Data Protection Policy for Job Applicants - Singapore

This Data Protection Policy (“Policy”) sets out the basis upon which Relativity ODA LLC and its subsidiaries and affiliates (“Relativity”, “we”, “us” or “our”) may collect, use, disclose or otherwise process personal data of job applicants in Singapore in accordance with the Personal Data Protection Act 2012 (“PDPA”). This Policy applies to personal data in our possession or under our control, including personal data in the possession of organisations which we have engaged to collect, use, disclose or process personal data for our purposes. This Policy applies only to individuals applying for employment with Relativity in Singapore, from application through our recruitment and hiring process. It does not apply to current or former employees, contractors, consultants, customers, website users or other individuals. If your application is successful, we will provide you with a separate privacy notice covering your employment.

Application of this Policy

1. This Policy applies to persons who have applied for any position with us (“job applicants”).

Personal Data

2. As used in this Policy, “personal data” means data, whether true or not, about a job applicant who can be identified: (a) from that data; or (b) from that data and other information to which we have or are likely to have access.
3. If you are a job applicant, personal data which we may collect includes, without limitation, your: (a) name or alias, gender, date of birth, nationality, and country and city of birth; (b) mailing address, telephone numbers, email address and other contact details; (c) resume, application form, cover letter and LinkedIn or other professional profile, educational qualifications, professional qualifications and certifications and employment references; (d) employment and training history; (e) work-related health issues and disabilities; (f) photographs; and (g) where a background check is conducted, information necessary to complete that check to the extent permitted by law (as detailed more fully below).
4. We do not require sensitive personal data to evaluate your application. If you voluntarily provide such information, we may process it to handle your application and to comply with our legal obligations, and you consent to our doing so as described in this Policy. If you provide personal data about other individuals (such as reference providers or emergency contacts), you must first inform them and make this Policy available to them.

Collection, Use and Disclosure of Personal Data

5. We generally collect personal data that (a) you knowingly and voluntarily provide in the course of or in connection with your job application with us, or via a third party who has been duly authorised by you to disclose your personal data to us (your “authorised representative”, which may include your recruitment or job-placement agency), after (i) you (or your authorised representative) have been notified of the purposes for which the data is collected, and (ii) you (or your authorised representative) have provided consent to the collection and usage of your personal data for those purposes, or (b) collection and use of personal data without consent is permitted or required by the PDPA or other laws. We may also collect your personal data from external job boards, from publicly available professional and employment-oriented sources, from recruiters who contact you, and from background-check providers and reference providers or prior employers you authorise us to contact. We shall seek your consent before collecting any additional personal data and before using your personal data for a purpose which has not been notified to you (except where permitted or authorised by law).
6. If you are a job applicant, your personal data will be collected and used by us for the following purposes and we may disclose your personal data to third parties where necessary for the following purposes: (a) assessing and evaluating your suitability for employment in any current or prospective position within the organisation; (b) verifying your identity and the accuracy of your personal details and other information provided; (c) communicating with you about your application and about other opportunities that may suit you; (d) conducting reference checks and, where applicable and permitted by law, background checks; (e) preparing for and, if you are successful, making and administering an offer of employment; and (f) complying with our legal and regulatory obligations and managing or defending legal claims relating to the recruitment process.
7. Background checks. In line with our security protocols and to the extent permitted by law, we may require you to complete a background check during recruitment or upon being hired. Background checks are conducted by a third-party provider, and we require that both we and that provider comply with all relevant laws when conducting the check and handling your personal data. Information obtained is used solely for recruitment and employment purposes and kept confidential. If you do not complete a required check or provide the correct information, we may, in accordance with applicable law, stop considering your application.
8. Disclosure. We share applicant personal data only where necessary for the purposes above: within Relativity and with our affiliates involved in recruitment, including through our global HR and recruitment systems (applicant information is otherwise shared internally only); with recruitment agencies, background-check providers, and reference providers or prior employers you authorise us to contact; with service providers that host or support our recruitment systems under confidentiality obligations; with government authorities, regulators, courts and professional advisors where legally required or to protect our rights; and with parties to an actual or proposed merger, acquisition, financing or sale of our business. We do not sell, rent or trade your personal data, and we do not share it for third-party marketing.
9. The purposes listed in the above clauses may continue to apply even in situations where your relationship with us has been terminated or altered in any way, for a reasonable period thereafter (including, where applicable, a period to enable us to enforce our rights).

