Privacy Notice

Mission Statement

Our mission is to protect your data, as we value your privacy as our organisation’s top priority. Subsequently, our key objectives are to sustain privacy protections as well as maintain your trust and confidence when processing your personal data information. This Privacy Notice serves the purpose of describing how we may collect, use and store the information provided by you when you apply for a job position with our organisation.

Notice Statement

Whenever dealing with one of the Kaizen Gaming Group companies (the “Kaizen Gaming Group”), the controller of your personal data will be the company that decides how and why your data is processed for the purposes covered under this policy. Where this Privacy Policy refers to “we”, “our” or “us” below, this shall mean the particular company that is the controller of your Data. Data controllers of our Kaizen Gaming Group are:

- Kaizen Gaming International Limited, a Maltese company, located at Unit 41/42, Level 4, Pendergardens Business Centre, Triq Sant’ Andrija, San Giljan, STJ 9023, Malta
- Kaizen Digital Services Single Partner SA Software Application Promotion and Support Services, a Greek company, located at Neratziotissis Str. 111, Marousi, 15124, Athens, Greece
- Kaizen Gaming Canada Inc., an Ontario company, located at 99 Bay Street, Suite 2200, Toronto Commerce Court West, M5L 1G4, Canada
- Kaizen Gaming Colombia S.A.S., a Colombian company, located at Cr 15 No. 106 32 Of Ph 3, Bogota D.C, Colombia
- Kaizen Gaming Nigeria Limited, a Nigerian company, located at the Zone Plot 9, Gbagada Industrial Scheme, Gbagada Expressway, Lagos, Nigeria
- Kaizen Gaming CZ Limited, a Maltese company, located at Level G, Office 1/0402, Quantum House, 75, Abate Rigord Street, Ta’ Xbiex XBX 1120, Malta
- Betkick Sportsbetting Ltd, a Maltese company located Unit 41/42, Level 4, Pendergardens Business Centre, Triq Sant’ Andrija, San Giljan, STJ 9023, Malta
- Digify International Limited, a Maltese company, located at Unit 41/42 Level 4 Pendergardens Business Centre, Triq Sant’ Andrija, San Giljan, STJ 9023, Malta
- Kaizen Gaming International LTD – Sucursal em Portugal, located in Rua da Artilharia 1, n.º79, 6.ºAndar, 1269-160, Lisbon, Portugal
- Insipia LTD, a Maltese company, located at Unit 41/42, Level 4, Pendergardens Business Centre, Triq Sant’ Andrija, San Giljan, STJ 9023, Malta
- Insipia LTD, Sucursal Argentina, located at Rivadavia 256, 7th floor, Province of Mendoza, Argentina
- Kaizen Gaming Peru SAC, a Peruvian company with legal domicile in Av. Camino Real No. 456, Int. 1202, San Isidro, Lima, Peru
- Kaizen Gaming Brasil Ltda., a company, located at Rua Capitão Antônio Rosa, 409, Sala 505, Jardim Paulistano, ZIP code (CEP) 01443-010, State of São Paulo, Municipality of São Paulo, Brazil

Kaizen Gaming Ghana LTD, a Ghanaian company located in P.O. BOX AF 268, Adenta Accra Ghana, GA/R, GPS address GA-374-1216

Kaizen Gaming Philippines INC, a Philippine company located in DJR Artistic Realty & Development Corp. Building, Open Canal Road, Malagasang II-C, Imus City, Cavite, Region IV-A (Calabarzon), 4103, Philippines
JPJ OPS SPAIN, S.A.U., a company constituted under the laws of Spain, with registered office at Paseo de la Marina Española, 24, entreplanta pta. 1a, 51001 Ceuta, Spain and with NIF number A56144447
Kaizen Gaming XYZ plc, a Maltese Company, located at Unit 41/42, Level 4, Pendergardens Business Centre, Triq Sant’Andrija, San Giljan, STJ 9023, Malta, Company registration number C 54599
Kaizen Gaming SE Limited, a Maltese Company located at Unit 41/42, Level 4, Pendergardens Business Centre, Triq Sant’ Andrija, San Giljan, STJ 9023, Malta

We are all committed to protecting and respecting your privacy and all of our companies follow the group’s data protection policies and procedures treating personal data at the highest standards. This Privacy Notice, together with any other documents referred to herein, sets out the overall framework under which any personal data collected from you and/or are provided to us, will be processed in correlation to the corresponding resourcing and recruitment practices.

