Vuxe Privacy Statement

Hello and welcome to VUXE. As you would expect, in order to properly perform our services, we need to collect and use information about you in a lawful, ethical and responsible manner.

VUXE is committed and adhering to strict instructions that you, the user, has given to us in respect of both respecting and protecting your privacy. This Privacy Information Statement (this “statement”) describes your privacy rights in relation to the information about you that we process, as well as the steps we take to ensure that your privacy is fully protected. We know it͛s long, but please read this Statement carefully and make sure you understand it.

Index

A. Some terms to be clear about.

B. What personal information does the company collect and use?

C. Why do we use personal information about you?

D. What we collect and for what purpose?

E. Do you have to give us the personal information we ask for?

F. Do we process information about you without any human intervention at all?

G. How long do you keep my personal information for?

H. Do we transfer your data to third parties?

I. Do we transfer your data outside the European Union?

J. What are your rights?

K. What about data security when using VUXE?

L. How can you contact us?

M. How do we handle changes to this Statement?

A. Some terms to be clear about

First, we need to be clear about how we use some words in this Statement. It may seem obvious but, in this Statement, you will be referred to as the Candidate or as the Client or as You (collectively as Users).When we talk about us, ͚VUXE or the Company, we mean VUXE as part of Staff Today Limited, a company registered in Scotland with company number SC507193 and registered address at Suite The Enterprise Hub, Level 6, Graham Hills Building, 50 Richmond Street, Glasgow. G1 1XP. VUXE provides staffing services to facilitate a hiring arrangement between Users as described in this Statement (our Activities).To carry out our Activities, the Company uses an online platform and App. The online platform, telephone calls, text messages and App bring candidates looking for work together with companies looking for workers. Both the website and mobile app is designed to allow you to search and apply for jobs that the Partner Company as above, – and its sister companies advertise that match your interests, skills and/or experience, in the locations where you have expressed an interest in working. Finally, this is Statement about information relating to people – like you and your family. It includes facts about you, but also opinions about you and that you hold (I’m a football fan for example). It’s not about information relating to the Company (although sometimes the two overlap). This type of information is sometimes called Personal Information, Personally Identifiable Information or PII. We use the term Personal Information in this Statement.

B. What personal information does the company collect and use?

Personal Information that the Company usually collects includes, but is not limited to:

  • your name, date and place of birth, contact details and qualifications (education, training courses and internships), documents evidencing your identity and right to work and any other information you listed on your resume or CV; including any additional voluntary information you choose to provide, such as a profile photo or copies of qualifications;
  • if you log on to the Portal using your LinkedIn or any other social media account: your profile data;
  • information about the Candidate which is necessary for drafting and processing the Contract of Employment as well as the Candidate Assignment contract. This includes, but it is not limited to, copies of identification documents and work permits, bank details, and other information necessary for registration with insurance companies;
  • Information about the client and the main points of contact necessary for registration with VUXE and in order to draft and process Candidate Assignment Contracts;
  • Information and content of the User͛s correspondence between the client the partner companies and VUXE temporary workers and the other Users (i.e. through contact forms and the Chat tool that have been built into VUXE);
  • if you contact us, in some cases, we will keep a record of that correspondence;
  • feedback about you from our staff and third parties; where you give us feedback on others, we will usually keep that too, which is Personal Information about you (it͛s your opinion after all);
  • your visits to our website/Portal including (but not limited to) your IP address, browser, timestamp, location, country traffic data, location data, weblogs and other communication data and the resources that you access. This information will make your visit to our website/Portal easier in the future. We might, for example, suggest jobs to you that are being handled by branches local to where you were when you contacted us;
  • information for marketing purposes and analysis, including information on how your respond to email, SMS, phone and other marketing campaigns;
  • photos and videos of your attendance at training or similar sessions (you will be given a chance at the session to ask not to be videoed or photographed);
  • details of any disabilities and any accommodations we may need to make for you in the workplace; and
  • in some cases, we will also collect sensitive personal information where we are permitted to do so by law (for example, in some countries we will ask you about your background for equal opportunities monitoring).

