GLOBALIZATION PARTNERS

PRIVACY NOTICE TO APPLICANTS

Last revised March 2021

Globalization Partners, LLC and its Group Companies (“Globalization Partners”, “we”, or “us”) respect
your privacy and the privacy of your personal information. The purpose of this privacy notice is to
explain how we collect, use, and disclose personal information we obtain from you during the course
of our relationship. This privacy notice also describes the choices available to you regarding how we
use your personal information, and how you can access and update your personal information. This
privacy notice applies to candidates for employment with Globalization Partners.

This privacy notice provides information about (1) the type of data we collect; (2) the purposes for
which we collect and disclose personal information; (3) the circumstances under which we disclose
personal information, including the types of potential recipients; (4) our privacy and information
safeguards; (5) the circumstances under which individuals may access and correct their personal
information; and (6) control of your personal information. This privacy notice covers all personal
information that Globalization Partners receives during the candidate application and recruitment
process regardless of how Globalization partners originally obtained the data. Globalization Partners’
websites, services, or online platforms may have additional privacy notices.

PERSONAL INFORMATION WE COLLECT

The process of applying for employment with Globalization Partners requires you to provide
information that could be used to individually identify you. We call this information “personal
information.”

We collect personal information that you give to us directly, such as home and mailing addresses,
contact telephone numbers, email addresses, home addresses, personal telephone numbers, salary
and compensation information, and employment history.

We may also receive personal information from third parties you identify as professional references,
such as confirmation of a previous job title, length of employment, and compensation information.
Globalization Partners may also receive personal information that is available through public records,
or is otherwise generally publicly available such as information retained by the Office of Foreign Asset
Controls. We may combine such information with personal information we already possess about you.

Globalization Partners and its representatives will never ask you for your credit or debit card
information. You should never share this information with anyone claiming to be affiliated with
Globalization Partners.

HOW WE USE PERSONAL INFORMATION

Globalization Partners collects and uses personal information in a reasonable and lawful manner.
Globalization Partners uses the personal information we collect about you for purposes of recruiting

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for and hiring candidates for open positions within the company, and to determine candidate
suitability and eligibility for employment.

To the extent possible, Globalization Partners restricts access to personal information to authorized
individuals among its internal personnel, agents, or contractors; and its corporate parent, affiliates,
divisions, or subsidiaries who have a legitimate business need for such access in furtherance of the
uses identified above.

HOW WE SECURELY COLLECT AND STORE PERSONAL INFORMATION

We follow generally accepted standards to protect personal information submitted to us, both during
transmission and once we receive it. We use reasonable and appropriate administrative, technical,
and physical measures to protect the confidentiality, integrity, and availability of personal information,
whether in electronic or tangible or hard copy form. We shall take reasonable steps to protect personal
information from loss, misuse, and unauthorized access, disclosure, alternation and destruction. When
sharing confidential information directly, we use secured email messaging or secured document
transmission platforms.

We maintain an active program to ensure compliance with this notice, as well as with applicable law
or contractual agreement on handling personal information. All internal personnel whose
responsibilities include the collection, processing, or storage of personal information are required to
adhere to this notice.

Because no method of transmission over the Internet or method of electronic storage is 100% secure,
you should take care in deciding what information you send to us via email. If you have any questions
about security, please contact us at Privacy@Globalization-Partners.com.

Our information is hosted on servers in the United States. Accordingly, if you are located outside of
the United States, any personal information you provide to us will be transferred to the United States
using approved data transfer mechanisms. By providing us with any information, you consent to its
transfer and storage in the United States.

REASONS WE SHARE PERSONAL INFORMATION

Globalization Partners will not make your personal information available except as provided in this
privacy notice. We will not sell, loan, rent, exchange, or share your personal information with any third
parties without your permission except and only to the extent explained in this notice.

Globalization Partners will in some circumstances share personal information with third parties,
including service providers, vendors, and government bodies. Globalization Partners will also
share personal information with third parties pursuant to your express consent, where
granted. This consent may be revoked at any time.

Globalization Partners will share personal information with service providers and vendors that assist
us in providing employment related opportunities. Globalization Partners will require these third

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parties to protect the confidentiality and security of the personal data that is shared with them. These
third parties will be required to agree that they will not use or disclose personal information about
you except as necessary to provide services to us or to perform services on our behalf, or as necessary
to comply with applicable laws or regulations. Upon notice, Globalization Partners will take reasonable
and appropriate steps to stop and remediate unauthorized processing by service providers and/or
vendors.