Withdrawing Consent by Job Applicants

10. The consent that you provide for the collection, use and disclosure of your personal data will remain valid until such time it is withdrawn by you in writing. If you are a job applicant, you may withdraw consent and request us to stop using and/or disclosing your personal data for any or all of the purposes listed above by submitting your request in writing or via email to our Data Protection Officer at the contact details provided below.
11. Upon receipt of your written request to withdraw your consent, we may require reasonable time for your request to be processed and for us to notify you of the consequences of us acceding to the same. In general, we shall seek to process and effect your request within thirty (30) days of receiving it.
12. Whilst we respect your decision to withdraw your consent, please note that depending on the nature and extent of your request, we may not be in a position to process your job application. We shall, in such circumstances, notify you before completing the processing of your request.
13. Withdrawing consent does not affect our right to continue to collect, use and disclose personal data where such collection, use and disclosure without consent is permitted or required under applicable laws.

Access To and Correction of Personal Data

14. If you wish to make (a) an access request for a copy of the personal data which we hold about you or information about the ways in which we use or disclose your personal data, or (b) a correction request to correct or update any of your personal data, you may submit your request in writing or via email to our Data Protection Officer at the contact details provided below.
15. A reasonable fee may be charged for an access request. If so, we will inform you of the fee before processing your request.
16. We will respond to your access request as soon as reasonably possible. Should we not be able to respond within thirty (30) days, we will inform you in writing of the time by which we will be able to respond. If we are unable to provide the personal data or make a correction requested, we shall generally inform you of the reasons (except where we are not required to do so under the PDPA).

Protection of Personal Data

17. To safeguard your personal data from unauthorised access, collection, use, disclosure, copying, modification, disposal or similar risks, we have introduced appropriate administrative, physical and technical measures such as encryption, access controls and need-to-know disclosure to authorised third-party service providers and agents.
18. You should be aware, however, that no method of transmission over the Internet or method of electronic storage is completely secure. While security cannot be guaranteed, we strive to protect the security of your information and are constantly reviewing and enhancing our information security measures.

Accuracy of Personal Data

19. We generally rely on personal data provided by you (or your authorised representative). To ensure your personal data is current, complete and accurate, please update us if there are changes by informing our Data Protection Officer.

Retention of Personal Data

20. We may retain your personal data for as long as it is necessary to fulfil the purposes for which it was collected, or as required or permitted by applicable laws. If you are not offered a position, we may retain your application information for up to three (3) years after the recruitment process is complete so that we may consider you for other suitable opportunities at Relativity, after which we will delete it unless you have joined Relativity or we are required to keep it for legal reasons.
21. We will cease to retain your personal data or remove the means by which the data can be associated with you, as soon as it is reasonable to assume that such retention no longer serves the purposes for which it was collected and is no longer necessary for legal or business purposes.

Transfers of Personal Data Outside of Singapore

22. Relativity is headquartered in the United States and operates globally. Your personal data may be transferred to, stored, or accessed by Relativity and its affiliates and service providers outside Singapore, including in the United States. Where we transfer your personal data outside Singapore, we will take steps to ensure that it continues to receive a standard of protection at least comparable to that required under the PDPA, including through appropriate contractual arrangements with the recipients.

Data Protection Officer

23. You may contact our Data Protection Officer if you have any enquiries or feedback on our personal data protection policies and procedures, or if you wish to make any request, as follows: Email: privacy.inquiries@relativity.com; Post: Relativity ODA LLC, ATTN: Legal (Singapore Data Protection Officer), 20th Floor, 231 S LaSalle St., Chicago IL 60604, USA.
24. If you are not satisfied with our response, you may lodge a complaint with the Personal Data Protection Commission of Singapore at www.pdpc.gov.sg.

Effect of Policy and Changes to Policy

25. This Policy applies in conjunction with any other policies, notices and consent clauses that apply in relation to the collection, use and disclosure of your personal data by us.
26. We may revise this Policy from time to time. You may determine if any revision has taken place by referring to the date on which this Policy was last updated.

Effective date: July 17, 2026

Last updated: July 17, 2026