Yobs Technologies GDPR Compliance Statement

The EU General Data Protection Regulation (“GDPR”) comes into force across the European Union on25th May 2018 and brings with it the most significant changes to data protection law in two decades.Based on privacy by design and taking a risk-based approach, the GDPR has been designed to meetthe requirements of the digital age.

The 21st Century brings with it broader use of technology, new definitions of what constitutespersonal data, and a vast increase in cross-border processing. The new Regulation aims to standardizedata protection laws and processing across the EU; affording individuals stronger, more consistentrights to access and control their personal information.

Our Commitment

We are committed to ensuring the security and protection of the personal information that weprocess, and to provide a compliant and consistent approach to data protection. We have always hada robust and effective data protection program in place which complies with existing law and abidesby the data protection principles. However, we recognize our obligations in updating and expandingthis program to meet the demands of the GDPR.

Yob Technologies is dedicated to safeguarding the personal information under our remit and indeveloping a data protection regime that is effective, fit for purpose and demonstrates anunderstanding of, and appreciation for the new Regulation. Our preparation and objectives for GDPRcompliance have been summarized in this statement and include the development andimplementation of new data protection roles, policies, procedures, controls and measures to ensuremaximum and ongoing compliance.

How We are Preparing for the GDPR

Yobs Technologies already has a consistent level of data protection and security across theorganization, however it is our aim to be fully compliant with the GDPR by 24th May 2018. Ourpreparation includes: -

  • Information Audit - carrying out a company-wide information audit to identify and assesswhat personal information we hold, where it comes from, how and why it is processed and ifand to whom it is disclosed.
  • Policies & Procedures - [revising/implementing new] data protection policies and proceduresto meet the requirements and standards of the GDPR and any relevant data protection laws,including: -
  • o Data Protection – our main policy and procedure document for data protection hasbeen overhauled to meet the standards and requirements of the GDPR. Accountabilityand governance measures are in place to ensure that we understand and adequately

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disseminate and evidence our obligations and responsibilities; with a dedicated focuson privacy by design and the rights of individuals.

o Data Retention & Erasure – we have updated our retention policy and schedule toensure that we meet the ‘data minimization’ and ‘storage limitation’ principles andthat personal information is stored, archived and destroyed compliantly and ethically.We have dedicated erasure procedures in place to meet the new ‘Right to Erasure’obligation and are aware of when this and other data subject’s rights apply; along withany exemptions, response timeframes and notification responsibilities.

o Data Breaches – our breach procedures ensure that we have safeguards and measuresin place to identify, assess, investigate and report any personal data breach at theearliest possible time. Our procedures are robust and have been disseminated to allemployees, making them aware of the reporting lines and steps to follow.

o International Data Transfers & Third-Party Disclosures – where Yobs Technologiesstores or transfers personal information outside the EU, we have robust proceduresand safeguarding measures in place to secure, encrypt and maintain the integrity ofthe data. Our procedures include a continual review of the countries with sufficientadequacy decisions, as well as provisions for binding corporate rules; standard dataprotection clauses or approved codes of conduct for those countries without. We carryout strict due diligence checks with all recipients of personal data to assess and verifythat they have appropriate safeguards in place to protect the information, ensureenforceable data subject rights and have effective legal remedies for data subjectswhere applicable.

o Subject Access Request (SAR) – we have revised our SAR procedures to accommodatethe revised 30-day timeframe for providing the requested information and for makingthis provision free of charge. Our new procedures detail how to verify the data subject,what steps to take for processing an access request, what exemptions apply and a suiteof response templates to ensure that communications with data subjects arecompliant, consistent and adequate.

