1.             Introduction

This Job Applicant Privacy Notice (“Notice”) how personal data is processed by Toptech Systems, Inc. (“Toptech”), 1124 Florida Central Parkway, Longwood, Florida 32750 (“Company”, “we” or “us”), part of IDEX Corporation (“IDEX” or “IDEX Group and Affiliates”) (please see https://www.idexcorp.com/affiliates-list/ for all companies involved), during the job application process. The Company is committed to the protection of the Personal Data that we process about you in line with the data protection principles set out in the Applicable Data Protection Legislation. This Notice informs you how we Process your Personal Data if you apply for a position with us.

With regard to the Processing of Personal Data of website users, please see our Website Privacy Notice, which you may access here.

Please note that in the course of the application process, data may also be processed by the respective operator of the network or platform through which you came across one of our job postings, such as LinkedIn. For such Processing the respective operator of the network or platform is the Data Controller. Please consult the privacy policy of the respective operator of the network or platform for details.

This Notice may be amended from time to time. We will post any change to this Notice a reasonable period of time in advance of the effective date of the change.

Capitalised terms used in this Notice are defined in Section 2 of this Notice.

2.             Definitions

The following terms used within this Notice and defined as follows:

3.             Identity and Contact Details of the Data Controller and the Data Protection Officer

The Company is responsible for Processing your Personal Data and is the Data Controller.

If you have any questions about this Notice, please contact us at

Toptech Systems, Inc.

1124 Florida Central Pkwy

Longwood, Florida 32750

+1 (407) 332-1774

Toptech Systems NV

Nieuwe Weg 1 – Haven 1053

B-2070 Zwijndrecht / Belgium

+32 (0)3 250 6060

Email: privacy@IDEXcorp.com

You can contact our Data Protection Officer at privacy@IDEXcorp.com

Categories and Sources of Personal Data we Process

We collect and store Personal Data that is provided to us through your application and during your application process. This may include:

• contact details and identity details, such as name; marital status, gender; nationality; date of birth; home address; contact details (including telephone number and email address);
• your application documents and the information contained therein, including inter alia your CV, cover letter and certificates or other documentation about your previous work experience, education or similar, pictures;
• information about your employment history and work related experiences and abilities, such as hire date; termination date and reason; employment status; current level of remuneration, any other supporting data submitted by candidates or employees, reference checks; previous job applications; evidence of skills/qualifications; relocation information
• information relating to character and job interests, including work-related and personal interests, knowledge or skills, awards or memberships;
• other personal data you provide during the recruitment process, including our notes from interviews with you and all correspondence you have with us or a recruitment agency during the application process;
• information on your work authorization status; and in certain circumstances
• Special Categories of Personal Data, such as your racial or ethnic origin, trade union membership, religious beliefs or information concerning your health, such as information about a disability for which the Company needs to make reasonable adjustments during the recruitment process.

We may also obtain the above data about you from other sources, including recruitment agencies, the references you provide us with, websites and other publicly available information on the Internet. This includes, for example, Personal Data that you have obviously made public in the context of an online profile. We may also receive information that you submit to us through third-party websites, such as LinkedIn.

4.             Purposes for Data Processing

The Company Processes Personal Data of Job applicants for various business purposes that are necessary:

• for carrying out your recruitment process, including to process your application, to evaluate your aptitude for the job offer in regard to capabilities and qualifications, to conduct reference checks as allowed or demanded by local laws, to respond to your inquiries and to communicate with you and to structure the recruitment process based on your needs, e.g. in regard to possible health issues; respectively
• to carry out the employment relationship, especially in regard to HR and performance management, after a successful application;
• for the purposes of business process execution and internal management, including for equal opportunity monitoring and ensuring a disabled-accessible workplace;
• for IT security and data breach procedures;
• for complying with legal obligations like tax regulation, predominantly however obligations addressed to employers in relation to the work relationship such as confirming the applicant´s eligibility to work in the respective country of Company;
• for optimizing our business processes, including to improve our application process or to optimize other recruitment processes or diversity programs; and
• for the assertion and defense of legal claims.

5.             Legal Basis for Processing Personal Data

The Company Processes Personal Data on different legal bases:

• 6 section 1 lit. a GDPR, if you have been informed about the intended Processing of your Personal Data, and have given us your consent. This may include foremost your consent to the Processing of your Personal Data by us for future recruitment activities, such as your inclusion in our internal Talent Pool. The scope of Processing is then determined by the content of the respective consent. You can always withdraw your consent. The withdrawal of consent will not affect the lawfulness of processing based on your consent before the withdrawal.
• 6 section 1 lit. b GDPR, if the Processing of your Personal Data is necessary in order to carry out the contract concluded between you and us, which might include a pre-contractual employment relationship.
• 6 section 1 lit. c GDPR, if the Processing is necessary for us in order to comply with a legal obligation we are subject to. E.g. laws on money laundering or similar compliance requirements might require us to process certain of your Personal Data.
• 6 section 1 lit. f GDPR, if the Processing is necessary for purposes of the legitimate interests pursued by us or by a third party, except where such interests are overridden by the interests or fundamental rights and freedoms of you which require protection of personal data. These legitimate interests can be:
• management of the recruitment process, including to enable process of recruitment, assessment and confirmation of suitable candidates for employment and procurement of a suitable recruitment strategy and corresponding implementation;
• administrative and management optimization purposes, including business process execution and internal management optimization, aggregate management reporting or internal training, working climate, equal opportunities monitoring ;
• the procurement of evidence for legal proceedings, including the defence against legal claims asserted against us or the assertion of our legal claims and prevention for compliance violations or other infringements;
• in accordance with Art. 9 para. 2 or para. 4 GDPR regarding Special Categories of Personal Data.