Hierarchy

In the event of any conflict between this global notice and any local agreement, policy, or specific version, the terms of the local agreement or specific version shall prevail to the extent of such conflict, subject to applicable local legislation.

Scope and Definitions

This Privacy Notice only applies to the personal data of job applicants, potential candidates for employment, as well as to our recruitment programs, campaigns and events. It does not apply to our employees, contractors or clients, or other personal data that the company collects for any other purposes.

As used in this Privacy Notice, the term “personal data” applies to the information that identifies job applicants and potential candidates for employment with us, that is being submitted either within the context of the online application and/or through any other alternative channels (e.g. via professional recruiting firms).

In addition, the company may also collect and process certain special categories of Personal Data (“Special Categories of Personal Data”) about candidates where this is necessary and in compliance with applicable data protection laws. In particular, the company may, in certain circumstances and in exceptional cases, process very limited health data particularly referring to a candidate’s disability/special needs, and racial and/or ethnic data, as required and to the extent permitted under national legislation.

Furthermore, and subject to the requirements under applicable national law, the company may process criminal record data, when this is required to ensure suitability for specific roles.

We will process your personal data in accordance with this Privacy Notice, unless such processing conflicts with the requirements of applicable law, in which case, applicable law will prevail. Please read the following carefully to understand our views and practices regarding your personal data and how we will treat it.

Information we collect from you

We collect and process the following categories of information:

Personal details and contact information: includes contact details, full name, email address, phone number, address, and any correspondence;
Talent, recruitment and application details: includes information provided through an online job site or hiring tool (e.g., Hibob, LinkedIn), via email, in-person interviews, or CVs, experience, education, academic and professional qualifications, online documentation/portfolio, voluntary information like photos, answers to screening questions, assessment results, and interview feedback;
Right to work / immigration data: identification data and documents for facilitating travel arrangements and ensuring the Right to Work;
Pre-employment screening data: reference letters and pre-employment check information, if necessary.

Information we create in connection with you

We generate and process the following categories of information in connection with your application:

Assessment results and feedback;
Business cases/ Technical assignments to further evaluate your candidature;
Job Offer details.

Information we collect from other sources

Recruitment services partners may facilitate the correlation of the data you provide to us, with other publicly available information about you that you have published on the Internet – this may include sources such as professional social media networks (e.g. LinkedIn).

We may receive personal data about you from a third party who recommends you as a candidate for a specific job opening or within the overall context of the industry we address.

We may receive your personal data from a services provider assisting us in the recruitment process, e.g. data derived from the results of an evaluation test.

When receiving job applications or referrals from third parties, we ensure that this privacy notice is made available to you at the earliest opportunity and in any case on our first interaction with you.

Uses Made of Your Information & Lawful Basis for Processing

We process personal data to:

Attract talent and market opportunities at the company including by arranging, hosting and participating in events, marketing and advertising opportunities and using recruitments to help find talent for us;
Identify and resource talent including searching our existing talent pool and publicly available sources, such as professional social media and job websites of which you are a member;
Process and manage applications for roles at our company, evaluate you for open positions that match your interests and working experience, manage your candidate profile, send you email notifications and other announcements, request additional information or otherwise contact you about your candidacy;
Conduct statistical analyses and create reports regarding the improvement of our recruitment and employer branding processes;
Assess your application on a role for which you have applied or with respect to other roles;
Communicate with you about the recruitment process;
Correlate any information that we receive from you with information obtained from third party data providers;
Protect our legal rights and comply with our obligations to the extent authorised or permitted by law;
Conduct anti-corruption and Anti-Money Laundering (AML) checks for the purpose of determining whether a candidate (i) has a documented history of involvement in money laundering, terrorist financing, or any other illegal activities, and/or (ii) holds the status of a politically exposed person (PEP);
Ensure compliance with legal requirements, including diversity and inclusion requirements and practices.

