Privacy Notice

Last updated: July 16, 2023

We at Surgimate, LLC (“us“, “we“, or “our” or “Company”) recognize and respect the importance of maintaining the privacy of our employment applicants. This Privacy Notice describes the types of information we collect from you when you apply for a position with us via the Comeet platform. This Privacy Notice also explains how we process, transfer, store and disclose the information collected, as well as your ability to control certain uses of the collected information. “You” means the applicant.

“Personal Data” means any information that refers, is related to, or is associated with an identified or identifiable individual or as otherwise may be defined by applicable law. This Privacy Notice details which Personal Data we collect when you apply for a position in our organization.

1. Personal Data We Collect

• We receive personal data about you as a candidate for positions at the Company, such as: contact information, address, Curriculum Vitae (resumé) information (including information such as skills, work experience, education), notes submitted with the application, URL of your LinkedIn and other online profiles, the position for which you have been or are being considered, the source who submitted your candidacy (e.g., recruiting agency, referral), email correspondences between you, the Company and between the Company and other sources (such as recruiting agency and referrals) about your candidacy, information from references, events in the lifecycle of your candidacy, your responses to questionnaires sent to you by us, information about your candidacy and employment options (such as availability to be hired and salary expectations), evaluations of your candidacy, internal discussions within the Company about your candidacy, materials you or other parties (such as evaluators or background check providers) submitted in relation to your candidacy. If you submit your candidacy by email, or online, then you are the main source of the personal data. Your personal data can also originate from other sources, such as LinkedIn profile, recruitment agencies, headhunters and referrals

• We also collect any materials including images and/or pictures and/or photos and/or documents (such as your CV) you may upload to Comeet platform.

• You are under no legal obligation to provide us with any such Personal Data. It is your voluntary decision whether to provide us with any Personal Data, but if you refuse to provide such information, we will not be able to review your candidacy.

2. How We Use Your Personal Data

• General. We will use your personal data in accordance with this Privacy Notice, including as needed to evaluate and consider you as a candidate for positions, in accordance with our processes and policies for evaluating employment candidates, to contact you for your candidacy status and interviews, to schedule meetings and interviews, amongst others.

3. Sharing the Personal Data We Collect. We share your information, including Personal Data, as follows:

• Affiliates. We share information, including your Personal Data, with our affiliated companies, Surgimate Ltd. where this is necessary in connection with the application process and for business management purposes.

• Comeet. We use the Comeet platform for the application process. Comeet is authorized to use your Personal Data as necessary to provide these services or as otherwise authorized by us. Comeet’s privacy policy is available here.

• Service Providers and Subcontractors. We disclose information, including Personal Data we collect from and/or about you, to our trusted service providers and subcontractors, who use such information to: help us in connection with the application process, including for purposes of performing background checks and/or reliability tests.

• If your details are submitted to the Company by a third-party (such as an employee of the Company or a recruiting agency), the Company can give the third-party access to your name, photo and some of the general recruitment status.

• If you apply to a job opening using a unique referral link that was provided to you by an employee of the Company to which you are applying, the Company may share some of your general recruitment status, without identifying you by name, with the person that provided you the referral link.

• The purpose of sharing the above information is to operate incentive programs (i.e. employee referral bonus programs) of the Company and to provide feedback to third parties who submit candidates to the Company regarding their submission.

• International Transfers. By accepting this Privacy Notice, you acknowledge and agree that we may share data with our affiliates and/or use subcontractors and service providers who are located in countries other than your own and may send them information we receive (including Personal Data). All of our subcontractors and service providers will be subject to non-disclosure and non-use obligations

• Business Transfers. Your Personal Data may be disclosed as part of, or during negotiations of, any merger, sale of company assets or acquisition (including in cases of liquidation). In such case, your Personal Data shall continue being subject to the provisions of this Privacy Notice.

• Law Enforcement Related Disclosure. We may share your Personal Data with third parties: (i) if we believe in good faith that disclosure is appropriate to protect our or a third party’s rights, property or safety (including the enforcement of this Privacy Notice); (ii) as is necessary to comply with any legal and/or regulatory obligation; or (iii) when required by subpoena, court order or the order of another governmental or law enforcement authority.

• Legal Uses. We may use your Personal Data as required or permitted by any applicable law, for example, to comply with audit and other legal requirements.

4. Security. We make efforts to follow generally accepted industry standards to protect the Personal Data submitted to and collected by us, both during transmission and once we receive it. However, no method of transmission over the Internet or method of electronic storage is 100% secure. Therefore, while we strive to use commercially acceptable means to protect your Personal Data, we cannot guarantee its absolute security. As the security of information depends in part on the security of the computer you use to communicate with us and the security you use to protect user IDs and passwords, please take appropriate measures to protect this information.

5. Your Rights. Subject to applicable law, you may request to see any Personal Data you have provided to us and request that such Personal Data be corrected or updated by emailing us at hr@surgimate.com

6. Data Retention

• Subject to applicable law, we retain Personal Data as necessary for the purposes set forth above. We may delete information from our systems without notice to you once we deem it is no longer necessary for these purposes.

• In some circumstances, we may store your Personal Data for longer periods of time, for instance where we are required to do so in accordance with legal, regulatory, tax, audit, accounting requirements and so that we have an accurate record of your dealings with us in the event of any complaints or challenges, or if we reasonably believe there is a prospect of litigation relating to your Personal Data or dealings.

7. Communications. We reserve the right to send you service-related communications in connection with the application process, including service announcements and administrative messages, without offering you the opportunity to opt out of receiving them.

8. Children. We do not knowingly collect Personal Data from children. In the event that you become aware that a child has provided us with Personal Data without parental permission, please advise us immediately.

9. Changes to the Privacy Notice. We may update this Privacy Notice from time to time to keep it up to date with legal requirements and the way we operate our business, and we will place any updates on this webpage. Please come back to this page every now and then to make sure you are familiar with the latest version. If we make material changes to this Privacy Notice, we will seek to inform you by notice on our Site or via email.

10. Comments and Questions. If you have any comments or questions about this Privacy Notice or if you wish to exercise any of your legal rights as set out herein, please contact us at hr@surgimate.com.