academic, work and other qualifications; verifying references; evaluating and selecting candidates for further consideration; to issue an employment offer; to deal with queries or complaints; asserting or managing any kind of claims that we may bring or that may be raised against us; and to consider unsuccessful candidates for future vacancies), except if in light of particular circumstances our interests are overridden by your interests or fundamental rights and freedoms that require protection of Personal Data.

3. With Whom Do We Share Your Personal Data?

As part of a multinational with affiliates in several countries, Polygon Labs may hire for its sites, and use resources, located outside the country where you live. Your Personal Data may be shared with affiliated companies where it is reasonable and necessary to do so, such as to ensure a consistent application of standards for candidate recruitment. Within Polygon Labs, your Personal Data can be accessed by or may be disclosed internally on a need-to-know basis to persons responsible for managing or making hiring decisions, Human Resources staff, system administrators and other support teams (such as IT and Finance).

Your Personal Data may also be accessed by third parties who provide us with services relevant to your recruitment, namely: recruiters; companies that host, support and/or maintain the IT systems supporting our recruitment system; and companies that verify your references, perform background checks solely to the extent permitted by applicable law or conduct vetting on our behalf.  

If your application for employment with Polygon Labs is successful and you accept a job offer from us, your Personal Data may also be shared as described in our employee privacy policy, and notably with Human Resources management, payroll and benefits systems, and the Personal Data contained in such systems may be accessible by providers of those systems, their affiliated companies and sub-contractors; tax authorities; regulatory authorities; and our lawyers, auditors, investors, consultants and other professional advisors. 

Polygon Labs may also share your Personal Data if it becomes involved in a reorganization, merger, consolidation, acquisition, or any form of sale of some or all of its assets, with any type of entity, whether public, private, foreign or local.

Polygon Labs expects all third parties to process any Personal Data disclosed to them in accordance with applicable law and contract terms, including with respect to Personal Data confidentiality and security. Where these third parties act as a “processor” (for example, by verifying your references at our request), they carry out their tasks on our behalf and upon our instructions for the above-mentioned purposes. In this case, your Personal Data will only be disclosed to these parties to the extent necessary to provide the required services.  

4. Security of Personal Data

We implement what we determine to be reasonable physical, technical and administrative security standards designed to protect your Personal Data from loss, misuse, alteration, destruction or damage.  

5. Where We Process and Store your Personal Data

From time to time your Personal Data will be transferred outside your country for the purposes described in this Policy. For example, your Personal Data may be transferred, among other purposes, to conduct the review of your application, the processing of your information, and the provision of support services by third parties.

Depending on the scope of your interactions with us, information about you, including personal information, may be stored in or accessed from multiple countries. For example, we may share your Personal Data with colleagues within Polygon Labs; with colleagues at Polygon Labs entities in the United States, a country which has not received a decision of the European Commission or the competent Swiss authorities confirming that it provides adequate protection to Personal Data; and with third parties as described in this Policy. Those third parties may be located in the United States and other countries which have been determined to provide adequate protection to Personal Data.

Whenever we transfer personal information to other jurisdictions, we will ensure that the information is transferred in accordance with this Policy and as permitted by applicable data protection laws by implementing appropriate safeguards, in particular Standard Contractual Clauses approved by the Federal Data Protection and Information Commissioner. Where applicable, you are entitled, upon request sent to privacy@polygon.technology, to receive a copy of the relevant contract (Standard Contractual Clauses or Binding Corporate Rules) showing that appropriate safeguards have been taken to protect your Personal Data in connection with such transfer.  

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6. Retention of your Personal Data

We will delete candidate Personal Data upon notification of rejection unless you explicitly agree to continued storage for a period of up to one year following the closure of the recruitment process relating to the role for which you applied in the event other job opportunities arise within Polygon Labs or an affiliate. In all cases, we will retain your Personal Data for a period of time corresponding to the applicable statute of limitations for any kind of claims that we may bring or that may be raised against us, or legal or regulatory obligations.

