GENIUS PEOPLE DATA PROTECTION POLICY.

IN ORDER TO PROVIDE SERVICES RELATING TO RECRUITMENT, ANALYSIS AND MANAGEMENT OF APPLICATIONS (HEREINAFTER REFERRED TO AS THE "SERVICES") THROUGH THE SITE LOCATED AT THE ADDRESS WWW.GENIUS-PEOPLE.COM (HEREINAFTER REFERRED TO AS THE "SITE"), GENIUS PEOPLE SPRL (HEREINAFTER REFERRED TO AS "GENIUS PEOPLE" OR "US") NEEDS TO ASK USERS TO PROVIDE PERSONAL DATA.

BY USING THE SERVICES OF GENIUS PEOPLE, ANY USER EXPLICITLY DECLARES THAT THEY ACCEPT THE GENIUS PEOPLE DATA PROTECTION POLICY AND UNDERTAKES TO COMPLY WITH IT. THEY CONSENT TO GENIUS PEOPLE COLLECTING AND PROCESSING THE DATA CONCERNING THEM ACCORDING TO THE TERMS AND PRINCIPLES DESCRIBED IN THIS DOCUMENT.

I. DATA COLLECTED WHEN CREATING AN ACCOUNT OR RESPONDING TO A JOB OFFER

When creating an Account or responding to a job offer placed on the Site, Users are asked to complete a form, some fields of which are followed by an asterisk (*) and are required in order to be able to offer the service requested.

"User" is given to mean any individual who uses the Services.

Users who provide personal data to open an APPLICANT Account (APPLICANT Account) or a RECRUITER Account (RECRUITER Account), or to respond to a job offer via the Site shall also be referred to as "Applicants" in the rest of this document.

Individuals who create a RECRUITER Account and/or who access Applicants' data in the context of a recruitment activity are also referred to as "Recruiters" in the rest of this document.

The data communicated by the Users as well as the data related to their use of our Services shall be processed by GENIUS PEOPLE SPRL. These data shall be used to provide and invoice our Services (if the service requested is fee-based) as well as to manage our client base and produce statistics intended to help us improve our Services. We may also process these data in the context of preventing and managing frauds related to the use of our Services and, in the event of a dispute, to defend our interests.

II. APPLICANTS' DATA DISCLOSED TO RECRUITERS

Applicants who create an APPLICANT Account may enter information about their identity (surname, first name, date of birth, photograph), their nationality, their contact details (postal address and e-mail address, telephone number) and data about their education, career, skills and interests.

N.B.: In reality, there are three possible scenarios for an APPLICANT Account :

1. An "active" and "identifiable" CV: The CV and all the other documents created by the Applicant are disclosed by us and may be consulted by Recruiters.
2. An "active" and "anonymous" CV: Recruiters can only access the CV and other documents in anonymous form (which does not mention your identity or your contact details). The Applicant may make their CV "identifiable" to Recruiters who request this through our Services, but only if the Applicant consents to this.
3. An "inactive" CV and all the other documents created by the Applicant are not disclosed by us and cannot be consulted by third parties. These data are stored electronically on a server operated by GENIUS PEOPLE, and the Applicant can attach them to an application when they apply online to one of the job offers on the Site.

Genius People allows an Applicant to apply to an advertisement without being registered. In this specific case, the Applicant's data are stored on our database and only used by the RECRUITER Account linked to the advertisement and by Genius People to encourage the Applicant to register for our services.

The Applicant's data shall be used from the time when the Applicant chooses to create their own APPLICANT Account. By default, the CV is "active" and "identifiable". On their account, the Applicant may choose to leave their CV "active" and "identifiable", "active" and "anonymous", or make it "inactive".

The Applicant consents to these data being made accessible in this way to the Recruiters who receive access to this Database, and consents to these Recruiters being able, if applicable, to copy, record, print and carry out any processing operation on these data for recruitment purposes.

The Applicant consents to their data being able to be accessed and processed by individuals located outside of Belgium, if applicable outside of the European Economic Area, in a country which does not offer protection which is adequate or equivalent to Belgian and European legislation.

We require the Recruiters who access the data from the CV Base:

• to process these data solely for recruitment purposes in the context of their own business activity;
• not to process the data from an anonymous CV to discover the identity of the Applicant in question without going through Us;
• only to keep these data insofar as is necessary for these recruitment purposes, subject to a maximum of five years from receipt of the data from the CV Base;
• to comply with the legislation applicable to them as a data controller.

However, the Applicant is aware that comprehensive monitoring of the User's usage is impossible, accepts the fact that GENIUS PEOPLE cannot monitor how Users store, use and transmit the data obtained through our Services, and releases us from any liability in this regard.

GENIUS PEOPLE keeps Applicants' personal data for five years from the CV Account being deleted in order to be able to produce statistics and studies on the use of our Services with a view to optimising them and being able to offer services or invitations to events, in accordance with the terms laid down in Article II.

