Privacy Notice

This statement sets out how the entities comprising DevelDas Group (“Develdas”, “we”, “us”, “our”) process your Personal Data.

This Privacy Notice will provide you with detailed information on how DevlDAS process Personal Data, and shall also provide you with details of:

• The rights you have in relation to your information, and how you can exercise those rights;

• The appropriate measures applied to safeguard your Personal Data;

• The types of Personal Data we collect about you, and how we collect and use it; and

• The criteria used to determine how long your data is kept for.

INTRODUCTION

This Privacy Notice applies to Develdas across our operations.

DEFINITIONS

For the purpose of this Privacy Notice the following definitions shall apply:

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It is useful to understand what constitutes personal data for the purposes of this notice:

Personal Data means any form of data which relates to a living individual who can be identified from it directly or indirectly. Also referred to as Personally Identifiable Information (PII), or Personal Information (PI), personal data includes data recorded on computers, databases or on paper, expressions of opinion about the individual and indications of intentions towards them. This individual is known as the ‘data subject’.

WHO WE ARE & WHAT WE DO

Develdas is a HR solutions provider in Iraq. Our team specializes in navigating the unique challenges and opportunities arising in Iraq. As part of our services, Develdas process a variety of information relating to data subjects in order to provide an effective and efficient service. We are committed to maintaining the highest standard of ethics and integrity in the conduct of our business including ensuring the ethos of Respect & Control whilst processing an individual’s Personal Data.

Develdas’s processing of Personal Data is conducted for the purpose of promoting, providing, evaluating, and reporting on the following services:

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INFORMATION DEVELDAS COLLECTS

In order for us to undertake our business in a manner that not only meets your expectations but applies controlled, satisfactory, and compliant services to all interested parties, there is a need to process accurate Personal Data. The type of data collected and level of detail is dependent on the services and relationship you have with us.

Data Subjects

The Personal Data collected by Develdas concerns the following categories of data subjects in relation to our core services and assignment support services:

• Candidates;

• Clients;

• Employees;

• External Providers;

• Website Users; and

• Other Contacts.

Personal Data

The Personal Data used by Develdas during the course of our services includes, but may not be limited to identification, nationality, and eligibility to work status, date of birth, education, job role, employment history, skills and preferences, payroll information, financial data such as social security numbers, tax and benefit data, and full contact details.

Personal Data also includes next of kin or relatives details that may be processed for the purpose of insurance, medical insurance cover or emergency contact reasons.

Special Categories of Data

In accordance with any specialist assignments, or as defined by local laws, data of a sensitive personal nature may be processed by Develdas or their authorised External Providers. In such instances, and where it is legally required, where you have entered into a contract with Develdas or where you have expressed interest in a particular role that requires it, the Sensitive Data processed may incorporate information relating to your:

• Physical or mental health conditions, including medical reports or results of any assessments such as drug and alcohol screening;

• Vaccination status (including COVID-19 vaccination status and evidence) relating to the location, role or project;

• Racial or ethnic origin;

• Results of criminal record checks; and

• Financial background checks.

In all instances, processing of Sensitive Data is undertaken under strict conditions and in accordance with local laws. Notification of such processing will be made to you and, if required, your formal consent obtained.

Vaccination data will be used to identify if you can be placed in a role for legal or client specific requirements as well as statistical awareness whilst on assignment. Vaccination data (including your individual vaccine status and evidence) may be shared with the client to contribute the health, safety, and wellbeing of the collective workforce or if required for legal and/or client requirements for a particular role.

PROCESSING ACTIVITIES

Develdas processes your Personal Data to provide our services, maintain our records, and meet our obligations as a personnel outsourcing partner. In addition, data from you or generated during the course of our relationship is also used for the purpose of reporting, monitoring and evaluation of services, as permitted by applicable law.

Whilst Develdas will not be seeking explicit consent from you for processing your data, we will not process any Personal Data for any other purpose than defined by this Privacy Notice and we shall ensure the conditions for processing fall into one of more of the following categories:

• Contract Performance;

• Legal Obligation;

• Vital Interest;

• Public Interest; and more specifically,

• Legitimate Interest.

