Saber Interactive Inc.
Global HR

This Recruitment Privacy Notice applies to Saber Interactive, Inc. (“Saber”) and all subsidiaries and affiliates worldwide

If you have any questions about this policy, please contact: privacy@saber3d.com

Recruitment Privacy Notice

Effective Date: July 1, 2026
Applies to: Saber Interactive, Inc. (“Saber”) and all subsidiaries and affiliates worldwide

1. Introduction

Saber Interactive Inc. and its affiliated companies ("Saber", "we", "our" or "us") are committed to protecting the privacy and security of personal data processed during our recruitment and hiring activities.

This Recruitment Privacy Notice explains how we collect, use, disclose, store and otherwise process personal data relating to applicants for employment, internships, freelance engagements and other positions with Saber.

This Notice is intended to satisfy the transparency requirements under Articles 13 and 14 of the General Data Protection Regulation (EU) 2016/679 ("GDPR") and other applicable data protection laws.

2. Who is Responsible for Processing Your Personal Data

The Saber company advertising the position for which you apply is generally the controller of your personal data.

Depending on the recruitment process, your personal data may also be processed by Saber Interactive Inc. and other Saber affiliates that provide centralized human resources, legal, information technology, security, finance, recruiting or management services.

3. Categories of Personal Data We Process

Depending on the position and the recruitment process, we may process the following categories of personal data:

Identity and Contact Information

• name;

• preferred name;

• title;

• gender where voluntarily provided or required by applicable law;

• date of birth where permitted by law;

• nationality or citizenship where relevant;

• residential and mailing address;

• email address;

• telephone number;

• emergency contact information where applicable.

Recruitment Information

• CV or résumé;

• cover letter;

• application forms;

• work authorization or immigration status;

• employment preferences;

• salary expectations;

• availability;

• desired work location;

• notice period.

Employment and Professional Information

• employment history;

• previous employers;

• job titles;

• responsibilities;

• work experience;

• references;

• professional memberships;

• qualifications;

• licenses;

• certifications;

• professional training.

Education Information

• schools attended;

• degrees;

• diplomas;

• certificates;

• academic achievements;

• transcripts where required.

Assessment Information

• interview notes;

• recruiter evaluations;

• hiring manager assessments;

• technical assessments;

• coding tests;

• written exercises;

• aptitude tests;

• personality assessments where permitted by applicable law;

• reference check results.

Identity Verification Information

Where necessary and permitted by law:

• government-issued identification information;

• passport details;

• national identity information;

• visa or work authorization documentation.

Multimedia Information

Where voluntarily provided or where interviews are conducted using video conferencing:

• photographs;

• video interview recordings where notice has been provided;

• voice recordings;

• video presentations submitted by candidates;

• portfolio materials.

Communications

• correspondence with recruiters;

• interview scheduling communications;

• emails;

• chat messages;

• notes relating to the recruitment process.

Technical Information

When using our recruitment systems:

• IP address;

• browser information;

• device information;

• authentication logs;

• security logs;

• system usage information.

4. Purposes of Processing

We process personal data for the following purposes:

• reviewing applications, CVs and supporting documents;

• assessing qualifications and suitability for employment;

• scheduling and conducting interviews;

• evaluating technical and professional competencies;

• communicating with applicants throughout the recruitment process;

• verifying qualifications, education and employment history where permitted by law;

• conducting background screening where legally permitted;

• determining eligibility to work;

• preparing employment offers;

• onboarding successful candidates;

• maintaining recruitment records;

• defending legal claims;

• complying with employment, tax, immigration and regulatory obligations;

• protecting the security of our systems, personnel and facilities;

• improving our recruitment processes.

5. Legal Bases for Processing

Where the GDPR applies, Saber relies on one or more of the following legal bases:

Performance of Pre-contractual Measures

(Article 6(1)(b) GDPR)

Processing necessary to take steps at your request before entering into an employment contract.

Compliance with Legal Obligations

(Article 6(1)(c) GDPR)

Processing necessary to comply with applicable employment, tax, immigration, anti-discrimination, health and safety and other legal obligations.

Legitimate Interests

(Article 6(1)(f) GDPR)

Processing necessary for our legitimate interests, including:

• recruiting suitable candidates;

• evaluating applicants;

• protecting our business;

• ensuring network and information security;

• preventing fraud;

• maintaining recruitment records;

• defending legal claims;

• improving recruitment processes.

Where required, we conduct an appropriate balancing test before relying upon legitimate interests.

