Applicant and Candidate Privacy Notice

Purpose.

At Tekion, we are building the next-generation automotive retail experience founded on transparency and trust. This begins with empowering you. This Applicant Privacy Notice (the “Notice”) explains how Tekion Corp and its affiliates and subsidiaries (“Tekion” or “we” or “us”) collect, use, store, and otherwise process personal data relating to job applicants (“you”) globally as part of our recruitment process, including when you access or use our careers website. Where applicable, we have indicated deviations from this Notice to comply with local regulations.

This Notice does not cover your use of any third-party websites and applications that you may use, including those to which we link in our websites, or your use of Tekion’s products or services as a customer (for more information, please read our website Privacy Notice). You should review the terms and policies for third-party websites and applications before clicking on any links.

See SCHEDULE 1 for a full list of all Tekion entities that handle employee Personal Information.

Collection, Use, and Disclosure of Personal Information.

For the purposes of this Notice, Personal Information is any information about you that, either by itself or in conjunction with other information, can be used to identify you (“Personal Information”).

We may collect this information in variety of ways. For example, data may be contained in application forms or CV’s (including when these are sent to us as part of speculative applications or queries), obtained from your passport or other identity documents, or collected through interviews or other methods of assessment.

We may also collect personal data about you from third parties, such as references supplied by former employers.

Data will be stored on various IT infrastructures, including on your application record, in our HR management systems and our email system.

1. What Personal Information Do We Collect?

   We collect and maintain different types of Personal Information that we require to manage our relationship with you. The Personal Information that we collect and maintain may begin at the point at which you apply to work with us.

   Personal Information that We collect from You:

   • Your identifiers. This includes your name, date of birth, and contact information such as telephone number, email address, postal address. video images, photograph, beneficiary and emergency contact details, and other similar contact data. If you are a family member of an employee, former employee, contractor or contingent worker, we may collect this information from the relevant individual to whom you are related;
   • Demographic information. This includes your age, income, martial/civil partnership status, gender, and military service;
   • Professional or employment-related information. This includes your CV, application form, references supplied by your former employer, performance related data and assessments, personal references and contact details, and other similar contact data;
   • Educational information. This includes your educational history, academic degrees, qualifications, certifications, and skills;
   • Information required for background checks. This includes criminal record checks (where permitted by local law), prior employment verification, credit history, and other information revealed including your information available on social media platforms;
   • Right to work information. This includes citizenship, work permit, visa application information, passport, social security number and other similar right to work data;
   • Sensitive personal information. This includes information requiring special handling related to gender, racial and ethnic origin, national origin, veteran status, and health and medical information such as disability status or vaccine status, where we have acquired your consent and collection of such data is allowed by applicable law;
   • On-premise monitoring. To the extent permitted by local law, we monitor our workplaces through video-monitoring (e.g., closed-circuit television) and badge scans to ensure the safety of our employees and to prevent theft of Tekion assets and information. Such monitoring may capture your image and voice data when you visit a Tekion facility or office;
   • Internet or other electronic network activity information. This includes information you submit through applications or software made available to you, information collected from you when you connect a device to our networks such as IP address, or communications sent to us or through our applications, and your telephone communications with customers via company devices or systems only for certain customer-facing roles; and
   • Other Information. Any other information that you voluntarily provide directly to us in connection with your application for employment including that which you provide via webform, during an interview, or as other forms of assessment as part of your application process.

   Please note that the above list represents the types of Personal Information that we may collect from you and does not mean that we will collect all this information from you. Personal Information does not include anonymous or non-personal information (i.e., information that cannot be associated with or tracked back to a specific individual).

   Personal Information We Collect from Other Sources:

   We may utilize the services of third parties in our business and may receive Personal Information collected by those third parties during the performance of their services for us. Where this is the case, we will take reasonable steps to ensure that such third parties have represented to us that they have the right to disclose your Personal Information to us. This includes employment screening agencies, background check agencies, recruiting agencies, service providers, former employers and/or schools and educational institutions, publicly available information on websites and social media, and other third parties where they are legally allowed to share your Personal Information with us.

   • Referred to Us. This includes individuals who may refer you to us and provide your personal information, such as your contact details and resume, to us.
   • Combining Personal Information. We may combine the personal information we receive from various sources with Personal Information we collect from you and use it as described in this Notice.
   • Video Recording. We may use videoconferencing and video recording as part of our interview process. You will be notified by through our videoconference tools prior to recording, and such recordings will be securely stored and deleted as soon as they are no longer needed to process your application.
   • Without Your Consent. Where permitted or required by applicable law or regulatory Requirements, we may also collect your Personal Information without your knowledge or consent, though this will be limited only to circumstances where it is necessary to achieve our business purposes or where required by law.
2. How Do We Use Your Personal Information?

