Zásady ochrany osobních údajů

Alumeco Group (which includes Alumeco ApS, Aluwind ApS, Alumeco Sverige AB, Alumeco Norge AS, Metallcenter West GmbH, Alumeco Service GmbH, Alcobra GmbH, Metalcenter Group GmbH, Alumeco Austria GmbH, Alumeco Finland OY AB, Metalcenter Finland OY AB, UAB Alumeco Baltic, Aluteam-Alumeco Sp. z o.o., Alumeco Service Sp. z o.o., Aluwind Sp. z o.o., Alumeco CZ s.r.o., and Alumeco NL) ("Alumeco") collects and processes personal data as part of the job application and recruitment process.

In this privacy policy for applicants ("Privacy Policy"), you can read more about how Alumeco processes applicants' personal data.

Alumeco's Privacy Policy for applicants describes:

• Which kinds of personal data Alumeco collects and for which purposes Alumeco uses this data for.
• Your rights.
• Our security measures.
• Your opportunity to contact Alumeco and to complain.

If you become an employee of Alumeco, you will receive information about our processing of employees' personal data (Alumeco's privacy policy for employees).

Data controller:

Alumeco ApS, Næsbyvej 26, 5000 Odense C, Denmark, business registration number DK19851974, is a company registered and incorporated under the laws of Denmark. In addition, the mentioned group companies belonging to Alumeco ApS are made up of numerous legal entities with offices located across the globe.

Due to the Alumeco Group structure – including in particular the similarity of the personal data processing activities, the extent of shared services and the consequent joint data responsibility - this Privacy Policy applies across the group. Each entity of Alumeco to which this Privacy Policy is relevant is the data controller for the processing of personal data in the respective entity, i. e., the relevant entity of Alumeco at which you have applied for a vacancy, along with Alumeco ApS, will as the data controller(s) collect and process personal data about you as a job applicant.

Alumeco kindly requests that you only submit personal data about yourself in your job application, CV or other relevant material you choose to provide to us, to the extent such information is relevant for the specific position you are applying for. For this reason, please do not include information on your civil registration number in the submitted documents and consider whether there is any other personal information, such as health information, information on family relations or similar, that is not necessary for Alumeco's recruitment process. Please also be aware of e-mail communication; should you chose to communicate to us via e-mail, remember that a regular e-mail is not secure communication, and that you should therefore not write anything in your e-mail that is private or sensitive, or that you otherwise think should be protected.

Information on applicants:

Alumeco collects and stores information about you in connection with your job application with Alumeco. What information we process depends on the specific position you have applied for, and it may be, for example:

• Identification information, such as name, address, telephone number, e-mail address.
• Other information that appears on your application and other accompanying documents (such as diplomas, recommendations, references, etc.).
• Personality and proficiency tests (certain positions).
• Criminal record and information on criminal offences (special positions where, for example, the legislation requires it).

Alumeco will, as a general rule, not process any special categories of personal data (sensitive personal data) about you unless you specifically include such personal data in your job application or in your CV, etc.

Purpose:

Alumeco processes personal data in connection with your application for the following purposes:

• Administration of the recruitment process including assessment and selection of the most suitable job candidate for the job position.

Source of information:

Alumeco processes the personal data you have provided to us by submitting your job application and related material.

Further, Alumeco may process personal data that are collected from third parties; for example, from public databases, via LinkedIn or other public social media platforms, an online search or a search and selection/recruitment agency.

If you have given your consent, Alumeco may also obtain and process statements from your former employers, such as information on your job assignments and qualifications.

If you have conducted tests, Alumeco obtains the test results from the test provider.

If a criminal record is required, this is obtained either directly from you or from the national police based on your former consent.

Legal basis for processing:

Alumeco processes the personal data for recruitment purposes to pursue the legitimate interests of Alumeco, such as administration of recruitment process and evaluation of the job applicants, including to hire the most suitable candidate for the specific position, cf. Article 6(1)(f) of the General Data Protection Regulation ("GDPR").

If you are chosen for one of our vacancies, such processing will also be necessary in order to take steps at your request prior to entering into an employment contract, cf. Article 6(1)(b) of the GDPR.

If Alumeco obtains and processes statements from your former employers, such processing will be based on your prior consent, cf. Article 6(1)(a) of the GDPR.

The processing of personality and proficiency tests is based on our legitimate interests in assessing and hiring the most suitable candidate, cf. Article 6(1)(f). To the extent your interests or fundamental rights and freedoms as a data subject override Alumeco's interests, the processing will be based on your prior consent, cf. Article 6(1)(a).

If you are not chosen for the vacancy you have applied for, but your profile is interesting and you accept further storage of your personal data for a potential relevant future vacancy, this storage only takes place based on your former consent, cf. Article 6(1)(a) of the GDPR.

