DATA PROCESSING NOTICE

on data processing related to recruitment for own purposes

The purpose of this information is to provide applicants for jobs advertised by Sugarbird Kft. with information on how Sugarbird Kft. processes the personal data of applicants when applying for a job advertisement.

1. DATA PROCESSOR

The data controller of your personal data related to recruitment (job application) is Sugarbird Kft. (hereinafter referred to as “Sugarbird” or “the company”).

Sugarbird ensures the provision of information regarding this data management, the enforcement of the rights set out in point 6 of this information, and the response to inquiries.

Our contact details for questions related to data processing: postal address: 1112 Budapest, Airport Road 2/B

Data Protection Officer: Orsolya Nemes

email mailbox: orsolya.nemes@sugarbird.com

phone: +36-30-927-5939

website: www.sugarbird.com

2. ON THE PROCESSING OF APPLICANTS' PERSONAL DATA DURING THE RECRUITMENT OF THE WORKFORCE

Sugarbird processes the personal data of job applicants as part of its own recruitment process.

If you apply for one of our positions, you declare that you consent to the processing of your personal data by Sugarbird in connection with the position to which you applied.

Applications and the personal data contained therein are accessible to our company's employees whose job responsibilities include administrative tasks related to recruitment.

Below we summarize in a table which data we process, for what purpose, on what legal basis and for how long.

	applying for a specific job posting	application without advertising (“cold” applications)
Purpose of data processing	Conducting the selection of applicants for job advertisements and preparing the selection.	If someone is not applying for an advertised job, but is just interested in whether we currently have a job that meets their needs, then the purpose of data processing is this inquiry. answering.
Legal basis for data processing	Your voluntary consent (GDPR Article 6 (1) (a)) In the absence of consent, the applicant cannot participate in the selection.
Form of consent	Sending your CV, cover letter, personal data, providing and making available additional personal data during the application process via email, telephone, in person or in any other way.
Scope of personal data processed	Minimum data required when applying: the applicant's last name, first name and telephone number (for identification and contact purposes); the CV submitted by the applicant, all data and information contained therein: including photo, age, professional background, interests, etc. the applicant's educational qualifications, training and previous work experience (for the purpose of assessing compliance with job requirements); data on altered work capacity, if required by the given job (e.g. standing work, physical work) The following data may also be processed: email address (for contact purposes) date of birth (if required by the job (e.g. physical work) additional personal data provided/made available by the applicant during the selection process: e.g. salary requirements, willingness to travel long-distance, etc. a note taken during the hearing (if any); certificate of good conduct (if its presentation is justified);
Duration of data processing	Personal data processed for the purposes set out in this notice will be deleted at any time upon the applicant's request. We would like to draw the attention of applicants to the fact that if they request the deletion of their data before the selection process is closed, they will no longer be able to participate in the selection process, as we will not have access to their application materials necessary for the evaluation.
Even in the absence of a request for deletion, we will delete personal data in the following cases:	We will delete the personal data processed in connection with the given job advertisement 3 months after the selection has been completed.

3. DATA SECURITY

In order to maintain the security and confidentiality of the personal data we process and to prevent the destruction, unauthorized use or alteration of personal data, we apply in particular the following IT and other data security and organizational measures. In addition, we always monitor the development of technology, the available technical, technological and organizational solutions, and apply solutions that are appropriate to the level of protection justified by our data processing.

We process personal data related to recruitment both on paper and electronically.

• We store paper documents containing personal data in a lockable cabinet, protected from unauthorized access.
• Personal data provided by e-mail or other electronic means is only accessible and processed by our employees with access rights. We ensure through backups that the data remains authentic and unchanged, and that the original data can be restored in the event of any destruction or alteration.

4. YOUR RIGHTS

1. Withdraw consent
2. Right to information
3. Right of access
4. Right to rectification
5. Right to erasure (“right to be forgotten”)
6. Right to object to processing based on legitimate interest
7. Right to restriction of data processing
8. Data portability

Withdraw consent: You have the right to withdraw your consent at any time without giving any reason. After the withdrawal of consent, we will no longer process the personal data of the data subject. The withdrawal of consent does not affect the lawfulness of the data processing prior to that.