   We use and disclose your Personal Information for our business purposes, including establishing, maintaining, or terminating your employment with Tekion. Such uses include:

   • Determining eligibility for initial employment, including the verification of references and qualifications, and background checks where permitted by law;
   • Administering pay and benefits, including remitting income tax and reporting income on tax slips;
   • Establishing training and/or development requirements;
   • Conducting performance reviews and determining performance requirements;
   • Assessing qualifications for a particular job or task;
   • Establishing an emergency contact point in the event of an emergency;
   • Complying with applicable labor or employment laws;
   • Internal analytics, including analysis used to promote workplace diversity;
   • Compiling workplace directories;
   • Ensuring the security of company-held information;
   • Other purposes as are reasonably required by Tekion in connection with your application for employment; and
   • For any additional purposes that we advise you of and for which we have a legal basis, including with your consent when such consent is required by law.
3. When Do We Share Your Personal Information?

   We may share your Personal Information with our employees, contractors, consultants, and other parties, including other Tekion entities, who require such information to assist us with establishing, managing or terminating our applicant or employment relationship with you.

   In some instances, such parties may provide information technology and data processing services to us, such as applicant screening tools, applicant management software, payroll, and benefit administration services, so that we may operate our business. When we share Personal Information with such parties, we require that they include contractual provisions that safeguard your Personal Information to at least the same standard that we use to protect such information.

   Additionally, we may share Personal Information with such parties both in and outside of your home jurisdiction. As result, your Personal Information may be collected, used, processed, stored or disclosed in Canada, France, Germany, the United Kingdom, the United States of America, India, and in some cases, other countries. Personal Information is only transferred by us to another country, including within Tekion entities, if (i) this is required or permitted under the applicable privacy legislation, (ii) only to extent necessary to carry out our business purposes or legal obligations, (iii) only to individuals who have a need-to-know this information and who are contractually obligated to safeguard your information to the same level that we use to protect your information, and (iv) only so far as a reasonable level of data protection is assured in the recipient country. The attached Schedules 2 through 6 outline additional privacy practices of your Personal Information for Canada, France, Germany, and the United Kingdom. Please note, however, that your Personal Information may still be subject to access by law enforcement agencies according to the laws of the jurisdictions in which the information is stored. In the event of a change in ownership of, or a grant of a security interest in, all or a part of Tekion through, for example, an asset or share sale, or some other form of business combination, merger or joint venture, provided that such party is bound by appropriate agreements or obligations that safeguard your Personal Information to at least the same standard that we use to protect employee information.

4. When Your Personal Information May Be Disclosed.

   We may disclose your Personal Information for the following reasons:

   • As permitted or required by applicable law or regulatory requirements. In such a case, we will endeavor to not disclose more Personal Information than is required under the circumstances;
   • To comply with valid legal processes such as search warrants, subpoenas or court orders;
   • As part of Tekion’s regular reporting activities to another subsidiary or affiliate of Tekion (including outside of your home jurisdiction);
   • To protect the rights and property of Tekion;
   • During emergency situations or where necessary to protect the safety of a person or group of persons;
   • Where the Personal Information is publicly available; or
   • With your consent where such consent is required by law.

   If you need further information concerning the lawful basis on which we collect, use, store, or otherwise process your Personal Information, please contact us at privacy@tekion.com.

   We do not sell Personal Information subject to this Notice to third parties.

5. Lawful Basis for Processing Your Personal Information.

   Tekion typically collects or uses Personal Information from you or others where the processing is in our legitimate interests and not overridden by your data protection interests or fundamental rights and freedoms, or where applicable, where we have obtained your consent to process your Personal Information for a specific purpose. Depending on the jurisdiction you reside in, there may be other applicable lawful reasons for processing your personal information that are not listed within this Notice. For instance, we may have a legal obligation to collect or retain Personal Information or need the Personal Information to protect your vital interests or those of another individual.

   Where your consent is required for our collection, use, or disclosure of your Personal Information, you may, at any time, subject to legal or contractual restrictions and reasonable notice, withdraw your consent. All communications with respect to such withdrawal or variation of consent should be in writing and addressed to our Data Privacy Officer at privacy@tekion.com.

6. How Is Your Personal Information Protected?

   Tekion maintains physical, technical and procedural safeguards that are appropriate to the sensitivity of the Personal Information in question. These safeguards are designed to protect your Personal Information from loss and unauthorized access, copying, use, modification or disclosure.