For specific information relating to how Develdas use Personal Data, refer to the separate sections below.

Reporting

In line with our legal obligations and to ensure we meet our duty of care from a safety or security perspective, our company reporting may be linked to individuals. This type of reporting is carried out under strict conditions to prevent unauthorised access and ensure Personal Data is only accessed by authorised Develdas individuals and External Providers.

Reporting functions used by us include:

• Compliance Reporting linked to contract performance or expected business conduct; and

• Evaluation of services such as customer or employee surveys.

Monitoring Activity

Outside of legal obligations, Develdas do not currently undertake practices that result in final decisions purely based on automated processing of data; all such decisions, finalised outcomes or performance results are subject to human interaction and conclusion.

If changes occur to any processing activities conducted by Develdas using your Personal Data, this Privacy Notice will be updated accordingly.

See section for ‘Changes to this Privacy Notice’ for more details.

CANDIDATE DATA

We understand that a career move is an important considered decision for you and therefore it is essential to ensure that the right information is captured, at the right time, to offer you introductions to the right job opportunities.

The type of data and methods of collection varies for Candidates and really depends upon whether you are seeking permanent employment, contract services or if you are applying for a role working directly with us. No matter what you are looking for, your Personal Data will be processed by us in a respected manner with appropriate security measures applied.

Information you give to us

As a candidate of Develdas, you have the opportunity to provide information in various ways and in different formats to suit your needs and preferences. Typically, this would involve you submitting your CV or Personal Data to us by way of:

• Registration through the Develdas website;

• Applying for a role through Develdas’s website or other site that utilises our job advertising partner;

• Contacting us through our website;

• Submitting a CV or application direct to a Develdas representative; or

• Submitting compliance criteria as part of our on-boarding process.

Data collected by the above means includes your Personal Data and, where present on CVs or included to a Candidates online profile, may include other types of data.

In summary, the level of detail you provide or is present on your CV when submitted by one of the above methods is classified as being given freely for the purpose of identifying suitable positions on a contract or permanent basis with Develdas. Data will be retained within the respective system and made available within Develdas for recruitment purposes.

By submitting your data to Develdas for this purpose, you acknowledge the methods in which Develdas process your data in accordance with this Privacy Notice.

Information from other sources

Along with submission of Personal Data directly, Develdas collect and use data obtained from other sources available to us in our capacity as a personnel outsourcing business.

These sources may include:

• Clients or Candidates as part of a referral or placement scheme;

• Search of online job boards such as Linked-In or other industry job sites; and from

• External Providers undertaking screening, background checks or insurance services.

Candidate Recruitment Services

Develdas may use your Personal Data to contact you to discuss a potential role and to promote your skills and expertise in line with your requirements. We may also use it to help confirm your suitability for the role, for example by confirming your eligibility to work status, obtaining references, or checking qualifications that are specific to the position you are interested in.

A record of discussions and details of your CV will be retained on our database.

Your CV details will be shared with our clients as part of our search and selection process, or where you have applied for an internal position directly with Develdas, shared with the local hiring manager.

If you are unsuccessful, we will keep your application on file along with some limited Personal Data (such as contact details, work preferences and CV details) and may contact you with regards to future vacancies.

If you are successful in securing a position you will enter into the On-Boarding stages.

On-Boarding New Candidates

On-Boarding involves ensuring Develdas, the Client and you, are compliant in terms of local laws or Client rules and requirements. It is important that the transition to your chosen role is undertaken smoothly with all associated documentation validated in a timely and effective manner.

This means that additional information will be requested from you.

Some of this may be Personal Data and some may lead to the processing of Sensitive Data - the type and nature all depends upon the legal obligations and Client stipulated requirements of the role you have accepted.

In summary, the Personal Data that Develdas processes and reasons for processing when a Candidate is on-boarded will encompass:

• Employment or academic history including certification or results from background and reference checks for the purpose of candidate screening, CV validation and compliance to role or industry standards.

• Financial details for the purpose of processing payments for contract services.

• Health / Medical status including results from medicals, drug and alcohol testing or medical declarations, including declarations on your vaccination status and evidence of vaccination for the purpose of medical and/or insurance cover, or to comply with on-site HSSE rules, relevant laws, duty of care obligations, client requirements or other industry rules.