6.             Your Rights

The GDPR provides you with certain rights in relation to the Processing of your Personal Data, including to:

• Request access to Personal Data about you (commonly known as a “data subject access request”). This enables you to receive a copy of the Personal Data we hold about you, and to check that we are lawfully Processing it.
• Request rectification, correction, or updating to any of the Personal Data that we hold about you. This enables you to have any incomplete or inaccurate information we hold about you corrected.
• Request Personal Data provided by you to be transferred in machine-readable format (“data portability”), to the extent this right is relevant in the employment context.
• Request erasure of Personal Data. This enables you to ask us to delete or remove Personal Data where there is no good reason for us continuing to Process it. You also have the right to ask us to delete or remove Personal Data where you have exercised your right to object to Processing (see below).
• Request the restriction of Processing of your Personal Data. This enables you to ask us to suspend the Processing of Personal Data about you (e.g. if you want us to establish its accuracy or the reason for Processing it).
• Withdraw any consent you may potentially have given at any time, without affecting the lawfulness of processing based on consent before its withdrawal.

These rights are not absolute and are subject to various conditions under: (a) Applicable Data Protection Legislation; and (b) other laws and regulations to which we are subject.

You may exercise your rights, by contacting us for example at the contact details given in Sec. 2 above.

You also have the right to lodge a complaint with a competent Data Protection Supervisory Authority.

7.             Data Sharing and International Data Transfers: Intra-Group and Third Parties

7.1          Intra-group transfers

As a member of a multinational enterprise operating under a matrixed management structure, Company may share Personal Data of Job Applicants with other Toptech group of companies listed in the Annex for the purposes set out in this Notice. Please note that Company only shares Personal Data of Job Applicants with those companies where this is covered by a lawful basis for such Processing.

These transfers are protected by the obligations set out in intra-group agreements that we have entered into among and between the various legal entities comprising the IDEX Group and Affiliates. International transfers within the IDEX Group and Affiliates are governed by EU Commission-approved Standard Contractual Clauses for Controllers and, where relevant, for Processors, complemented by additional safeguards established after the European Court of Justice ruling Schrems-II. You may receive a copy of these Standard Contractual Clauses used in our intra-group agreements by contacting us at the contact details given in Sec. 3 above.

7.2          Third Parties

Company may share Personal Data with external vendors that we engage to perform services or functions on our behalf and under our instructions. Where applicable, their Processing of your data will be subject to the GDPR requirements. Company will also ensure that its contracts with these parties ensure that they only Process Personal Data in accordance with our instructions and in order to provide the agreed services and protect the integrity and confidentiality of the Personal Data entrusted to them, in line with the GDPR requirements.

For the purposes set out in this Notice, we may also disclose your Personal Data to our IT service providers, auditors, lawyers, consultants, law enforcement and other public authorities (such as tax and social security bodies), the police, prosecutors, courts and tribunals. Some of these recipients are themselves responsible to determine the purposes and means of the Processing and for the lawfulness of the Processing on their end. Where necessary, we will ensure that appropriate contractual measures are in place to ensure the protection of your Personal Data.

Some of the third parties that we engage to Process your Personal Data are located outside the European Economic Area. We will ensure that these transfers are either

• to countries, which fall under an adequacy decision by the EU-Commission and is deemed to provide an adequate level of protection, currently including Switzerland, Uruguay, Argentina, Japan, Israel, Isle of Man, New Zealand, Guernsey, Canada, Andorra, Faroe Islands and Jersey; or are
• governed by one of the safeguards according to Art. 44 ff GDPR, especially: EU Commission-approved Standard Contractual Clauses or Binding Corporate Rules approved by an EU data protection authority, extended by additional safeguards according to the ECJ findings in Schrems-II. You may receive a copy of these data protection safeguards by contacting us at the contact details given above.

8.             Retention of Personal Data

Company will keep and Process your Personal Data only for as long as is necessary for the above-mentioned purposes for which they were collected or for legal obligations. Such legal obligations may arise particularly under tax and commercial law. If your data is no longer necessary for the fulfilment of contractual or legal obligations or for the fulfilment of the above-mentioned purposes, they will be deleted; unless they are needed to secure, assert or enforce legal claims. In this case, we will retain them in accordance with the regular limitation period. During this period, this data is blocked and is no longer available for any other use.

In general, application data will be deleted after three months the latest, if your application is being rejected and if the application proceeding has ended. We will keep the application data for a longer period of time if you consent to us storing such data in our talent pool. We will not delete your application data if we sign an employment contract with you. In this case, the applicant data will be transferred to the personnel file. For the deletion of this data, we refer to the privacy policy for employees.

9.             Statutory/Contractual Requirements

In certain cases, you may choose to not provide us with your Personal Data and/or provide incomplete Personal Data. However, please be aware that we may not be able to proceed with your application procedure properly as your Personal Data may be required for administrative purposes and/or to fulfill statutory requirements.

10.          Automated Decision-Making and Profiling

Your Personal Data will not be used for automated decision-making and/or profiling.