Data PrivacyPolicy for Candidates and Visitors

1.Introduction

Here at Nexton, we take privacy very seriously and are committed to protecting all the information you share with us.

Within this Privacy Policy for Candidates (the “Privacy Policy”), you will find:

• What information we collect and how we do it
• How we use the information
• What rights you have in relation to this policy

Please, read it carefully. If there are any terms in this Privacy Policy that you do not agree with, or if you have any questions or concerns about our policy or our practices with regards to your personal information, please contact our Privacy Officer at[email protected].

This Privacy Policy applies to all information collected through our website, social media, products, services, sales, marketing or events (we refer to them collectively in this Privacy Policy as the "Services").

For the purpose of this Privacy Policy, any and all individuals who are or have been part of a selection process by Nexton in connection to any of our clients, are referred to as “Candidates”. Any other person that has visited our website, social media, marketing campaigns and/or participated in any way of our events, is referred to as “Visitor”. This Privacy Policy applies to both Candidates and Visitors.

2.Collection of Personal Information

a. Personal Information voluntarily disclosed

We collect the personal information you provide to us such as name, personal identification number, date of birth, full address, contact information, email address, work experience, education, social media accounts and any other personal information you may provide to us (the “Personal Information”).

All Personal Information that you provide to us must be true, complete and accurate, and you must notify us of any changes to such personal information.

b. Personal Information publicly displayed

We may collect certain Personal Information that you publicly display (for instance, through social media platforms such as LinkedIn, Instagram, Facebook, and other social media platforms that exist or will come to existence in the future). This information might also be collected automatically, provided that you have granted public access to the relevant social media.

c. Information from Minors

We do not knowingly solicit data from or market to children under 18 years of age. By using the Website, you represent that you are at least 18 or that you are the parent or guardian of such a minor and consent to such minor dependent’s use of the Website. If we learn that personal information from users less than 18 years of age has been collected, we will take reasonable measures to promptly delete such data from our records. If you become aware of any data we may have collected from children under age 18, please contact us at [email protected].

3.Use of Personal Information

We may use Personal Information to create, operate and improve our Services; to communicate with you; to match job openings with your profile, to customize content for Candidates and Visitors, and to improve our website.

In all cases, your Personal Information is treated as confidential, securely stored and accessible to authorized personnel only.

We use Personal Information, either voluntarily disclosed or publicly displayed, for a variety of business purposes described below:

• Legitimate business interests ("Business Purposes");
• In order to enter into or perform a contract with you ("Contractual Reasons");
• For compliance with our legal obligations ("Legal Reasons").

In particular, we use the information we collect for the following purposes:

• Job Openings. We may use your Personal Information to find and present to you job opportunities that may fit your profile. Accordingly, we may use your Personal Information to present your profile to our clients in relation to a job opportunity.
• Marketing. We use your full name, basic contact data and geographic location to send you marketing and promotional communications. You can opt-out of our marketing emails at any time (see the "Your Privacy Rights" information below).
• Targeted Advertising. We use your basic contact data, e-mail address and location to deliver you targeted advertising. We may work with third parties to develop and display content and advertising tailored to your interests and/or location and to measure its effectiveness.
• Enforcement. We use your full name and basic contact data, national identifiers, automatically collected data and information collected from other sources to enforce our terms, conditions and policies, for Business Purposes, Legal Reasons and/or in some cases for Contractual Reasons.
• Subpoenas and Other Legal Requests. We use your full name and basic contact data, national identifiers, automatically collected data and information collected from other sources to respond to legal requests and prevent harm, for Legal Reasons. For example, if we receive a subpoena or other legal request, we may need to inspect the data we hold to determine how to respond. In general, we can use your information to resolve disputes, charge fees and solve problems.
• Internal Business Purposes. We use your full name and basic contact data, behavior data and other automatically collected data and information collected from other sources for other Business Purposes, such as data analysis, identifying usage trends, determining the effectiveness of our promotional campaigns and to evaluate and improve our Services, our marketing and enhancing your user experience. We also use the information for quality control and staff training.

4.Cookies

We use cookies and other tracking technologies on our website. They ensure a consistent and efficient experience for visitors, and perform essential functions.

Cookies are small pieces of data, stored in text files, and on your computer or other device when websites are loaded in a browser. Both websites and HTML emails may also contain other tracking technologies such as “web beacons” or “pixels”. These are typically small transparent images that provide us with statistics, for similar purposes as cookies.

5.Share of Personal Information

We share information to comply with laws, to protect your rights, and to fulfill business obligations. We take care of allowing your Personal Information to be accessed only by those who reasonably need it to perform their tasks and duties, and sharing it with third parties who have a legitimate purpose to access it.

