1. INTRODUCTION

1.1 Pomelo Technology US Inc., a Delaware corporation with the registered address at 251 Little Falls Drive, Wilmington, DE 19808, USA, and its affiliated group companies worldwide ("us", "we", "our", "Pomelo Group", "Pomelo Entites") operating as 'LemFi', recognises and respects the right to personal data protection.

1.2 This Privacy Notice "Prospective Candidates" applies to all Prospective Candidates applying to LemFi for full-time, part-time employment, contract hire or any ad-hoc paid assignment with LemFi ("you", "your").

1.3 If you do not agree with the collection, use, disclosure and processing of your personal data, please do not provide us with your personal information.

2. What is Personal Data

2.1 For the purpose of this Notice, the term 'personal data' means any information relating to natural persons who can be identified or who are identifiable, directly from the information in question, or who can be indirectly identified from that information in combination with other information.

2.2 During and after your recruitment, we receive and process personal data about you for various reasons. This Privacy Notice tells you what kind of personal data we process, the purposes of the processing, the legal basis we rely on to process this data, for how long we retain it and other privacy related details. The information we process about you will vary depending on your location, role, and personal circumstances. Please be aware that data privacy laws may vary in different jurisdictions where Pomelo operates, and that this Privacy Notice is a general guide to how we process your personal data.

2.3 This Notice should be read in conjunction with our third Party Data Processors Privacy Notice:

Ashby's Privacy Notice

2.4 We will provide a 'just in time' notice to cover any additional processing activities not mentioned in this Notice.

2.5 Due to our global presence and matrix structure, other Pomelo Entities may also process your personal data as Data Controllers as your recruitment may require being in contact with other Pomelo Entities. You can receive details about other Pomelo Entities which may process your personal data by contacting us at the e-mail address below:

Email to contact us: Privacy LemFi

3. Who and what is a Data Controller

3.1 Individual entities within the Pomelo Group who decide on the means and purpose of processing your personal data are the ultimate Data Controllers. We take the protection of your personal data seriously and we are fully committed to protecting your personal data. We will only process your personal data for the purposes we inform you about and in accordance with data protection laws applicable to your personal data.

3.2 We may amend this Notice at any time to reflect any changes in the way in which we process your personal data. We will provide you with a new privacy notice when we make any substantial updates, and we may also notify you in other ways from time to time about the processing of your personal data.

3.4 If you have any questions about how we process your personal data, please do not hesitate to contact us by Email at: Privacy LemFi

4. What Personal Data do we Collect**

We may collect personal data, including but not limited to the following::

We may also collect any additional information as considered necessary.

5. WHAT IS THE PURPOSE OF PROCESSING YOUR PERSONAL DATA?

5.1 We process your personal data for the following purposes:

1. identifying and evaluating Prospective Candidates for potential employment, screening as well as for future roles that may become available;
2. maintaining records in relation to recruiting and hiring;
3. ensuring compliance with legal requirements, including those relating to public health and workplace safety;
4. fostering our diversity and inclusion programs and practices;
5. if you receive an offer from us, conducting background checks, including, to the extent permitted by applicable law, criminal history checks;
6. protecting our legal rights to the extent authorized or permitted by law;
7. managing claims or the defense of claims made against us; and
8. protecting the workplace and communicating with medical professionals, law enforcement, or other public authorities in the event of an emergency or public health event, such as when the health or safety of you or one or more individuals may be endangered.

5.2 We may also use your personal data for our analytics purposes, including in aggregated/pseudonymized form, to improve our recruitment and hiring process and augment our ability to attract successful candidates.

6. WHAT ARE THE LEGAL BASIS FOR PROCESSING YOUR PERSONAL DATA?

6.1 We process your personal data as necessary to fulfil our legal and contractual obligations as a recruiter under applicable laws, to manage the recruitment process based on our legitimate interest and for compliance with legal obligations to which we are subject.

6.2 We may rely on our complying with applicable law with regard to personal data necessary to satisfy our legal and regulatory obligations, including with regard to public health and workplace safety.

6.3 We may also process your personal data to perform precontractual measures relating to your potential employment relationship with us.

6.4 In certain specific situations we may also process your personal data based on your consent (e.g., for using your photograph attached to your submission or your voluntary submission of an application outside the ongoing recruitment processes). Where we process your personal data on the basis of consent, this may be withdrawn at any time.

