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    Hotel Co 51 Privacy Notice for Applicants

    This privacy notice describes how, as part of any recruitment process, Hotel Co 51 B.V. (Hettenheuvelweg 51,1101 BM Amsterdam, The Netherlands) (hereinafter: “Hotel Co 51”, “we”, “our” or “us”) handles, collects and processes your personal data (“Privacy Notice”). We are committed to being transparent about how we collect and use that data and to meeting our data protection obligations. This Privacy Notice applies to all applicants who apply for employment with us (“applicants” or “you”). Hotel Co 51 acts as the “data controller” for the processing of your Personal Data.

    Personal data will be processed in compliance with European data protection, the EU General Data Protection Regulation (Regulation (EU) 2016/679) and any other EU or national legislation which implements or supplements the foregoing). “Personal data”, “Processor”, and “Controller” have the meanings given in the applicable data protection laws.

    Any questions about the contents of this privacy notice or how personal data will be used, stored, or transferred, should be sent to dpo@hotelco51.com.

    1. Where do we get your Personal Data from? Hotel Co 51 may collect your Personal Data from the following sources: (i) We may obtain your Personal Data you provided to us as part of your job application process. (ii) We may collect Personal Data that is publicly available, including via social media (to the extent that you choose to make your profile publicly visible). (iii) We may receive your personal data from the different job boards we use. (iv) We may receive your Personal Data from third parties who provide it to us, e.g.: ➢ Recruitment or executive search companies; ➢ References provided by referees; ➢ Background information provided or confirmed by academic institutions or certification providers; and/or ➢ Other Hotel Co 51 entities for the purposes outlined in this Privacy Notice. 2. Which categories of Personal Data do we Process? For the purpose of managing your application throughout the entire application process, Hotel Co 51 may Process the following types of Personal Data: • Personal details, including contact details: such as your first and last name(s), address, email address, telephone number, gender, nationality, citizenship, date of birth, degree/title, social security/national identification number or national insurance number (where applicable), details of dependents and family members (where applicable). • Recruitment data and professional qualifications: such as any Personal Data contained in your resume, application form and other application documentation such as education and work history, certificate of good conduct, certificates, licences, experience information, references and referee details, publicly available information displayed on platforms such as LinkedIn, language skills and memberships of committees or other (voluntary) bodies. • Interview data and assessments results: such as records of interviews or interview notes. For certain roles, we will obtain the results from assessments we have conducted with you or from assessment agencies that have conducted an assessment with you. • Documentation required under immigration laws: such as citizenship and residency information, visa number (where applicable), work permits (where applicable / required to comply with laws). • Video surveillance (CCTV) footage: such as video surveillance footages recorded in our premises if you come to our site for an interview. • Visitor logs: some of our premises have a registration log for visitors, logging first and last name, time of arrival & departure and, if applicable, vehicle registration number. • Feedback information: any feedback or opinions you voluntarily provide to us during the recruitment process. • Any other Personal Data: any other Personal Data which you choose to disclose to us during the course of the application process.

    In principle, we do not collect or use any special categories of Personal Data of applicants, such as health data or other sensitive types of data, unless you provide this to us voluntarily as part of your application documentation or during an interview.

    3. Lawful basis for processing of Personal data Please see below the purposes for processing your Personal Data and the corresponding Lawful Basis.

    Purpose:

    To conclude (and take steps prior to entering into) an employment or other type of contract with you.

    Lawful Basis:

    • Necessary for the hiring decision/performance of contract of employment or other agreement with applicant • Necessary for the purposes of a legitimate interest of Hotel Co 51 or other third parties*

    Purpose:

    For handling emergencies and maintaining on site safety and security: (a) ·communicating with designated contacts in case of an emergency; (b) Processing as required to ensure the safety and protection of Hotel Co 51’s workers, facilities, resources, and communities including (without limitation) protecting occupational health and safety and authenticating worker status to authorize access to Hotel Co 51 technology, resources and facilities; and (c) conducting security screenings, to the extent permitted by law.

    Lawful Basis:

    • Necessary for the protection of the vital interests of the applicant or of another individual • Necessary for the purposes of a legitimate interest of Hotel Co 51 or other third parties*

    Purpose:

    For legal and regulatory purposes: (a) complying with applicable laws and statutory requirements such as income tax, national insurance deductions, and employment and immigration laws; and (b) responding to and complying with requests and legal demands from regulators or other authorities.

    Lawful Basis:

    Necessary for compliance with legal obligations to which Hotel Co 51 is subject in particular in the area of labor and employment law, social security and protection law, data protection law, tax law, and corporate compliance laws

    Purpose:

    Where we have your consent: In principle, we do not rely on your consent to Process your Personal Data. We will only do so in very limited circumstances. If we do so, we will provide you with full details of the data that we would like and the reason we need it, so that you can carefully consider whether you wish to freely consent. Where we rely on consent as a lawful basis, you have the right to withdraw your consent for use of your Personal Data at any time using the contact details provided in Section 9 of this Privacy Notice.