We rely on legitimate interest as the lawful basis on which we collect and use your personal data, either directly to our HR or via recruitment platforms (e.g. Linkedin, Indeed). Our legitimate interests are the recruitment of competent and appropriate staff for our business, that also constitute values fit to our organisation. You are not required to provide any requested information to us, but failing to do so could result in the ending of the assessment process of your candidacy, if we fail to continue with your assessment. In relation to job applications in Kaizen Gaming International LTD – Sucursal em Portugal, we may process your Personal Data for the purpose of the internal reporting channel regarding the further investigation of forms of misconduct, including but not limited to acts of corruption, breaches of applicable Union or National Laws. Additionally, within the scope of this internal reporting channel and based on the company’s legitimate interests in upholding legal compliance and fostering a safe environment, we may also investigate infractions such as discrimination, harassment, and violations related to responsible gaming.

We may wish to retain your personal data to consider you for future employment opportunities. In such an event, you will specifically be informed prior to your application and you will have the right to object to such a processing. Your consent will be required for contacting you regarding job openings that might not be relevant to the one you have applied for. Also, we will require your consent so as to be part of one of our recruiting events/campaigns/surveys or our newsletter list or seasonal communication, with this communication being absolutely optional.

Use of Artificial Intelligence (AI) and Automated Tools

As part of our recruitment process, we use AI-assisted and automated tools, including Google Gemini, Anthropic Claude, and Bob AI, to support certain recruitment activities. These tools are used as follows:

Purposes: transcribe interviews and assist with drafting, polishing, and formatting interview notes and scorecards; support interview preparation and the preparation of scorecards aligned with the requirements of the relevant role; assist recruiters in reviewing CVs and candidate experience; and support recruiters with sourcing and reviewing publicly available candidate information;
Personal data used: interview content and notes, information contained in CVs and applications, professional experience and skills, existing interview or recruitment-related feedback, and publicly available candidate information.

AI-assisted tools are used as supportive tools throughout the recruitment process. They may help our recruitment teams organise information, reduce repetitive administrative work, identify relevant information and prepare recruitment materials, but they do not replace the professional judgement, experience or decision-making of our recruitment teams.

The use of AI does not determine a candidate’s suitability, progression or hiring outcome. Authorised personnel remain responsible for assessing candidates and making recruitment decisions, taking into account the wider context and information available to them.

Disclosure of Your Information

We may use third parties to assist us with our recruitment process, especially in identifying the recruiting talent, administering and evaluating pre-employment screening and testing and improving our recruiting practices. For a list of main third-party recruitment service providers and processors used across the Group, please refer to Annex A below. In principle, these parties are considered as processors, being only entitled to process your personal data in accordance with our instructions.

When you apply for a job opening via the application function on a job site or similar online service providers (indicatively LinkedIn) you should note that the relevant Partner may retain your personal data and may also collect data from us in respect of the progress of your application. Any use by the Partner of your data, in the role of a separate controller, will be in accordance with the Partner’s Privacy Notice.

We follow processes designed to 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. Where required by law, we put in place legal mechanisms designed to ensure adequate data protection of your personal data in a third country.

In the context of anticorruption and AML checks, we may share data with regulatory bodies, local authorities, law enforcement, and our data analytics provider, LexisNexis Risk Solutions, to comply with legal or regulatory obligations related to money laundering, terrorist financing, and other illegal activities. Data will be disclosed only if required and only to the extent necessary.

Finally, we may disclose or transfer your personal data in the event of a reorganisation, merger, sale, joint venture, assignment, or other transfer or disposition of all or any portion of our business.

