Applicant Privacy Policy Notice

By submitting your information and application, you confirm that you have read and agree to the country or regional recruitment notice to your place of residence detailed below.

1. Scope

1.1 This Job Applicant Privacy Notice (“Notice”) details the Personal Information (defined below) ZT Group Int’l, Inc. and its affiliates (together, “ZT Systems”, “Company”, “we”, “our”, “us”) receives about job applicants of the Company (collectively, “Applicants”). If you are located in the UK or the European Union (“EU”), please see Annex 1 for the EU/UK specific additional information regarding the processing of your Personal Information and EU/UK specific rights. If you are located in the mainland of the People’s Republic of China (“PRC”), please see Annex 2 for the PRC specific additional information regarding the processing of your Personal Information and PRC specific rights. This Notice also details how we process Personal Information about Applicants and your respective rights regarding such information. “Personal Information” means information that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular Applicant.

1.2 This Notice applies to Applicants whose Personal Information is collected by us.

1.3 We may update this Notice from time to time.

1.4 You may contact us for all questions relating to this Notice:

• Contact: Human Resources
• E-mail: [email protected]
• Phone: 201-559-1000
• Address: 200 Plaza Drive, 3rd Floor, Secaucus, NJ 07094 USA

2. What personal information does Company collect and use about personnel and for what purposes?

2.1 We may collect some or all of the following Personal Information about you as part of your job application with us and we may use it for the following purposes:

Table A

Categories of Personal Information Collected	Purpose for Use and Disclosure	Categories of Recipients	Legal Basis for Processing (as may be applicable)
Identity information such as name, contact information, gender, citizenship, nationality, date of birth, photograph, (including race, gender, and social security number), passport or other unique ID number, proof of eligibility to work and details of any visa or work permit application, including biometric data, personal and family details, and medical and health screening details.	We use this information to determine and validate your qualifications and suitability for employment, verify your eligibility to work, obtain references, screen your educational and professional background information, conduct background checks, improve our recruiting process, create an employment record, and communicate with you.	Vendors who provide services on our behalf (e.g., cloud service providers, background check providers, benefits programs, etc.) Other personnel in order to communicate with you.	Necessary for entry into employment contract. Verifying eligibility to work and certain background checks are necessary for our legal obligations as an employer. Necessary for our legitimate interests (to comply with its responsibilities as an employer and help us prevent fraud).
Contact details such as home and work address, phone number(s), email address(es), emergency contacts, beneficiaries and next of kin.	Contact you and for personal administration including maintaining your contact information and emergency contact information.	Vendors who provide services on our behalf (e.g., cloud service providers, background check providers, benefits programs, etc.)	Necessary for our performance of your employment contract. To protect the vital interests of the data subject.
Information with respect to your previous employment and qualifications, such as, date of hire, employee category, full/part-time status, qualifications, references, resumé(s) or curriculum vitae, language(s) spoken, background checks (including education, professional licenses, civil and criminal records, regulatory matters, directorship, and credit checks) and membership of professional bodies.	We use this information for job application management purposes.	Vendors who provide services on our behalf (e.g., cloud service providers, background check providers, benefits programs, etc.)	Necessary for our legitimate interests (to comply with its responsibilities as an employer and to run a successful and efficient business).

3. How long does Company retain personal information?

We retain your Personal Information in accordance with the appropriate statutory limitation periods as provided by applicable local laws or administrative regulations, or in other cases, for as long as such Personal Information is needed for the following reasons:

3.1 as required by law or court order;

3.2 as needed to defend or pursue legal claims;

3.3 in line with industry codes of practice;

3.4 to fulfil our employment relationship with you; and/or

3.5 as required for legitimate business purposes.

