Global Job Candidate Privacy Notice

This Privacy Notice applies to all personal information and other information you provide to CyberFortress (“Personal Information”). Certain countries may refer to such Personal Information as personal data or sensitive personal data. This Privacy Notice details the types of Personal Information that you might provide to CyberFortress. For example, Personal Information could include your application, cover letter, resume, or Curriculum Vitae that you submit when applying for a job with CyberFortress.

The Personal Information that you provide to CyberFortress shall be treated in accordance with the provisions set out in this Job Candidate Notice and the CyberFortress Privacy Statement. From time to time, we may send you other information about our data collection, use and sharing practices. These additional notices may supplement this Job Candidate Notice, provide you with further options related to how we process your data, or clarify our privacy practices as described in the notice. The “Last Updated” section at the end of this Notice states when this Job Candidate Notice was last revised.

As part of the job candidate process, we may request certain Personal Information such as your full name, address, date of birth, email address, passport, social security number, national identification number, telephone number, citizenship or immigration status, past work experience, educational history and certifications, criminal background information, fingerprint, photograph, academic verification information, and other types of information necessary to assess your job application.

CyberFortress does not request nor require Sensitive Personal Information regarding your religion or your political affiliation in connection with your application. If you have a disability or would like us to consider an accommodation, you may provide information about your medical condition or health during the recruitment process. In certain countries, CyberFortress may also ask that you provide information such as race, ethnicity, sexual orientation, gender, disability, veteran or military status for the purposes of monitoring our equal opportunity program and compliance. You provide this information on a voluntary basis, and you determine the extent of information you provide. If you provide us with this information, it will not be considered in the hiring or selection process unless otherwise required by law.

CyberFortress may also obtain information about criminal convictions or offenses in order to comply with the applicable law and to meet our contractual commitments.

We may also obtain information about you from other sources to the extent permitted by applicable law, such as through your interactions with CyberFortress, through employment research firms, identity verification companies and websites (subject to the third party’s privacy policies). You may also grant us access to Personal Information stored by third parties or social media platforms (i.e., LinkedIn). When you authorize CyberFortress to access this information, you agree that CyberFortress may collect, store and use this information in accordance with this Privacy Notice.

CyberFortress may use your Personal Information for the following non-exclusive purposes: to arrange and conduct job interviews and tests; evaluation of your job application; assessment of your skills, the evaluation and assessment of interview results and as is otherwise needed for recruitment processes; assessment of your eligibility and authorization to work in the role; human resource operations; maintenance of a global human resources database; implementation of global processes and tools; creation and maintenance of a global compensation and benefits strategy and other human resource management activities; your transfer to another country; compliance with general legal or regulatory requirements, and audit functions.

Purposes and Legal Bases for Processing (EEA only): We will comply with applicable data protection principles, including the General Data Protection Regulation (GDPR). Consequently, if you are a job candidate from the European Economic Area (EEA), the legal bases for collecting and using Personal Information depends on the type of information and how it was collected. Normally, we will only collect your Personal Information where:

• We have your consent to do so.
• Necessary to do so to process your application.
• Required to review your qualifications.
• Ensure compliance with applicable law.
• Necessary to protect the vital interests of any person; or
• Where the processing is in our or a third party’s legitimate interests, which are not overridden by your data protection interests or fundamental rights and freedoms.

CyberFortress shares the personal data you provide with its affiliates, business partners and service providers who are involved in the employment application and recruitment process. We may also disclose your Personal Information to our designated agents, or third-party service providers, who require such information to assist us with administering our employment application and recruitment process, such as, but not limited to, background and employment verification agencies and recruiting firms or software providers. CyberFortress requires that its affiliates, business partners and service providers protect your personal data in a manner consistent with this Job Candidate Notice and applicable law. CyberFortress and its affiliates, business partners and service providers will only use your personal data for the purpose it is gathered, unless you consent or as required by law.

We may also share your information: with your consent; in order to comply with legal process or government requests (including responses to law enforcement or national security requirements or equal opportunity laws and regulations); when it is necessary to protect the vital interests of any person; or as needed during negotiations of, any merger, financing, acquisition, corporate reorganization, sale of company assets, dissolution or similar event.

