EVOCS

Job Applicant Privacy Notice

Effective Date: May 22, 2026   |   Version 7.0

1. Introduction

This Job Applicant Privacy Notice (“Notice”) describes how Evolution Cloud Services (“EVOCS,” “we,” “us,” or “our”) collects, uses, and discloses personal data about individuals who apply for employment with us. This Notice applies to applicants in all US states and territories, as well as Argentina and India.

This Notice does not form part of any employment offer or contract and does not create any contractual rights or obligations.

2. Personal Data We Collect

We may collect the following categories of personal data during the application and recruitment process:

• Contact Details: name, address, phone number, personal email address.
• Professional & Background Information: work history, certifications, language skills, references, resume/CV, cover letter, and other application materials.
• Demographic Data: date of birth, gender, marital status (only where required or permitted by law).
• Work Eligibility: immigration status, residency, and official government documents.
• Identity Documents: government-issued ID as required for verification or legal compliance.
• Social Media: publicly available profiles and information relevant to the role.
• Previous Applications: any prior applications or employment history with EVOCS.
• Audio/Visual: photographs or video recordings taken during interviews or on-site visits.
• Inferences: assessments of qualifications and suitability drawn from the above information.

Failure to provide required information may affect our ability to process your application.

3. Sensitive Personal Data

In certain circumstances, we may collect sensitive personal data, including:

• Health or disability information (to arrange reasonable accommodations).
• Racial or ethnic origin (to meet legal reporting obligations).
• Criminal conviction history (where relevant to the role and permitted by law).

We collect sensitive personal data only where permitted or required by law, where you have given explicit consent, or where necessary to fulfill our legal employer obligations. Where consent is required, we will request it separately and in writing.

4. How We Use Your Personal Data

We use your personal data for the following purposes:

• Evaluate your application and assess suitability for a role.
• Verify information provided, including background and reference checks.
• Communicate with you throughout the recruitment process.
• Reimburse eligible interview-related expenses.
• Assist with immigration or work permit processes if you are selected.
• Send alerts about future job openings at EVOCS (you may unsubscribe at any time).
• Maintain records of our hiring activities as required by law or regulation.
• Protect the security of our premises, systems, and networks.
• Comply with applicable legal and regulatory obligations.

We process personal data on the following legal bases: performance of a contract or pre-contractual steps; compliance with legal obligations; our legitimate business interests; or your consent (where explicitly required).

5. Sharing Your Personal Data

We may share your personal data with:

• EVOCS subsidiaries and affiliated entities involved in the recruitment process.
• Third-party service providers (e.g., applicant tracking, background checks, travel, data hosting).
• Government authorities or regulators where required by law.
• Potential acquirers or business partners in connection with a merger, acquisition, or corporate restructuring.

All third-party providers are contractually required to implement appropriate security measures and to process your data only on our instructions and for specified purposes. We do not sell your personal data or use it for cross-context behavioral advertising.

We use Greenhouse as our third-party applicant tracking system. Please review their privacy policy at https://www.greenhouse.com/privacy-policy.

6. United States — Applicable Privacy Laws

Unlike consumer privacy, the US does not have a single federal law governing job applicant data. Instead, a set of targeted federal laws and a growing body of state and local laws directly govern what employers may collect, how they must handle it, and what rights applicants have. Only the laws described in this section apply specifically to the collection of personal data in the context of job applications.

Note on state comprehensive privacy laws: As of 2026, twenty US states have enacted comprehensive consumer privacy laws. With the sole exception of California, all of these laws expressly exempt employee and job applicant data. They are therefore not addressed in this section. Separately, several states regulate specific employment practices such as biometric data collection and the use of automated decision-making tools; those laws are addressed below.

6.1 Federal Laws

The following federal laws apply directly to EVOCS’s collection and use of applicant data and govern our practices in all 50 states:

Fair Credit Reporting Act (FCRA)

If we use a consumer reporting agency to conduct background, credit, or reference checks, we will: (a) provide you with a standalone written disclosure before initiating any check; (b) obtain your written authorization before proceeding; and (c) if a check results in an adverse hiring decision, provide you with a pre-adverse action notice, a copy of the report, and a summary of your FCRA rights, followed by a final adverse action notice.

Equal Employment Opportunity (EEO) Reporting Laws

Federal law (Title VII, the ADA, and related statutes) requires us to collect and report certain demographic information for EEO-1 filing purposes. This data — including race, ethnicity, sex, disability status, and veteran status — is collected on a voluntary basis, stored separately from your application file, and is not used in any hiring decision.

Americans with Disabilities Act (ADA) and ADA Amendments Act (ADAAA)

Any medical or disability-related information you share in connection with a request for reasonable accommodation is kept strictly confidential. It is maintained in a file separate from your general application and is shared only with individuals who need to know in order to provide the accommodation or meet legal obligations.

