Be My Eyes Personnel Data Privacy Policy Effective Date: February __ 2026 Scope: This policy applies to all Accessibly Inc. and Be My Eyes ApS employees (full-time, part-time, temporary), contractors, consultants, job applicants, and former employees, contractors and consultants. It covers all personal data processed in the context of recruitment, employment, and workforce management. Introduction Accessibly Inc. dba Be My Eyes and its wholly-owned subsidiary Be my Eyes ApS (collectively, “we,” “us,” or “the Company”) are committed to protecting the privacy and security of your personal information. This policy describes how we collect and use personal information about you during and after your working relationship with us, in accordance with the EU General Data Protection Regulation (GDPR), the UK GDPR, and applicable US state privacy laws. Types of Data We Collect We may collect, store, and use the following categories of personal information: Identification Data: Name, address, phone number, personal email, date of birth, and government identifiers (e.g., SSN, National Insurance number, CPR Number, Tax ID). Employment Records: CV/Resume, references, job titles, work history, and training records. Financial & Benefits Data: Bank account details, salary, bonus, benefits information, and tax status. Technical Data: Information captured through our IT systems, including IP addresses, log-in data, and usage of company hardware/software. Sensitive Data: Where permitted by local law, we may collect information about health (for disability accommodations or sick leave) and diversity / equal opportunity data (where voluntarily provided). Background Checks. For most positions, if we extend an employment offer to you or employ you, we will perform a standard background check in compliance with local law where you live and/or will be employed. Other Data. The examples above are illustrative and not exhaustive. We may collect additional information in any of the above categories under this policy. How We Use Your Data We process personal data for the following purposes: Recruitment and hiring decisions Employment administration and HR management Payroll, tax, and benefits administration Legal and regulatory compliance Performance management and training IT security and business continuity Health, safety, and workplace accommodations Legal Bases for Processing We process your personal data for the following Lawful Bases: Contractual Necessity: To pay you and provide benefits. Legal Obligation: For tax reporting, social security contributions, national insurance, employment law compliance, and other applicable legal requirements. Legitimate Interests: To manage our business, ensure IT security, and conduct performance reviews. Consent: In specific cases where you have given clear permission (e.g., featuring your photo on the company website). Data Sharing and International Transfers As a company with personnel in the US, UK, and EU, your data may be transferred across borders. Internal Transfers: Data may be shared between our global offices for administrative and management purposes. Third Parties: We share data with service providers (e.g., payroll processors, health insurance providers, and cloud services like Google Workspace). Safeguards: All third-party processors are required to protect personal data and use it only for authorized purposes in accord with applicable law. Your Rights You may have defined legal rights with respect to your personal data. The existence, scope, and extent of those legal rights depends on where you live and/or work. We will honor any of the requests below regardless of whether there is a legal right applicable to you, and will also comply with any other legal rights you have with respect to personal data: Access: Request a copy or disclosure of all data held. Correction: Rectify inaccurate information. Erasure: Request deletion (subject to legal exceptions and preservation requirements). Portability: Move data to another provider. Data Security and Retention We have implemented appropriate security measures to prevent your personal information from being accidentally lost, used, or accessed in an unauthorized way. We retain your personal information only for as long as necessary for (a) employment and business purposes; and (b) legal, tax, and regulatory requirements. Retention periods vary by data type and jurisdiction. Data is securely deleted or de-identified when no longer required. Contact and Complaints If you have questions or concerns about this policy or how we handle your data, please contact: Privacy Lead: Clay Deanhardt, clay@bemyeyes.com or legal@bemyeyes.com. If you live in the UK or the EU, you also have the right to lodge a complaint with your local data regulator. For the UK, that is the Information Commissioner’s Office (ICO). Each EU country has a specific national authority you can reach out to (e.g., Datatilsynet – the Danish Data Protection Agency).