    Lawful Basis:

    Consent

    4. How do we protect Personal Data? We have implemented adequate technical and organisational measures to protect Personal Data against unauthorised, accidental or unlawful destruction, loss, alteration, misuse, disclosure or access and against all other unlawful forms of processing. All personnel accessing Personal Data must comply with the internal rules and processes in relation to the processing of Personal Data to protect them and ensure their confidentiality. They are also required to follow all technical and organisational security measures put in place to protect the Personal Data. 5. Who has access to Personal Data and with whom are they shared? 5.1 Within Hotel Co 51 and Interogo Holding Group We may transfer Personal Data internally at Hotel Co 51 on a need-to-know basis and to other companies of the group to which we belong (the “Interogo Holding Group”). Such other companies of Interogo Holding Group will either act as another controller under this notice or will only process personal data on behalf and upon request of Hotel Co 51. 5.2 Outside Hotel Co 51 and Interogo Holding Group We may also transfer Personal Data to third parties outside Interogo Holding Group to complete the purposes listed in Section 3 above, to the extent they need it to carry out the instructions we have given to them. Such third parties may include: • Third parties who process Personal Data, such as our (IT) systems providers, our payroll provider, transport companies or travel agency, cloud service providers, database providers, consultants and third parties who carry out pre-employment checks and tests on prospective Co-workers. These third parties have entered into an agreement with Hotel Co 51 to keep Personal Data secure; • Successors in title of our business in case of a corporate transaction; • Any national and/or international regulatory, enforcement or exchange body or court where we are required to do so by applicable law or regulation or at their request; and any central or local government department and other statuatory or public bodies. 6. Transfers outside the European Economic Area The Personal Data transferred within or outside Interogo Holding Group as set out in Sections 5.1 and 5.2, may also be processed in a country outside the European Economic Area (the “EEA”), which covers the EU Member States, Iceland, Liechtenstein and Norway. Non-EEA countries may not offer the same level of personal data protection as EEA countries. If your personal data is transferred outside the EEA, we will put suitable safeguards in place to ensure that such transfers is carried out in compliance with the applicable data protection rules. You may request additional information in this respect and obtain a copy of the relevant safeguard by exercising your rights as set out below.

    7. For how long do we keep and store your Personal Data? We will keep your Personal Data for as long as necessary to fulfil the purpose for which it was collected. This means that if your accept employment with us, we will keep and use your Personal Data in accordance with our Employee Privacy Notice, which is provided to all employees. If your application was not successful, we will only retain your Personal Data for 3 months, unless you consent to keep your record for one year in order for us to contact about possible future job opportunities with us.

    8. Individual rights

    Individuals whose Personal Data is processed by Hotel Co 51 have certain legal rights in respect of the information. These include: • Request access to your Personal Data (for example the right to be provided with certain information about Hotel Co 51’s Processing of Personal Data and access to that data (subject to exceptions)); • Request rectification or correction of your Personal Data (such as where the employee’s home address changes and Hotel Co 51 needs to have the up to date information); • Request erasure of your Personal Data in certain circumstances including where it is no longer necessary for Hotel Co 51 to Process the Personal Data for the purpose it was collected; • Request restriction of Processing of your Personal Data (for example, where you dispute the accuracy of Personal Data relating to you or where Hotel Co 51 no longer needs the Personal Data but the contractor needs it for the establishment, exercise or defense of legal claims); • Request data portability (such as the right to receive any Personal Data you have provided to Hotel Co 51 in a structured, commonly used and machine-readable format, as well as to require Hotel Co 51 to transmit it to another controller when technically feasible); • Object to the Processing of your Personal Data (such as on grounds relating to their particular situation where such Processing is based on Hotel Co 51’s legitimate interests or on public interest); and • Withdraw consent (where such consent was obtained and relied on for the purposes of the Processing).

    You also have the right to lodge a complaint at the local supervisory authority.

    Applicants wishing to exercise any of the above rights can send an email to dpo@hotelco51.com. Hotel Co 51 will honour any of the above requests, withdrawal or objections as required under the applicable data protection rules but not all of these rights are absolute; they do not always apply, and sometimes exemptions may be engaged. We may, in response to a request, ask you to verify your identity and/or provide information that will help us to understand your request better. If we do not comply with your request, we will explain why. 9. Updates This Notice may be revised from time to time. If a fundamental change to the nature of the use of your Personal Data is involved or if the change is in any other manner relevant to you, we will ensure that information is provided to you in advance of the change actually taking effect.

    10. How to contact us? If you have any questions or concerns regarding our use of your Personal Data, or if you wish to exercise any of your rights, please email us at dpo@hotelco51.com, indicating the nature of your query.

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