• Nationality, identification, and personal preferences for the purpose of on-boarding Candidates, visa applications and/or eligibility to work status. This type of data is also processed to comply with equality and diversity laws, or where a specialist role with one of our clients requires that such conditions are declared.

• Background screening including financial checks, criminal record checks, drug & alcohol screening, vaccinations, or fingerprint roll, for the purpose of compliance to relevant laws, HSSE rules, Client or industry standards and Develdas’s duty of care obligations.

• Travel profiles for the purpose of on-boarding Candidates, rotation and/or hotel arrangements where applicable to your assignment; includes profiles linked to travel preparations and/or preferences, and any special conditions linked to assignment or health/vaccination status for travel purposes.

• Dependant data for the purpose of providing accurate insurance provision to you and (where applicable) your family, and for use in the event of an emergency situation. This type of data may include Personal Data relating to your partner and/or dependents.

• Other Personal Data for the purpose of communications, arranging assignment support services with internal or external parties and to clarify terms associated with your assignment contract or permanent placement.

CLIENT DATA

Working with a talent pool of global Candidates it is important that Develdas fully understand your requirements and proficiently match these with the right Candidate in terms of specification and expertise. To allow this, the relationship between you, your organisation and Develdas needs to be strong and the understanding of the overall objective clear.

This is why retaining up to date Client contact information is important for both continued business and future developments.

Information you give to us

The level of information Develdas holds on Client contacts is limited in terms of Personal Data and is usually made available through one of the following ways:

• Provided by your organisation when entering into contract with Develdas;

• Submitted to Develdas when seeking staffing solutions or at special events or campaigns; or

• Available to Develdas through previous placement as a Candidate.

Information from other sources

Along with submission of Personal Data directly, we may collect and use data obtained from other sources available to us. These sources could include:

• Clients or Candidates as part of a referral or placement scheme;

• Employment Referee details;

• Supplied by Candidates on your projects and site locations;

• Researched from publicly available newsletters, publications or similar media; and

• Obtained as a business development lead or potential Client from online job boards such as Linked-In or other industry job sites.

The Personal Data held about you, as a client contact of Develdas would typically cover your contact details (business location and email details, name, and position) and communications made with us during the course of our relationship.

All other information does not amount to personal or Sensitive Data; Develdas nevertheless processes such information in line with our core values and always in a confidential manner.

Client Staffing Solutions

We will use your data to contact you to discuss potential business, your organisations staffing needs and to establish the type of Candidates suitable for you to fulfil your requirements.

If you are designated as the Account Manager in relation to services provided by Develdas, your contact details will be used for the purpose of:

• Entering into and agreeing contractual terms;

• Invoicing for the contractually agreed services; and

• Performing our contractual obligations.

More specifically, your contact data processed by Develdas during the course of our relationship is used for the purpose of Communications, including but not limited to:

• Financial transactions; used for processing invoices and associated orders.

• Provision of services as set out in the contract between us, marketing emails outlining available services and evaluating these services from your perspective.

• Commercial and Legal reasons associated with the business relationship such as contractual requirements, legal aspects arising from the services provided to you, and as confirmation of assignment start and end periods.

Potential Clients

Where Develdas have obtained your data from other sources, such as a recruitment job site or Linked-In, your contact details will be retained for the purpose of providing staffing solutions as a potential lead or Client. Processing is undertaken by the means and purposes defined above.

If you don’t want Develdas to contact you for this purpose please let us know.

EMPLOYEE DATA

As a direct staff Employee of Develdas, you’ll be a part of company that is close-knit and supportive. The start of your career with Develdas involves us getting to know you and you getting to know the business, this includes sharing information to allow us to operate our business effectively and ensure that our relationship gets off to a good start.

Employee On-Boarding

A majority of the Personal Data Develdas needs from you will be present on your CV; however as a business we would want to expand on this to ensure we meet our statutory obligations and will offer you the opportunity to validate this data through our internal systems.

Further information collected from you may include:

• Contact information for communication purposes, legal, employment and business references.Next of kin contact information for the purpose of emergency.