7. Your Rights

Subject to conditions set forth in applicable data protection legislation, you have the following rights:

• to request access to your Personal Data;
• to request rectification of inaccurate or incomplete Personal Data;
• to request erasure of your Personal Data;
• to restrict the processing of your Personal Data;
• to object to our use of your Personal Data;
• where relevant, to request the portability of your Personal Data;
• where you have given consent to the processing of your Personal Data, to withdraw your consent; and
• to lodge a complaint with the competent supervisory authority, in particular of your habitual residence, place of work or place of alleged infringement, if you consider that the processing of your Personal Data infringes applicable law.

8. How to Contact Us; How to Exercise Your Rights 

To obtain further information regarding your rights, to exercise any of your rights (other than to lodge a complaint), or to ask any questions regarding the processing of your Personal Data, please contact privacy@polygon.technology. To lodge a complaint, please contact the relevant Data Protection Supervisory Authority.

9. Changes to this Policy

We may update this Policy from time to time. If we make any changes, we will change the Last Updated date above. We encourage you to periodically review the Policy for the latest information on our privacy practices.

Polygon Labs Services (UK) Ltd. and its affiliate Polygon Labs Services (Delaware) Inc. take your data protection rights and our legal obligations seriously. The information that you provide to us in the course of your application for employment with us as well as other information that relates to you or other identified or identifiable individuals (“Personal Data”) will be treated in a secure and confidential manner as set out in this Privacy Policy (“Policy”).

Polygon Labs Services (UK) Ltd. and its affiliate Polygon Labs Services (Delaware) Inc. (together, “Polygon Labs”, “we”, “us” or “our”) are the joint controllers of your Personal Data. This means that both entities will determine together how and why your Personal Data is processed, principally because our local entity does not have its own human resources department and therefore is working with its affiliate for certain processing activities. The entities have entered into a joint controller agreement by which they both are responsible for informing you about the processing of your Personal Data in this Policy. You may exercise your rights as a data subject with either entity as set forth below. In addition, where processing of Personal Data is undertaken by other affiliates of Polygon Labs for their own purposes, these affiliates may be independent controllers, or joint controllers with us, in relation to your Personal Data and a separate privacy policy will be provided to you.

Throughout this Policy we use the term “processing” to refer to all activities involving your Personal Data, including collecting, handling, storing, sharing, accessing, using, transferring, erasing and disposing of Personal Data.

This Policy is provided to you in compliance with data protection laws. This Policy does not constitute or form part of any contract nor is it an offer to contract or an offer of employment.  This Policy does not confer any contractual right on you, or place any contractual obligation on us.

1. Personal Data

We may collect various types of Personal Data about you for the purposes described in this Policy:

• Data about you: full legal name, date of birth, age, home contact details (e.g., address and location, telephone number, e-mail), national ID and other governmental IDs and numbers, immigration and eligibility to work data; to the extent permissible by applicable law, records of your past criminal convictions, sex offender registry status, fraud convictions, other sanctions; and you and your family’s outside business activities relevant to Polygon Labs.
• Data about your employment history and qualifications: education and training, employment history, LinkedIn information, qualifications, references.
• Data about your application: CV/resume and application, interview data.
• Other information: Social media information such as Twitter handle or Github profile information; or other information you voluntarily provide us through the application process.

You may give us the Personal Data described above during the recruitment process, whether through your application, further communications, on the telephone or during interviews. 

We may also receive Personal Data about you from third parties: recruiters; references from a previous employer; business partners; sub-contractors providing recruiting or technical services; analytics providers; and background check and search information providers; as well as from publicly available sources such as social media where such Personal Data is proportionate to the position for which you are applying. We may also retain that Personal Data after you have been employed (where this is relevant and to the extent permitted by applicable law).

We may also receive information (which may include your Personal Data) from our hiring manager, from our Human Resources staff, and, from time to time, from our other employees (for instance, in the course of conducting an interview). 