III. USE OF USERS' CONTACT DATA

We shall use the contact data provided by a User:

1. To contact them in the context and for the requirements of providing and invoicing our Services, particularly in order to inform them about new functionalities;
2. To send them information about our Services or events related to the recruitment sector that we hold or promote, except if the User has refused this;
3. To send them information about events or services provided by other companies or events organised by third parties related to the recruitment sector, if the User has consented to this;
4. To provide them with job offers that match their search criteria.

You have the option at any time to refuse to allow your contact data to continue to be used in the context of the last two scenarios.

IV. COOKIES

GENIUS PEOPLE may use a technology called a "cookie". A cookie is a small piece of data sent by the server hosting the Site to the User's browser when they access the Site. Cookies make the Site more functional and enable its use to be analysed more precisely. For example, the Site may install a cookie on its Users' browsers so that they do not have to enter their password every time they visit the Site.

We recommend that you accept cookies from GENIUS PEOPLE insofar as they enable the use of certain functionalities of the Site.

V. CONFIDENTIALITY AND SECURITY

Confidentiality. We undertake to observe the strictest confidentiality concerning the personal data that we store and process in the context of the Services and not to disclose them to third parties except insofar as is necessary to provide Services or if the law requires us to do so. We shall ensure compliance with this obligation by our employees, agents or sub-contractors as applicable.

Data storage and security. GENIUS PEOPLE shall take all reasonable technical measures according to the state of the art to protect the personal data against accidental or unauthorised destruction by third parties, against accidental loss as well as against alteration, access and any other unauthorised processing by third parties. However, we cannot guarantee that these data shall not be accessed by third parties in the event of hacking or online piracy.

With regard to the data storage services, the servers on which the data associated with the RECRUITER Accounts are stored, are located within the European Economic Area or in a country offering an adequate level of protection according to the criteria of the Law of 8 December 1992 on personal data privacy. You may ask us for information at any time about where these data are stored.

We may call on third companies and sub-contract services to them or rent a data storage medium from them. In this case, we demand commitments from the sub-contractor or third party in terms of confidentiality and security that are equivalent to those made to the Client in the framework of these general terms as regards the security and confidentiality of the data.

Users whose data are stored by us may request a written description of the technical and organisational measures implemented to ensure the confidentiality and security of the data at any time, by sending a written request along these lines to the following address: Rue Emile Francqui, 7F - 1435 Mont-Saint-Guibert. We may omit from this description any technical information or details which, if disclosed, could prejudice the security of the data.

By using our Services, the User recognises :

• that they have been sufficiently informed about the technical and organisational measures we take to ensure the security and confidentiality of their data so that these are adequately protected, taking into account the state of the art, against accidental or unauthorised destruction by third parties, against accidental loss as well as against alteration, access and any other unauthorised processing by third parties.
• that these measures are sufficient and adequate with regard to the data that the User stores in the context of the Services.

Data security breach. If a User discovers a data security incident, they undertake to inform us as soon as possible at the following address support@genius-people.com.

VI. RIGHT TO ACCESS, CORRECT AND DELETE DATA

Data accessible through the Accounts. A User who has created an APPLICANT Account or a RECRUITER Account may consult, alter or delete their personal data at any time. All they need to do is log onto their Account, go to their profile and make the desired alterations or deletions.

However, if third parties have had access to the personal data of a User who has since consulted, altered or deleted them, GENIUS PEOPLE cannot alter or delete these data on their systems.

Data from the CV Base. The data are in the CV Base for as long as you have an APPLICANT Account and your CV is active.

We will delete your data from the CV Base within one month from the termination of your APPLICANT Account. Furthermore, we reserve the right to delete your data from the CV Base at any time:

• If we believe that the data you have transmitted violate the rules of this Charter or our Terms of Use;
• If we notice that your CV Account has been inactive for more than one year.

Applicants are aware that the fact that their data have been deleted from the CV Base does not mean that these data have been deleted by the individuals who accessed them before they were deleted and who are liable to continue to process these data.

Other personal data. Any User may exercise their right to access, correct and refuse the use of their personal data. For the personal data that we process and which cannot be consulted, corrected or deleted directly by the User through the functionalities of the Services, the User may send an access, correction or refusal request by post to the following address: Rue Emile Francqui, 7F - 1435 Mont-Saint-Guibert.

They will be asked for proof of their identity, which means that they must attach a copy of their identity card. The request must be signed and dated. GENIUS PEOPLE shall act on this request within the period laid down by Belgian data protection legislation.

VII. AMENDMENT OF OUR DATA PROTECTION POLICY

GENIUS PEOPLE reserves the right to update and amend the terms of its data protection policy, at any time and on a regular basis, subject to prior notice. The most up-to-date version of this policy will always be available on the Site. Use of the Site or the Services following amendments or revisions of the Declaration signifies acceptance of the amended or revised Declaration.

VIII. APPLICABLE LAW

Our personal data protection commitments and requirements are subject to the Belgian legislation on personal data protection.