The processing of personal data relating to (potential) criminal convictions and offences is based on section 8(3)-(5) of the Danish Data Protection Act according to which processing, including any disclosure, may take place when necessary for the purpose of pursuing a legitimate interest, which clearly overrides the interest of the data subject. Such interest includes crime prevention and protection of Alumeco and our trade secrets. If this requirement is not fulfilled, Alumeco will process the personal data when the processing is necessary for the establishment, exercise, or defence of legal claims or obtain your prior explicit consent.

Recipients:

If deemed necessary, Alumeco may disclose personal data about you to certain third-party recipients, such as intra-group companies or service providers in relation to recruitment process (including search and selection/recruitment agencies).

Alumeco also uses data processors in order to provide certain functionalities in connection with the recruitment process. This applies, for example, to a data processor that offers a system that can handle applications. Alumeco has entered into data processing agreements with the suppliers, and such suppliers will only process personal data about you on behalf of and in accordance with the instructions given by Alumeco.

We disclose information to authorities if we are required to do so by law.

Transfer of your personal data to a third country (outside of EU/EEA):

In certain cases, your personal data may be transferred to countries outside of the EU/EEA. Alumeco ensures that such transfer will be carried out in accordance with the applicable data protection laws. This entails that any party outside of the EU/EEA that will receive your personal data will ensure an adequate level of protection, for example, by entering into the EU standard contractual clauses with Alumeco. Alumeco will adopt supplementary safeguards if deemed necessary in the specific case. You may receive a copy of the legal basis for transfers upon request. Please contact GDPR@alumeco.dk.

Storage of your personal data:

As a rule, we delete your personal data no later than 6 months after the employment process has been completed if you are not chosen for the vacancy. Hereafter, your personal data will be deleted. We regularly review the personal data we hold, and your personal data will be deleted sooner if we determine that continued storage is not necessary.

If Alumeco stores your personal data for relevant future recruitment based on your consent, we will assess continuously if it is necessary to continue storing your personal data e.g., once a year. The specific storage period will depend on the specific position you initially applied for. If you withdraw your consent to the storage of your personal data for the purpose of relevant future recruitment, we will delete your personal data as soon as possible after the withdrawal of your consent.

If the law obliges us to store the information for a longer period of time or, if the purpose of storing the information is the establishment, defense or exercise of a legal claim, the period may be longer.

Security:

Alumeco keeps your personal data secure and confidential. We have implemented both technical and organizational security measures that aim to protect your information against its accidental or unlawful destruction, loss or alteration and against it coming to the knowledge of unauthorized persons, misused or otherwise processed in violation of the law.

Alumeco's security measures are continuously monitored to ensure that your personal data is handled responsibly, in accordance with the data protection legislation, especially with continued respect for your rights as a data subject.

Your rights:

Alumeco has implemented measures to ensure your rights as a data subject.

You have the right to access the personal data Alumeco processes about you and to receive additional information. Furthermore, depending on the circumstances you have the right to rectification, erasure (the "right to be forgotten") or restriction of the personal data Alumeco processes about you. You also have the right to object to the processing of your personal data in certain circumstances.

Under specific circumstances, you may have the right to data portability. Where processing is based on a consent or a contract with you and the processing is carried out by automated means, you have the right to receive the personal data concerning you in a structured, commonly used and machine-readable format if technically possible. Thus, you have the right to transmit this personal data to a third party without hindrance from Alumeco.

As a general rule, you have the right not to be subject to a decision based solely on automated processing, including profiling, which produces legal effects concerning you or similarly significantly affects you. This does not apply if, among other things, automated decision-making and profiling is necessary for entering into, or performance of, a contract between you and Alumeco.

If we have obtained your consent to a processing, you can withdraw your consent at any time. If you choose to withdraw your consent, it will not affect the lawfulness of our processing of your personal data on the basis of your previously given consent and up to the time of withdrawal. Therefore, if you withdraw your consent, it will only take effect from that point on. If a processing is based on your consent, you will have provided this before the processing. We always point out when you need to give your consent.

The Danish Data Protection Agency has issued a guideline on the data subjects' rights. If you want to read more about your rights, please click here. Please note that the guideline is in Danish.

QUESTIONS AND COMPLAINTS:

If you wish to exercise your rights or otherwise have questions about Alumeco's Privacy Policy for applicants, you are welcome to contact Alumeco at: Alumeco A/S, Næsbyvej 26, DK 5000 Odense C, e-mail: GDPR@alumeco.dk.

You also have the right to lodge a complaint with a supervisory authority concerning Alumeco's processing of your personal data. In Denmark, the Danish Data Protection Agency is the relevant data protection supervisory authority whose contact information is available on their website: www.datatilsynet.dk. Please note that the relevant data protection supervisory authority only is competent of handling complaints regarding Alumeco's processing of your personal data; complaints concerning the handling of the recruitment process, rejections, etc. must be forwarded to Alumeco.

Last revision: 23.06.2022