2. Why We Process Your Personal Data; Legal Bases

The Personal Data requested from you during the recruitment process is required by us in order to assess your application for employment with Polygon Labs. If you do not provide some or all of this Personal Data it may affect our ability to process your application and therefore to offer you employment. In some cases, it may mean that we are unable to continue with your application for employment as Polygon Labs will not have the Personal Data we believe to be necessary for the effective and efficient management of the recruitment process.

We collect the Personal Data described in Section 1 above for the purposes of managing Polygon Lab’s  recruitment related activities, namely: verification of qualifications and employment eligibility; the evaluation and selection of candidates; setting up and conducting interviews and tests; and conducting evaluations, assessments and otherwise as needed in the recruitment process, including if relevant, issuing employment offers; bringing successful candidates into Polygon Labs;  dealing with queries or complaints relating to the recruitment process; for asserting or managing any kind of claims that we may bring or that may be raised against us; to comply with legal or regulatory obligations; and, where appropriate, retaining information relating to unsuccessful candidates for consideration in future relevant vacancies. 

We process your Personal Data for the purposes described above on the following legal bases:

• Legal obligations: the processing is necessary for compliance with an UK legal obligation to which Polygon Labs is subject (purposes of processing: verifying eligibility for employment or complying with obligations regarding non-discrimination; complying with other legal or regulatory obligations such as law enforcement requests or other); or
• Contractual obligations / Pre-contractual steps: the processing is necessary to comply with the terms of our recruitment process, as disclosed to you prior or during the recruitment process or in order to take steps at your request prior to offering you employment (purposes of processing: communicating with you about your application); or 
• Legitimate interests: the processing is necessary for the legitimate interests pursued by Polygon Labs in hiring qualified and appropriate persons (purposes of processing: setting up and conducting interviews and tests; conducting evaluations and assessments; verifying your academic, work and other qualifications; verifying references; evaluating and selecting candidates for further consideration; to issue an employment offer; to deal with queries or complaints; asserting or managing any kind of claims that we may bring or that may be raised against us; and to consider unsuccessful candidates for future vacancies), except if in light of particular circumstances our interests are overridden by your interests or fundamental rights and freedoms that require protection of Personal Data; or

3. With Whom Do We Share Your Personal Data?

As part of a multinational with affiliates in several countries, Polygon Labs may hire for its sites, and use resources, located outside the country where you live. Your Personal Data may be shared with affiliated companies where it is reasonable and necessary to do so, such as to ensure a consistent application of standards for candidate recruitment. Within Polygon Labs, your Personal Data can be accessed by or may be disclosed internally on a need-to-know basis to persons responsible for managing or making hiring decisions, Human Resources staff, system administrators and other support teams (such as IT and Finance).

Your Personal Data may also be accessed by third parties who provide us with services relevant to your recruitment, namely: recruiters; companies that host, support and/or maintain the IT systems supporting our recruitment system; and companies that verify your references, undertake background checks solely to the extent permitted by applicable law or conduct vetting on our behalf. 

If your application for employment with Polygon Labs is successful and you accept a job offer from us, your Personal Data may also be shared as described in our employee privacy policy, and notably with Human Resources management, payroll and benefits systems, and the Personal Data contained in such systems may be accessible by providers of those systems, their affiliated companies and sub-contractors; tax authorities; regulatory authorities; and our lawyers, auditors, investors, consultants and other professional advisors. 

Polygon Labs may also share your Personal Data if it becomes involved in a reorganization, merger, consolidation, acquisition, or any form of sale of some or all of its assets, with any type of entity, whether public, private, foreign or local.

Polygon Labs expects all third parties to process any Personal Data disclosed to them in accordance with applicable law and contract terms, including with respect to Personal Data confidentiality and security.  Where these third parties act as a “processor” (for example, by verifying your references at our request), they carry out their tasks on our behalf and upon our instructions for the above-mentioned purposes.  In this case, your Personal Data will only be disclosed to these parties to the extent necessary to provide the required services.  

4. Security of Personal Data‍

We implement what we determine to be reasonable physical, technical and administrative security standards designed to protect your Personal Data from loss, misuse, alteration, destruction or damage.  

