Legal

Candidate Data Collection Disclosure

This Candidate Data Collection Disclosure (“Disclosure”) describes how Gemini Tech Services, LLC and its affiliates (“GTS,” “we,” “us,” or “our”) collect, use, retain, and protect Personal Information in connection with recruitment and employment application activities (“Recruitment Activities”). This Disclosure applies to information provided directly by applicants and by third-party recruitment agencies acting on their behalf.

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Personal Information We May Collect

In connection with Recruitment Activities, GTS may collect the following categories of Personal Information, where permitted by applicable law:

• Full name, mailing address, telephone number, and email address
• Date of birth, gender, country of origin, and language
• Work eligibility information, including residency status, work authorization, nationality, passport information, and government-issued identification numbers
• Emergency contacts and next-of-kin information
• Current and previous employment history, job titles, and professional references
• Educational background, professional qualifications, certifications, awards, and professional memberships
• Resume or curriculum vitae content
• Skills assessments and pre-employment test results
• Criminal record, background check results, and credit history (where permitted and required by law or the position)
• Driver’s license information and driving history (where applicable to the position)
• Marital status
• Veteran status and ethnicity (where voluntarily disclosed and where permitted by applicable law)
• Trade union membership

Certain categories above, including health information, biometric data, criminal records, ethnicity, veteran status, and trade union membership, are considered sensitive Personal Information. Collection of sensitive information is subject to additional legal requirements and is conducted only where permitted or required by applicable law.

How We Use Your Personal Information

GTS uses the Personal Information collected during Recruitment Activities to:

• Evaluate your suitability and eligibility for open positions
• Communicate with you regarding your application and the status of Recruitment Activities
• Conduct background screening, reference verification, and skills assessments
• Comply with federal, state, and local legal and regulatory requirements applicable to the recruitment and hiring process
• Exercise our legal rights and protect our interests in connection with any legal claims arising from the recruitment process
• Support equal employment opportunity recordkeeping obligations

Retention of Personal Information

If you are not selected for employment, your Personal Information will be retained for no longer than 12 months following the conclusion of the applicable Recruitment Activity, unless a shorter period is required by applicable law. In the European Union, United Kingdom, and Switzerland, your data will be retained for the duration of the recruitment process plus no longer than 6 months.

If you are hired by GTS, Personal Information collected during the recruitment process will be retained and processed as part of your employment record in accordance with applicable law and GTS's employee data policies, which will be provided to you upon hire.

In certain circumstances, legal, regulatory, or contractual obligations may require GTS to retain records for a longer period. Records may also be retained to resolve disputes or fulfill contractual obligations that arise from the recruitment process.

Sources of Personal Information

GTS collects Personal Information directly from you through application forms and correspondence. We may also receive Personal Information from third parties engaged in connection with Recruitment Activities, including:

• Recruitment and staffing agencies
• Background screening providers
• Skills and pre-employment assessment providers
• Prior employers and professional references you provide

Disclosure of Your Personal Information

Access to your Personal Information within GTS is limited to Human Resources personnel, Legal, and those managers directly involved in the Recruitment Activity. GTS does not sell candidate Personal Information.

GTS may share your Personal Information with third-party service providers engaged to support Recruitment Activities, including background screening firms, skills assessment vendors, and recruitment agencies. We may also contact references and prior employers whose details you have provided in order to verify information in your application. GTS will not otherwise share your Personal Information with third parties except:

• As required by applicable federal, state, or local law or regulation
• As necessary to enforce our legal rights or protect the rights or property of GTS or third parties
• In connection with a merger, acquisition, or sale of GTS or its assets, in which case your information may be disclosed to advisers and transferred to any successor entity

Transfer of Personal Information

GTS operates primarily within the United States. Personal Information collected through Recruitment Activities may be stored and processed in the United States or in other locations where GTS or its authorized service providers operate. GTS takes reasonable steps to ensure that any such transfers are conducted in compliance with applicable law and that appropriate safeguards are in place to protect the security and confidentiality of your Personal Information.

Protection of Your Information

GTS maintains physical, technical, and administrative safeguards designed to protect Personal Information from unauthorized access, loss, misuse, alteration, or destruction. Access to candidate Personal Information is restricted to authorized personnel with a legitimate need in connection with Recruitment Activities.

Your Rights

Subject to applicable law, you may have the right to:

• Request access to the Personal Information GTS holds about you, together with information about how and on what basis it is processed
• Request correction of inaccurate or incomplete Personal Information
• Request deletion of your Personal Information in circumstances where it is no longer necessary for the purposes for which it was collected
• Request that processing of your Personal Information be restricted in certain circumstances
• Lodge a complaint with the relevant supervisory or regulatory authority in your jurisdiction

Contact

For questions regarding this Disclosure or to exercise any of your rights, please contact GTS Human Resources:

This Disclosure was last updated April 2026. GTS reserves the right to update this Disclosure at any time. Material changes will be communicated through our website or directly to active candidates.