Who We Are Gemini Folk is a consulting and recruitment business. We act as a data controller in respect of the personal data we collect and process about candidates and contractors in the course of our recruitment and placement activities. If you have any questions about how we handle your personal data, please contact us at: [email protected]

Personal Data We Collect We collect and process the following categories of personal data: • Identity data: full name, date of birth, and government-issued identity documents (e.g. passport or driving licence) • Contact data: email address, phone number, and postal address • Professional data: CV, employment history, qualifications, and references • Right to work documentation: as required under UK law • Financial data: bank account details for payment purposes, where applicable • Equal opportunities data: ethnic origin, where voluntarily provided for monitoring purposes

How We Collect Your Data We collect personal data in the following ways: • Directly from you — when you submit a CV, application, or onboarding documentation • From publicly accessible professional platforms — such as LinkedIn or job boards, where you have made your professional information available

How We Use Your Personal Data We use your personal data for the following purposes: • To assess your suitability for roles and match you with relevant opportunities • To share your details with prospective clients and employers (including Accenture and its affiliates) as part of the placement process • To verify your identity and right to work in the UK • To fulfil our contractual and legal obligations in connection with your placement • To process payments where applicable

Legal Basis for Processing We rely on the following legal bases under UK GDPR: • Contractual necessity — where processing is required to fulfil or prepare a contract with you • Legitimate interests — where processing is necessary for our legitimate business interests in operating a recruitment service, and those interests are not overridden by your rights • Legal obligation — where processing is required to comply with applicable law (e.g. right to work checks) • Consent — where we have obtained your explicit consent, such as for equal opportunities monitoring data

Who We Share Your Data With We share your personal data with: • Prospective and confirmed client organisations — including Accenture and its affiliates — for the purposes of evaluating and confirming your placement • Our technology suppliers — including Microsoft 365 and our recruitment CRM — who process data on our behalf as data processors under appropriate Data Processing Agreements We do not sell, rent, or share your personal data with any third party for their own commercial purposes.

International Transfers Your personal data is primarily stored and processed within the UK and EEA. Where data is processed outside these regions — for example via cloud infrastructure — we ensure appropriate safeguards are in place, including Standard Contractual Clauses or reliance on adequacy decisions recognised under UK GDPR.

How Long We Keep Your Data We retain your personal data only for as long as necessary for the purposes set out in this notice, and in line with applicable statutory obligations: • Candidate data where no placement is made: up to 2 years from last contact, unless you request earlier deletion • Right to work documentation: 2 years post-engagement, as required by the UK Home Office • Financial and payroll records: 6 years, as required by HMRC • Contracts and engagement records: 6 years post-termination

Your Rights Under UK GDPR you have the following rights in relation to your personal data: • Right of access — to request a copy of the personal data we hold about you • Right to rectification — to request correction of inaccurate or incomplete data • Right to erasure — to request deletion of your data in certain circumstances • Right to restriction — to request that we limit processing of your data • Right to portability — to receive your data in a structured, machine-readable format • Right to object — to object to processing based on legitimate interests • Right to withdraw consent — where processing is based on consent, you may withdraw it at any time To exercise any of these rights, please contact us at: [email protected]. We will respond within one calendar month of receiving your request.

Right to Complain If you are unhappy with how we have handled your personal data, you have the right to lodge a complaint with the UK Information Commissioner's Office (ICO): • Website: www.ico.org.uk • Helpline: 0303 123 1113 We would, however, appreciate the opportunity to address your concerns directly before you contact the ICO.

Changes to This Notice We may update this privacy notice from time to time. Where changes are material, we will notify you directly. The current version will always be available on request.