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5. Where We Process and Store your Personal Data

From time to time your Personal Data will be transferred outside your country for the purposes described in this Policy. For example, your Personal Data may be transferred, among other purposes, to conduct the review of your application, the processing of your information, and the provision of support services by third parties.

Depending on the scope of your interactions with us, information about you, including personal information, may be stored in or accessed from multiple countries. For example, we may share your Personal Data with colleagues within Polygon Labs; with colleagues at Polygon Labs entities in the United States, a country which has not received a decision of the UK confirming that it provides adequate protection to Personal Data; and with third parties as described in this Policy. Those third parties may be located in the United States and other countries which have been determined to provide adequate protection to Personal Data.

Whenever we transfer personal information to other jurisdictions, we will ensure that the information is transferred in accordance with this Policy and as permitted by applicable data protection laws. Where applicable, you are entitled, upon request sent to privacy@polygon.technology, to receive a copy of the relevant contract (e.g. the UK’s International Data Transfer Agreement or Addendum, as applicable) showing that appropriate safeguards have been taken to protect your Personal Data in connection with such transfer.  

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6. Retention of your Personal Data

We will retain candidate Personal Data for a period of up to one year following the closure of the recruitment process relating to the role for which you applied in the event other job opportunities arise within Polygon Labs or an affiliate. In all cases, we will retain your Personal Data for a period of time corresponding to the applicable statute of limitations for any kind of claims that we may bring or that may be raised against us, or legal or regulatory obligations.

7. Your Rights

Subject to conditions set forth in applicable data protection legislation, you have the following rights:

• Right to Access - You have the right to request access to any Personal Data concerning you, subject to limited exceptions that may be prescribed by applicable law.
• Right to Correct (Rectification) - Polygon Labs aims to ensure that all of your Personal Data is correct. You are entitled to have any inadequate, incomplete or incorrect Personal Data corrected (that is, rectified). 
• Right to Withdraw Consent - In the event your Personal Data is processed on the basis of your consent, you have the right to withdraw consent at any time, without affecting the lawfulness of processing based on consent before its withdrawal.
• Right to Data Portability - If we rely upon your consent as the legal basis for processing, or where processing is necessary to perform a contract to which you are party or to take steps at your request prior to entering a contract, and the Personal Data is processed by automated means, you have the right to receive all such Personal Data which you have provided to us in a structured, commonly used and machine-readable format, and also to require us to transmit it to another controller where this is technically feasible.
• Right to Erasure - You are entitled to have your Personal Data erased under specific circumstances, such as where you have withdrawn your consent, where you object to processing based on legitimate interests and we have no overriding legitimate grounds or where Personal Data is unlawfully processed.

• Right to Restriction of Processing - You have the right to restrict our processing of your Personal Data (that is, allow only its storage) where: 
  - you contest the accuracy of the Personal Data, until we have taken sufficient steps to correct or verify its accuracy; 
  - where the processing is unlawful but you do not want us to erase the Personal Data;
  - where we no longer need your Personal Data for the purposes of the processing, but you require such Personal Data for the establishment, exercise or defense of legal claims; or 
  - where you have objected to processing justified on legitimate interest grounds (see below), pending verification as to whether we have compelling legitimate grounds to continue processing.
  - Where your Personal Data is subject to restriction we will only process it with your consent or for the establishment, exercise or defense of legal claims.

Right to Object to processing justified on legitimate interest grounds - Where we are relying upon legitimate interest to process Personal Data, you have the right to object to that processing based on grounds related to your particular situation. If you object, we must stop that processing unless we can demonstrate compelling legitimate grounds for the processing that override your interests, rights and freedoms, or we need to process the Personal Data for the establishment, exercise or defense of legal claims. Where we rely upon legitimate interest as a basis for processing, we believe that we can demonstrate such compelling legitimate grounds, but we will consider each case on an individual basis.

