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Firstwork Solutions, Inc.

Global Job Candidate Privacy Notice

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Last updated:  November 2026 

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This Global Job Candidate Privacy Notice (“Notice”) describes what personal data we – Firstwork Solutions, Inc. and our affiliates (“Firstwork”, “we”, “our” or “us”) collect and process on our job candidates, applicants and individuals we or our recruitment partners contact about roles at Firstwork (“Candidates”, “you” or “your”) with respect to our application and recruitment process, why we collect it and how we use it. It also describes how candidates may exercise their rights to such data held with us.

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We strongly urge you to read this Notice and make sure that you fully understand and agree to it. If you do not agree to this Notice, please avoid providing us with your personal data. 

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You are not legally required to provide us with any personal data, and may do so (or avoid doing so) at your own free will. However, without it, we may not be able to process your application.

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  1. What information do we collect and how do we collect it? 

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Throughout the application and recruitment process, you may provide us (or we may otherwise have access to) personal data about you, such as your identifying information, contact details, resume/CV, work-related information, salary expectations, social media activity, etc. We may collect this information directly from you, as you provide it voluntarily through your application and candidacy review process, or from other sources such as referrals, recruitment agencies, recruitment partners who identify and contact potential candidates on our behalf, background check services (as applicable and subject to applicable law), public information or your references.

In certain regions, we may also require you to submit sensitive data relating to your ethnicity, gender, and whether you have a disability, to ensure our compliance with our legal obligations under applicable law when processing your application. We may also collect sensitive data about your prior criminal convictions and offences as part of our background checks for specific roles if permitted or required by law. To the extent legally required, we will obtain your explicit consent prior to any such collection and use.

For the purposes of the California Consumer Privacy Act (“CCPA”), in the last 12 months, we have collected the above-mentioned types of personal information about our Candidates, which pertain to the following categories: identifiers; customer record information; protected characteristics; professional or employee-related Information; geolocation data; audio, electronic or similar Information; education information; and Inferences from personal information collected. We may also require you to submit sensitive personal information (as outlined above).

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  1. For what purposes do we use your personal data?
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    1. We use your personal data as part of the employment application for the following purposes and in reliance on the lawful bases detailed below: 

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Should we wish to conduct any additional activities that may require the use of your personal data, we will notify you in advance, and if required by applicable law, request your prior specific consent. 

If you reside in a territory governed by privacy laws under which “consent” is the only or most appropriate legal basis for the processing of personal data as described herein, your application means that you have had the opportunity to read and that you accept this Notice and will be deemed as your consent to the processing of your personal data for all purposes detailed in this Notice. If you wish to revoke such consent, you may do so at any time by contacting us at privacy@firstwork.com. 

We do not use or disclose sensitive personal information outside of the purposes allowed by the CCPA. 

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  1. Where do we store our personal data?

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Your personal data will be maintained, processed and stored by Firstwork and our Service Providers (as defined in Section 6 below) in the applied position’s location(s), in jurisdictions where Firstwork operates or has personnel (including in the US, India, the UK, and the UAE), and other jurisdictions, as necessary for the proper handling of your candidacy. 

While privacy laws may vary between jurisdictions, Firstwork, our affiliates and Service Providers processing personal data on our behalf, are each committed to protecting your personal data in accordance with this Notice, customary industry standards, and such appropriate lawful mechanisms and contractual terms requiring adequate data protection, regardless of any lesser legal requirements that may apply in the jurisdiction to which such personal data is transferred.

To the extent we transfer Candidates’ personal data originating in the European Economic Area (EEA), UK, or Switzerland to countries that have not been recognized as offering an adequate level of data protection by the relevant competent authority, we rely on appropriate contractual undertakings and data transfer mechanisms as established under applicable law, such as the standard contractual clauses adopted by the EU (available here) and the UK (available here). 

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  1. For how long may we keep your personal data? 

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Firstwork will retain personal data for the period necessary to fulfill the purposes outlined in this Notice, unless a longer retention period is required or permitted by law. The criteria used to determine the retention periods relate to the nature, scope, context and purposes of processing. For example, we may retain personal data even after the applied position has been filled or closed so we can reconsider Candidates for other positions and opportunities at Firstwork in the future. We may also retain personal data to use as reference for future applications submitted by a Candidate. Where a Candidate is hired, we may retain personal data for additional employment and business purposes. We may also retain personal data as reasonably necessary to comply with our legal obligations, to resolve disputes, prevent fraud and abuse, enforce our agreements or otherwise protect our legitimate interests.

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  1. How do we secure your personal data?

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Firstwork will take appropriate measures to protect personal data that are consistent with applicable privacy and data security laws and regulations, including requiring service providers to use appropriate measures to protect the confidentiality and security of personal data. Please be aware that regardless of the measures we take and the efforts we make, we cannot and do not guarantee the absolute protection and security of any personal data stored with us.

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  1. Who may have access to your personal data?