Genetic Information Non-Discrimination Act (GINA)

We do not request or use genetic information (including family medical history) in our hiring process. If such information is inadvertently received, we will maintain its confidentiality and will not use it in any employment decision.

EEOC Recordkeeping (29 CFR Part 1602)

Federal regulations require us to retain applicant records (including resumes, applications, and records relating to the hiring decision) for at least one year from the date the record was made or the personnel action taken, whichever is later. For positions subject to OFCCP jurisdiction (federal contractors), the retention period is two years.

6.2 California — CCPA / CPRA

California is the only US state whose comprehensive privacy law — the California Consumer Privacy Act (CCPA), as amended by the California Privacy Rights Act (CPRA) — applies in full to job applicant data. If you are a California resident, you have the following rights:

• Right to Know: request the categories and specific pieces of personal information collected about you, the sources, our business purposes for collection, and the categories of third parties with whom we share your data. You may request information collected beyond the prior 12-month period.
• Right to Delete: request deletion of personal information we have collected, subject to certain legal exceptions (e.g., recordkeeping obligations under EEO and FCRA).
• Right to Correct: request correction of inaccurate personal information we hold about you.
• Right to Limit Use of Sensitive Personal Information: direct us to limit our use of sensitive personal information to what is necessary for the recruitment process.
• Right to Opt Out of Sale or Sharing: we do not sell your personal information or share it for cross-context behavioral advertising.
• Right to Non-Discrimination: we will not deny employment, penalize, or retaliate against you for exercising any of these rights.
• Right to Opt Out of Automated Decision-Making and to Access ADMT Information: where the California Privacy Protection Agency’s ADMT regulations apply, you may opt out of certain uses of automated decision-making technology and request information about the logic and likely outcomes of such tools.

Categories of personal information collected about California applicants include: identifiers; professional and employment-related information; education information; characteristics of protected classifications (race, gender, disability status, veteran status); audio, electronic, and visual information; inferences drawn from the above; and sensitive personal information (e.g., government ID numbers, racial or ethnic origin, religious beliefs).

To exercise your California rights, contact us at careers@evocs.tech or call (240) 931-3701. You may designate an authorized agent; identity verification will be required.

6.3 Biometric Identifiers

Where EVOCS collects biometric identifiers or biometric information from applicants — including fingerprints, retina or iris scans, voiceprints, face geometry scans, or hand geometry — we comply with all applicable biometric privacy laws regardless of where the applicant is located. The following commitments apply to all applicants from whom we collect biometric data:

• Written notice prior to collection: before collecting any biometric data, we will inform you in writing of the specific biometric identifiers being collected, the purpose for collection, and the length of time for which they will be stored and used.
• Written consent: we will obtain your written consent (including electronic signature where permitted) before collecting any biometric identifier. Consent will not be a condition of application unless directly required for a reasonable background check, identity verification, or access control purpose.
• No sale or profit: we will never sell, lease, trade, or otherwise profit from your biometric data.
• No unauthorized disclosure: we will not disclose your biometric data to third parties without your consent, except as required by law or as necessary to complete a transaction you initiated.
• Retention and destruction: we maintain and make publicly available a written biometric data retention and destruction policy. Biometric data will be destroyed no later than the earliest of: (a) when the purpose for collection has been satisfied; (b) within three years of your last interaction with us; or (c) the earliest date required by applicable law.
• Security: we protect biometric data using reasonable security standards at least as protective as those we apply to other sensitive personal information.
• Third-party oversight: any third-party vendor that processes biometric data on our behalf is contractually required to comply with these same standards.

Enforcement varies by jurisdiction. Illinois law (BIPA) provides a private right of action with statutory damages of $1,000–$5,000 per violation plus attorney’s fees. In Colorado, Texas, and Washington, enforcement is by the respective state Attorney General. We comply with the highest applicable standard in all cases.

6.4 New York City — Local Law 144 (Automated Employment Decision Tools)

If EVOCS uses any Automated Employment Decision Tool (AEDT) — such as AI-driven resume screening, candidate scoring, or video interview analysis software — to make or substantially assist hiring decisions for positions in New York City, we comply with NYC Local Law 144 (in effect July 5, 2023):

• Bias Audit: any AEDT used in our hiring process undergoes an independent annual bias audit evaluating disparate impact across race, ethnicity, and sex. A summary of the most recent audit results is published on our website.
• Candidate Notice: at least 10 business days before an AEDT is used to evaluate your application, we will notify you (via job posting, email, or mail) that an AEDT will be used, what it will assess, and what data it will collect.
• Data Disclosure: our AEDT data retention policy, the type of data collected, and its source are available on our website at all times.

Penalties for non-compliance range from $500 to $1,500 per day per violation, enforced by the NYC Department of Consumer and Worker Protection.