Security

We take all appropriate measures to ensure that all personal data which is processed in our own systems, is secure, including security measures that prevent personal data from being accidentally lost, or used or accessed in any unauthorised way. Access to personal data is strictly restricted to authorized personnel who need such access for legitimate recruitment and business purposes on a strict “need-to-know” basis. Those processing your information will do so only in an authorised manner and are subject to a duty of confidentiality. In the same manner, when entrusting third parties with personal data, we require that equivalent security measures are in place.

We also have procedures in place to deal with any suspected personal data breach. We will notify you and any applicable regulator of a suspected personal data breach where we are legally required to do so.

Where We store your personal data

Your personal data is stored on secure servers within the EU, EEA, or where there is a regime with equivalent level of protection.

How long we keep your personal data

We will retain your personal data only for as long as necessary for the purposes for which it was collected and in accordance with applicable legal and regulatory requirements. In principle, where you provide your explicit consent to the retention of your personal data for future employment opportunities, we may retain it and include you in our talent pool for future opportunities for a period not exceeding 2 years from the date of your job application. You may withdraw your consent at any time. Withdrawal of consent will not affect the lawfulness of processing carried out before your withdrawal. Following withdrawal, your personal data will be deleted within a reasonable period, unless we have another lawful basis or legal obligation to retain it.

If you accept an offer of employment by us, any relevant personal data collected during your pre-employment period will become part of your personnel records and will be retained in accordance with our Employees Privacy Policy.

The applicable retention period may vary depending on the country in which you apply and any specific legal or regulatory requirements applicable to the recruitment process. Where a different retention period is required by applicable law, we will retain your personal data for the applicable period.

Your personal information will be deleted on any of the following occurrences:

In reasonable time after the lapse of the retention period as referred to above;
Following withdrawal of your consent, where consent is the applicable legal basis for retention, unless another lawful basis or obligation requiring or permitting the further retention of data, applies; or upon your objection to such processing;
Upon a written request by you to erase your personal data, via email to [email protected] and [email protected].

See section below for more information.

Your rights

Under the applicable data protection regulations, you have a number of important rights free of any obligation. In summary, those include your right to:

Right of access: Request access to your personal data and to certain other supplementary information that this Privacy Notice is already designed to address;
Right to rectification / correction: Request the correction/updating with respect to your personal information;
Right to erasure: Request the erasure of personal data concerning you in certain situations;
Right to data portability: Receive the personal data concerning you which you have provided to us, in a structured, commonly used and machine-readable format and have the right to transmit those data to a third party in certain situations;
Right to object: Object at any time to any processing of personal data concerning you;
Right to object to automated decision-making: Object to decisions being taken by automated means which produce legal effects concerning you or similarly significantly affect you;
Right to withdraw consent: Withdraw your consent without detriment;
Right to restriction of processing: Otherwise restrict our processing of your personal data in certain circumstances; or
Right to lodge a complaint: File a complaint to a competent data protection or equivalent authority and/or claim compensation for damages caused by our breach of any data protection laws.

If you would like to exercise any of those rights, please contact us using our Contact details below, providing we have:

Enough information to identify you (i.e. your full name and your personal email address);
Proof of your identity and address; and
Information to which your request relates.

We hope that we can resolve any query or concern you raise about our use of your information.

Contact Us

All questions, comments and requests regarding this Privacy Notice can be addressed to our Data Protection Office at [email protected].

It is important to point out that we may amend this Privacy Notice from time to time. Please just visit this page if you want to stay up to date, as we will post any changes here.

Lately revised on 09/2026.

Annex A – Third-Party Processors

The following is a non-exhaustive list of main third-party recruitment service providers and processors used across the Group:

Name	Service / Purpose
LinkedIn	Recruitment / Talent Sourcing
Bob Hiring	Applicant tracking / Recruitment
CodeSignal	Technical Assessment Provider
KPMG	Assessment Center Provider
People for Business	Assessment Center Provider
SHL Platform	Assessment Center Provider
LexisNexis Risk Solutions	Background & AML Screening