Job Applicant Privacy Notice

Oximio, (SMO UK LIMITED, together referred to as ‘Oximio, ‘we’, ‘us’ ‘our’ throughout this notice) commits to the protection of your personal data that is shared with us. This Job Application Privacy Notice provides information on how Oximio processes your personal data during the recruitment process, as well as our rights in respect of this personal data. What personal data do we collect? In terms of our recruitment process, we kindly ask you to provide us with your personal data for the purposes of evaluation of your application. Please note that all the data that you provide to Oximio is supplied on a voluntary basis. Oximio will be the personal data controller of the personal data that you may provide to us on this occasion. The extent to which you disclose it wholly depends on you. Basically, Oximio may collect the following personal data of yours:

• Name, identity and contact details
• Employment background – e.g., current and previous positions, work experience, employment references
• Educational background – e.g., degrees, certificates, schools and other information pertaining to the education you have received (or are currently receiving)
• Any other information that you decide to share with Oximio – e.g., personal preferences, social preferences, hobbies.

Oximio does not require you to provide any sensitive personal data including that pertaining to your health, religion, political affiliation and sexual orientation. We may receive data pertaining to you from third parties. For instance, you may provide us with access to your job-related social media profiles, or you may provide data to our contractors providing us with recruitment services. By providing us with access to this data, you agree that Oximio may treat this data in accordance with this Privacy Notice. Our purposes for processing your personal data Oximio may process your personal data in order to:

• Evaluate your application
• Make a decision on further employment with Oximio or with any other companies of the SMO Group (here and further – subsidiaries of SP-Logistics Holdings LTD or affiliates to SMO UK LIMITED)
• Arrangement of employment visas (if required)
• Prepare your employment contract.

Legal basis on which Oximio processes your personal data For the purposes of processing your personal data, Oximio relies on our legitimate interests that are not overridden by your interests, fundamental rights and freedoms. We have legitimate interests in:

• Processing your personal data during the recruitment process and keeping relevant records. This processing facilitates management of the recruitment process, assessment and confirmation of your suitability for the contemplated position at Oximio. We may need to process the personal data to respond and defend against legal claims
• Providing top-quality clinical trials logistics services that would depend on recruitment of our personnel
• Developing and growing our business that inherently depends on recruitment of our staff.

Occasionally, we need to process your data to comply with our legal obligation (e.g., if we are required to check your eligibility to work in the country of the Oximio business location). Additionally, Oximio may process your personal data in order to conclude an employment contract with you. Special provision for recruitment agencies In cases where the personal data is provided by a recruitment agency (its representative, employee, contractor, director, etc.), the recruitment agency bears full responsibility for the lawfulness of transfer of the personal data to Oximio and it warrants that the agency has a viable legal basis for collection, processing and transfer of the personal data provided to Oximio . The recruitment agency undertakes to indemnify Oximio and any company of the SMO Group from any claims, damages and requirements pertaining to this transfer of the personal data. Who may have access to your personal data? Your personal data may be shared internally within the Oximio for the above-mentioned processing purposes. The personal data may be accessed by our HR Team members and employment Managers that are either employed at Oximio or at any of the SMO Group companies. Oximio also reserves its right to provide your persona data to any relevant state authority in case such data transfer is required by law or other mandatory regulations. How will Oximio process your personal data? For the above-mentioned recruitment purposes, Oximio may perform the following processing operations with your personal data: recording, organization, structuring, storage, retrieval, use, disclosure by transmission, destruction. Profiling and automated decision making Oximio does not perform any profiling and automated decision-making pertaining to you with the usage of your personal data. How does Oximio protect your personal data? We have internal policies and controls in place preventing your personal data from being lost, accidentally destroyed, misused, or disclosed. Your personal data will be accessed only by authorized personnel, unless otherwise stated previously in this Privacy Notice. How long do we keep your personal data? Oximio will retain your personal data only as long as we have a legitimate purpose for such retention. If your application is unsuccessful, we will retain your data for 6 months for the purposes of possible future employment in case we have similar or suitable positions to offer to you. Once we have no legitimate reasons for the retention of your personal data, Oximio will securely delete and destroy it. In case of your successful application, your data may be further used for employment with Oximio or any of the SMO Group companies. Special provision for applicant from Russian Federation Please be assured that Oximio fully complies with all local personal data protection requirements. If you are from the Russian Federation and/or you are subject to Russian personal data protection regulations, your personal data will be permanently stored in a dedicated server located in the territory of the Russian Federation. International transfers During processing of your personal data, we may transfer this data internally between the companies of the Oximio. Such transfers may include cross-border transfers within or outside EEA countries. Transfer outside the EEA may rely on transfer to countries with an adequate level of personal data protection (i.e., Israel) or may be performed based on the standard data protection clauses approved by the Commission. Your rights as the Data Subject As a personal data subject, you have the following rights that may be subject to certain limitations according to the provisions of GDPR, Data Protection Act 2018 or other applicable privacy laws and regulations:

• Access – you have the right to request information on how we process your personal data and obtain a copy of this personal data
• Rectification – you have the right to request rectification of inaccurate personal data pertaining to you and to require any incomplete personal data about you to be corrected
• Objection – you have the right to object to processing of your personal data
• Erasure – you have the right to request erasure of your personal data
• Restriction – you have the right to ask us to restrict our processing of your personal data, so that we no longer process this data until the restriction is removed
• Portability – you have the right to receive your personal data, which you have provided to us, in a structured, commonly available and machine-readable format.

Please note that you have a right to address a relevant supervisory authority, however, we kindly ask you to lodge with us any complaints you may have so that we may efficiently settle any relevant issues. If you do not provide your personal data Please note that you are under no statutory or contractual obligation to provide your personal data for the Oximio recruitment process. Provision of the data must made voluntarily and with the full understanding of the content of this Privacy notice. In the case where you do not provide your personal data to Oximio, we may not be able to consider your application.. Changes to this Job Applicant Privacy Notice We reserve the right to change the terms of this Privacy Notice at any time by posting revisions to our website. If we lawfully decide to process your personal data for other purposes than those provided in this Privacy Notice, we will provide you with the relevant notice. Contact us Please contact Oximio if you have personal data protection questions or concerns, or if you wish to make a complaint by sending an email to RA@smo-group.com.