4. How does Company use applicant personal information?

4.1 Your Personal Information will be handled by us in accordance with this Notice.

4.2 Your Personal Information may be retained in accordance with the policies and procedures adopted by us from time to time and (a) as required by law, regulation, legal or judicial process or audit, decision of a court or arbitral tribunal, decision of a governmental authority with relevant powers, or by the rules of applicable stock exchange or recognized market place, or by a regulator, or self-regulatory organization or pursuant to mandatory ethics rules applicable to us or our affiliates (collectively, “Law”) or (b) as reasonably required in relation to any claim or investigation pursuant to any Law and/or any matter which may lead to such a claim or investigation (a “Claim or Investigation”).

5. Disclosure of Applicant Personal Information

5.1 Where we are under an obligation to do so by law, we will disclose Personal Information to regulators, courts, the police or tax authorities, or in the course of litigation or other legal or regulatory matters. We may also disclose Personal Information to third parties in the context of any sale, merger or acquisition of a company or business in which we are involved. In some cases, it may not be reasonably practicable or possible to notify you in advance about the details of such disclosures. We will use reasonable efforts to disclose the minimum Personal Information necessary in such cases.

5.2 Personal Information may also be disclosed to a third party such as your bank, mortgage company, lender, credit agency, other financial institutions, landlord, prospective employer, relocation company, visa or travel agency, but only with your consent.

5.3 We use a number of third-party vendors (such as for occupational health, employee assistance, relocation services, visa and travel, training, time and attendance and office security, IT service providers, human resources, expenses, payroll, legal counsel, accounting, tax advisors, etc.) to provide services to us. We will use reasonable efforts to ensure that such suppliers protect your Personal Information with appropriate security measures.

Annex 1 – EU/UK Job Applicant Notice

1. Controller Information

For the purposes of UK General Data Protection Regulation and the Data Protection Act 2018 (“UK GDPR”), if you are located in The Netherlands, ZT Netherlands B.V. is the data controller.

2. Our Legal Basis for Processing

Please refer to Table A above.

3. Disclosure of Your Personal Information and Transfers Overseas

All your Personal Information will be accessible from and may be transferred to our parent company in the United States under the European Commission’s model contracts for the transfer of Personal Information to third countries (i.e., the standard contractual clauses) or any equivalent contracts issued by the relevant competent authority of the UK, as relevant.

4. Your Rights

4.1 You have the right to ask us for a copy of your Personal Information; in certain circumstances, to correct, delete or restrict (stop any active) processing of your Personal Information; and to obtain the Personal Information you provide to us in a structured, machine-readable format and to ask us to share (port) this data to another organization.

4.2 In addition, you can object to the processing of your Personal Information in some circumstances (in particular, where we are not required to process your data to meet a contractual or other legal requirement). These rights may be limited, for example if fulfilling your request would reveal Personal Information about another person, or if you ask us to delete information which we are required by law to retain or have compelling legitimate interests in retaining.

4.3 To exercise any of these rights, please contact our Human Resources Team at [email protected]. In addition, you have the right to complain to your applicable data protection supervisory authority.

ANNEX 2 – PRC Addendum to Job Applicant Privacy Notice

This PRC Addendum to the Job Applicant Privacy Notice applies to you if you are within the mainland of the People’s Republic of China (“PRC”) in which case your Personal Information will be Processed in accordance with the PRC’s Personal Information Protection Law.

Entrusted Processing, Sharing, Disclosure of Your Personal Information and Transfers Overseas

List of Overseas Recipients

All of your Personal Information will be stored outside of the PRC and may be accessed by and transferred to our parent company in the United States, as well as to certain third parties outside of the PRC for the purposes set out in the Privacy Notice. Our data transfers to overseas recipients will be in accordance with PRC laws and regulations, including those on cross-border data transfer.

You may check the name and contact information of the overseas recipient, the purpose and method of processing, the types of Personal Information processed and the mechanism in which you can exercise your rights as a data subject by referring to the list of overseas recipients below.

Overseas recipient	Contact information	Purpose and method of processing	Type of information	Way of exercising right
ZT Systems affiliates	See section 1.4 of this Privacy Notice.	Internal human resources management and administration	All Personal Information set out in the Privacy Notice	Please email the HR team (see section 1.4 of this Privacy Notice).

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