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• Right to lodge a complaint - You may lodge a complaint with the Information Commissioner’s Office. You can find further information by visiting www.ico.org.uk or by calling the ICO on 0303 123 1113. If you would like to write, the ICO’s address is: Information Commissioner’s Office, Wycliffe House, Water Lane, Wilmslow, Cheshire, SK9 5AF.

8. How to Contact Us; How to Exercise Your Rights 

To obtain further information regarding your rights, to exercise any of your rights (other than to lodge a complaint with the Information Commissioner’s Office), or to ask any questions regarding the processing of your Personal Data, please contact privacy@polygon.technology. 

9. Changes to this Policy

Any changes or updates we may make to this Policy will be posted on this page. Please check back frequently to see any updates or changes to this Policy as they are applicable as of the date of posting the revised terms.

PT Services DMCC and its affiliates D.N. Researchers FZE LLC and Polygon Labs Services (Delaware) Inc. take your data protection rights and our legal obligations seriously. The information that you provide to us in the course of your application for employment with us as well as other information that relates to you or other identified or identifiable individuals (“Personal Data”) will be treated in a secure and confidential manner as set out in this Privacy Policy (“Policy”).

PT Services DMCC and its affiliates D.N. Researchers FZE LLC and Polygon Labs Services (Delaware) Inc. (together “Polygon Labs”, “we”, “us” or “our”) are the joint controllers of your Personal Data. This means that all three entities will determine together how and why your Personal Data is processed, principally because our local entity does not have its own human resources department and therefore is working with its affiliate for certain processing activities. These entities have entered into a joint controller agreement by which they both are responsible for informing you about the processing of your Personal Data in this Policy. You may exercise your rights as a data subject with either entity as set forth below. In addition, where processing of Personal Data is undertaken by other affiliates of Polygon Labs for their own independent purposes, these affiliates may be controllers or joint controllers of your Personal Data and a separate privacy policy will be provided to you.

Throughout this Policy we use the term “processing” to refer to all activities involving your Personal Data, including collecting, handling, storing, sharing, accessing, using, transferring, erasing and disposing of Personal Data.

This Policy is provided to you in compliance with data protection laws. This Policy does not constitute or form part of any contract nor is it an offer to contract or an offer of employment. This Policy does not confer any contractual right on you, or place any contractual obligation on us.

1. Personal Data

We may collect various types of Personal Data about you for the purposes described in this Policy:

• Data about you: full legal name, date of birth, age, home contact details (e.g., address and location, telephone number, e-mail), national ID and other governmental IDs and numbers, immigration and eligibility to work data; to the extent permissible by applicable law, records of your past criminal convictions, sex offender registry status, fraud convictions, other sanctions; and you and your family’s outside business activities relevant to Polygon Labs.
• Data about your employment history and qualifications: education and training, employment history, LinkedIn information, qualifications, references.
• Data about your application: CV/resume and application, interview data.
• Other information: Social media information such as Twitter handle or Github profile information; or other information you voluntarily provide us through the application process.

You may give us the Personal Data described above during the recruitment process, whether through your application, further communications, on the telephone or during interviews. 

We may also receive Personal Data about you from third parties: recruiters; references from a previous employer; business partners; sub-contractors providing recruiting or technical services; analytics providers; and background check and search information providers; as well as from publicly available sources such as social media where such Personal Data is proportionate to the position for which you are applying. We may also retain that Personal Data after you have been employed (where this is relevant and to the extent permitted by applicable law).

We may also receive information (which may include your Personal Data) from our hiring manager, from our Human Resources staff, and, from time to time, from our other employees (for instance, in the course of conducting an interview). 

2. Why We Process Your Personal Data; Legal Bases

The Personal Data requested from you during the recruitment process is required by us in order to assess your application for employment with Polygon Labs. If you do not provide some or all of this Personal Data it may affect our ability to process your application and therefore to offer you employment. In some cases, it may mean that we are unable to continue with your application for employment as Polygon Labs will not have the Personal Data we believe to be necessary for the effective and efficient management of the recruitment process.