Consent

(Article 6(1)(a) GDPR)

We rely on consent only where required by applicable law, including for optional processing such as retaining your application for future opportunities.

Special Categories of Personal Data

Where special categories of personal data are processed, Saber will do so only where permitted under Article 9 GDPR, including where:

• required by employment law;

• necessary for establishing, exercising or defending legal claims;

• the information has been manifestly made public by you; or

• you have provided explicit consent where required.

6. Sources of Personal Data

We may collect personal data:

• directly from you;

• through recruitment agencies;

• from employee referrals;

• from publicly available professional sources such as LinkedIn or professional portfolios;

• from references you authorize;

• from educational institutions where permitted;

• from background screening providers where legally permitted.

7. Recipients of Personal Data

Your personal data may be shared with:

• authorized Human Resources personnel;

• hiring managers;

• interviewers;

• company executives involved in hiring decisions;

• Legal;

• Information Security;

• Information Technology;

• Finance where necessary;

• affiliated Saber companies;

• recruitment agencies;

• applicant tracking system providers;

• cloud hosting providers;

• identity verification providers;

• background screening providers;

• payroll and onboarding providers for successful candidates;

• government authorities where legally required;

• external advisers and auditors.

Recipients only receive personal data on a need-to-know basis.

8. International Transfers

Because Saber operates internationally, your personal data may be transferred to and processed in countries outside your country of residence, including countries outside the European Economic Area.

Where required, such transfers are protected through appropriate safeguards, including:

• European Commission Standard Contractual Clauses;

• UK International Data Transfer Addendum;

• adequacy decisions;

• other legally approved transfer mechanisms.

9. Retention

We retain recruitment records only for as long as necessary to:

• complete the recruitment process;

• comply with applicable legal obligations;

• resolve disputes;

• establish, exercise or defend legal claims.

If you separately consent to future recruitment opportunities, we may retain your application for the period described in the Optional Candidate Consent or until your consent is withdrawn.

10. Security

Saber maintains appropriate technical and organizational measures designed to protect personal data, including measures intended to safeguard confidentiality, integrity and availability of recruitment information.

11. Your Rights

Where applicable, you may have the right to:

• access your personal data;

• correct inaccurate information;

• request deletion;

• request restriction of processing;

• object to processing based on legitimate interests;

• receive your personal data in a portable format where applicable;

• withdraw consent at any time where processing relies upon consent;

• lodge a complaint with your local supervisory authority.

12. Contact

Questions regarding this Recruitment Privacy Notice or the processing of your personal data may be directed to the contact details identified in the applicable Saber Privacy Notice or by contacting the Saber privacy team at:

Email: privacy@saber3d.com

Optional Candidate Consent for Future Employment Opportunities

The following consent is entirely voluntary.

Your decision will not affect your application for the current position.

Talent Pool Consent

☐ I consent to Saber Interactive Inc. and its affiliated companies retaining my application materials and personal data after the conclusion of the current recruitment process in order to consider me for future employment opportunities that may match my qualifications.

I understand that:

• This consent is optional;

• refusing consent will not affect my current application;

• I may withdraw my consent at any time by contacting privacy@saber3d.com;

• withdrawal of consent will not affect processing carried out before withdrawal;

• Saber will retain my application for future recruitment only for the retention period specified in this Recruitment Privacy Notice or until I withdraw my consent, whichever occurs first.

Name: __________________________

Signature (where applicable): ________________________

Date: __________________________ 

Schedule A – Country-Specific Recruitment Information

This Schedule supplements the Recruitment Privacy Notice of Saber Interactive Inc. and its affiliated companies ("Saber"). Where local law provides additional rights or obligations, those provisions supplement and, where required by law, prevail over the general provisions of the Recruitment Privacy Notice.

A. European Economic Area (EEA)

Applicants located in the European Economic Area are protected by the General Data Protection Regulation (EU) 2016/679 ("GDPR") and applicable national implementing legislation.

Controller

The Saber affiliate advertising the position is generally the data controller.

Where recruitment functions are centralized, Saber Interactive Inc. and other Saber affiliates may process personal data as independent controllers or joint controllers, as appropriate, or as processors acting on behalf of the recruiting entity.

Legal Bases

Saber generally relies upon one or more of the following legal bases:

• Article 6(1)(b) GDPR – taking steps prior to entering into an employment contract;

• Article 6(1)(c) GDPR – compliance with legal obligations;

• Article 6(1)(f) GDPR – legitimate interests;

• Article 6(1)(a) GDPR – consent (only where legally appropriate).

