GLOBAL CANDIDATE PRIVACY NOTICE

Last modified: May 2025

Moon Active Ltd. and its subsidiaries and affiliates (collectively, “Moon Active“, the “Company”, “we“, “our” or “us“) is committed to protecting the privacy and security of your personal data. This Candidate Privacy Notice (“Notice”) describes how we collect and use your personal data when you apply for a job or other role with us, and the rights you have in connection with that information.

The precise data controller in respect of your personal data will typically be the Moon Active entity to which you are applying, although other entities in the Moon Active group may access and process your information for the purposes set out in this Notice.

The terms “candidate” or “you” that are used in this Notice refer to anyone who applies for a job role and/or internship opportunities, or who otherwise seeks to carry out work with or for us (whether on a permanent or non-permanent basis).

This Notice does not form part of any contract of employment or other contract to provide services.

It is important that you read this Notice and any other privacy notice we may provide to you on specific occasions when we are collecting or processing personal data about you, so that you are aware of how and why we are using such information and what your rights are under applicable data protection legislation.

1. Sources of your personal data

1.1. Personal data we collect from you

To process your application, we ask you to provide personal data about yourself. All personal data is provided on a voluntary basis, and you determine the extent of information you provide to Moon Active. However, some personal data may be necessary to complete an evaluation of your application, and if it is not provided, our ability to consider you as a candidate may be limited.

The types of personal data we may collect and process when you apply for a role with us include (but not limited to):

Category of personal data collected	What this means
Identity data	Such as name, address, email address, phone number and other contact information.
Background information	Such as certifications, résumé, curriculum vitae, cover letter, training courses, publications, transcript information, work history, professional qualifications, performance information, details included in your CV/resume (which might include details of any membership or interests constituting sensitive personal data), references provided, information provided or confirmed by academic institutions and training or certification providers.
Education information	Such as academic degrees, professional qualifications, certifications, training courses, publications, and transcript information.
Information necessary to confirm your ability to work for Moon Active	Such immigration information, citizenship, visa information and similar information, where it is legally required or permitted to collect as part of the application process.
Public Information	Such as social media profiles (where permitted).
Audio, electronic, visual, or other sensory information	Such as CCTV footage at Moon Active physical office locations, badge entry and exit information (including badge photo, where applicable), and interview recordings (where permissible).
Lifestyle data	Information provided by you on a voluntary basis, such as your hobbies, social activities, holiday preferences and links to social media accounts.
Other information you provide to us	Any other personal data you voluntarily choose to provide in connection with your job application, such as your age or compensation history.

Certain categories of data may be afforded more protection under applicable data protection laws (“Sensitive Personal Data”). In the EU/UK, Sensitive Personal Data includes any information that reveals your racial or ethnic origin, religious, political or philosophical beliefs, genetic data, biometric data for the purposes of unique identification, trade union membership, or information about your health/sex life.

As a general rule, we try not to collect or process any Sensitive Personal Data about you, unless authorized by law or where necessary to comply with applicable laws. However, in some circumstances, we may need to collect or request on a voluntary disclosure basis, some Sensitive Personal Data for legitimate recruitment-related purposes; for example, information about your disabilities for the purposes of equal opportunities monitoring (on the basis that it is in the public interest and in accordance with applicable law).

1.2. Personal data collected from third parties

Depending on your residency, we may collect some information from sources other than you in the course of our recruitment process, including, without limitation:

Certain background and other information from recruitment or executive search agencies, academic institutions, referees, background checking agencies and other third parties during your recruitment;
References provided by referees;
Information collected from publicly available sources, including any social media platforms you use or other information available online;
We may collect personal data you submit in public forums, such as information made publicly available on a personal webpage (where permitted).

(in each case, where permissible and in accordance with applicable law).

1.3. Personal data we collect automatically

You can visit the Careers section of our website at: Moon Active – Careers (the “Website”) and search for jobs without providing personal data, however, we do collect certain personal data automatically from your device when you visit our Website. For more information, please see our Cookie Policy.

2. Purposes for processing personal data

We will only use your personal data for the purposes for which we collected it, as further explained below, unless we reasonably consider that we need to use it for another reason and that reason is consistent with the original purpose.

Generally, we process personal data for the following purposes:

Recruitment purposes: we collect and process your personal data to determine your qualifications and suitability for employment with us and to reach a hiring decision. This includes assessing your skills, qualifications and background for particular roles, verifying your information, carrying out reference checks or background checks and to generally manage the hiring process and communicate with you about it.
Law-related purposes: we may also process your personal data in order to comply with corporate governance and other legal and regulatory requirements.

If you are accepted for a role at the Company, the information collected during the recruitment process will form part of your ongoing staff member record and will be processed in accordance with the Company’s applicable Data Privacy Notice for Moon Active Personnel.

If you are not successful, we may still keep your application to allow us to consider you for other suitable openings within the Company in the future subject to Section 7 of this Notice, unless you tell us that you do not want us to do so.

3. Legal basis for processing personal data

In respect of each of the purposes for which we use your personal data, certain laws (to the extent applicable) require us to ensure that we have a legal basis for that use. Most commonly, we will rely on one of the following legal bases:

To take steps prior to entering into an employment contract with you, where you are considered for employment.
Where we need to comply with a legal or regulatory obligation, such as immigration and/or employment laws and regulations.
Where it is necessary for our legitimate interests and your interests and fundamental rights do not override those interests, particularly taking into consideration the safeguards that we put in place.
Where we have your consent to do so. Where we have requested your consent to process your personal data, you have the right to withdraw your consent at any time.