We collect the Personal Data described in Section 1 above for the purposes of managing Polygon Lab’s  recruitment related activities, namely: verification of qualifications and employment eligibility; the evaluation and selection of candidates; setting up and conducting interviews and tests; and conducting evaluations, assessments and otherwise as needed in the recruitment process, including if relevant, issuing employment offers; bringing successful candidates into Polygon Labs; dealing with queries or complaints relating to the recruitment process; for asserting or managing any kind of claims that we may bring or that may be raised against us; to comply with legal or regulatory obligations; and, where appropriate, retaining information relating to unsuccessful candidates for consideration in future relevant vacancies. 

We process your Personal Data for the purposes described above on the following legal bases:

• Legal obligations: the processing is necessary for compliance with a legal obligation to which Polygon Labs is subject (purposes of processing: verifying eligibility for employment or complying with obligations regarding non-discrimination; complying with other legal or regulatory obligations such as law enforcement requests or other); 
• Assessment of working capacity: the processing is necessary for us to assess your capacity to become one of our employees; or
• Contractual obligations / Pre-contractual steps: the processing is necessary to comply with the terms of our recruitment process, as disclosed to you prior or during the recruitment process or in order to take steps at your request prior to offering you employment (purposes of processing: communicating with you about your application); or 
• Consent: the processing is necessary for setting up and conducting interviews and tests; conducting evaluations and assessments; verifying your academic, work and other qualifications; verifying references; evaluating and selecting candidates for further consideration; to issue an employment offer; to deal with queries or complaints; asserting or managing any kind of claims that we may bring or that may be raised against us; and to consider unsuccessful candidates for future vacancies) .     

3. With Whom Do We Share Your Personal Data?

As part of a multinational with affiliates in several countries, Polygon Labs may hire for its sites, and use resources, located outside the country where you live. Your Personal Data may be shared with affiliated companies where it is reasonable and necessary to do so, such as to ensure a consistent application of standards for candidate recruitment. Within Polygon Labs, your Personal Data can be accessed by or may be disclosed internally on a need-to-know basis to persons responsible for managing or making hiring decisions, Human Resources staff, system administrators and other support teams (such as IT and Finance).

Your Personal Data may also be accessed by third parties who provide us with services relevant to your recruitment, namely: recruiters; companies that host, support and/or maintain the IT systems supporting our recruitment system; and companies that verify your references, perform background checks solely to the extent permitted by applicable law or conduct vetting on our behalf.

If your application for employment with Polygon Labs is successful and you accept a job offer from us, your Personal Data may also be shared as described in our employee privacy policy, and notably with Human Resources management, payroll and benefits systems, and the Personal Data contained in such systems may be accessible by providers of those systems, their affiliated companies and sub-contractors; tax authorities; regulatory authorities; and our lawyers, auditors, investors, consultants and other professional advisors. 

Polygon Labs may also share your Personal Data if it becomes involved in a reorganization, merger, consolidation, acquisition, or any form of sale of some or all of its assets, with any type of entity, whether public, private, foreign or local.

Polygon Labs expects all third parties to process any Personal Data disclosed to them in accordance with applicable law and contract terms, including with respect to Personal Data confidentiality and security.  Where these third parties act as a “processor” (for example, by verifying your references at our request), they carry out their tasks on our behalf and upon our instructions for the above-mentioned purposes.  In this case, your Personal Data will only be disclosed to these parties to the extent necessary to provide the required services.  

4. Security of Personal Data

We implement what we determine to be reasonable physical, technical and administrative security standards designed to protect your Personal Data from loss, misuse, alteration, destruction or damage.  

5. Where We Process and Store your Personal Data

From time to time your Personal Data will be transferred outside your country for the purposes described in this Policy. For example, your Personal Data may be transferred, among other purposes, to conduct the review of your application, the processing of your information, and the provision of support services by third parties.

Depending on the scope of your interactions with us, information about you, including personal information, may be stored in or accessed from multiple countries. For example, we may share your Personal Data with colleagues within Polygon Labs; with colleagues at Polygon Labs entities in the United States; and with third parties as described in this Policy. Those third parties may be located in the United States and other countries which have been determined to provide adequate protection to Personal Data.

