PRIVACY POLICY

The UniqueTrafficGroup of Companies (** UniqueTrafficGroup **) respects the privacy of individuals with regard to personal data.

**A. INFORMATION COLLECTED**

1 “Personal Data” consists of any information we collect that identifies you, or from which you are reasonably identifiable, and includes:

* information collected when you fill in our Candidate Data Form or update your information with us, which may include personal data such as your photograph, name and contact details;

* the contents of all documents submitted to us;

* any messages or comments you submit to us in whatever manner, which may include personal data such as name, email address and telephone number; and

* CCTV/security recordings and location tracking/GPS information.

**B. PURPOSE OF COLLECTION OF PERSONAL DATA**

1 By providing any of your Personal Data to the UniqueTrafficGroup , you hereby agree that the UniqueTrafficGroup shall collect, retain and use the Personal Data for the following purposes:

* to determine your suitability for a position with our clients or for within the UniqueTrafficGroup and, if applicable, your terms of employment or engagement; and/or

* disclosed to third parties to verify or obtain additional information including education institutions, current/previous employers and credit reference agencies; and/or

* providing you with services or benefits under any of the UniqueTrafficGroup ’s businesses; and/or

* where relevant, marketing of services and sending any updates or market intelligence to you; and/or

* performing statistical analysis for various objectives in the UniqueTrafficGroup ; and/or

* purposes connected with the operation, administration, development or enhancement of the UniqueTrafficGroup ’s business including to support and/or assist in any of the UniqueTrafficGroup ’s businesses (for example, providing information on you and on your working experience to fulfil information as required for the submission of tenders for projects or for fulfilling regulatory requirements); and/or

* where required by law, where the UniqueTrafficGroup considers that such use or disclosure is necessary to respond to any claims or legal process, or where the UniqueTrafficGroup suspects that fraud or unlawful activity has been, is being or may be engaged in; and/or

* where a third party acquires or wishes to acquire, or makes inquiries in relation to acquiring, an interest in any company within the UniqueTrafficGroup ; and/or

* where a third party requires in order for such third party to perform functions or services as required by the UniqueTrafficGroup (for example, to insurance companies who are arranging for the UniqueTrafficGroup ’s term life policy and to banks who are arranging for salary remittances); and/or

* where a third party requires in order for such third party to perform functions or obligations as required under the laws, rules, regulations, by laws and/or guidelines (whether or not having the force of law) or as required by any governmental and/or non governmental authorities, agencies or departments (for example, to external auditors who are auditing the UniqueTrafficGroup ’s human resource processes); and/or

* making such disclosures as may be required for any of the above purposes or by law.

**C. USE AND DISCLOSURE**

1 You agree that the UniqueTrafficGroup may disclose and transfer (whether in your country or abroad) amongst any company within the UniqueTrafficGroup and/or to third parties including but not limited to any of the UniqueTrafficGroup ’s clients to whom you are/will be introduced to, the UniqueTrafficGroup ’s agents, consultants, solicitors, auditors, employees, contractors, suppliers, partners, advertisers, network operators, associated companies, any relevant authorities, embassies, statutory bodies, regulatory bodies, organisations or any relevant financial institutions, any other persons under a duty of confidentiality to the UniqueTrafficGroup , any referee whose details are provided by you, proposed assignees or transferees of any of rights of the companies within the UniqueTrafficGroup , service providers for the UniqueTrafficGroup ’s operational, administration and development requirements and to organizations who provide archival, auditing, professional advisory, debt collection, insurance, banking, marketing, advertising, mailhouse, delivery, recruitment, call centre, technology, research, utility and security services to use, disclose, hold, process, retain or transfer such Personal Data for the purposes of (B) above for and on behalf of UniqueTrafficGroup .

2 You hereby confirm that you have duly obtained the consent of your referee(s) for the use and disclosure of your referee(s)’ Personal Data to the UniqueTrafficGroup and that the UniqueTrafficGroup may use your referee(s)’ Personal Data in accordance with this Privacy Notice.

**D. IMPACT OF NON PROVISION OF PERSONAL DATA**

1 Please note that in the event that sufficient Personal Data is not supplied, or is not satisfactory to the UniqueTrafficGroup and its clients then your application or request to the UniqueTrafficGroup for any of the above purposes as set out in (B) above may not be accepted or acted upon and the UniqueTrafficGroup will not be able to provide the full range of benefits and/or services it offers.

**E. STORAGE AND RETENTION OF THE PERSONAL DATA**

1 Your Personal Data shall be stored either in hard copies in the UniqueTrafficGroup ’s offices or stored in servers located in or outside your country and operated by the UniqueTrafficGroup or its service providers in or outside your country.

2 Any Personal Data supplied by you will be retained by the UniqueTrafficGroup as long as necessary for the fulfilment of the purposes stated in (B) above or is required to satisfy legal regulatory, accounting requirements or to protect the UniqueTrafficGroup ’s interests.

**F. CONFIDENTIALITY**

1 Personal Data held by the UniqueTrafficGroup will be kept confidential in accordance with this Privacy Notice and any applicable laws that may from time to time be in force.

2 Any questions, comments, suggestions or information other than Personal Data submitted to us in whatever manner will be deemed voluntarily provided to the UniqueTrafficGroup on a non-confidential and non-proprietary basis.

3 The UniqueTrafficGroup reserves the right to use, reproduce, disclose, transmit, publish, broadcast and/or post elsewhere such information freely as set out in (C) above.

**G. SAFETY OF PERSONAL DATA**

1 The UniqueTrafficGroup uses a number of mechanisms to protect the security and integrity of your Personal Data.

**H. TRANSFER OF PERSONAL DATA**

1 Due to the global nature of the UniqueTrafficGroup ’s business, the UniqueTrafficGroup may transfer your Personal Data to the other members of the UniqueTrafficGroup (which may be located in other countries) or to any parties located in other countries (including countries that have a different data protection regime than is found in the country where you are based). Any Personal Data transferred shall be used for the purposes as set out in (B) above and disclosed to parties stated in (C) above.

**I. RIGHT OF ACCESS TO PERSONAL DATA**

1 Under the Act, you have the right of access to your Personal Data held by UniqueTrafficGroup on payment of a prescribed fee and to request correction of the Personal Data that is inaccurate, incomplete, misleading or not up-to-date.

2 If you have any questions regarding this Privacy Notice or if you wish to request access to your Personal Data or if you wish to correct your Personal Data or if you wish to withdraw your consent to the UniqueTrafficGroup for the processing of your Personal Data for the purposes as set out in (B) above or for the transfer of your Personal Data to the parties stated in (C) above, you may send your request in writing at the following address:

**The UniqueTrafficGroup of Companies**

4023 Kennett Pike #54126

Wilmington, DE 19807

**Attention: The Data Protection Officer**

[info@ UniqueTrafficGroup .com](mailto:info@ UniqueTrafficGroup .com)

The UniqueTrafficGroup reserves the right to charge you a reasonable fee for the processing of any data access request.

**J. CHANGES TO PRIVACY NOTICE**

1 The UniqueTrafficGroup reserves the right to amend this Privacy Notice from time to time without prior notice. The UniqueTrafficGroup advises that you check this Privacy Notice on a regular basis.