If we ask you to provide personal data to comply with a legal requirement or to perform a contract with you, we will make this clear at the relevant time and advise you whether the provision of your personal data is mandatory or not (as well as of the possible consequences if you do not provide your personal data).

If you have questions about or need further information concerning the legal basis on which we collect and use your personal data, please contact us using the contact details provided in Section ‎10 of the Notice.

4. Who we share your personal data with

We take care to allow access to personal data only to those who require such access to perform their tasks and duties, and to third parties who have a legitimate purpose for accessing it. Whenever we permit a third party to access personal data, we will implement appropriate measures to ensure the information is used in a manner consistent with this Notice and that the security and confidentiality of the information is maintained.

Transfer to third party service providers

We may make certain personal data available to third parties who provide services relating to the recruitment process to us, including (in each case, where permissible and in accordance with applicable law), without limitation:

Recruitment or executive search agencies involved in your recruitment;
Background checking or other screening providers (where applicable and permissible); and
Data storage, shared services and recruitment platform providers, IT developers and support providers

We may also disclose personal data to third parties on other lawful grounds, including, without limitation:

Where you have provided your consent;
To comply with our legal obligations, such as where necessary to abide by law, regulation or contract or to respond to a court order;
In response to lawful requests by public authorities (such as for tax, immigration or health and safety purposes);
As necessary to establish, exercise or defend against potential, threatened or actual legal claims;
Where necessary to protect your vital interests or those of another person; and
In connection with the sale, assignment or other transfer of all or part of our business.

5. Transfers abroad

Moon Active operates internationally and uses affiliates and service providers based around the world. In some cases, the sharing described in this Notice may result in your personal data being transferred internationally, including to countries outside the EEA or the UK. In such circumstances, those parties’ processing of your personal data will involve a transfer of your personal data outside of your country of residence where privacy laws may not be as protective as those in your state, province, or country.

Where required by law, we have taken the appropriate safeguards to ensure that your personal data remains protected in accordance with this Notice, including by implementing an appropriate data export solution, such as entering into the EU Standard Contractual Clauses or the UK Standard Contractual Clauses with the data importer or taking other measures to provide an adequate level of data protection under the EU/UK law when transferring your personal data to a country outside of EEA/UK (as applicable).

6. Your privacy rights

You may exercise the rights available to you under applicable data protection laws. Subject to your residency and the data protection laws that apply to you, these may include:

Right to access, rectify and delete your personal data: You have the right to request access to any of your personal data that Moon Active may hold, and to request correction/completion of any incorrect/incomplete data relating to you. You also have the right to request deletion of personal data we hold about you if certain conditions are met.
Right to withdraw your consent to the processing: in cases where we rely on your consent for processing your personal data, you can withdraw such consent at any time. Withdrawing your consent will not affect the lawfulness of any processing we conducted prior to your withdrawal, nor will it affect processing of your personal data conducted in reliance on lawful processing grounds other than consent.
Right to restriction: in some cases, you have the right to restrict the processing of your personal data, for example when the accuracy of your personal data is contested, you do not want your data to be erased, the decision on your objection to the processing is pending or the data is no longer needed for the original purpose but may not be deleted yet because of legal grounds.
Right to object to the processing: you have the right to object to our processing of your personal data when we rely on our legitimate interests. We will no longer process your personal data upon your request, unless we have compelling legitimate grounds for the continuation of the processing which override your interests, rights and freedoms, or for the establishment, exercise or defense of legal claims.
Right to data portability: under certain circumstances, you have the right to have your personal data transmitted to you or to another data controller in a structured, commonly used and machine-readable format.

For further information regarding your rights, or to exercise any of your rights, please contact us via the contact details available in Section 10.

Subject to legal and other permissible considerations, we will make every reasonable effort to honor your request promptly or inform you if we require further information in order to fulfill your request. However, we may not always be able to fully address your request, for example if it would impact the duty of confidentiality we owe to others, or if we are legally entitled to deal with the request in a different way.

In addition to your rights outlined above, if you are not satisfied with our response to a request you make, or how we process your personal data, you can make a complaint to the data protection regulator in your habitual place of residence:

If you are established in the EEA, the contact information for the data protection regulator in your place of residence can be found here: Members | European Data Protection Board.
If you are established in the UK, the contact information can be found here: Make a complaint | ICO.

7. Data retention periods

Personal data will be stored in accordance with applicable laws and kept as long as needed to carry out the purposes described in this Notice, unless a longer retention period is permitted or required by applicable law. We may also retain your personal data in accordance with applicable law to consider you for other job opportunities, unless you have told us that you do not wish us to retain your information for such purposes.

You can request deletion of your personal data at any time (see Section 6 for further information) and we will consider your request in accordance with applicable laws.

8. External links

The Website may provide links to or the ability to connect with third-party websites, services, social networks, applications or social media features (“Application Features”). Connecting with such Application Features may allow the applicable third party to process your personal data, and this Notice does not cover processing activities by such third-parties. Please review the privacy notice of the applicable third party prior to interacting with them or providing them with your personal data for the purpose of submitting your application.

9. Changes to this Notice

We may update this Notice from time to time in response to changing legal or technological developments and/or our business needs. When we update this Notice, we will note the date of its most recent revision above. If we make material changes to this Notice, we may take appropriate measures to inform you in a manner that is consistent with the significance of the changes we make. We encourage you to review this Notice frequently to be informed of how Moon Active is protecting your personal data.

10. Contact details

If you have any questions or concerns about our use of your personal data, please contact us using our e-mail address: [email protected].