Whenever we transfer personal information to other jurisdictions, we will ensure that the information is transferred in accordance with this Policy and as permitted by applicable data protection laws     .  

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6. Retention of your Personal Data

We will retain candidate Personal Data for a period of up to one year following the closure of the recruitment process relating to the role for which you applied in the event other job opportunities arise within Polygon Labs or an affiliate. In all cases, we will retain your Personal Data for a period of time corresponding to the applicable statute of limitations for any kind of claims that we may bring or that may be raised against us, or legal or regulatory obligations.

7. Your Rights

• Subject to conditions set forth in applicable data protection legislation, you have the following rights. Note that the rights set out are not absolute and are each subject to certain exceptions:     
• Right to Information – Whilst Polygon Labs aims to provide you with as much information as possible with respect to our processing of your Personal Data within this Policy, you may be able to request certain additional information from us. Specifically, information with respect to the procedures to be taken in the event of a breach or infringement of your Personal Data, especially if the breach or infringement poses a direct and serious threat to the privacy and confidentiality of your Personal Data.  
• Right to Correct (Rectification) - Polygon Labs aims to ensure that all of your Personal Data is correct. You are entitled to have any inadequate, incomplete or incorrect Personal Data corrected (that is, rectified). 
• Right to Withdraw Consent - In the      event your Personal Data is processed on the basis of your consent, you have the right to withdraw consent at any time, without affecting the lawfulness of processing based on consent before its withdrawal.
• Right to Request Personal Data and Right to Data Portability - If we rely upon your consent as the legal basis for processing, or where processing is necessary to perform a contract to which you are party     , and the Personal Data is processed by automated means, you have the right to receive all such Personal Data which you have provided to us in a structured      and machine-readable format, and also to require us to transmit it to another controller where this is technically feasible.
• Right to Erasure - You are entitled to have your Personal Data erased under specific circumstances, such as where you have withdrawn your consent, where you object to our processing of your Personal Data and where we have no legitimate reason to continue processing it, where your Personal Data is no longer required for the purpose for which it was collected and / or where our processing of your Personal Data is not in line with applicable laws and where erasure is necessary for us to comply with those laws     .

• Right to Restriction of Processing - You have the right to restrict our processing of your Personal Data (that is, allow only its storage) where: 
  - you contest the accuracy of the Personal Data, until we have taken sufficient steps to correct or verify its accuracy; 
  - where the processing is unlawful;
  - where the processing exceeds the purposes set out within this Policy.

• Right to Request Continued Processing – You have a right to request that we continue to process your Personal Data once we have fulfilled our purposes for processing where such Personal Data relates to a legal proceedings. 
• Right to Stop Processing – You have a right to object to, and stop, our processing of Your Personal Data where we use it for direct marketing purposes, where we conduct statistical surveys, and in the event that we process it other than in accordance with the Personal Data Processing Controls set out under Article 5 UAE PDPL.

• Right to lodge a complaint - You may lodge a complaint with the supervisory authority of your country of residence, place of work or place of alleged infringement.

8. How to Contact Us; How to Exercise Your Rights 

To obtain further information regarding your rights, to exercise any of your rights (other than to lodge a complaint), or to ask any questions regarding the processing of your Personal Data, please contact privacy@polygon.technology. To lodge a complaint, please contact the relevant Data Protection Supervisory Authority.

9. Changes to this Policy

We may update this Policy from time to time. If we make any changes, we will change the Last Updated date above. We encourage you to periodically review the Policy for the latest information on our privacy practices.

10. Consent

If and to the extent to which an alternative lawful basis for processing is not available for any purpose for processing described within this Policy, I hereby consent to Polygon Labs’ processing of my Personal Data for such purposes. Where Polygon Labs does rely on my consent, I understand that I have the right to withdraw my consent at any time. The withdrawal of my consent will not affect the lawfulness of Polygon Labs’ processing of my Personal Data up until the date at which I withdrew my consent.