• Nationality, identification and personal preferences for the purpose of engagement, confirming eligibility status and where applicable for the purpose of managing travel and/or hotel arrangements, visa applications and any relocations.

In some instances your data will be processed to comply with local laws relating to equality and diversity requirements in a specific jurisdiction.

• Employment or Academic history including certification or results from background and reference checks for the purpose of CV or competency validation, compliance to a specific role or industry standards.

• Financial details for the purpose of processing payments, expenses, benefits and/or pension arrangements and to meet our legal obligations in relation to the employment contract.

• Health / Medical status including results from medicals and health declarations in line with your position, your working location within Develdas and our duty of care obligations.

• Dependant data for the purpose of providing accurate insurance provision to you and where applicable your family, to process any applicable or chosen benefits and to comply with legal requirements.This type of data may include Personal Data relating to your partner and/or dependents.

Should you not provide the required data, we may be unable, in some circumstances, to comply with our legal or employer obligations and we will tell you about the implications of that decision.

Other Processing Activities

During the course of your employment with Develdas your Personal Data and data generated about your time with us may be used for commercial, legal or performance reasons.

Amongst the reasons identified above this may include:

• Attendance tracking involving holiday leave, sickness absence or other out of office absences such as home working and external office visits.Data generated in this manner is used for legal purposes associated with your absences or may be used towards an evaluation on your overall performance.

• Training & Competency records are maintained about you to maintain Skills & Competency levels associated with your role, and where pertinent, to record activity relating to legal compliance associated with business conduct.

• Health status & incidents are recorded centrally in line with local laws and Develdas’s commitment to your safety and wellbeing during employment. Reporting is undertaken against this data for the same purpose and records may extend to include systems notes and doctors records.In event of incidents your Personal Data (name and address) may be shared to comply with local HSE laws.

• Performance appraisals will be carried out with you as an employee of Develdas with records maintained on performance, success areas and future development.

• Transactional data relating to financial activities such as payments, deductions or benefits, and reporting linked to payments to ensure financial legal obligations are achieved.

• Photographs of a physical or digital format as submitted by you or taken during a social or business environment.

• Travel arrangements and profiles linked to your business travel preferences.

Special Categories of Data

Where there is a need to process any Sensitive Data about you (including vaccination status and evidence in relation to COVID-19 or otherwise), we shall ensure this is undertaken under strict conditions and in accordance with local laws; further, notification of processing will be made to you and if required, in line with local laws, your formal consent obtained.

Develdas may also, where directed by local laws or in line with our duty of care obligations, collect information on your vaccination status. Again, this data is processed under strict controls and will be used to identify statistical awareness to contribute the health, safety, and wellbeing of the workforce.

Performance Criteria & Monitoring

Internal systems are used across the business to allow monitoring and measurement associated with key performance indicators or performance values for management reporting. These are linked to your role and responsibilities or agreed within your annual appraisal. This type of monitoring may be used to evaluate:

• Pay rises or promotions;

• Business Conduct;

• Training & Development needs;

• Business performance;

• Disciplinary, dismissals or complaints; or

• Legal obligations such as tax or benefit returns.

Where system calculations are used for monitoring and performance purposes, no final decision is taken that may result in a detrimental decision based on the system results; rather the relevant Manager (or their nominee) reviews details as applicable for discussion.

Systems & Devices

As an Employee of Develdas you will be equipped with a suitable level of process equipment for business purposes, including email, network drives and in some instances a mobile device. Monitoring usage is undertaken in line with business policy and laws relating to security of information, cybersecurity and expected conduct behaviours.

EXTERNAL PROVIDERS

Develdas aims to establish mutually beneficial relationships with our External Providers and would therefore expect them and their representatives to be committed to the highest level of ethical standards and conduct throughout their organisation, and to process any Personal Data in line with legal and contractual requirements.

The Personal Data collected and used by Develdas relating to External Providers is generally associated with the background screening and the requirements of our contractual relationship.

