Data Consent Policy for Recruitment Purposes

1. About Ciellos

Ciellos, Inc. and Ciellos subsidiaries thereof, are Microsoft technology providers founded to provide Business Systems Consulting and Microsoft Business Support to Partners & Customers in the Microsoft Channel being ISV’s, VAR’s & Corporations (end users). Our purpose is to guide and advise our customers and partners in business systems change and the infrastructure that it supports, including systems/technology road mapping, systems selection, process definition and re-engineering, systems implementations, customization and integration, Cloud infrastructure and migrations, and upgrading and managing ongoing support.

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2. Introduction

This Data Consent Policy for Recruitment Purposes, together with Ciellos, Inc.'s Privacy Policy, explains how Ciellos, Inc. collects, processes, and protects personal data during recruitment and hiring processes. It also outlines your rights regarding your personal data when using Ciellos' online career resources, applying for a job at Ciellos, and undergoing pre-hire or onboarding procedures.

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3. Data Controller

Ciellos, Inc. (hereinafter either “we”, “us”, “our”, or “Ciellos”) is the data controller responsible for the processing of your personal data during recruitment and/or onboarding. Ciellos uses a web-based HR system for its recruitment process.

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4. Collection and Use of Personal Data

The types of information requested from you and the manner in which that information is collected and accessed are determined in accordance with the Ciellos Privacy Policy which can be found here. When you apply for a job at Ciellos, we collect and process personal data about you, including but not limited to:

• Your personal details that you submit in the application form;
• Data requested to provide during the recruitment process, to the extent allowed by applicable law;
• Data you submit in résumés / CVs, letters, writing samples, or other written materials (including photographs and videos) and other details from the job application form;
• Data generated by interviewers and recruiters, based on their interactions with you or basic Internet searches where allowed under applicable law;
• Communication with you during your candidacy, including requests for additional information if required;
• Data provided by third-party placement firms, applicant matching platforms, recruiters, or job-search websites, where applicable;
• Photograph and images/audio/video recordings of interviews captured in the course of recruitment events or video recruitment interviews;
• Recommendations provided on your behalf by others;
• Documentation required under immigration laws;
• Data about your prior employment, education, and where applicable, credit history, criminal records or other data revealed during background screenings;
• To the extent legally permissible, data about your health or disability where it is relevant to your ability or availability to work or to a workplace accommodation, subject to legal limits on the timing of collection of such data and other applicable limitations.
• In specific jurisdictions, we may collect data about race, ethnicity, religion, disability, sexual orientation and gender identity, military/veteran status, refugee status, for purposes of government reporting where required, as well as to support Ciellos diversity goals, evaluate the effectiveness of our equal opportunity policy and promote diversity best practices.
• Data generated by your participation in psychological, technical or behavioral assessments. You will receive more information about the nature of such assessments before your participation in any of them.

You are not required to provide any requested information to Ciellos but failing to do so may result in not being able to continue your candidacy for the job for which you have applied.

By submitting your information, you acknowledge that all representations made by you are true and correct to the best of your knowledge and belief, and you have not knowingly omitted any related information of an adverse nature. Providing any inaccurate information, to the extent required for your application or onboarding, may make you ineligible for employment.

If you choose to sign an employment contract with us your personal data may be shared with our customers to be able to staff projects.

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5. Why does Ciellos Process your Personal Data and on What Basis

Ciellos processes your personal data for the following reasons, based on the legal grounds outlined below:

We will process your personal data for the purposes outlined in the table above, obtaining your consent where required by applicable law.

If you are prompted to accept this statement within our systems, your acceptance will be treated as consent only in countries where consent is legally required. In other regions, clicking an acceptance or agreement button will simply confirm your acknowledgment of this statement.

Ciellos will not process your personal data for any purposes beyond those specified in this document.

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6. Where Does Ciellos Obtain Your Personal Data?

Ciellos may collect your personal data from the following sources:

• Directly from you when you submit your resume or other application materials online.
• From Ciellos affiliates that may share relevant recruitment-related information.
• Through interactions with recruiters and hiring managers, including interviews and conversations, which may be recorded with your prior consent.
• From publicly available sources, such as job search platforms or professional networking sites (e.g., LinkedIn) if you have made your information public.
• From previous employers or professional references where applicable.
• From social media, if legally permitted and relevant to the recruitment process.
• From third-party recruiters, staffing agencies, or applicant-matching platforms when you are introduced to Ciellos through one of these services. Ciellos only works with external recruiters under a formal agreement and does not accept unsolicited resumes.
• From background checks, where allowed by law. If a background check is required, you will receive details before it begins. This may include information from publicly available records, previous employers, educational institutions, and other sources as permitted by local regulations.

Ciellos is committed to handling your data responsibly and in compliance with all applicable laws.

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7. Data Processing and Storage

Your personal data may be processed by our data processors, including hosting partners located within the USA, EU, and EEA. Where personal data is transferred outside the EEA, Ciellos ensures compliance with GDPR through appropriate safeguards, such as Standard Contractual Clauses or other legally recognized transfer mechanisms.

We use an HR system for recruiting purposes. The information that you submit as part of the recruitment process is collected and accessed in accordance with the Ciellos Privacy Policy which can be found here.

Recorded video and Teams conversations are stored for up to two (2) years for recruitment and documentation purposes unless you request deletion sooner, or unless otherwise required by law. If no deletion request is received, or in cases where legal or official documentation requirements prevent deletion, Ciellos, Inc. reserves the right to retain recordings for longer periods.

Ciellos retains your data based on the following factors:

• We keep your data as long as we have an ongoing recruitment relationship with you, including potential future job opportunities. For the latter, we will periodically ask you to renew your consent.
• Where permitted by law, we may retain your data to match you with future open positions, provided that you give us consent to retain your data
• We retain your data if required by legal obligations or compliance requirements.
• In cases where retention is necessary to protect Ciellos’ legal position, such as for regulatory purposes or in case of legal claims.

Additionally, anonymized transcripts or audio files of these conversations may be retained for internal educational and compliance purposes.

In all aspects of collecting and processing personal data Ciellos is committed to the principle of balancing of interests.

If you have concerns about this, please reach out to your recruitment contact.

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8. Your Rights

You have the following rights regarding your personal data:

• The right to revoke your consent at any time with future effect.
• The right to request access to your personal data.
• The right to request rectification or deletion of your data.
• The right to restrict the processing of your personal data.
• The right to object to our processing of your data.
• The right to data portability, depending on circumstances.

Your rights may vary depending on your location and applicable data protection laws.

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9. Contact for Data Inquiries

If you wish to exercise any of your rights or file a complaint regarding the processing of your personal data, please contact our Data Protection Officers at privacy@ciellos.com. For recruitment-related inquiries, you may also contact our recruitment team at: recruitment@ciellos.com

This Data Consent Policy is subject to change, and any updates will be communicated accordingly.

The current version of the Policy is available on the Company’s website at www.ciellos.com‍