   Despite these safeguards, no method of transmission over the Internet or data storage is fully secure. If we are required by law to inform you of a breach to your Personal Information we may notify you electronically, in writing, or by telephone, if permitted to do so by law.

7. How Long Is Your Personal Information Retained?

   Except as otherwise permitted or required by applicable law or regulatory requirements, Tekion retains your Personal Information only for as long as it reasonably believes is necessary to fulfill the purposes for which the Personal Information was collected (including, for meeting any legal, accounting or other reporting requirements or obligations, resolving a dispute, making and defending legal claims, or any other legitimate business purpose). We may de-identify Personal Information by combining or removing pieces of information to prevent identification of any individual. This Notice does not apply to information that has been anonymized under applicable data protection law.

8. Accessing, Updating, and Deleting Your Personal Information

   Your Privacy Rights

   Laws in certain jurisdictions may provide individuals with rights relating to personal data, such as those listed below. Tekion will honor these rights to the extent required by law. To exercise any of these rights, please contact us at privacy@tekion.com.

   • You can access the Personal Information that we hold about you, including details of why we are processing it.
   • You can correct Personal Information about you that is inaccurate or incomplete.
   • In certain situations, you can ask that we delete your Personal Information, object to, restrict the use of Your Personal Information, or export Your Personal Information to another entity or person.
   • You have a right to withdraw consent at any time. This will not affect the lawfulness of processing prior to the withdrawal of your consent. At any time, you can request that we stop using Your Personal Information for recruiting purposes.
   • We are committed to resolving valid complaints about your privacy and our collection, use, storage, or other processing of your Personal Information. You have a right to raise a complaint with your local data protection authority at any time if you are unsatisfied with our response to your complaint.

   We may ask you to provide additional information to validate your identity if you or your authorized agent exercises your privacy rights. The information that we collect will be limited only for verification and only to the extent that we need to confirm your identity or your agent’s authority to act on your behalf.

   Please note that where the Personal Information that you are requesting is contained in systems to which you have access, we may direct you to those systems so that you may access your Personal Information at your convenience.

9. Supplemental Privacy Disclosures for Job Applicants and/or Candidates in Certain Countries:

   If you reside in Canada, France, Germany, United Kingdom, or India, the below applicable Schedules also apply to the processing of your Personal Information under this Notice. To the extent there is a conflict between the country-specific language in each Schedule and this Notice, the applicable Schedule shall control to the extent of that conflict.

   Schedule 2: Canada

   Schedule 3: France

   Schedule 4: Germany

   Schedule 5: United Kingdom

   Schedule 6: India

   Please note that in the event you are approved during the recruitment and hiring process, the processing of your Personal Information shall be controlled by Tekion’s Employee Privacy Policy. In case of a conflict between this document and Tekion’s Employee Privacy Policy, the Employee Privacy Policy shall prevail.

10. Revisions to this Notice

    We may from time to time make changes to this Notice to reflect changes in its legal or regulatory obligations or in the manner in which we deal with your Personal Information. We will communicate any revised version of this Notice. Any changes to this Notice will be effective from the time the changes are communicated, except for any changes where your consent is required before we can collect, use, share, store or disclose your Personal Information. In those circumstances, the changes will be effective once we have obtained your consent to such change. This Notice was last reviewed as of the Effective Date set forth below.

11. Interpretation of this Notice

    Any interpretation associated with this Notice will be made by the Data Privacy Officer. This Notice includes examples but is not intended to be restricted in its application to such examples. Accordingly, where the word “including” is used, it shall mean “including without limitation.”

    This Notice does not create or confer upon any individual any rights or impose upon Tekion any rights or obligations outside of, or in addition to, any rights or obligations imposed by applicable privacy laws. Should there be any inconsistency between this Notice and any applicable privacy laws, this Notice shall be interpreted in way that complies with those privacy laws.

Schedule 1: Tekion Entities

• Tekion Corp
• Tekion Canada ULC
• Tekion France SAS
• Tekion Germany GmbH
• Tekion UK Limited
• Tekion India Private Limited

Schedule 2: Canada

Supplemental Privacy Disclosures for Job Applicants and/or Candidates in Canada

Purpose. For job applicants and/or candidates located in Canada, the controller is Tekion Canada ULC located at Tekion Canada ULC, 1600-925 Georgie Street West, Vancouver, BC V603L2.