  • Legal Basis for Processing - we are reviewing all processing activities to identify the legal basisfor processing and ensuring that each basis is appropriate for the activity it relates to. Whereapplicable, we also maintain records of our processing activities, ensuring that our obligationsunder Article 30 of the GDPR and Schedule 1 of the Data Protection Bill are met.
  • Privacy Notice/Policy – we have revised our Privacy Notice(s) to comply with the GDPR,ensuring that all individuals whose personal information we process have been informed ofwhy we need it, how it is used, what their rights are, who the information is disclosed to andwhat safeguarding measures are in place to protect their information.
  • Obtaining Consent - we have revised our consent mechanisms for obtaining personal data,ensuring that individuals understand what they are providing, why and how we use it andgiving clear, defined ways to consent to us processing their information. We have developedstringent processes for recording consent, making sure that we can evidence an affirmativeopt-in, along with time and date records; and an easy to see and access way to withdrawconsent at any time.
  • Data Protection Impact Assessments (DPIA) – where we process personal information that isconsidered high risk, involves large scale processing or includes special category/criminalconviction data; we have developed stringent procedures and assessment templates for

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carrying out impact assessments that comply fully with the GDPR’s Article 35 requirements.We have implemented documentation processes that record each assessment, allow us torate the risk posed by the processing activity and implement mitigating measures to reducethe risk posed to the data subject(s).

  • Processor Agreements – where we use any third-party to process personal information on ourbehalf (i.e. Payroll, Recruitment, Hosting etc), we have drafted compliant ProcessorAgreements and due diligence procedures for ensuring that they (as well as we), meet andunderstand their/our GDPR obligations. These measures include initial and ongoing reviews ofthe service provided, the necessity of the processing activity, the technical and organizationalmeasures in place and compliance with the GDPR.
  • Special Categories Data - where we obtain and process any special category information, wedo so in complete compliance with the Article 9 requirements and have high-level encryptionsand protections on all such data. Special category data is only processed where necessary andis only processed where we have first identified the appropriate Article 9(2) basis or the DataProtection Bill Schedule 1 condition. Where we rely on consent for processing, this is explicitand is verified by a signature, with the right to modify or remove consent being clearlysignposted.

Data Subject Rights

In addition to the policies and procedures mentioned above that ensure individuals can enforce their data protection rights, we provide easy to access information via email or our website yobstech.comof an individual’s right to access any personal information that Yobs Technologies processes about them and to request information about: -

  • What personal data we hold about them
  • The purposes of the processing
  • The categories of personal data concerned
  • The recipients to whom the personal data has/will be disclosed
  • How long we intend to store your personal data for
  • If we did not collect the data directly from them, information about the source
  • The right to have incomplete or inaccurate data about them corrected or completed and theprocess for requesting this
  • The right to request erasure of personal data (where applicable) or to restrict processing inaccordance with data protection laws, as well as to object to any direct marketing from us andto be informed about any automated decision-making that we use

The right to lodge a complaint or seek judicial remedy and who to contact in such instances

Information Security & Technical and Organizational Measures

Yobs Technologies takes the privacy and security of individuals and their personal information veryseriously and take every reasonable measure and precaution to protect and secure the personal datathat we process. We have robust information security policies and procedures in place to protectpersonal information from unauthorized access, alteration, disclosure or destruction and have severallayers of security measures, including: -SSL, hashed passwords, encryption for sensitive data, JWT tokens, secure AWS tools such as S3bucket, SQS and cloud watch.

GDPR Roles and Employees

Yobs Technologies has designated Talha Obaid as its Data Protection Officer and has appointed a data privacy team to develop and implement our roadmap for complying with the new data protection Regulation. Mr. Obaid has a wealth of experience in data protection and security and is a reputable author of patents and technical publications on the topic of data privacy and IT security specifically. He previously spent 6 years at Symantec working on security-related topics over bothAWS and on-premise. His publications and prior work at Symantec are used by thousands of developers to inform their decisions. Mr. Obaid and the team are responsible for continuously promoting awareness of the GDPR across the organization, assessing the organization’s GDPR readiness, identifying any gap areas and implementing the new policies, procedures and measures.

Yobs Technologies understands that continuous employee awareness and understanding is vital to the continued compliance of the GDPR and have involved our employees in our preparation plans. We have implemented an employee training program specific to the which will be provided to all employees prior to May 25th, 2018, and forms part of our induction and annual training program.

If you have any questions about our preparation for the GDPR, please contact Talha Obaid