C. Why do we use personal information about you?

The Company collects and processes Personal Information to:

1. provide you with the services you expect from us, such as finding you suitable jobs/assignments to apply for or facilitating the process of such applications. This includes providing your details to prospective Partner Companies for their consideration as detailed further below;

2. create the User profiles required for using VUXE;

3. bring candidates looking for work together with companies looking for workers. For this purpose, information about Candidates is made available to Partner Companies and their points of contact. Likewise, information about Partner Companies such as their points of contacts, details of jobs and hourly rates are made available to the Candidates via VUXE͛s platform;

4. verify whether the Candidate is suitable for an open position, in particular by obtaining certificates and references from the Candidate, which can also be shared with the Partner Company;

5. verify a Partner Company͛s credit rating;

6. draft and process the relevant contracts between VUXE, the Partner Company and the Candidates, and between those of VUXE and the Partner Companies;

7. record the time worked;

8. make payment to the Candidate and invoice the Partner Company;

9. assess Candidates and Partner Companies;

10. put VUXE in contact with Users and to put Users in contact with each other;

11. inform Users about changes and other events relating to VUXE that could be of interest to them;

12. use, with your consent, your contact data for direct marketing for example via e-mail, messaging or telephone;

13. further develop, test and improve our website/platform, or other existing or new systems/processes to better serve you; this mainly takes place in the context of new IT systems and processes, so that information about you may be used in the testing of those new IT systems and processes where dummy data cannot fully replicate the operation of that new IT system;

14. perform studies and statistical and analytical research, for example, to compare the effectiveness of our placement of candidates between different business sectors and geographies and seek to identify factors that might influence any differences we identify;

15. transfer data to third parties (see section H below); and

16. comply, where necessary, with any legal or regulatory obligations.

We may also process your information to:

1. promote the security and protection of people, premises, systems and assets;

2. monitor compliance with internal policies and procedures;

3. administer communications and other systems used by the VUXE and Staff Today Limited (including internal contact databases);

4. investigate or respond to incidents and complaints;

5. cooperate with investigations carried out by the police, government or regulators; and

6. participate in any potential or actual purchase or sale, or joint venture, of all or part of a business or company, that any member of Staff Today Limited wishes to participate in.

D. What we collect and for what purpose?

We are required by Scottish law to give you access to information on the data that we hold about you. The reason for collecting and holding on to your data is so we can facilitate our services. When you are working with or through VUXE, our processing of Personal Information for all these purposes is based on processing grounds like the performance of a contract to which the data subject is a party to (e.g. purposes 1 – 9 and 12), processing necessary data to comply with legal or regulatory obligations (e.g. purpose 16) and/or processing necessary data in the legitimate interests of VUXE/Staff Today Limited in exercising its and its staff͛s fundamental rights to run a business in a way that does not unduly affect your interests or fundamental human rights and freedoms (e.g. purposes 8-15). When processing is necessary for the legitimate interests of VUXE/Staff Today Limited, we ensure that processing is conducted in such a manner that our legitimate interests outweigh any individual͛s interest. We shall only process your Personal Information other than onthese grounds with your consent (a further processing ground).

The legal basis and reasons for processing of data are as follows;

1. Prevent fraudulent activities;

2. For conflict resolution;

3. To enhance customer experience and increase customer satisfaction;

4. For the improvement of the platform and other related technologies; and

5. For targeted marketing.

E. Do you have to give us the Personal Information we ask for?

You are not obliged to provide Personal Information to us, but it will be more or less impossible for us to work with you and provide our services to you if you do not.

F. Do you have to give us the Personal Information we ask for?

Yes, we do at times. The Company may use automated systems/processes and automated decision-making tools (such as profiling) to provide you, and our Partner Companies, with the services you request from us. For example, when our Partner Businesses are looking for candidates for jobs, we may conduct a search of our candidates list using automated criteria, which takes into account your availability, skillset, pay rate and, in some circumstances, previous feedback we have received from clients. This will enable us to compile a shortlist, which ranks candidates that are most likely to fulfil the client͛s requirement. This means that sometimes your position in the rank may be higher than others, depending on how these factors match the clients͛ needs.

G. How long do you keep my personal information for?

The Company can keep your Personal Information for up to 3 years after you register with us and we will keep it as long as you continue using our services. However, we promise to delete it after 3 years of inactivity. Please bear in mind, we might keep it longer in case of any legal or regulatory action against the Company or its agents. If you are successful in finding work through us, the Company will need to keep your Personal Information for a longer period in order to comply with its on-going legal and contractual obligations. We retain your personal data concerning taxes, contracts of employment and any financial information (including payroll data and data relating to pay, etc.) for no longer than 3 years but other less important user data, such as log files, will be deleted after 7 days. We may collect non-identifiable data from user activities, which may be stored for longer periods of time for analytics and improvement of our customer experience.