6.5 We may also process your personal data if processing is necessary to secure your vital interest (e.g., in case of emergency).

6.6 We will only use your personal data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason being compatible with the purpose for which they were initially collected or where we have the legitimate interest provided it does not unduly affect your interests or fundamental rights and freedoms. Please note that we always seek to balance our legitimate interests with your privacy when processing your personal data on this basis.

Such 'legitimate interests' are:

1. evaluating your application to manage our relationship with you, to ensure that we recruit appropriate employees, and to evaluate and maintain the efficacy of our recruiting process more generally;
2. meeting our corporate and social responsibility objectives,
3. the establishment or assertion of civil law claims by Pomelo in the course of its business, as well as the defense of such claims,
4. internal administrative purposes, e.g., measures taken to maintain operational activities (e.g., workforce planning, budget planning, space planning, etc.).

6.7 If we need to use your personal data for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so.

7. HOW WE COLLECT AND RECEIVE YOUR PERSONAL DATA?

7.1 Generally, we collect personal data directly from you, during the recruitment process. However, some information about you has been inferred based on other information you provide us, through your interactions with our human resources staff, or from third parties such as your recommender or recruitment agencies. In some cases, the third parties will be acting as a controller of your personal data and therefore we advise you to read their privacy notice and/or data protection policy.

7.2 The provision of your personal data is mandatory and necessary for the recruitment. If you do not provide your personal data to us, we will not be able to hire you.

8. BACKGROUND SCREENING

8.1 If you receive an offer from us, we may conduct a background check on you or instruct a third party to do so on our behalf. Background screening will only be done where permitted by the law applicable to the location where the position is located and to the extent necessary and proportionate to the role that you are being offered.

8.2 A background check will only involve criminal background data to the extent permitted by law. Our legal basis for background screening is our need to perform precontractual measures related to establishing our employment relationship. If a background screening is required, you may be contacted by us or a third-party background screening service provider to request authorization for the release of your information, and at that time you will be provided with further information about the process and what personal data it might involve.

9. AUTOMATED DECISION MAKING / PROFILING

We do not take decisions having a significant impact on you based only on using automated means. There is always human intervention into decisions based on automated processing.

10. WHO WE SHARE YOUR DATA WITH.

10.1 Internal sharing: in order to carry out the purposes outlined above, personal data about you will be disclosed to human resources and recruitment staff and other internal functions on a need to now basis to manage the recruitment process or where we have a legitimate interest in doing so to payroll, finance or IT services providers, consultants, advisers and auditors.

10.2 Pomelo Group sharing: we may share your personal data with other companies within our group. They may use your personal data as part of our regular reporting activities e.g., on hiring, in the context of a business re-organization or group restructuring exercise or for systems maintenance support and hosting of data. Like most international businesses, we have centralized certain aspects of our data processing in order to allow us to better manage our business and share your personal data accordingly if required and needed in this context.

10.3 Your personal data may be accessed by recruiters and interviewers working in the country(ies) where the position(s) for which you are applying is(are) based, as well as by recruiters and interviewers working in different countries within Pomelo Group.

10.4 We may use third-party service providers to provide a recruiting software system. We may also share your personal data with other third-party service providers that may assist us in identifying and recruiting talent, administering and evaluating pre-employment screening and testing, and improving our recruiting practices.

10.5 Except to the extent necessary to accomplish Pomelo Group uses and purposes described in this Privacy Notice, we do not disclose your personal data to third parties. We also prohibit our service providers from using your personal data for non-Pomelo Group purposes. We do not otherwise share or sell your personal data to third parties.

10.6 We reserve the right to disclose any personal data we have concerning you if we are compelled to do so by a court of law or requested to do so by a governmental entity or if we determine it is necessary or desirable to comply with the law or to protect or defend our rights or property in accordance with applicable laws. We also reserve the right to retain personal data collected and to process such personal data to comply with accounting, tax regulations and any specific record retention laws (where applicable).

10.7 When we share your personal data with third parties and/or within Pomelo Group, we only disclose personal data that is necessary for the recipient in view of the function or to provide their service and in line with applicable law.

