PRIVACY POLICY

Last Updated: 06.06.2024

Please read carefully

This Privacy Policy explains what types of personal data we may collect about our employees and contractors and how it may be used.

Term	Definition	Legal Status
“us” or “we”	APL Publishing Ltd., Reg. No. HE 424713	Data Controlle
“you” or “your”	Collectively APL Publishing Ltd. current and prospective employee and contractors	Data Subject

What personal data do we collect, on what basis and why?

For Data Subjects that are APL Publishing Ltd. employees:

Purpose of the processing	Data categories	Legal basis
Identifying and communicating effectively with other employees and management	Name Gender Job title Telephone number Email	APL Publishing Ltd.’s legitimate interests being those purposes described in the section headed “Purpose of the processing”
Providing and administering remuneration, salary, benefits, and incentive schemes and providing relevant information to payroll	Name Date of birth Residency Work permit status Nationality Passport information Social security or other taxpayer/government identification number Payroll information, banking details Wage and benefit information Sick pay, Paid Time Off, retirement accounts, pensions, insurance and other benefits information.	Performance under an employment contract with APL Publishing Ltd.
Recruitment, training, development, promotion. Appropriate vetting for recruitment and team allocation including, relevant employment history, relevant regulatory status and professional qualifications	Information from interviews and phone-screenings you may have had, if any. Letters of offer and acceptance of employment. Your resume or CV, cover letter, previous and/or relevant work experience or other experience, education, transcripts, or other information you provide to us in support of an application and/or the application and recruitment process. References and interview notes. Information relating to any previous applications you may have made to APL Publishing Ltd. and/or any previous employment history with APL Publishing Ltd.	APL Publishing Ltd.’s legitimate interests being those purposes described in the section headed “Purpose of the processing”
Processing information about absence or medical information regarding physical or mental health or condition in order to assess eligibility for incapacity or permanent disability related remuneration or benefits	Records of work absences, vacation/paid time off, entitlement and requests, salary history and expectations, performance appraisals, letters of appreciation and commendation, and disciplinary and grievance procedures (including monitoring compliance with and enforcing our policies).	Compliance with a legal obligation to which APL Publishing Ltd. is subject
Operating email, IT, Internet, intranet, social media, HR related and other company policies and procedures.	Name Job title Telephone number Е-mails, correspondence, documents, and other work product and communications created, stored or transmitted for professional or job related purposes using our networks, applications, devices, computers, or communications equipment	APL Publishing Ltd.’s legitimate interests being those purposes described in the section headed “Purpose of the processing”
For business operational and reporting documentation	Name Gender Job title Telephone number Email	APL Publishing Ltd.’s legitimate interests being those purposes described in the section headed “Purpose of the processing”
Complying with applicable laws and regulation (for example maternity or parental leave legislation, working time and health and safety legislation, taxation rules, worker consultation requirements, other employment laws and regulation to which APL Publishing Ltd. is subject in the conduct of its business)	Depends on the applicable laws and regulations	Compliance with a legal obligation to which APL Publishing Ltd. is subject
To enforce our legal rights and obligations, and for any purposes in connection with any legal claims made by, against or otherwise involving you	Depends on the rights and obligations	APL Publishing Ltd.’s legitimate interests being those purposes described in the section headed “Purpose of the processing”
To comply with lawful requests by public authorities (including without limitation to meet national security or law enforcement requirements), discovery requests, or where otherwise required or permitted by applicable laws, court orders, government regulations, or regulatory authorities (including without limitation data protection, tax and employment), whether within or outside your country	Depends on the request	Compliance with a legal obligation to which APL Publishing Ltd. is subject

Apart from personal data relating to yourself, you may also provide us with personal data of related parties, notably your dependents and other family members, for purposes of your HR administration and management, including the administration of benefits and to contact your next-of-kin in an emergency. Before you provide such third-party personal data to us you must first inform these third parties of any such data which you intend to provide and of the processing to be carried out by us. You must ensure and secure evidence that these related parties, or their legal representatives if they are minors, have given their free and express consent that their personal data may be processed by APL Publishing Ltd. and/or its affiliates and subcontractors for the purposes described in this Privacy Policy.

For Data Subjects that are APL Publishing Ltd. contractors:

Purpose of the processing	Data categories	Legal basis
Check relevant regulatory status and professional qualifications assessment	Information from interviews and phone-screenings you may have had, if any. Service agreement details. Your relevant work experience or other experience, education, transcripts, or other information you provide to us. References and interview notes. Information relating to any previous applications you may have made to APL Publishing Ltd. and/or any previous employment history with APL Publishing Ltd.	APL Publishing Ltd.’s legitimate interests being those purposes described in the section headed “Purpose of the processing”
Providing and administering remuneration	Name Date of birth Residency Nationality Passport information Social security or other taxpayer/government identification number Banking details Compensation information	Performance under an agreement with APL Publishing Ltd.
Allocating and managing duties and responsibilities and the business activities to which they relate; Identifying and communicating effectively with management	Name Gender Telephone number Email	APL Publishing Ltd.’s legitimate interests being those purposes described in the section headed “Purpose of the processing”
Managing and operating performance, allegations, complaints, investigations	Е-mails, correspondence, documents, and other service provision results and communications created, stored or transmitted for professional related purposes using our networks, applications, devices, computers, or communications equipment.	APL Publishing Ltd.’s legitimate interests being those purposes described in the section headed “Purpose of the processing”
Operating email, IT, Internet, intranet, social media	Name Telephone number Е-mails, correspondence, documents, and other service provision results and communications created, stored or transmitted for professional related purposes using our networks, applications, devices, computers, or communications equipment.	APL Publishing Ltd.’s legitimate interests being those purposes described in the section headed “Purpose of the processing”
Complying with applicable laws and regulation	Depends on the applicable laws and regulations	Compliance with a legal obligation to which APL Publishing Ltd. is subject
To enforce our legal rights and obligations, and for any purposes in connection with any legal claims made by, against or otherwise involving you	Depends on the rights and obligations	APL Publishing Ltd.’s legitimate interests being those purposes described in the section headed “Purpose of the processing”
To comply with lawful requests by public authorities (including without limitation to meet national security or law enforcement requirements), discovery requests, or where otherwise required or permitted by applicable laws, court orders, government regulations, or regulatory authorities requests, whether within or outside your country	Depends on the request	Compliance with a legal obligation to which APL Publishing Ltd. is subject