The storage by Globalization Partners of personal information on servers and/or on software made
available or hosted by service providers or vendors shall not be considered disclosures of personal
information to a third party so long as the service provider or vendor does not have direct access to
the personal information stored or hosted. In all events, we shall ensure by contract that a service
provider or vendor protects your personal information that is shared with them.

We may share some or all of your personal information with any of our parent companies, subsidiaries,
joint ventures, or other companies under common control with us. If Globalization Partners is involved
in a merger, acquisition, or sale of all or a portion of its assets, your personal information may be
transferred to the acquiring person or entity. You will be notified via email of any change in ownership
or uses of your personal information, as well as of any choices you may have regarding your personal
information in the event of such a change.

In certain situations, we may be required to disclose personal information in response to lawful

requests by public authorities, including to meet national security or law enforcement requirements.
We may also share your personal information as required by law, such as to comply with a subpoena
or other legal process, when we believe in good faith that disclosure is necessary to protect our rights,
protect your safety or the safety of others, investigate fraud, or respond to a government request.

DATA INTEGRITY AND PURPOSE LIMITATION

We limit the collection, use and retention of your personal information to that which is relevant for
the intended purposes of collection or as authorized by you. Globalization Partners employs
reasonable means to keep personal information reliable, accurate, complete and up-to-date. All
Employees have a responsibility to assist us in keeping the personal information we maintain about
them reliable, accurate, complete, and current. The Company shall also adhere to the Principles for as
long as it retains your personal information.

HOW TO ACCESS OR CONTROL YOUR PERSONAL INFORMATION

If you want to correct, amend, or delete inaccurate personal information, or if you have any inquiries,
feedback, or complaints about the collection, use, or disclosure of personal information, you may
contact Globalization Partners by mail, email, phone, or fax, as follows:

Globalization Partners LLC

Privacy Department
175 Franklin Street, 17th Floor

175 FEDERAL STREET, 17TH FLOOR, BOSTON, M A 02110

GLOBALIZATION-PARTNERS.COM
Boston, MA 02110
USA

Email: privacy@globalization-partners.com (add “Personal Information Access” in the subject line)

We will permit corrections, amendments, or deletions to inaccurate or incomplete information except

(i) where the burden or expense of providing access would be disproportionate to the risks to your
privacy, (ii) for requests which are manifestly abusive, based on unreasonable intervals or their
number or repetitive or systematic nature, or (iii) where the rights of other persons would be violated.
Globalization Partners will respond to requests to correct or change data within 30 business days.

For security purposes, Globalization Partners may require verification of identity before providing
access to personal information. Globalization Partners may deny or limit access to the extent that
granting full access would reveal its own confidential commercial information.

Globalization Partners is not required to identify the sources of personal information when such
identification is not possible through reasonable efforts, or where the rights of other persons would
be violated. If there are compelling grounds to doubt the legitimacy of a request for correction,
amendment, or deletion of personal information, Globalization Partners may require further
justifications before honoring your request. Globalization Partners is not required to notify third
parties to whom your data has been disclosed of any rectification, amendment, or deletion when such
notification involves a disproportionate effort or unreasonable burden.

Please report any suspicious activity to Globalization Partners, including automated messages or calls
from parties you cannot identify, without delay.

PERIOD OF DATA RETENTION

Globalization Partners will retain your personal information for as long as needed to meet the
purposes for which it was collected, as required by contract, or to comply with the required local,
federal, and international laws that apply to our business and to the services that we provide. We will
retain and use this personal information for as long as necessary to comply with our legal obligations,
resolve disputes, enforce our agreements, and, where applicable, for the appropriate statute of
limitations period.

CHANGES TO THIS POLICY

In general, changes may be made to this privacy notice to address new or modified laws, or new or
modified business procedures and privacy practices. When we update this privacy notice, we will also
update the “Last Revised” date on this document.

WE VALUE YOUR FEEDBACK

Globalization Partners periodically verifies that this privacy notice is accurate, comprehensive for the
information intended to be covered, is available to candidates and applicants, is completely
implemented and accessible. We encourage you to raise any concerns using the contact information

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provided above and we will investigate and attempt to resolve any complaints and disputes regarding
use and disclosure of personal information.

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