We may also disclose your information where we are legally required to do so in order to comply with applicable law, governmental requests, a judicial proceeding, court order or legal process, such as in response to a court order or a subpoena (including in response to public authorities to meet national security or law enforcement requirements).

Finally, we may share your data with third party vendors, service providers, contractors or agents who perform services for us or on our behalf and require access to such information to do that work.

We may disclose your personal information for any other purpose with your express Consent.

6.Retention and Deletion

We will only keep your personal information for as long as it is necessary for the purposes set out in this Privacy Policy, unless a longer retention period is required or permitted by law (such as tax, accounting or other legal requirements).

The criteria used to determine the period for which personal information about you will be retained varies depending on the legal basis under which we process the personal information:

• Consent. Where we are processing personal information based on your Consent, we generally will retain the information for the period of time necessary to fulfill the underlying agreement with you.
• Business Purposes. Where we are processing your personal information for our Business Purposes, we generally will retain such information for a reasonable period of time based on the particular interest.
• Legal Reasons. Where we are processing personal information based on a legal obligation, we generally will retain the information for the period of time necessary to fulfill the legal obligation.

Except in the case of Personal information being stored for Legal Reasons, your Personal Information will be deleted upon your request.

7.Protection of Personal Information

a.Nexton is an international company and our Staff are working remotely from different countries; consequently, your Personal Information may be transferred from the location in which you reside to other physical locations where Staff may need to access it on a need to know basis. It may also be transferred to third parties located in or outside Latin America.

Nexton has implemented appropriate technical and organizational security measures designed to protect the security of any Personal Information processed. We protect your personal information by maintaining physical, electronic and procedural safeguards. We use network safeguards such as firewalls and data encryption and authorize access to personal information only for those who require access to fulfill their work responsibilities.

The risks of transferring data outside of your jurisdiction include the possibility of data breaches and loss. Please note that we cannot guarantee that no event of data breach or loss will ever occur.

No mobile information will be shared with third parties/affiliates for marketing/promotional purposes. All other categories exclude text messaging originator opt-in data and consent; this information will not be shared with any third parties.

In case a data breach incident occurs, we have adequate proceedings in place to contain the effect of the incident, by mitigating the potential damages, seeking to restore any information that might have been lost and taking all necessary measures to prevent it from happening again. In all cases,if your Personal Information has been compromised in any way, you will be immediately informed.

b. Protection of Third-Party Confidential Information

At Nexton, we recognize and prioritize the importance of safeguarding confidential information. This policy underscores our dedication to safeguarding not only our own confidential information but also that of third parties. This pertains to information subject toconfidentiality agreements, trade secrets, proprietary knowledge or sensitive information not publicly accessible (the “Third-Party Confidential Information”).

We require all candidates to exercise due diligence and the highest degree of confidentiality when dealing with Third-Party Confidential Information, particularly relating to current or past employers. We also require candidates to refrain from incorporating this type of information in their resume.

While Nexton is not accountable for Third-Party Confidential Information shared by candidates during the recruiting process, if such information is identified by our staff, it will be treated confidentially and promptly removed from our databases.

8.Acceptance of these Conditions

We assume that all Candidates and Visitors in contact with us have carefully read this Privacy Policy and agree to its content.

We reserve the right to modify, revise, or otherwise amend this Privacy Policy at any time and in any manner; if we do so, however, we will notify you.

9.Your Privacy Rights

Depending on which country’s laws apply, your privacy rights may include:

• The right to request access and obtain a copy of your personal information;
• The right to request rectification of your personal information;
• The right to request erasure of your personal information;
• The right to restrict the processing of your personal information;
• If applicable, the right to data portability;
• If applicable, the right to object to the processing of your personal information;
• Where we rely on your consent for processing of your personal information, as described in this Privacy Policy, you may also have the right to withdraw your consent to such processing.

You can request to exercise one of the rights listed above by contacting us using the contact information within this Privacy Policy.

We will evaluate your request within a period of 30 business days, counted from the day following the receipt of your request. This period may be extended up to 60 days when there are justified causes. We reserve the right not to comply with requests in circumstances where we are not required to do so under applicable law.

10.Modifications and revisions

We may update this Privacy Policy from time to time. The updated version will be indicated by an updated "Revised" date and the updated version will be effective as soon as it is accessible. If we make material changes to this privacy notice, we may notify you either by prominently posting a notice of such changes or by directly sending you a notification.We encourage you to review this privacy notice frequently to be informed of how we are protecting your information.

11.Contact Information

If you have questions or comments about this Privacy Policy, you may email us at [email protected]or by post to:

Advanced Engineering Services LLC 16192 Coastal Highway Lewes, DE 19958 United States.