Data Processing Policy in Application Management

This special Policy governs the processing of applicants' personal data by the Borgstena Group and complements the general Personal Data Protection and Privacy Policy.

1.Commitment to data protection

Dual Borgstena Textile Portugal, Unipessoal, Lda., hereinafter referred to as Borgstena, a legal person with identification number 502355409, complies with the applicable European Union and national legal regulations in the field of data protection, privacy and security of applicants' personal information, in accordance with the general terms of the Personal Data Protection and Privacy Policy, accessible at www.borgstena.com or at any of its service points, as well as with the special terms of this Policy.

2.Personal data

Borgstena collects and processes the following personal data of applicants: the name, title, role or position, the company where the applicant works and the respective contacts within that company, as well as business card data and all data contained in the curriculum vitae or in the application form.

3.Data sources

Borgstena collects applicants' personal data through the submission of the curriculum vitae, the completion of the application form or from various sources of personal information accessible to the general public — namely websites, professional networks and media — as well as on the basis of personal references.

4.Purpose of processing

Borgstena processes applicants' personal data exclusively for the purposes of human resources management and the selection or recruitment of employees.

5.Legitimacy of processing

Borgstena bases the legitimacy of the processing of applicants' personal data, depending on the specific processing activities, on the applicants' consent, on the performance of pre-contractual steps or on the legitimate interest of human resources management for the pursuit of the selection and recruitment of human resources, within the exercise of a legitimate economic activity. Where processing is based on consent, this may be withdrawn at any time, without affecting the lawfulness of the processing carried out up to that point.

6.Data retention period

Borgstena keeps the data for the period necessary to achieve the purposes of the processing, in compliance with the applicable legal deadlines, the applicant being able to request, at any time, their erasure or the exercise of any other right. The default retention period for the curricula and personal data of applicants processed by the human resources management services is two years.

7.Communication of personal data

Applicants' personal data are processed exclusively by Borgstena's human resources management services and are not communicated to third parties, save in the situations legally provided for the mandatory communication of data.

8.Data processing information sheets

In compliance with the principles of fairness and transparency and the duty to provide information, Borgstena delivers directly or makes publicly available to all data subjects, depending on how their personal data are collected, information sheets on the processing activities carried out, accessible for consultation at any service point or upon request to the Data Protection Officer. The Information Sheet on Data Processing in Application Management is available at borgstena.dataprotectionofficer.help/borgstena/information.

9.Applicants' rights

Borgstena facilitates the exercise of applicants' rights regarding the protection of personal data. In addition to always being able to lodge a complaint with the respective supervisory authority, for the exercise of any type of data protection rights — namely the rights to withdraw consent, to information, of access, rectification, objection, restriction of processing or erasure — applicants may contact Borgstena's Data Protection Officer directly by email at dataprotection@borgstena.com, describing the subject of the request and indicating an email address, a telephone contact or a correspondence address for reply. A Form for Exercising the Rights of Data Subjects is available at borgstena.dataprotectionofficer.help/borgstena/forms or at any Borgstena service point.

10.Reporting of personal data breach incidents

Borgstena has implemented an incident management system for data protection and information security. Should they wish to report the occurrence of a personal data breach — which, accidentally or unlawfully, results in the unauthorised destruction, loss, alteration, disclosure of, or access to, personal data transmitted, stored or otherwise processed — the applicant may contact Borgstena's Data Protection Officer or use Borgstena's general contact details. A Personal Data Breach Incident Report Form is available at borgstena.dataprotectionofficer.help/borgstena/forms.

11.Permanent security contact point

Borgstena has implemented a Permanent Contact Point for the management of information security and cyberspace security incidents. Should they wish to report the occurrence of an information security incident or a cyberspace security incident, the applicant may contact Borgstena's Permanent Contact Point through the communication channels available at borgstena.dataprotectionofficer.help/borgstena/security. An Information Security or Cyberspace Security Incident Reporting Form is available at borgstena.dataprotectionofficer.help/borgstena/forms.

12.Whistleblower protection

Borgstena has implemented a Whistleblowing Channel, in accordance with the legal regulations in force, namely Law No. 93/2021 of 20 December, guaranteeing the protection of the personal data of data subjects, under the terms of the Whistleblower Protection Policy accessible at borgstena.dataprotectionofficer.help/borgstena/whistleblowing. The Whistleblowing Officer at Borgstena may be contacted through the contact details available on that page, where the Whistleblowing Platform is also accessible.

13.Corruption prevention

Borgstena has implemented a Regulatory Compliance Programme within the scope of the Prevention of Corruption, in accordance with the legal regulations in force, namely Decree-Law No. 109-E/2021 of 9 December, guaranteeing the protection of the personal data of data subjects. For the purpose of submitting reports within the scope of the corruption prevention regime, any interested party may use Borgstena's Whistleblowing Platform or the Whistleblowing Form, accessible from borgstena.dataprotectionofficer.help/borgstena/whistleblowing.

14.Data protection policies

The Data Processing Policy in Application Management is complemented by Borgstena's general Personal Data Protection and Privacy Policy, accessible at www.borgstena.com. The other special data protection policies may also be consulted, namely the Data Protection Policy in the Employment Context, by sending a request to the Human Resources Department at info@borgstena.com or by contacting any service point in person.

15.Versions of the Policy

Version of this Policy: 202605. Date: 25 May 2026. This version supersedes version 202306. In order to ensure its updating, development and continuous improvement, Borgstena may, at any time, make any changes deemed appropriate or necessary to its data protection policies, their publication in the various channels being ensured. To consult previous versions, the data subject may send a request by email to dataprotection@borgstena.com.