We at Zound Industries International AB, a company duly incorporated in Sweden and its subsidiaries, need to keep information about job applicants and sourced candidates. Job applicants and sourced candidates are hereinafter jointly referred to as “candidates“. Information about candidates is referred to as “personal data”. In this Privacy Policy, we inform you about how we use candidate personal data. In general, the Zound Industries group company that you have been in contact with, is data controller for the processing of your personal data. For information about which Zound Industries group companies that are covered by this Privacy Policy, please see the Candidates’ rights and how to contact us section below.

What kind of personal data do we use?

Personal data may be provided to us by the candidate or from other sources.

Such personal data may broadly be grouped into the following categories:

• Identification data, such as name, User ID and password (if you create an account via our web site) and other data that you may choose to provide, photograph and date of birth;
• Contact details, such as email, address and telephone number;
• Recruitment-related information, such as information regarding previous work experience, qualifications and work history, educational background, language skills, professional skills and talents, professional memberships, geographic mobility interests;
• Publicly accessible personal data, such as information available on social media and information that appear in search results;
• Reference data; contact details to reference persons and information provided by such persons
• Test results; such as from personality tests and logical reasoning tests
• Interview notes;
• Communication details, such as content in correspondence; and
• Reports from candidate sourcing firms and executive search firms; including the aforementioned types of data and assessments and recommendations.
• Connect with us account data; if you register in our candidate pool Connect with us, we will process Identification data, Contact details, date of registration and what positions you have applied for.

Why do we use personal data and why do we have the right to do so?

The main purpose of using the personal data is to manage our process for recruiting staff to various positions. The data is used in order to communicate with candidates, to assess applications and descriptions of qualifications from social media profiles, to make selections between candidates and as a basis for decision making.

Personal data may also be used to meet any employment-related requirements or to coordinate applications internally across relevant Zound Industries companies.

Who do we share candidate data with?

We may transfer personal to third parties for the following reasons:

• Within the Zound Industries Group: personal data may be transferred between group companies for the purposes set out in this Privacy Policy.
• Suppliers: we may use externally provided IT-systems or services to facilitate the recruitment process. Personal data may be made available to such suppliers. Where this is the case, these are subject to appropriate data processing agreements.

Please note that our vendors may act as either data processors, i.e. processing personal data on our behalf, or as data controllers. Where our vendors act as data controllers, they are responsible for providing you with accurate information about their privacy practices. We encourage you to review that information carefully.

For EU citizen
Personal data may be provided to parties that are located outside the European Economic Area (“EEA”), for example if an applicant apply for a position with a Zound Industries group company that is not located in the EEA. In such cases, we will ensure that the personal data is subject to measures that provide an equivalent level of protection as provided by data privacy laws in the EU (such as the EU General Data Protection Regulation; GDPR). Further information about what safeguards we apply with respect to transfer to countries outside of the EEA, you may contact us on the details provided below under the Candidates’ rights and how to contact us section below.

How long do we keep personal data?

Personal data is stored by us or by other parties on our behalf, but only as long as necessary for the performance of our obligations and for the time necessary to achieve the purposes for which the information was obtained.

The personal data will be removed from our records or properly anonymized when it is no longer needed. The main principle is that personal data pertaining to a job application will be deleted as soon as a decision has been made in respect of the job and any applicable

period to appeal or otherwise dispute the decision, e.g. on the basis of discrimination has expired.

If you have created an account with us, you can delete data registered in your account by yourself.

Where the processing of personal data is based on consent, we will retain the personal data encompassed for the validity term of the consent, which is twelve (12) months or until the consent is withdrawn.

Candidates’ rights and how to contact us

If you are located in the EU/EEA, or if your personal data is otherwise being processed by a Zound entity within the EU/EEA, you have the following rights:

1. Right of access: a right to ask whether or not we have personal data about them and, if that is the case, request information on what personal data we have. We will also have to respond to questions about inter alia why we are using personal data, details about what data we have and to whom we have provided access to the data.
2. Right to rectification: We are required to rectify inaccurate personal data, or to complete personal data that is incomplete, on request.
3. Right to erasure (right to be forgotten): We are in some circumstances required to erase personal data on request by the candidate concerned.
4. Right to restriction of processing: We are in some circumstances required to restrict our use of personal data on request by the person concerned. In such cases, we may only use the data for certain limited purposes set out by the law.
5. Right to data portability: Under certain circumstances, candidates may have the right to receive their personal data to which we have access, in a structured, commonly used and machine-readable format and to transmit those data to another entity without hindrance from us.
6. Right to object: In some cases, private individuals are entitled to object to our use of their personal data. We may then be required to stop using the personal data. That may e.g. be the case where we apply automated decision making, including profiling.

In addition to the above, a consent to process personal data can always be withdrawn. Please note that these rights may be subject to national restrictions.

You are welcome to contact us if you have any questions about this Privacy Policy or if you have any other queries as to how we process candidate personal data.

Zound Industries Smartphones AB
Zound Industries International AB
Zound Industries International French Branch
Zound Industries UK Ltd

You can contact us by sending a mail to: gdpr@zoundindustries.com

Candidates may also lodge a complaint with the relevant data protection authority.

Data Protection Authorities

Sweden
Datainspektionen
https://www.datainspektionen.se/

France
Commission nationale de l’informatique et des libertés (CNIL)
https://www.cnil.fr/

United Kingdom
Information Commissioner’s Office (ICO)
https://ico.org.uk/