This notice explains how Arsia Limited (trading as "Travel Better"), registered at 12, Tigné Place, Office 2/4B Tigné Street, Sliema SLM 3173, Malta ("we", "us", "the Company"), collects and uses personal data about job applicants and candidates ("you") when you apply for a role with us. It applies wherever you apply from and regardless of the outcome of your application.

1. Who is the data controller
Arsia Limited is the data controller for the personal data you submit as part of your application.

Contact for data protection questions: hr@travelbetter.com

2. What data we collect
Depending on the role and how you apply, we may collect:

• Contact details (name, email, phone number, location)
• CV/resume, cover letter, and any information contained in them (work history, education, skills, certifications)
• LinkedIn profile or portfolio links you provide
• Answers to application questions (e.g. "why do you want to join us")
• Interview notes and assessment/test results, if you proceed further in the process
• References, if and when you provide them or authorize us to request them
• Any other information you choose to submit

We do not ask for special category data (health, religion, union membership, etc.) as part of the standard application process, and we ask that you do not include such information in your CV or answers unless legally relevant (e.g. a disability accommodation request).

3. Why we process your data and our legal basis
Purpose
Legal basis (GDPR Art. 6)
Assessing your suitability for the role you applied to Necessary for steps prior to entering into a contract (Art. 6(1)(b))
Communicating with you about your application
Legitimate interest (Art. 6(1)(f))
Keeping records to defend against potential claims relating to the recruitment process
Legitimate interest (Art. 6(1)(f))
Keeping your profile on file for future, different vacancies ("talent pool")
Consent (Art. 6(1)(a)) — only if you separately opt in
Complying with legal/regulatory obligations (e.g. employment law record-keeping)
Legal obligation (Art. 6(1)(c))

4. Who we share it with
Internal hiring team and relevant managers involved in the recruitment decision
Applicant Tracking System acting as our processor
Professional advisors, regulators, or authorities where required by law

We do not sell your data, and we do not share it with third parties for their own marketing purposes.

5. How long we keep your data
If your application is unsuccessful: we retain your data for 6 months after the recruitment process for that role has closed, to allow us to respond to any claim arising from the process, after which it is deleted.

If you are hired: your application data is transferred into your employee record and retained in line with our employee data retention rules.

Talent pool: if you separately opt in to being contacted about future roles, we retain your data for 24 months or until you withdraw consent, whichever is earlier, and will ask you to reconfirm periodically.

6. Your rights
Under GDPR, you have the right to:

• Access the personal data we hold about you
• Rectify inaccurate or incomplete data
• Erase your data ("right to be forgotten"), subject to the exceptions below
• Restrict or object to certain processing based on legitimate interest
• Data portability, where technically applicable
• Withdraw consent at any time where processing is based on consent (e.g. talent pool), without affecting processing done before withdrawal
• Lodge a complaint with a supervisory authority — in Malta, the Information and Data Protection Commissioner (IDPC), idpc.org.mt, or the supervisory authority in your own country of residence

Note: we may need to retain certain data even after an erasure request if we have an overriding legitimate interest to do so (for example, to defend against a legal claim within the applicable limitation period). If we decline a request, we will explain why.

To exercise any of these rights, contact us at hr@travelbetter.com. We will respond within one month (extendable by a further two months for complex requests, with notice).