Job Applicant Privacy Notice

March 2026

As part of any recruitment process, Interogo Fund Management S.A. (“IFM”) (“we”, “our” or “us”) collects, handles and processes personal data relating to job applicants. We are committed to being transparent about how we collect and use that data and to meeting our data protection obligations. This notice applies to all applicants who apply for employment in our Luxembourg office only.

IFM acts as the data “Controller” for the processing of your personal data. Personal data will be processed in compliance with the Luxembourg law of 1 August 2018 on the organization of National Commission for Data Protection (CNPD) and on the general data protection regime, and the EU General Data Protection Regulation (GDPR) its implementing ordinance, and any other applicable laws or regulations which implement or supplement the foregoing) (collectively, the “applicable data protection laws”). “Personal data”, “processor”, and “controller” have the meanings given in the applicable data protection laws.

Any questions about the contents of this privacy notice or how personal data will be used, stored, or transferred, should be sent to the Data Protection Manager (“DPM”), being namely Alexandra Tanase, senior legal counsel at IFM at [[email protected]] or at the following address: Alexandra Tanase, Interogo Fund Management S.A., 2, rue Jean Bertholet, L-1233 Luxembourg. l

What personal data do we collect?

IFM may collect and process a range of personal data about you. This includes, but is not limited to:

  • your name, address and contact details, including email address and telephone number;
  • gender, nationality, citizenship, date of birth, details of dependents and family members (where applicable);
  • education and employment information (e.g. remuneration, bonus, pension entitlements, insurance and other benefits information, employment dates such as dates of hiring/promotion/position change, performance evaluation, position information such as position title and reference number, attendance information including illness or leaves of absence, language skills, degree grade/title, certificates, licences, memberships of committees or other bodies);
  • records of interviews (including attendance details at our office) or interview notes. For certain roles, we will obtain the results from assessments we have conducted with you or from assessment agencies that have conducted an assessment with you;
  • any feedback or opinions you voluntarily provide to us during the recruitment process;
  • national insurance number, social security number or local equivalent;
  • evidence of your right to work in the place of your prospective employment; and
  • any other personal data which you choose to disclose to us during the course of the application process.

In principle, we do not collect or use any special categories of personal data of applicants, such as health data or other sensitive types of data, unless you provide this to us voluntarily as part of your application documentation or during an interview.

IFM may collect this information in a variety of ways. For example, data might be contained in application forms, CVs or resumes, obtained from your passport or other identity documents, or collected through interviews or other forms of assessment. IFM may also collect personal data indirectly from recruiters, external assessors, academic institutions, certification providers and industry bodies, from other administration, or from publicly available sources (including via social media, to the extent that you choose to make your profile publicly available).

IFM may carry out background checks as part of the application process and may use a third party for the purpose. Those checks may include criminal record checks, credit reference checks and similar background verification activities.

We may also, with your permission, collect personal data from any person who you have nominated as an employment referee.

Why does IFM process personal data?

We need to process personal data to manage your application through the entire application process and to take steps at your request prior to entering into a contract with you. We may also need to process your data to enter into a contract with you. In some cases, we need to process data to ensure that we are complying with our legal obligations.

IFM has a legitimate interest in processing personal data during the recruitment process and for keeping records of the process. Processing data from job applicants allows us to manage the recruitment process, assess and confirm a candidate's suitability for employment and decide to whom to offer a job. We may also need to process data from job applicants to respond to and defend against legal claims.

How does IFM protect personal data?

We take the security of your data seriously. We have implemented adequate technical and organisational measures to protect personal data against unauthorised, accidental or unlawful destruction, loss, alteration, misuse, disclosure or access and against all other unlawful forms of processing. All personnel accessing your personal data must comply with the internal rules and processes in relation to the processing of personal data to protect them and ensure their confidentiality. They are also required to follow all technical and organisational security measures put in place to protect the personal data.

Who has access to personal data and with whom are they shared?

We may transfer personal data internally at IFM on a need-to-know basis and to other companies of the group to which we belong (the “Interogo Holding Group”). Such other companies of Interogo Holding Group will either act as another controller under this notice or will only process personal data on behalf and upon request of IFM.

We may also transfer personal data to third parties outside Interogo Holding Group to complete the purposes listed in the table above, to the extent they need it to carry out the instructions we have given to them. Such third parties may include: 

  • third parties who process personal data, such as our (IT) systems providers, our payroll provider, transport companies or travel agency, cloud service providers, database providers, consultants and third parties who carry out pre-employment checks and tests on prospective Co-workers. Where relevant, these third parties have entered into an agreement with IFM  (or another Interogo Holding Group member) to keep personal data secure;
  • successors in title of our business in case of a corporate transaction;
  • any national and/or international regulatory, enforcement or exchange body or court where we are required to do so by applicable law or regulation or at their request; and
  • any central or local government department and other statutory or public bodies.

The Personal Data transferred within or outside Interogo Holding Group above, may also be processed in a country outside the United Kingdom and the European Economic Area (collectively, the “equivalent standard jurisdictions"). Countries other than the equivalent standard jurisdictions may not offer the same level of personal data protection as the equivalent standard jurisdictions.

If your personal data is transferred outside the equivalent standard jurisdictions, we will put suitable safeguards in place to ensure that such transfers is carried out in compliance with the applicable data protection laws (e.g., use of standard contractual clauses), provided that we cannot rely on a statutory exemption clause. You may request additional information in this respect and obtain a copy of the relevant safeguard by exercising your rights as set out below.

For how long does IFM keep data?

We will keep your personal data for long as necessarily to fulfil the purpose for which it was collected.

If your application for employment is unsuccessful, we will keep your personal data on file for three months (from the date that we communicate this) in case of any potential legal claim. 

We may ask your consent to contact you about future employment opportunities. If you agree, we will keep your personal data on file for up to 12 months for this purpose.

If your application for employment is successful, your personal data will be processed in accordance with our internal personal data protection policy.

Profiling and automated decision-making

We do not use profiling and do not make any automated individual decisions within HR.

Your rights

Individuals whose personal data is processed by IFM have certain legal rights in respect of the information. These include:

  • request access to or correction of your personal data;
  • request the erasure of your personal data;
  • request the restriction of the processing of your personal data;
  • withdraw or restrict your consent where IFM obtained your consent to process personal data (without this withdrawal affecting the lawfulness of processing prior to the withdrawal); and
  • request data portability (such as the right to receive any Personal Data you have provided to IFM in a structured, commonly used and machine-readable format, as well as to require IFM to transmit it to another controller when technically feasible).

If you would like to exercise any of these rights, please contact DPM.  IFM will honour any of the above requests, withdrawal or objections as required under the applicable data protection laws but not all of these rights are absolute; they do not always apply, and sometimes exemptions may be engaged. We may, in response to a request, ask you to verify your identity and/or provide information that will help us to understand your request better. If we do not comply with your request, we will explain why. 

What if you do not provide personal data?

You are under no statutory or contractual obligation to provide data to IFM during the recruitment process. However, if you do not provide the information, we may not be able to process your application properly or at all.

Updates

This notice may be updated periodically and without prior notice to reflect changes in IFM’s personal information practices. IFM will post the updated version on its website and indicate at the top of the notice when it was most recently updated.