Request for information / Right of access: You may request information at any time about whether we are processing your personal data. You have the right to request clear, transparent and understandable information about how we process your personal data and what rights you have in this regard. This data management information also serves this purpose. Upon request, we will provide information about the data we process about you, the purpose, legal basis, duration of the data processing, as well as who receives or has received your data and for what purpose, what rights the data subject has if we did not receive your data from you, and the source of the data. Together with the information, we will also provide you with a copy of your personal data processed by us upon request. The first copy is free of charge, however, we are entitled to charge a reasonable fee for each additional copy. We will inform you of the amount of this in advance.

Right to correct and supplement data: If you notice that we are recording any of your personal data incorrectly, incorrectly or incompletely, or if your personal data has changed in the meantime (e.g. you have changed your name, acquired a new qualification), please provide us with the correct, changed or additional data in order for us to make the correction or addition and ensure that the data is up-to-date.

The right to have your personal data erased (“the right to be forgotten”): You may notify us at any time, without giving any reason, that you are no longer interested in a given job opportunity or that we do not want to contact you with job offers in the future (withdrawal of consent). We will then delete your personal data – unless there is another legal basis. The withdrawal of consent does not affect the lawfulness of the data processing prior to that. We would like to inform you that we may refuse to delete your data, in particular if the data is or may be necessary to fulfil our legal obligation or to assert a claim.

Objection to data processing based on legitimate interest: You may object to our processing of your data if you consider that the processing is harmful to you. In the event of an objection, we will delete your personal data, unless there are compelling legitimate grounds for the processing which override your interests, rights and freedoms or for the establishment, exercise or defence of legal claims.

Restriction of data processing: You may request that we mark your personal data for the purpose of restricting its future processing if one of the following applies:

1. a) you contest the accuracy of the personal data, in which case the restriction shall apply for a period of time that allows us to verify the accuracy of the personal data;
2. b) the processing is unlawful and you oppose the erasure of the data and instead request the restriction of their use;
3. c) we no longer need the personal data for the purposes of the original data processing, but you require them for the establishment, exercise or defense of legal claims,
4. d) you have objected to the data processing and time is needed to examine whether the deletion is prevented by another reason.

During the period of restriction, we only store the data and do not perform any other data processing operations, unless you consent to further operations or they are necessary to protect your own rights or the rights of a third party or in the public interest. In the event of a restriction of data processing, we will inform you in advance of its lifting.

Right to data portability: If we process your personal data electronically, you may request that we provide the personal data you have provided to us in a commonly used and easily usable electronic format to you or another person designated by you.

5. HOW TO EXERCISE YOUR RIGHTS: CONTACT SUGARBIRD LTD.

If you wish to exercise your rights above, please submit your request in writing, if possible, in person or send it to us at orsolya.nemes@sugarbird.com to the e-mail address or by post to Sugarbird Kft. 1112 Budapest, Repülőtéri út 2/B. address. In the letter, we ask that you provide the data necessary for personal identification and your mailing address. If we have any doubts about your identity or the data provided is insufficient for identification, we are entitled to request additional identification data from you.

We will fulfill your request within 1 month. If necessary, we are entitled to extend this deadline by another two months, for which we will send you a reasoned information.

We will process well-founded requests free of charge. However, if the request is manifestly unfounded or excessive, especially given its repetitive nature, we may charge a reasonable fee or even refuse to act on the request.

We will inform all those to whom we have disclosed the data about the rectification, erasure or restriction of data, unless this proves impossible or involves a disproportionate effort. Upon your request, we will inform you of the recipients to whom we have informed in accordance with the above.

6. APPLYING TO COURT

We inform you that you are also entitled to assert your claim in court. The courts have jurisdiction over the lawsuit. You can initiate the lawsuit before the court of Sugarbird's registered office or even before the court of your place of residence or residence.

7. CONTACTING THE DATA PROTECTION AUTHORITY, FILING A COMPLAINT

In case of unlawful data processing, you also have the right to contact the National Authority for Data Protection and Freedom of Information (NAIH) and initiate its proceedings.

website: http://naih.hu

address: 1055 Budapest, Falk Miksa utca 9-11. postal address: 1363 Budapest, P.O. Box: 9.

Budapest, August 23, 2023.