6.5 State Laws Governing AI in Employment Decisions

In addition to NYC Local Law 144, several US states have enacted laws regulating the use of artificial intelligence and automated decision-making in employment. Where applicable, EVOCS complies with each of the following:

Colorado AI Act (SB 24-205)

Effective February 1, 2026, the Colorado Artificial Intelligence Act applies to high-risk AI systems used to make, or to substantially factor into, consequential employment decisions affecting Colorado residents. EVOCS commits to: (a) exercise reasonable care to protect applicants from algorithmic discrimination; (b) complete impact assessments for any high-risk AI system used in hiring; (c) provide pre-decision notice when a high-risk AI system is used to make a consequential employment decision; and (d) provide an opportunity to correct inaccurate personal data and appeal an adverse decision. Enforcement is by the Colorado Attorney General.

Illinois HB 3773 (Illinois Human Rights Act Amendments)

Effective January 1, 2026, Illinois prohibits the use of AI in employment decisions that produces a discriminatory effect on individuals based on protected classes, or that uses zip code as a proxy for protected classes. Where AI is used in our Illinois hiring process, we will provide notice to applicants before its use. Enforcement is by the Illinois Department of Human Rights, with a private right of action available.

Other Jurisdictions

We monitor emerging state and federal AI employment laws (including New Jersey, California ADMT regulations, and pending federal legislation) and update our practices and this Notice as new requirements take effect.

6.6 US Laws Applicable to Applicant Data — Summary

The following table summarizes the principal US laws governing the collection and use of job applicant data and the jurisdictions in which they apply:

7. International Data Transfers

EVOCS operates across the US, Argentina, and India. Your personal data may be transferred to and processed in countries that may not provide the same level of data protection as your home country. Where required, we implement appropriate safeguards as described below.

Argentina Applicants

Transfers from Argentina are conducted in compliance with Argentina’s Personal Data Protection Law (Law 25,326) and regulations issued by the Agency of Access to Public Information (AAIP). Where transfers are made to countries deemed not to provide adequate protection, we use AAIP-approved model clauses or seek the applicant’s informed consent.

India Applicants

We process personal data of India-based applicants in accordance with the Digital Personal Data Protection Act, 2023 (DPDPA), seeking consent where required, providing notice in the form required by the rules issued under the DPDPA, and implementing reasonable security safeguards. Applicants may contact our grievance officer through the email address listed in Section 13.

8. Data Security

We implement appropriate technical, organizational, and physical security measures to protect your personal data against unauthorized access, loss, alteration, or disclosure. Access is limited to those with a legitimate business need.

9. Data Retention

We retain your personal data only for as long as necessary to fulfill the purposes described in this Notice or as required by applicable law. The federal EEOC recordkeeping rule (29 CFR Part 1602) requires retention of applicant records for at least one year, or two years for federal contractors subject to OFCCP. Beyond those minimums, retention ranges from one to three years depending on jurisdiction, after which data is securely deleted or anonymized.

If you accept a position, your data will be transferred to your employment record. If you are not hired, we may retain your data to consider you for future openings. We recommend retaining copies of any materials you submit to us.

Biometric data is subject to the shorter retention and deletion schedules described in Section 6.3 of this Notice and required under applicable biometric privacy laws.

10. SMS/Text Messaging Program

By opting in to receive SMS/text messages from EVOCS, you consent to receive messages related to your job application, including interview scheduling, application status updates, and follow-up communications from our recruiting team.

Message frequency varies. Standard message and data rates may apply. You may opt out at any time by replying STOP to any message you receive from us. After opting out, you will receive a confirmation message and we will stop sending SMS messages to your number. Reply HELP for assistance or contact careers@evocs.tech.

No mobile information will be shared with third parties or affiliates for marketing or promotional purposes. All the above categories exclude text messaging originator opt-in data and consent; this information will not be shared with any third parties.

11. Your Privacy Rights — International Applicants

Argentina Applicants

Under Law 25,326, you have ARCO rights (Access, Rectification, Cancellation, Opposition). Contact us at careers@evocs.tech. We will respond within 20 business days, consistent with AAIP requirements.

India Applicants

Under the DPDPA, you have the right to access, correct, complete, update, and request erasure of your personal data, as well as the right to withdraw consent and the right to grievance redressal. You may also nominate a representative to exercise these rights on your behalf.

12. Changes to This Notice

We may update this Notice from time to time. If we make material changes, we will notify you by email or through the application portal before those changes take effect. The current version is always available at https://job-boards.greenhouse.io/evocsprivacypolicy.

13. Contact Us

For questions about this Notice or to exercise your privacy rights, please contact us:

EVOCS — Privacy Office

201 University Blvd, Suite 200

Denver, CO 80206, USA

Email: careers@evocs.tech

Phone: (240) 931-3701 (toll-free for privacy and CCPA requests)

Global Privacy Contact:

Email: careers@evocs.tech

India Grievance Officer (DPDPA):

Contact via careers@evocs.tech — name and details to be appointed in accordance with DPDPA rules.