Information Collected About You

The level of information Develdas holds on you as an External Provider representative is limited and can be made available to us through one of the following ways:

•Submitted from you personally during the course of your business marketing strategy for services and/or products;

•Provided by you or your organisation when entering into a contract for services;

•Submitted to Develdas in our search for a preferred supplier or business partner;

•Referred to Develdas by a third party as part of a referral or assignment;

•Obtained from a public source during our search for an External Provider including credit or financial checks; or

•Through our business and ethic due-diligence process, conducted to ensure compliance to legal or commercial obligations, and ethical standards.

Processing Activities

The Personal Data involved is typically your contact name associated with your corporate details. Such data is used to enable an effective business relationship between all parties and would therefore cover the data types and processing activities linked to:

• Communications - encompassing your name along with corporate details of contact number and email address, and your professional position within the organisation.

• Financial transactions used for processing invoices and associated orders and ensuring payment for services and/or products is made in a timely manner.

• Commercial and Legal information for reasons associated with our business relationship such as contractual requirements, legal aspects arising from the services and/or products provided by your organisation, and as confirmation of the services entered into or products required.

• Declarations of compliance retained as part of our supplier due-diligence process and expected business conduct standards.

Your name, as the business representative for your organisation, may also be linked to evaluations, HSE or data protection impact assessments, and other types of performance or assessment criteria used to manage our relationship and delivery of services and/or products.

Whilst providing services to Develdas and its client’s, your business details may be shared with our client organisation in line with legal requirements associated with services, data processing, and HSE standards.

WEBSITE USERS

Your data may be collected by Develdas when you visit our website; the information collected is about your computer including where your IP address is available from, operating system and browser type, for system administration and to report aggregate information to our advertisers or to agencies or employers.This is statistical data about our users' browsing actions and patterns and does not identify any individual.

For the same reason, we may obtain information about your general internet usage by using a cookie file which is stored on the hard drive of your computer. Cookies contain information that is transferred to your computer's hard drive. They help us to improve our website usage and efficiency and to deliver a more personalised service to you.

There are different types of cookies available to organisations. They may include:

In summary these are:

• Performance cookies: Used to collect information about how the website is used. These Cookies do not collect data on the individual visitor.

• Functionality cookies: Used to customise your visit and provide you with access to the services you select.These Cookies do not track your browsing activity on other websites.

• Advertising & Remarketing cookies: Used to collect anonymous data about interests and demographics of users to the website and improve experiences overall.These Cookies do not identify you or give Develdas access to your computer or mobile device.

You may refuse to accept cookies by activating the setting on your browser which allows you to refuse the setting of cookies. However, if you select this setting you may be unable to access certain parts of our website. Unless you have adjusted your browser setting so that it will refuse cookies, our system will issue cookies when you log on to the Develdas website (www.develdas.com) ("Site").

You can update your preferences direct on our website.

Sharing Your Data

As part of our service provision, information is shared with External Providers for the purpose of performing our contractual commitments to you, including but not limited to payments, insurances, emergencies, travel arrangements or for other commercial or legal obligations relating to the contract performance.

If you have requested us to help you find a position with one of our Clients, we may pass your Personal Data to our Client(s) in order to provide you with that service; this may be in a form of a Develdas formatted CV or resume, or a profile highlighting skills and competencies associated with the position. We will attempt to contact you first to understand your interest and availability and get your agreement. If we have been unable to reach you we may, where we consider it to be the type of role you have advised us that you are seeking and is in your best interests, still pass on your information.

If you do not want us to send your information to any of our Clients without your prior specific permission (even when we are unable to contact you and we believe that it serves your best interests) you should contact Develdas.

In the event you enter into a contract with us or one of our Clients, we may pass your Personal Data to our Client or External Provider so they can provide services relating to your contract, or for Develdas staff Employees, in relation to our obligations as an employer.

Other circumstances in which Develdas would share your Personal Data, are in relation to the services provided by:

• Insurance brokers;

• Emergency service providers;

• Audit, Legal & Financial partners;

• Compliance and Screening Specialists;

• Medical and Health specialists;

• Approved travel partners; and

• Payroll providers.

Develdas only uses External Providers that meet our high expectations in terms of service and ethical standards including confidentiality and information security, and for the purposes of processing Personal Data, Develdas retains control as the appointed Data Controller.

It will be evident from the information provided as part of your contract with Develdas what services from External Providers we may utilise.

