Transparency Notice – Nova Recruiter (Article 14 GDPR)

1. Who we are

Nova Recruiter is operated by NGlobal Holding AB and its subsidiaries (together, “Nova”). Our contact details are:

• NGlobal Holding AB (”Nova”)
• C/O Talent Venture Group AB, Postbox 3053, 10361 Stockholm, Sweden
• privacy@novatalent.com

Nova has appointed a Data Protection Officer pursuant to Articles 37–39 GDPR. The DPO can be contacted for any inquiries regarding this Notice or Nova’s processing of personal data: dpo@novatalent.com

2. Why we publish this notice

You may see your professional information inside the Nova Recruiter platform even though you never created an account with us. Under Article 14 GDPR, Nova must explain how and why we process personal data obtained from public or third-party sources, and how you can exercise your rights.

Because Nova Recruiter indexes millions of professional profiles that change frequently, providing individual notice to each data subject would involve disproportionate effort (Article 14(5)(b) GDPR). Nova therefore provides this public transparency notice, an in-product opt-out function, and direct contact via privacy@novatalent.com as a layered transparency approach.

3. What data we process

Nova Recruiter processes professional and business-context information only, such as:

• Full name
• Current and past roles, employers and industries
• Email address
• LinkedIn URL or other public profile link
• Location (city/country)
• Education and career history
• Professional skills and experience

Nova does not process special-category data (e.g. health, beliefs, political views) or any data unrelated to your professional activity.

4. Where the data comes from

Your information may have been obtained from either:

• Publicly available sources such as company websites, conference pages or public directories;
• Licensed data providers such as ContactOut Limited, which lawfully compile and license professional data collected from public sources under GDPR-compliant conditions.

ContactOut and similar providers act as independent Data Controllers and are responsible for ensuring lawful collection before sharing it with Nova. Nova acts as a subsequent Controller for the limited purpose of enabling legitimate recruitment activity within Nova Recruiter.

5. Why we process this data

Nova processes professional data to:

• Enable authorized recruiters and companies to identify and contact qualified candidates for legitimate hiring purposes
• Maintain the accuracy and relevance of professional information displayed on Nova Recruiter
• Produce aggregated, non-identifiable statistics to improve our service.

We never resell or distribute data as a standalone dataset.

6. Legal basis

Processing of professional data from public or licensed sources is carried out under legitimate interest (Article 6(1)(f) GDPR).

Nova’s legitimate interest is to operate a business-to-business recruitment platform that facilitates fair, efficient matching between employers and professionals in a manner consistent with individuals’ reasonable expectations in a professional context.

A three-part legitimate-interest assessment confirms that the processing is necessary for this purpose, uses only professional data, and applies safeguards such as access controls, audit logging, and easy opt-out.

A summary of this assessment can be provided upon request.

7. Who can access your data

Access is restricted to:

• Verified Nova Recruiter clients (recruiters and companies) bound by contractual terms limiting use to recruitment purposes; and
• Nova’s authorized employees and service providers who process data on Nova’s behalf under confidentiality and security obligations.

Data is not publicly searchable and is not sold or shared for marketing or advertising.

8. Your rights

You may at any time:

• Request access to the personal data we hold about you
• Request correction or deletion of that data
• Object to our processing based on legitimate interest
• Request restriction of processing or data portability.

To exercise any of these rights, contact us at privacy@novatalent.com. If you object, we will remove your profile from Nova Recruiter unless we have an overriding legitimate reason (e.g. ongoing recruitment communication initiated before your objection).

If we cannot identify you in our index with the information you provide, we may ask you for additional details — such as your LinkedIn URL, current employer, or public profile link — solely to locate your record. We will not retain this information after resolving your request.

If your professional data originated from a licensed provider (for example, ContactOut Limited), we will, where contractually possible, also inform that provider of your objection or deletion request so they can update their dataset accordingly.

You also have the right to lodge a complaint with your local Data Protection Authority (e.g. AEPD in Spain, IMY in Sweden or Garante Privacy in Italy).

9. How long we keep your data

Professional data is retained only while relevant and accurate for legitimate recruitment purposes.Data is reviewed and refreshed regularly. When you object or request deletion, your record is immediately removed from active search results and placed on a suppression list to avoid re-entry from third-party updates.

10. Security and updates

Nova employs technical and organisational measures —including encryption, access control, and monitoring—to protect personal data against unauthorised access, loss, or misuse.

This Notice may be updated periodically to reflect legal, technical, or operational changes; the revision date above always shows the latest version.

© 2025 NGlobal Holding AB (Nova). All rights reserved.

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