H. Do we transfer your data to third parties?

As mentioned above, we will often disclose your data to third parties. This is done to complete the purposes set out above. We do this in the following circumstances:

• With Partner Businesses and the points of contact who receive information about Candidates via VUXE. This may include sharing Candidates contact details directly with Clients via VUXE in order to facilitate use of the Chat tool;

• With Candidates who receive information about Clients and the points of contact via VUXE;

• With our suppliers. We may, for example, engage a supplier to carry out administrative and operational work in support of our relationship with you. The supplier(s) will be subject to contractual and other legal obligations to preserve the confidentiality of your data and to respect your privacy, and will only have access to the data they need to perform their functions; the relevant suppliers are typically IT suppliers (who host or support our IT systems, including information about you), premises management companies (who look after physical security at our buildings, and therefore may need to know about you to allow access to our buildings) and back office finance and accounting management providers (who might need to handle details of candidates in order to process accounts payable and receivable). We may also engage suppliers who provide IT technology services and solutions, which might include video interview and skills assessment tools;

• With other VUXE branch offices and affiliates, including their suppliers, service providers and agents who are involved in providing the VUXE online platform, its content and the services provided by VUXE;

• With suppliers, service providers and agents who are involved in providing the VUXE online platform, its content and the services provided by VUXE, these include our service providers, for example, who is responsible for hosting the platform and the content as well as providers of certain functionalities provided by VUXE, such as the Chat tool integrated in VUXE and the map showing Candidates the location of work and for staff management.

• We will share your data with government, police, regulators or law enforcement agencies if, at our sole discretion, we consider that we are legally obliged or authorised to do so or it would be prudent to do so; and

• As part of due diligence relating to (or implementation of) a merger, acquisition or other business transaction we may need to disclose your data to the prospective seller or buyer and their advisers.

I. Do we transfer your data outside the European Union?

Your data can be transferred and processed in one or more other countries, in or outside the European Union. A full list of the countries in which we operate is available in the ͚choose your country͛ function of our website.

We will only transfer your data outside the EU to countries which the European Commission believes offers an adequate level of protection to you (a list of those countries is available here:

http://ec.europa.eu/justice/data-protection/international-transfers/adequacy/index_en.htm), or where VUXE has put in place appropriate safeguards to seek to preserve the privacy of your information (for which we usually use one of the forms of data transfer contracts approved by the European Commission, copies of which are available here: http://ec.europa.eu/justice/data-protection/international-transfers/transfer/index_en.htm).

J. What are your rights?

You have the following rights to:

• Access and obtain a copy of your Personal Information: You are entitled to request confirmation whether we process any of your Personal Information. Where this is the case, you may have access to some of your Personal Information (via the platform) and to certain information about how it is processed. In some cases you can ask us to provide you with an electronic copy of your information.

• Correct your Personal Information: If you can demonstrate that Personal Information we hold about you is not correct, you can request that this information is updated or otherwise corrected. We would encourage you to access the online platform where possible and update your Personal Information directly.

• Be forgotten/have data deleted: In certain circumstances you have the right to request that we restrict the processing of your personal data and/or that your personal data is deleted. You may make such a request at any time and VUXE will evaluate if your request should be granted, however this right is subject to any legal rights or obligations we may have to retain such data. For situations where, in accordance with the law, we determine that your request to have your Personal Information deleted must be granted, we will do so without undue delay. Please bear in mind, once your data is deleted the Company is unlikely to be of service to you anymore and if you wanted to re-register with the Company again, you would have to re-enter your personal data.

• Revoke your consent: you have the right to revoke your consent at any time free of charge.

• Object: as far as the Company͛s processing of your data is based on the Company͛s legitimate interest (and no other processing ground) or relates to direct marketing, you are entitled to object to the Company processing your data by reference to your particular situation.

If you want to exercise any of your rights, please email us at [email protected] When you email us to exercise your rights, the Company may ask you to identify yourself before acting on your request. Finally, you have the right to lodge a complaint with the data protection authority in the place where you live or work, or in the place where you think an issue in relation to your data has arisen.

K. What about data security when using VUXE?

You are responsible for keeping your login details to the Portal safe, in particular the password and login tokens from any third parties (or other authentication method) that we have given you and/or that you have chosen. These login credentials are for your own use. You are not permitted to share your credentials or other account details with any other person(s).

L. How can you contact us?

If you have any questions or concerns regarding this Statement or would like further information about how we protect your Personal Information, please email us at [email protected]

M. How do we handle changes to this Statement?

The terms of this Statement may change from time to time. We will publish any material changes to this Statement through appropriate notices either on this website or contacting you using other communication channels.