Legal notices

Dear Applicant,

Thank you for your interest in a career with Wrist Group. Protecting your personal information is important to us. This notice explains how we collect, use, disclose, and protect your personal data during the recruitment process, in accordance with applicable data protection laws, including

• the EU General Data Protection Regulation (GDPR)
• the UK Data Protection Act 2018

• the UAE Personal Data Protection Law

• Singapore’s Personal Data Protection Act (PDPA)
• the People’s Republic of China Personal Information Protection Law (PIPL)
• the Republic of Korea Personal Information Protection Act (PIPA)
• Panama's Law No. 81 of 2019

• Québec Act respecting the protection of personal information in the private sector (legisquebec.gouv.qc.ca)
• the Brazilian General Data Protection Law (LGPD)
• And any other applicable legislation.

1. Who is responsible for your personal data?

Wrist Ship Supply A/S  ("we", "us" or "our" or “Mother Company”) acts as a data controller jointly with each of its relevant subsidiaries and affiliates (“Group Company” or together, the "Group Companies").

The specific Group Company responsible for processing your personal data depends on your relationship with us and is listed in Annex 1 of this Policy.

For the purposes of applicable data protection laws the Mother Company and the relevant local Group Company are considered joint data controllers.

This means that both the Mother Company and the applicable Group Company share responsibility for deciding how and why your personal data is processed.

If you have any questions about the processing of your personal data, please contact legal@wrist.com

2. What data do we collect?

We collect personal data you provide directly to us, including:

• Name, contact information (address, phone, email)
• Application materials (CV/resume, cover letter, references, educational and employment history, certifications)
• Data from publicly available sources (e.g., LinkedIn profile)
• Results from assessments or background checks (where applicable)
• Any sensitive data you voluntarily submit (e.g., health information, if disclosed)

3. Purpose and legal basis for processing

We process your personal data for the following purposes:

• Assessing your qualifications and suitability for employment
• Managing and administering the recruitment process
• Verifying information provided and conducting background checks (where permitted)
• Complying with legal obligations
• Protecting our legitimate interests in managing recruitment effectively

Legal bases for processing (where applicable):

• GDPR: Processing is necessary to take steps prior to entering into a contract (Article 6(1)(b)), compliance with legal obligations (Article 6(1)(c)), or for our legitimate interests (Article 6(1)(f)). Special categories of personal data are processed under Article 9(2)(f).
• UK: Processing is necessary for the performance of a contract (Article 6(1)(b) of the UK GDPR), compliance with legal obligations (Article 6(1)(c)), or for our legitimate interests (Article 6(1)(f)).
• UAE: We process your personal data during the recruitment process in accordance with the Federal Decree-Law 45 of 2021, hereunder article 4 (8), (9) and (10) and where required we rely on your consent to collect use and disclose personal data.
• Brazil, Republic of Korea and China:

§  based on your consent and such consent is given voluntarily and expressly under the premise of being fully informed (if any of the following legal bases is applicable, we can process your personal information without obtaining your consent);

§  we need to process your personal information in order to enter into or perform any contract to which you are a party;

§  we need to process your personal information in order to perform any statutory duties or obligations undertaken by the Company;

§  we may need to use your personal information in order to respond to public health emergencies or to protect the life, health, and property safety of you or other natural persons in emergency situations;

§  the personal information we process is information you have made public, or information legally made public through other channels; or

§  other legal bases for processing personal information stipulated by laws and administrative regulations.

·       Singapore, Panama and Canada (Québec): We process your personal data during the recruitment process with your written consent to the collection and usage of your personal unless collection and use of personal data without consent is permitted or required by law.

4. Data sharing

We may share your personal data with:

• Recruitment agencies, assessment providers, and background screening services acting on our instructions
• IT and system providers supporting our recruitment systems including the Global Group HR system, which is hosted by CEGID within the European Union.
• Group companies or affiliates involved in the recruitment process
• Regulatory authorities or law enforcement, if legally required

If your personal data is transferred outside your country (e.g., from the EU, UK, UAE, Singapore, China, South Korea, Panama, Canada or Brazil), we ensure appropriate safeguards are in place to protect your information.

5. Data retention

We will retain your personal data for up to six (6) months after the conclusion of the recruitment process, unless a longer retention period is required or permitted by law or you provide consent for us to keep your data on file for future opportunities.

Data Retention and Future Opportunities:We will only process your personal data for the specific job position you have applied for. Once the recruitment process for this position is complete, your personal data will not be retained unless you provide consent to be considered for other relevant roles within the company. If you are not selected for the current position, we may contact you separately to request your consent to retain your resume and application materials for future opportunities. Your consent is voluntary, and you can withdraw it at any time.

6. Your rights

You have the right, subject to applicable law, to:

• Request access to and a copy of your personal data
• Request correction or update of your personal data
• Request deletion of your personal data
• Object to or restrict our processing of your personal data
• Withdraw consent where we rely on it for processing (without affecting processing based on other legal bases)
• Lodge a complaint with a competent supervisory authority

For any requests, please contact us at: legal@wrist.com.

7. Updates

We may update this Privacy Notice from time to time. Any changes will be communicated through appropriate channels.

Annex 1: