HEIDELBERG DISTRIBUTING COMPANY 

RECRUITING PRIVACY POLICY

Heidelberg Distributing Company (HDC) is committed to respecting your privacy and protecting your personal data. We define personal data broadly as information that directly identifies an individual or that makes an individual identifiable when combined with other information.

This Recruiting Privacy Notice (“Privacy Notice”) describes how we handle and protect your personal data in connection with HDC’s recruiting processes and programs. In case of a conflict between this Privacy Notice and applicable law, applicable law will govern.

This Privacy Notice only applies to the personal data of job applicants, potential candidates for employment or partnership, and those who participate in our recruiting programs and events.

By submitting your personal data to us, you acknowledge that:

• You have read and understood this Privacy Notice and      agree to the use of your personal data as set out herein.
• You are not required to provide any requested      information to us, but your failure to do so may result in our not being      able to continue your candidacy for the job for which you have applied.
• All of your representations are true and correct to      the best of your knowledge and belief, and you have not knowingly omitted      any related information of an adverse nature. Providing any inaccurate      information may make you ineligible for employment.
• This Privacy Notice does not form part of any      contract of employment offered to candidates hired by HDC.

PERSONAL DATA WE COLLECT

HDC usually collects personal data directly from you when you apply for a role with us through our online application process, such as your name, address, contact information, work and educational history, achievements, identity documents, test results, any information that may be required due to legal requirements (e.g. residence or work permits) and other categories of data that you voluntarily decide to share with us. We also collect data about you which is created by our recruiting personnel in the course of their interactions with you during the recruiting process or through your participation in our interactive assessment tools. Where permitted by law, we may collect photographs or videos, including those obtained during our recruiting events or as part of the recruiting process itself. If you receive an offer from us, we may then conduct a background check and, to the extent permitted by applicable law, we may also collect data related to criminal offences and proceedings. We also collect similar personal data about you from third parties, such as professional recruiting firms, your references, prior employers, HDC employees with whom you have interviewed or who recommended your candidacy, and, to the extent permitted by applicable law, employment background check providers. We may also collect personal data about you online to the extent that you have chosen to make this information publicly available on professional social media websites. For example, we may find your profile on LinkedIn and contact you about suitable roles.

Sensitive personal data is a subset of personal data that includes ethnicity, health, trade union membership, philosophical beliefs, sexual orientation, and other categories as prescribed by law. We may collect sensitive personal data about a candidate to the extent permitted or required to do so by applicable laws (e.g., U.S. equal opportunity laws) and to support efforts to create an inclusive and welcoming environment. Under limited circumstances and to the extent permitted by applicable law, we may also collect sensitive personal information relating to health and medical characteristics, , to address our public health and workplace safety obligations , to provide reasonable accommodations to facilitate the interview process (in case of disabilities) and to protect the Company and its employees, clients, and third parties.

HDC may process the following categories of personal information for our recruitment activities:

• Identifiers information such as name, email address,      photos, and contact details
• educational background
• employment background
• job qualifications and work eligibility, including      your nationality, country of residence, and visa and immigration status
• jobs in which you have expressed an interest or for      which you would like to submit an application
• CV, resume or transcripts, and any supporting      documentation attached to your resume such as copies of certificates and      diplomas
• employment references
• compensation details, such as salary information,      depending on your region
• background check information, such as a verification      of your educational and professional background, and other relevant      information subject to Oracle policies and applicable laws
• information about your personality, competency,      ability and suitability for a position
• data from surveys conducted by Oracle or by third      parties on behalf of Oracle
• publicly available information, such as social media      or other online resources where your information is made publicly      available
• certain types of sensitive personal information as      described in Section 12 below

USE OF YOUR PERSONAL DATA

HDC collects and uses your personal data for legitimate human resources and business management reasons, including:

• identifying and evaluating candidates for potential      employment, as well as for future roles that may become available;
• maintaining records in relation to recruiting and      hiring;
• ensuring compliance with legal requirements,      including those relating to public health and workplace safety;
• fostering our diversity and inclusion programs and      practices;
• if you receive an offer from us, conducting      background checks, including, to the extent permitted by applicable law,      criminal history checks;
• protecting our legal rights to the extent authorized      or permitted by law; and
• protecting the workplace and communicating with      medical professionals, law enforcement, or other public authorities in the      event of an emergency or public health event, such as when the health or      safety of you or one or more individuals may be endangered.

HDC may also use your personal data for HDC analytics purposes, including in aggregated/pseudonymized form, to improve our recruitment and hiring process and augment our ability to attract successful candidates.

LEGAL BASIS FOR PROCESSING YOUR PERSONAL DATA

HDC’s processing of your personal data for the purposes mentioned above is based in one or several of the following legal grounds:

• in part, on our legitimate business interests in      evaluating your application to manage our relationship with you, to ensure      that we recruit appropriate employees, and to evaluate and maintain the      efficacy of our recruiting process more generally; and in operating our      business and protecting the Company and its employees, clients, and third      parties. When we rely on this legal ground, HDC will only process your      personal data after assessing the adequacy, proportionality, and      legitimacy of the data processing activity;
• in part, on our performing contractual and      precontractual measures relating to our potential employment relationship      with you;
• in part, on our complying with applicable law with      regard to personal data necessary to satisfy our legal and regulatory      obligations, including with regard to public health and workplace safety;
• in part, on your consent, if we offer you the      opportunity to participate in our optional recruiting programs or if we      collect sensitive personal data for legally permitted purposes other than      compliance with our legal obligations regarding public health and      workplace safety.

BACKGROUND SCREENING

HDC process information about you to connect the right candidate with the right job at HDC and evaluate whether you are the right applicant for a position. If you receive an offer from HDC, we may conduct a background check on you or instruct a third party to do so on our behalf. Background screening will only be done where permitted by the law applicable to the location where the position is located and to the extent necessary and proportionate to the role that you are being offered. A background check may involve criminal background data to the extent permitted by law, educational verification, and motor vehicle reports if the position involves driving on behalf of the Company. Our legal basis for background screening is our need to perform precontractual measures related to establishing our employment relationship. If a background screening is required, you may be contacted by a third-party background screening service provider to request authorization for the release of your information, and at that time you will be provided with further information about the process and what personal data it might involve. HDC may also invite you to participate in assessments to evaluate your knowledge, skills, and suitability for a position. In evaluating your suitability for the position, HDC personnel may access your assessment and receive results and personal information a third-party assessment service.

DATA RECIPIENTS

Your personal data may be accessed by recruiters and interviewers working in the locations where the position(s) for which you are applying is(are) based, as well as by recruiters and interviewers working for HDC’s affiliate companies. Individuals performing administrative functions and IT personnel within HDC may also have access on a need to know basis to your personal data to the extent necessary perform their jobs. 

HDC may use third-party service providers to provide a recruiting software system. HDC may also share your personal data with other third-party service providers that may assist us in identifying and recruiting talent, administering and evaluating pre-employment screening and testing, and improving our recruiting practices.

Except to the extent necessary to accomplish the HDC uses and purposes described in this Privacy Notice, we do not disclose your personal data to third parties. We also prohibit our service providers from using your personal data for non-HDC purposes. We do not otherwise share or sell your personal data to third parties.

We maintain processes designed to help ensure that any processing of personal data by third-party service providers is consistent with this Privacy Notice and protects the confidentiality, availability, and integrity of your personal data in compliance with applicable law. 

In addition, we may disclose or transfer your personal data in the event of a re-organization, merger, sale, joint venture, assignment, or other transfer or disposition of all or any portion of our business.

DATA RETENTION

If you accept an offer of employment with HDC, any relevant personal data collected during your pre-employment period will become part of your personnel records and will be retained in accordance with specific legal requirements and with the privacy notice applicable to HDC employees, which will be provided during the on-boarding process.

If we do not employ you, and unless you object by following the process described in the Section “Your Rights” below, we may nevertheless continue to retain and use your personal data for a period of time for system administration purposes, to consider you for potential future roles, and to perform research, not to exceed five (5) years from your date of application. Thereafter, we retain a minimal amount of your personal data to record your recruiting activity with us.

To the extent that we have collected personal data, including sensitive personal data, for the specific purpose of fulfilling our legal obligations regarding public health or workplace safety, we will retain that data for the duration of those legal obligations. Thereafter, we retain a minimal amount of your personal data to establish our compliance with those obligations.

We may want to remain in contact with you and consider you for future employment opportunities. In such an event, we will seek your consent to include you in one of our recruiting programs that provides you ways to further learn about and stay in touch HDC, either prior to or after you formally apply for a job opportunity. Participation in these recruiting programs is entirely optional.

To the extent permitted or required by law, HDC  may delete your personal information at any time. As a result, you should retain your own copy of any information you submit to us.

YOUR RIGHTS

HDC takes reasonable steps that are designed to keep your personal data accurate, complete, and up-to-date for the purposes for which it is collected and used. We also have implemented measures that are designed to help ensure that our processing of your personal data complies with this Privacy Notice and applicable law.

Subject to applicable law, including exceptions, you have the following rights with regard to the personal data that we collect about you:

• right to request information about the personal data      that we hold about you, including information about how we use your      personal data.
• right to request a copy of the personal data that we      hold about you;
• right to request portability of your data to permit      you to provide a copy of your personal data in a structured, commonly      used, and machine-readable format and to transmit that personal data to      another controller;
• right to request that we correct or otherwise amend      your personal data if it is not correct or otherwise not complete, timely,      and accurate for the purposes for which we are using it;
• right to request deletion of your personal data;
• right to request that we cease processing or restrict      or limit the processing of your personal data;
• right to withdraw your consent to our processing of      your personal data where the basis of our processing is your consent. This      right may not apply if there are other legal justifications to continue      processing or we need to retain certain personal data where required or      permitted under applicable law
• right to not be discriminated against for exercising      your individual rights regarding your personal data;

If you would like to exercise your data protection rights regarding your personal data, you can do so by:

• emailing your request to us at: Legal@HeidelbergDistributing.com 
• contacting us by postal mail at:

Heidelberg Distributing Company

Attn: Legal Department
3601 Dryden Road

Dayton, Ohio 45439

Upon receipt of your request to exercise your data protection rights, we will acknowledge receipt within the time period required by applicable law and provide you with information about the next steps in the process and the timing. To help protect your privacy and security, we may take reasonable steps to verify your identity before acting on certain data protection rights, in accordance with applicable law. 

Please note that applicable laws include exceptions to assertions of data protection rights that may prevent us from providing access to your personal data or otherwise fully complying with your request. If we believe exceptions apply, we will respond to your request to the extent we are able to do so, and we will provide an explanation of the basis for not complying wholly or partially with your request.

YOUR RESPONSIBILITIES

You are responsible for the personal information that you provide or make available to HDC and must ensure it is truthful, accurate, and up-to-date in all respects. You must ensure that the information provided does not contain material that is obscene, defamatory, or infringes on any rights of any third party; does not contain malicious code; and is not otherwise legally actionable. Further, if you provide any personal information concerning any other person, such as individuals you provide as references, you are responsible for providing any notices and obtaining any consents necessary for HDC to collect and use that information as described in this Privacy Policy. If you provide misleading, inaccurate, or incomplete information, HDC may determine you are ineligible for employment. You understand that this Privacy Policy does not form part of any employment contract you may be offered in connection with your employment at HDC.

SECURITY

HDC uses generally accepted standards of technical and operational security to secure your personal data. Only authorized personnel of HDC and of our third-party service providers are permitted to access personal data, and these employees and third-party service providers are required to treat this information as confidential. Despite these precautions, we cannot guarantee that unauthorized persons will not obtain access to your personal data.

[Updated: June 25, 2025]