Where special categories of personal data are processed, Saber relies upon an applicable condition under Article 9 GDPR.

International Transfers

Personal data may be transferred outside the EEA only where appropriate safeguards have been implemented, including:

• European Commission Standard Contractual Clauses;

• adequacy decisions;

• other transfer mechanisms recognized under the GDPR.

B. United Kingdom

Applicants located in the United Kingdom are protected by the UK GDPR and the Data Protection Act 2018.

International transfers from the United Kingdom are protected using one or more of the following:

• UK International Data Transfer Agreement (IDTA);

• UK Addendum to the EU Standard Contractual Clauses;

• adequacy regulations adopted by the UK Government;

• other legally recognized safeguards.

C. Spain

Where Spanish law applies:

• recruitment records may be retained only for as long as necessary for recruitment purposes and to comply with applicable legal obligations;

• background checks will only be conducted where legally permissible and proportionate;

• criminal record information will only be processed where expressly authorized by applicable law.

D. Sweden

Where Swedish law applies:

• recruitment decisions will not be based solely on automated processing where prohibited by applicable law;

• applicants may request additional information regarding processing based on legitimate interests.

E. Serbia

Where Serbian data protection legislation applies, applicants enjoy rights substantially equivalent to those provided under the GDPR.

Cross-border transfers outside Serbia will only occur where permitted under applicable Serbian law and appropriate safeguards have been implemented.

F. Cyprus

Applicants located in Cyprus enjoy the rights provided by the GDPR and applicable Cypriot legislation.

Where work authorization documentation is processed, such processing is carried out only to determine eligibility for employment and compliance with applicable immigration laws.

G. United States

Applicants located in the United States may be subject to federal and state privacy laws depending upon their state of residence.

Where applicable, applicants may have rights regarding:

• access to personal information;

• correction of inaccurate information;

• deletion of personal information;

• limitations on certain uses of sensitive personal information;

• non-discrimination for exercising privacy rights.

These rights are subject to applicable statutory exemptions, including exemptions relating to employment and recruitment records.

H. Background Checks

Background screening is conducted only where:

• permitted by applicable law;

• proportionate to the position;

• necessary for legitimate business purposes;

• required by law; or

• authorized by the applicant where required.

Background screening may include, where legally permissible:

• verification of employment history;

• verification of educational qualifications;

• professional license verification;

• identity verification;

• work authorization verification;

• reference checks;

• sanctions and restricted party screening where relevant to the position;

• criminal record checks only where expressly permitted by applicable law and relevant to the position.

I. Artificial Intelligence and Automated Processing

Saber may use technology-assisted tools during recruitment to support administrative functions, including:

• résumé parsing;

• duplicate application detection;

• interview scheduling;

• skills matching;

• fraud prevention;

• recruitment analytics.

These tools assist recruiters but do not replace human decision-making.

Saber does not make hiring decisions based solely on automated decision-making that produces legal or similarly significant effects unless expressly permitted by applicable law.

J. Recruitment Communications

Saber may communicate with applicants by:

• email;

• telephone;

• SMS or text message;

• applicant portals;

• video conferencing platforms; or

• other communication methods provided by the applicant.

K. Retention Periods

Unless a longer retention period is required or permitted by applicable law:

• unsuccessful applicant records will generally be retained for up to two (2) years following the conclusion of the recruitment process for the purpose of defending legal claims, complying with legal obligations, maintaining recruitment records, and improving recruitment practices;

• where an applicant provides separate consent to remain in Saber’s talent pool, Saber may retain the applicant's recruitment records for up to two (2) years after the conclusion of the recruitment process, or until consent is withdrawn, whichever occurs first;

• records relating to successful applicants will become part of the individual's personnel file and will thereafter be retained in accordance with Saber's Employee Privacy Notice and applicable records retention policies.

Where local law prescribes a shorter or longer retention period, Saber will comply with the applicable legal requirements.

L. Candidate Responsibilities

Applicants should ensure that:

• all information provided is accurate and complete;

• application materials do not include confidential information belonging to current or former employers unless disclosure is authorized;

• unnecessary special categories of personal data (such as health information, racial or ethnic origin, religious beliefs, political opinions, trade union membership, sexual orientation, biometric data or genetic data) are not included unless specifically requested or required by law.

M. Updates to this Schedule

Saber may update this Schedule from time to time to reflect changes in applicable law, recruitment practices or organizational structure.

Material changes will be communicated in accordance with applicable law.