Privacy & Data Protection Notice

Depending on how you interact with Exacta, we may collect information including:

Candidates

• Name and contact details
• CV and employment history
• Job title and professional experience
• Skills and qualifications
• Salary expectations
• Location and relocation preferences
• Notice period and availability
• Languages
• Interview and assessment information
• Recruitment preferences
• Communications with Exacta
• Information required to assess suitability for employment opportunities

We may receive this information directly from you or, where appropriate, from professional networking platforms, referrals, previous recruitment processes, publicly available professional sources or other recruitment-related sources.

Employers and Clients

• Name
• Company
• Job title
• Business contact details
• Recruitment requirements
• Candidate enquiries
• Communications with Exacta
• Information relating to services requested from us

Website Visitors

When you use the website, we may also collect technical information such as:

• IP address
• Device and browser information
• Pages viewed
• Traffic and interaction data
• Candidate or job profiles viewed
• Enquiry form submissions

This information may be collected through cookies and analytics technologies.

Exacta may invite selected candidates to appear within the Featured Talent section of our website. Candidate participation is voluntary.

Before a candidate profile is published, Exacta will obtain the candidate's specific consent to participate.

The publicly displayed profile is designed to prevent the candidate from being directly identified and may contain information such as:

• Professional title
• Seniority
• General experience
• Sector experience
• Skills
• General location
• Salary expectations or range
• Notice period or availability
• Languages and other relevant professional information

Exacta may generalise or remove information where we believe that displaying it could reasonably identify the candidate.

The candidate's name, photograph, email address, telephone number and other directly identifying information will not appear on the public profile. Exacta will continue to hold the candidate's underlying recruitment record separately.

Where an employer is interested in an anonymised candidate profile, the employer may submit a "Request an Introduction" enquiry.

Submitting an enquiry does not automatically disclose the candidate's identity.

Exacta will review the request and contact the candidate. The candidate will then be given sufficient information about the prospective employer and opportunity to decide whether they wish to proceed.

The candidate's identifying information will only be disclosed to that employer after the candidate has agreed to the introduction.

A candidate is free to decline an introduction without affecting their relationship with Exacta or their participation in other recruitment processes.

For the Featured Talent service, we operate two separate consent stages:

Stage 1 — Publication

The candidate agrees to the publication of their anonymised professional profile on the Exacta website.

Stage 2 — Introduction

Where a specific employer requests an introduction, the candidate separately decides whether their identity and contact information may be disclosed to that employer.

Consent can be withdrawn at any time. Where a candidate withdraws consent to publication, Exacta will remove their public profile as soon as reasonably practicable. Withdrawal of consent does not affect processing which lawfully took place before the consent was withdrawn.

Candidates may browse job opportunities advertised on the Exacta website.

Where a candidate expresses interest in a role, we may collect information including their:

• Name
• Contact details
• CV
• Current role
• Professional background
• Message or enquiry
• Details of the job in which they expressed interest

Exacta may then contact the candidate regarding the opportunity and, where appropriate, other relevant recruitment opportunities. Submitting an expression of interest does not guarantee that a candidate will be presented to the employer or proceed within the recruitment process.

We may use personal data to:

• provide recruitment and executive-search services;
• assess candidates for opportunities;
• communicate with candidates and employers;
• respond to enquiries;
• manage job applications;
• create and manage candidate records;
• operate the Featured Talent service;
• facilitate candidate introductions;
• verify candidate information;
• improve our recruitment services;
• administer and secure the website;
• analyse website engagement and usage;
• comply with legal and regulatory obligations; and
• send marketing or business communications where legally permitted.

Depending on the circumstances, Exacta may process personal data because:

• you have consented to the processing;
• processing is necessary to take steps at your request before entering into a contract;
• processing is necessary for the performance of a contract;
• Exacta has a legitimate interest, including operating and improving its recruitment business, managing professional relationships, responding to enquiries and protecting its systems; or
• processing is necessary to comply with a legal obligation.

Where we rely on consent, you may withdraw that consent at any time. Where we rely on legitimate interests, we consider whether those interests are balanced against the rights and interests of the individuals concerned.

We do not intend to display sensitive or special-category personal data within public candidate profiles. Where such information is processed as part of a recruitment process, it will only be processed where there is an appropriate lawful basis and where it is necessary and relevant.

We may share personal information where necessary with:

• prospective employers;
• clients engaging Exacta for recruitment services;
• companies within relevant client groups where appropriate;
• technology and website providers;
• CRM and recruitment-system providers;
• email and communication providers;
• cloud hosting providers;
• analytics providers;
• professional advisers;
• regulators or public authorities where required by law.

Service providers processing personal data on Exacta's behalf are required to protect that information and process it only for authorised purposes. We do not sell candidate personal data.

Some clients, employers or service providers may be located outside Malta or outside the European Economic Area. Where personal data is transferred outside the EEA, Exacta will use an appropriate legal mechanism where required, which may include:

• an adequacy decision recognised by the European Commission;
• Standard Contractual Clauses;
• contractual and organisational safeguards; or
• another legally permitted transfer mechanism.

We retain personal information only for as long as reasonably necessary for the purpose for which it was collected, including:

• maintaining recruitment relationships;
• considering candidates for present and future opportunities;
• providing services to clients;
• complying with legal, accounting or regulatory requirements;
• resolving disputes; and
• protecting Exacta's legitimate business interests.

Retention periods may therefore vary depending on the nature of the information and our relationship with you. Candidate participation in the Featured Talent section will be reviewed periodically, and profiles may be removed when they are no longer current, the candidate is no longer available, or the candidate withdraws consent.

Candidates are encouraged to notify Exacta if their professional information changes. We may periodically contact candidates to verify that information remains accurate and current. Where we identify information that is materially inaccurate or outdated, we may update, restrict or remove the relevant profile.

The Featured Talent service does not make automated employment or recruitment decisions. Candidate suitability, employer enquiries and introductions remain subject to human review by Exacta. If this changes in the future, this Notice will be updated accordingly.

Exacta takes reasonable technical and organisational measures to protect personal data against:

• unauthorised access;
• accidental loss;
• misuse;
• alteration;
• disclosure; and
• destruction.

Access to candidate identity information is restricted to authorised individuals and service providers who require access for legitimate business purposes.

The Exacta website may use cookies and similar technologies to operate the website and understand how visitors interact with it. These may include:

• essential website cookies;
• analytics cookies;
• functionality cookies; and
• marketing cookies.

Where consent is legally required, non-essential cookies will only be used after consent has been provided.

Depending on the circumstances, you may have the right to:

• be informed about how your data is used;
• request access to your personal data;
• request correction of inaccurate information;
• request deletion of your personal data;
• request restriction of processing;
• object to certain processing;
• request data portability;
• withdraw consent at any time where consent is the legal basis; and
• object to certain forms of direct marketing.

Requests may be submitted to info@exactasolutions.com. Exacta may need to verify your identity before processing certain requests. We generally respond to data-subject requests within one month, subject to permitted extensions in more complex cases.

If you have concerns about how Exacta processes your personal data, we encourage you to contact us first so that we can try to resolve the matter.

You also have the right to lodge a complaint with the Maltese supervisory authority, the Office of the Information and Data Protection Commissioner (IDPC), Malta — idpc.org.mt.

The Exacta website may contain links to third-party websites or social-media platforms. Exacta is not responsible for the privacy practices of external websites. Users should review the relevant privacy notice when leaving our website.

We may update this Privacy & Data Protection Notice periodically to reflect changes to our services, technology or legal obligations. The latest version will always be published on this page together with the date of the most recent update.