11. INTERNATIONAL DATA TRANSFER

11.1 Due to our global presence, the recruitment process may involve an international transfer of your personal data to recipients located in countries outside of the country in which you work or, for Candidates being recruited in the European Union, to countries outside European Union/European Economic Area, including but not limited to the United States, Canada, United Kingdom, European Union member states, Nigeria, Kenya, Ghana, and the Philippines. These countries may have different data protection laws than your jurisdiction, and in some cases, they may not provide the same level of data protection.

11.2 Whenever we share information outside of your domicile, we ensure that the transfer complies with local law so that your personal information is adequately protected. To ensure the continued protection and security of your personal data, we implement appropriate safeguards in accordance with applicable data protection laws. These safeguards may include the use of standard contractual clauses (like EU Model Clauses) approved by the relevant authorities or other measures designed to protect your privacy rights as binding corporate rules, privacy certifications, or adherence to codes of conduct to safeguard your personal data during international transfers.

11.3 As required under the applicable law, third parties are required to use appropriate safeguards to protect personal information, and they can only access the personal information that is necessary for performing their specific tasks. You can obtain a copy of the appropriate or suitable safeguard by contacting us at: Privacy LemFi

12. FOR HOW LONG WE KEEP YOUR PERSONAL DATA

12.1 If you accept an offer of employment with us, any relevant personal data collected during your pre-employment period will become part of your personnel records and will be retained

12.2 In accordance with specific country requirements and with the privacy notice applicable to Pomelo Group employees and staff, which will be provided to you, during the on-boarding process.

12.3 If we do not employ you, and unless you object by following the process described in the section "What Are Your Rights" below, we may nevertheless continue to retain and use your personal data for a period of time (which may vary depending on the country) for system administration purposes, to consider you for other potential future roles, and to perform research. Thereafter, we retain a minimal amount of your personal data to record your recruiting activity with us.

12.4 To the extent that we have collected personal data, including sensitive personal data, for the specific purpose of fulfilling our legal obligations regarding public health or workplace safety, we will retain that data for the duration of those legal obligations. Thereafter, we retain a minimal amount of your personal data to establish our compliance with those obligations.

12.5 We may want to remain in contact with you and consider you for future employment opportunities. In such an event, we will seek your consent to include you in one of our recruiting programs that provides you ways to further learn about and stay in touch with Pomelo either prior to or after you formally apply for a job opportunity. Participation in these recruiting programs is entirely optional.

12.6 Where we process your personal data on the basis of consent, your data will be processed until you withdraw your consent for singular processing purpose (with the proviso that such withdrawal shall not affect the lawfulness of processing carried out prior to the withdrawal of consent).

12.7 When processing of your personal data is no longer necessary in relation to the purposes for which they were collected, we erase the personal data, unless required to retain it under applicable law. Please contact us atPrivacy LemFi if you would like to receive specific retention schedules related to your personal data.

13. WHAT ARE YOUR RIGHTS?

Applicable data protection laws may allow you certain rights in respect of your personal data:

Right to access: you have the right to demand an access into your personal data processed by us and to request a copy of your personal data being processed by us.

Right to rectification: you have the right to have incorrect or incomplete personal data corrected.

Right to erasure: where legally envisaged you have the right to have your personal data deleted under certain circumstances. In the individual case, the right to deletion may be excluded.

Right to restriction of the processing: under certain conditions, you have the right to demand restriction of the processing of your personal data.

Right to data portability: under certain circumstances, you have the right to get the personal data that was provided to us by you free of charge in a readable format.

Right to object: where your personal data is processed on the legal basis of our legitimate interest, you can object processing on grounds relating to your particular situation.

Right to lodge a complaint with the supervisory authority: You have the right to appeal to a competent supervisory authority against the method of the processing of your personal data.

Right to withdraw your consent: You have the right to revoke your consent at any time, without affecting the lawfulness of processing based on your consent before withdrawal.

LemFi will review your requests, demands or objections in accordance with applicable data protection laws. However, please note that these rights are not absolute, and the regulations provide for exceptions to their application.

In order to ensure that your personal data is up to date and accurate, we may periodically ask you to check and confirm the personal data we hold about you or inform us of any changes to that personal data (such as a change of address, contact telephone number.

If you are not satisfied with the way in which we process your personal data, please notify us of the problem and we will investigate any irregularities that arise.

You may exercise your rights by contacting your recruitment partner from human resources department or the Data Protection Manager at Privacy LemFi.