Access to Your Personal Information and Deletion of Your Personal Information if you are Quebec, British Columbia, and Alberta-Based Applicants Only

• You can request access to and rectification or deletion of Personal Information that we hold about you.
• To make such a request, please contact our Data Privacy Officer using the contact information set out below. Please note that any such communication must be in writing.
• Your right to access, rectify, or delete the Personal Information that we hold about you is not absolute. There are instances where applicable law or regulatory requirements allow or require us to refuse your request. In addition, the Personal Information may have been destroyed, erased or made anonymous in accordance with our record retention obligations and practices.
• If we cannot provide you with access to, or rectification or deletion of your Personal Information, we will inform you of the reasons why, subject to any legal or regulatory restrictions.

We will not discriminate against you for exercising any of your rights described in this Policy.

If you have any questions or requests about updating your Personal Information, questions about this Notice, or how we manage your Personal Information, please contact us at HR_North_America@tekion.com or privacy@tekion.com.

If you are unsatisfied with our response to your complaint or if you have questions about your privacy rights in Canada, you have a right to raise questions or complaints through The Office of the Privacy Commissioner of Canada (OPC). The OPC can help individuals and organizations identify, address and report concerns related to possible mishandling of personal information. There are numerous ways to connect with the OPC through https://www.priv.gc.ca/en/report-a-concern/, by phone at Toll-free: 1-800-282-1376 or Phone: (819) 994-5444, or mail to Office of the Privacy Commissioner of Canada, 30, Victoria Street, Gatineau, Quebec, K1A 1H3.

Schedule 3: France

Supplemental Privacy Disclosures for Job Applicants and/or Candidates in France

Purpose. For job applicants and/or candidates located in France, the controller is Tekion France SAS located at 78 Boulevard De La Reine CS 90958 Versailles Cedex France. 78035.

Your Privacy Rights. You may exercise the privacy rights provided in Section 8 subject to any limitations under applicable law.

If you are unsatisfied with our response to a complaint, you have a right to raise questions or complaints with the French supervisory authority (Commission Nationale de l’Informatique et des Libertés – “CNIL”) at any time. You can contact this authority by sending a letter to the CNIL at 3 Place de Fontenoy, 75007 Paris, France, or by phone at +33 1 53 73 22 22.

If you have any questions or requests about updating your Personal Information, questions about this Notice, or how we manage your Personal Information, please contact us at HR_EMEA@tekion.com or privacy@tekion.com.

Schedule 4: Germany

Supplemental Privacy Disclosures for Job Applicants and/or Candidates in Germany

Purpose: For job applicants and/or candidates located in Germany, the controller is Tekion Germany GmbH located at Preilmayerstrabe 3, 80335 München, Germany.

Your Privacy Rights. You may exercise the privacy rights provided in Section 8 subject to any limitations under applicable law.

If you have any questions or requests about updating your Personal Information, questions about this Notice, or how we manage your Personal Information, please contact us at HR_EMEA@tekion.com or privacy@tekion.com.

If you are unsatisfied with our response to a complaint, you have a right to raise questions or complaints with the Hessee DPA (Hessisischer Beauftragter für Datenschutz und Informationsfreiheit) at https://datenschutz.hessen.de/, by Telephone +49 611 1408 – 0, or at The Hessian Commissioner for Data Protection and Freedom of Information, PO Box 3163, 65021 Wiesbaden (Der Hessische Beauftragte für Datenschutz und Informationsfreiheit, Postfach 3163, 65021 Wiesbaden).

Schedule 5: United Kingdom

Supplemental Privacy Disclosures for Job Applicants and/or Candidates in United Kingdom

Purpose: For job applicants and/or candidates located in the United Kingdom, the controller is Tekion UK Limited located at 5 New Street Square, London, United Kingdom EC4A 3TW.

Your Privacy Rights. You may exercise the privacy rights provided in Section 8 subject to any limitations under applicable law.

If you have a general complaint about how we are processing your personal data, you can make a complaint under our Data Protection Complaints Procedure or contact HR_EMEA@tekion.com.

If you think Tekion is processing your data unlawfully, or you also have the right to lodge a complaint with the Information Commissioner’s Office, which is the UK data protection regulator. More information can be found on the Information Commissioner’s Office website at https://ico.org.uk/

Schedule 6: India

Supplemental Privacy Disclosures for Job Applicants and/or Candidates in India

Purpose: For job applicants and/or candidates located in India, the controller is Tekion India Private Limited located at XPC5+MPC, Bagamane Solarium City, 3rdn& 4th floors, Neon Building, Kundalahalli Colony, Brookefield, Bengaluru, Karnataka 560037, India.

If you have any questions or requests about updating your Personal Information, questions about this Notice, or how we manage your Personal Information, please contact us at hr_india@tekion.com or privacy@tekion.com.