Disclosing Data for Other Reasons

In certain circumstances Personal Data may be disclosed to assist in the prevention and detection of crime and for law enforcement purposes without the consent of the individual concerned. Under these circumstances Develdas will use reasonable endeavours to check the request is legitimate before disclosing requested data and in all cases shall first seek authorisation through the relevant officers of the Develdas business.

If Develdas is involved in any transactional process regarding its ownership your Personal Data may be disclosed subject to strict confidentiality obligations and anonymisation where possible.

We may transfer your personal data to a third party as part of a sale of business assets or as part of any business restructuring or reorganisation, however we will always take steps to ensure that your privacy and rights continue to be protected.

Third Party Transfers

We will only share your Personal Data to third parties where there is a legitimate or legal ground to do so associated with our services, or associated with the relationship you have with us as defined in this Privacy Notice.

MARKETING

Where you have previously engaged with Develdas, such as providing your details for the purpose of our services, or have entered into a contract with us, Develdas may contact you. This will be to make you aware of other opportunities available to you. These instances are referred to as a ‘soft opt-in’ option where we adopt the understanding that you are happy to receive contact from us unless or until you specifically state otherwise.

Develdas may use your Personal Data to contact you via post, phone and/or email. There are various reasons why we may contact you in relation to your relationship with us and the services you have shown interest in.

Our marketing contact may be undertaken for legitimate reasons relating, but not limited to:

• The services we provide;

• In relation to your employment or contract offer with Develdas;

• Communication of newsletters, industry news or safety bulletins on local environmental issues;

• In relation to local events, holidays or festivals; and

• To understand your perceptions of our services from a business or legal aspect.

Of course, you are in control.

If you visit or register through our website, you will be asked to confirm your preferences relating to job alerts, Cookies and to gain information about our services. Likewise, if you have not previously engaged with Develdas about our services, it is important that you review what choices you have and if, and how, you want to be contacted by us.

If you don’t want to receive marketing contact from Develdas you can let us know at any time.

SECURITY MEASURES

Your Personal Data is important to you and important to Develdas; in fact, it is vital to the success of our business relationship.We shall therefore ensure that when processing information on your behalf your Personal Data is treated with respect, and that appropriate technical and security measures are applied to maintain the confidentiality, integrity and availability of data held on our systems, within data centres controlled by us, and as part of our service provision to you.

RETENTION OF DATA

We will only retain your Personal Data for as long as we need to in line with our legitimate interests and will take the necessary actions to keep this information up to date and accurate to the best of our knowledge and ability. Accordingly, our data management practices encompass retention of Personal Data, storage requirements and accuracy.

Keeping Your Data Accurate

Develdas will keep in touch with you regularly, providing an opportunity to update our central records and, where necessary any Personal Data we have about you. Additionally, we have the following facilities available to you so you can manage your data:

• Our website has the facility for you to manage your data by creating your own profile and providing up to date information;

• Our consultancy teams will keep in touch with you so you can let us know of changes;

• We may provide contact points to allow you to let us know of changes to your Personal Data; and

• As part of our on-boarding processes, we will check your details are correct.

How long we keep your information

Personal data will only be kept for as long as Develdas has a genuine business need for it or are required to keep it by law, whichever is longer.

Any documents we hold which contain Personal Data about you are retained in line with our document management practices, with controls and security applied on access and location

We segregate data depending upon the purpose of processing and the type of data processed, as this will determine the retention periods.The criteria we use to determine the retention period includes:

• The nature of the Personal Data;

• Our legal obligations;

• Purpose of your engagement with Develdas;

• Whether a contract has been performed and/or cannot be performed anymore;

• Whether you have exercised your right to erasure;

• Whether your data is no longer considered to be up to date; and

• In line with our staffing expertise and knowledge of the industry by country, sector and job role.

Personal data we no longer need to keep is archived, destroyed or deleted securely.

Transactional data relating to our services and contractual obligations will be retained for an extended period in line with legal or business requirements.

CHANGES TO THIS PRIVACY NOTICE

Any changes we make to our Privacy Notice or the defined processing activities will be posted to our website. You are encouraged to visit our website frequently to see any updates or changes.

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