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Firstwork will share your personal data with our selected Service Providers, whose services and solutions complement, facilitate and enhance the processing of your application and our recruitment process. These include any recruitment partners that have sourced/referred you to us, candidate evaluation centers, recruitment software providers, background checks providers (where applicable), data and cybersecurity services, web analytics, and our business, legal, compliance and financial advisors (collectively, "Service Providers"). Such Service Providers may receive or otherwise have limited access to our Candidates’ personal data, depending on each of their particular roles and purposes in facilitating and enhancing our recruitment process, and may only use it for such purposes. 

We may also work with recruitment agencies who act as independent controllers when sharing with us your personal data for recruitment purposes; in such cases we may share minimal data back with such partners regarding the success of the recruitment process. 

Additionally, we may disclose or otherwise allow competent public authorities access to any Candidate’s personal data pursuant to a binding legal request, such as a subpoena, search warrant or court order, or in compliance with applicable laws, with or without notice to you, if we have a good faith belief that: (a) we are legally compelled to do so;  (b) such disclosure is appropriate in connection with efforts to investigate, prevent, or take action regarding actual or suspected illegal activity, fraud or other wrongdoing; or (c) such disclosure will help protect the rights, personal safety or property of Firstwork, any of our employees, or any member of the general public, including yourself or other applicants.

Finally, we may share personal data internally within our family of companies, for the purposes described above. In addition, should Firstwork undergo any change in control, including by means of merger, acquisition or purchase of all or part of its assets, your personal data may be shared with the parties involved in such event.

For the purposes of the CCPA, in the past 12 months, we may have disclosed to the above-mentioned third parties our candidates’ identifiers; customer record information; protected characteristics; professional or employee-related information; geolocation data; audio, electronic or similar information; education information; Inferences from personal information collected; sensitive personal information.

We do not “sell” or “share” your personal information for the intents and purposes of the CCPA.

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  1. Which cookies and tracking technologies do we use?

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If you apply to one of our positions via our website (or that of a Service Provider) please note the use of certain monitoring and tracking technologies, such as “cookies” or similar technologies. These technologies are used to maintain, provide and improve our processes and operations on an ongoing basis, and in order to provide a better experience to our website visitors and Candidates. For example, these technologies enable us to better secure our website and services and detect abnormal behaviors, to identify technical issues, and to monitor and improve the overall performance of our services and processes. To learn more about our cookies practices, please visit our Cookie Policy or, where applicable, the privacy policies of our Service Providers.

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  1. How can you exercise your privacy rights?

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If you wish to exercise your rights under any applicable law (including the EU or UK General Data Protection Regulation (GDPR), or the CCPA) such as, to the extent applicable – the right to know/access to (specific pieces of personal data collected; categories of personal data collected; categories of sources from whom the personal data was collected; purpose of collecting personal data; categories of third parties with whom we have shared personal data), to request rectification or erasure of your personal data held with Firstwork, to port such personal data, or to restrict or object to such personal data’s processing, to withdraw your consent to any processing of your personal data which is based on such consent (as detailed in Section 2 above), the right to equal services and prices (e.g., freedom against discrimination) or any similar rights afforded to data subjects under the laws that apply to you – please contact us at privacy@firstwork.com. We will respond to your request consistent with applicable law. Please note, however, that such rights are not absolute, and certain personal data may be exempt from requests pursuant to applicable data protection laws or other laws and regulations. Where we cannot accommodate your request, we will inform you of the reasons why, subject to any legal or regulatory restrictions.

If we or one of our recruitment partners acting on our behalf contact you about a role and you do not want to hear from us again, reply to that message or email privacy@firstwork.com saying so, and we will stop contacting you about roles at Firstwork.

You may designate an authorized agent, in writing or through a power of attorney, to request to exercise your privacy rights on your behalf. The authorized agent may submit a request to exercise these rights by emailing us.

Please note that we may require additional information, including certain personal data, in order to authenticate and process your request. Such additional information, along with records pertaining to your request, its handling by us and subsequent communications between you and us, may be then retained by us for legal purposes (e.g., as proof of the identity of the person submitting the request or proof of request response), in accordance with Section 4 above. 

Additionally, you have a right to lodge a complaint with a competent data protection authority, such as the supervisory authority in the EU Member State of your habitual residence, place of work, or of the alleged GDPR infringement, the UK’s Information Commissioner’s Office, or your State’s Attorney General (as applicable).

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  1. Will this Notice be updated?

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We may update this notice to reflect changes in our privacy practices. If we make any changes that we deem as "material", we will update this page prior to the change becoming effective. 

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  1. What if you have any questions?

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If you have any comments or questions regarding our data practices or your privacy, or if you have any concerns regarding your personal data held with us, or if you wish to make a complaint about how your personal data is being processed by Firstwork, you can contact us at privacy@firstwork.com. 

Data Protection Officer: Firstwork has appointed Siva Subrahamanyam Varma Kusampudi as our Data Protection Officer (DPO), for monitoring and advising on Firstwork’s ongoing privacy compliance and serving as a point of contact on privacy matters for data subjects and supervisory authorities. If you have any comments or questions regarding this Notice, any concerns regarding your privacy, or if you wish to make a complaint about how your personal data is being processed by Firstwork, you can contact privacy@firstwork.com.

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