You have the right to correct or update Personal Information provided to us at any time by sending an email to [email protected]. Any other requests regarding CyberFortress’s privacy practices should be sent by email to [email protected] or in writing to CyberFortress Legal Department: 21750 Hardy Oak Blvd. Suite 104, PMB 96884, San Antonio, TX 78258.

Some regions (such as the European Economic Area) grant additional privacy rights including:

• Right of access: You may have the right to access the Personal Information we hold about you.
• Right to rectification: You have the right to request that we modify your Personal Information if it is incomplete or incorrect.
• Right to data portability: In certain limited circumstances, you may have the right to have the Personal Information we hold about you ported to another provider.
• Right to erasure: You may have the right to erasure of Personal Information that we hold on you in certain circumstances.
• Right to restrict processing: You may have the right to request that CyberFortress restrict the processing of your Personal Information in certain circumstances.
• Right to object: You may have the right to request that CyberFortress stop processing your Personal Information or stop sending you communications.
• Right to withdraw consent: Where we rely on your consent in order to process Personal Information, you have the right to withdraw or decline your consent at any time. Please note that if you withdraw your consent, we may not be able to proceed with the job candidate review process.

You also have the right to lodge a complaint with your national Data Protection Authority or equivalent regulatory body.

Your information may be processed, stored, or transferred by us or our service providers, partners or affiliates in the United States and potentially other countries whose data protection laws may be different from the laws of your country. Where we export your Personal Information to a country other than a foreign country in which you are engaging with CyberFortress, then this Personal Information may be available to the applicable foreign government or its agencies under a lawful order made in that foreign country for purposes other than as described in this Job Candidate Notice.

Where we process, store, or transfer your Personal Information to a country that is not considered adequate by the EU, we will do so in accordance with this Privacy Notice and will take appropriate contractual or other steps to protect your Personal Information based on applicable law. These steps may include implementing the European Commission’s Standard Contractual Clauses or similar safeguards.

CyberFortress maintains, and requires its service providers to maintain, appropriate technical and organizational measures designed to protect the security of your Personal Information. For example, CyberFortress employs physical access controls, internet firewalls, encryption, intrusion detection and network monitoring depending on the nature of the data and scope of processing. Even the best security programs are not completely secure. Consequently, we advise you to exercise caution when disclosing Personal Information online and to use tools such as firewalls, anti-virus and anti-spyware software or similar programs to protect your information. If you think that your interaction with us may not be secure or your Personal Information has been compromised, please contact us using the contact information below.

CyberFortress will retain your Personal Information where we have an ongoing legitimate business purpose to do so or as long as needed to fulfill the purposes outlined in this Privacy Notice, unless otherwise permitted or required by law. We may also retain your Personal Information to consider you for other job opportunities unless you have told us that you do not want us to use your information for this purpose. CyberFortress may delete your Personal Information at any time unless otherwise required by law so you should maintain your own copy of any information that you submit to CyberFortress.

If you provide Personal Information to CyberFortress, regardless of whether the Personal Information relates to you or a third party, you must ensure, on a continuing basis, that:

(a) This Personal Information is accurate, relevant, and complete.

(b) You have provided the CyberFortress privacy notices to and/or received appropriate consent from any third party whose Personal Information you provided, and

(c) You have a lawful basis to provide CyberFortress with this Personal Information.

If you choose not to provide us with certain Personal Information, then CyberFortress may not be able to satisfy our own contractual or legal obligations and, in such circumstances, employment with CyberFortress may not be permissible. You acknowledge and agree that CyberFortress shall not be held liable for any consequence that results from these circumstances.

By submitting your Resume or other personal data to CyberFortress, you agree that CyberFortress may collect and use it for recruitment purposes, which may include transferring your Personal Information to: other countries where CyberFortress operates, which may not provide privacy protections similar to those that your own country provides; other companies that are authorized to perform specific services for CyberFortress. You further agree that you are responsible for providing any notices and obtaining any consents necessary for CyberFortress to collect and use information for any individual you provide as a reference. If you do not agree that your information can be transferred as described in this paragraph, please do not provide CyberFortress with the information.

If you have any questions or concerns regarding this Privacy Notice, you may write to us at [email protected] or by mail to: Data Protection Officer, CyberFortress, 21750 Hardy Oak Blvd., Suite 104, PMB 96884, San Antonio, TX 78258.