How is personal data collected?

Generally, we collect personal data directly from you in circumstances where you provide personal data (during the onboarding process, for example). However, in some instances, the personal data we collect has been inferred about you based on other information you provide us, through your interactions with us, or from third parties. When we collect your personal data from third parties it is either because you have given us express consent to do so, your consent was implied by your actions (e.g., your use of a Third-Party employee service made available to you by us), or because you provided explicit consent to the Third-Party to provide the personal data to us. Where permitted or required by applicable law or regulatory requirements, we may collect personal data about you without your knowledge or consent.

We reserve the right to monitor the use of our equipment, devices, computers, network, applications, software, and similar assets and resources for the safety and protection of employees and intellectual property. In the event such monitoring occurs, it may result in the collection of personal data about you. If required by applicable law, we will notify you of such monitoring and obtain your consent.

Sharing personal data

Your personal data may be shared, including to our affiliates, subsidiaries, and other third parties, as follows:

• Where you request us or provide your consent to us.
• In order to carry out the uses of personal data described above. When using or collaborating with third parties in the operation of our business, including in connection with providing many of the benefits and services we offer our Data Subjects. When we share personal data with third parties we typically require that they only use or disclose such personal data in a manner consistent with the use and disclosure provisions of this Privacy Policy and applicable law.
• We may buy or sell businesses and other assets. In such transactions, Data Subjects data is generally one of the transferred business assets and we reserve the right to include your personal data as an asset in any such transfer. Also, in the event that we, or substantially all of our assets, are acquired, your personal data may be one of the transferred assets.
• Where required by law, by order or requirement of a court, administrative agency, or government tribunal, which includes in response to a lawful request by public authorities, including to meet national security or law enforcement requirements or in response to legal process.
• If we determine it is necessary or desirable to comply with the law or to protect or defend our rights or property.
• As necessary to protect the rights, privacy, safety, or property of an identifiable person or group or to detect, prevent or otherwise address fraud, security or technical issues, or to protect against harm to the rights, property or safety of APL Publishing Ltd., our users, applicants, candidates, employees or the public or as otherwise required by law.
• Where the personal data is public and exempted from coverage under applicable data protection laws.
• To seek advice from our lawyers and other professional advisors.
• To professional advisors (e.g. bankers, lawyers, accountants) and potential buyers and vendors in connection with the sale, disposal or acquisition by use of a business or assets.

Who has access to personal data?

Your information will be shared internally, including with members of the legal team, your supervisor, managers in the business area in which you volunteer and IT staff if access to the data is necessary for performance of their roles.

APL Publishing Ltd. does not share your data with third parties.

How do we protect personal data?

APL Publishing Ltd. takes the security of your data seriously. APL Publishing Ltd. has internal policies and controls in place to try to ensure that your data is not lost, accidentally destroyed, misused or disclosed, and is not accessed except by its employees in the performance of their duties.

How long do we keep your personal data?

Personal data for Data Subjects in the European Union is by default erased by APL Publishing Ltd. after termination of your employment or service agreement, with the exception of certain types of personal data, which may be stored for an extended period of time due to administrative purposes, or where such personal data must be retained to comply with regulatory requirements.

Your rights

As a data subject, you have several rights. You can:

• access and obtain a copy of your data on request
• require APL Publishing Ltd. to change incorrect or incomplete data
• require APL Publishing Ltd. to delete or stop processing your data, for example where the data is no longer necessary for the purposes of processing
• object to the processing of your data where APL Publishing Ltd. is relying on its legitimate interests as the legal grounds for processing
• ask APL Publishing Ltd. to stop processing data for a period if data is inaccurate or there is a dispute about whether or not your interests override APL Publishing Ltd.'s legitimate grounds for processing data.

If you would like to exercise any of these rights, please contact us:

• by email: legal@aplpublish.com
• by post: Neofytou Nikolaidi & Kilkis, 35, Flat/Office 312, 8011 Paphos, Cyprus

If you believe that we have not complied with your data protection rights, you can complain to the Office of the Commissioner for Personal Data Protection of Cyprus.

What if you do not provide personal data?

We would not be able to set up or continue a contracting arrangement with you.

Automated decision-making

No decisions taken by us connected with Data Subjects are based solely on automated decision-making.