Candidate Privacy Statement Portugal

Candidate Privacy Statement Portugal

Link Financial’s approach on dealing with personal information provided by candidates.

Who are we

Link Financial (referred to as “LINK”, “we”, “us” or “our” in this privacy statement) is committed to protecting the privacy and security
of your personal information and we are open and transparent about how we handle it and about our obligations under applicable
data protection laws and regulations, including the General Data Protection Regulation (GDPR). We are a Data Controller for the
purposes of the GDPR. This means we are responsible for deciding how we hold and use personal information about you.

This Candidate Privacy Statement (Statement) explains the basis on which we will control and process any personal information we
collect from you or that you may provide to us through our website or otherwise.

Our contact details are as follows:

EVERYDAY FINANCE S.A., DA REPUBLICA 18, 3RD FLOOR, 1050-191 LISBON
Telephone: +351 210 534 889 | Email: info@linkfinancial.pt

Do we have a Data Protection Officer

We have appointed a Data Protection Officer (DPO) to oversee compliance with this Statement and our obligations under the
GDPR more generally. You can contact our Data Protection Officer (currently Fernando Rocha, Managing Director) at the
following email address: frocha@linkfinancial.eu or write to the Data Protection Officer at the address listed above.

General Data protection principles

In collecting and processing your personal information, we will comply with the data protection law in force at the time. This
requires that the personal information we hold about you must be:
1. Used lawfully, fairly and in a transparent way
2. Collected only for valid purposes that we have clearly explained to you and not used in any way that is incompatible with
those purposes
3. Relevant to the purposes we have told you about and limited only to those purposes
4. Accurate and kept up to date
5. Kept only as long as necessary for the purposes we have told you about
6. Kept securely

What information do we collect

We may process the following categories of personal data about you (this list is not exhaustive):

  • Name, address, email, telephone number, date of birth, gender, nationality
  • CV (if applicable) and previous job and education information
  • Answers to application/interview questions
  • Information about your remuneration
  • Any other information you wish to provide in support of your application

How do we collect your data

We collect information that is specifically provided by you as part of an application process or sometimes from an employment
agency or background check provider.

What do we do with your information

We may use your information on any of the following lawful grounds:

a. For compliance with a legal obligation to which we are subject; or
b. For the purposes of our legitimate interests, except where such interests are overridden by your interests or fundamental rights and freedoms.

Our legitimate interests include the following:

  • To deal with your application
  • To communicate with you regarding the vacancy
  • To satisfy legal requirements
  • To protect our legal rights and interests including screening for fraud prevention and anti-money laundering purposes
  • For record keeping
  • To generate reports
  • For statistical analysis
  • To contact you about other vacancies
  • For the establishment, pursuance or defence of complaints, investigations and legal claims
  • To grow our business

All applications are viewed by a member of our Recruitment Team and no automated decisions are made in relation to your
application.

How long do we keep your information for

We will store your application data for up to 6 months after the vacancy has closed. After this period, it will be destroyed.

How we may collect more data from you

Should you be successful in being offered a role, you will be asked to provide further information as part of our Pre-Employment
Screening Process. We may collect the following (this list is not exhaustive):

  • Passport/Identification Documents
  • Proof of Legal Right to Work in the UK
  • Proof of Address
  • Proof of Activity
  • Information to conduct a Credit Check
  • Information to conduct a Criminal Records Check
  • Names and address of references who will be contacted.

Only if you are successfully recruited, will we upload your details to our Employee filing systems, and as a member of our team,
you will sign a contract of employment and agree to additional terms on how your data is handled and stored as per our Employee Privacy Statement.

Who do we share your information with

We may share your information with our affiliates, accountants, lawyers, auditors, insurers, professional advisors, or third party
service providers who provide services to us. We may also disclose information we have a legal or regulatory right or obligation
to report. Further, we may share your information with third parties to whom we sell, transfer or merge parts of our business or
our assets.

It is our commitment that prior to disclosing any personal information about you to another organisation we have taken all
reasonable steps to ensure that that organisation will hold and protect your information with adequate security measures and in
accordance with relevant regulation.

How do we keep your information safe

We protect your information with appropriate security measures under the laws and regulations that apply to prevent your personal
data from being accidentally lost, used, altered, disclosed or accessed without authorisation. We confirm our security measures are subject to regular testing and updated as appropriate to the level of data that we hold.

We have procedures in place to deal with suspected personal data breaches and will notify you and any applicable regulator of a
breach if we are legally required to do so.

What are your rights regarding your information

You have explicit rights concerning your personal information and we will ensure that your rights are protected while your data is
in our possession. Your rights include the following:

  • Right of Access – you may request a copy of all the personal information we hold about you and we will respond within one
    month. If your request is particularly complex or you have made a number of requests, we may extend this period by a
    further two calendar months and we shall explain our reasons.
  • Right of Deletion – You may wish to have certain data we hold deleted and we will comply with this right where, for example,
    it is no longer necessary for us to hold the data or if there is no lawful ground for processing.
  • Right of Rectification – You have a right to request that any incorrect, inaccurate or incomplete data is updated, corrected
    and/or completed.
  • Right of Restriction – You may wish to restrict us from using your data where, for example, you contest the accuracy of
    the data.
  • Right to Object – You have a right to object to us using your data where processing is carried out for our legitimate interest.
    We will no longer process your data unless we can demonstrate compelling legitimate grounds.
  • Right to Data Portability – You have a right to request we share your data with another organisation and we will assist with
    that process where possible.

Complaints

If you wish to make a complaint then you may do so in person, by telephone, in writing and/or by email. Please note that all
complaints are dealt with according to our complaints policy and will be fully logged and investigated.

You can also contact the CNPD (“Comissão Nacional de Protecção De Dados”) which is the national supervisory authority for data
protection issues (www.cnpd.pt).

General

We will not transfer your data to a country outside of the European Economic Area unless that country ensures an adequate level
of data protection, has appropriate safeguards in place or relies on one of the derogations provided for under applicable law and
regulation.

This Statement may be updated by us at any time.

Link Financial, May 2018