CANDIDATE PRIVACY NOTICE

1. Who is responsible for your personal information

The business responsible for your personal information is:

Green Future USA, Inc. d/b/a Green SM (“Green SM,” “we,” “us”), located at 9881 Irvine Center Drive, Irvine, CA 92618, United States.

Green SM’s parent company and global headquarters, GSM Green and Smart Mobility JSC in Vietnam, participates in decisions about how candidate information is used for group-wide recruitment approval, workforce planning and governance. For those activities, Green SM and the Vietnam headquarters share responsibility for your personal information. Green SM remains your primary point of contact and is responsible for responding to your requests.

For any questions regarding this notice or your personal information, please contact us at: v.driver.us@greensm.com, or at the postal address above.

The United States has no single national privacy regulator for employment-related data. Depending on where you live, you may raise concerns with your state Attorney General, and California residents may also contact the California Privacy Protection Agency. Nothing in this notice limits any right you may have to contact a regulator or to pursue a remedy available to you under applicable law.

2. What this notice covers

This Privacy Notice explains how Green SM collects, uses, stores, shares, transfers and otherwise processes the personal information of individuals who apply for, are considered for, or express an interest in working with Green SM, as an employee, in the fifty United States and the District of Columbia ("Candidates"). Throughout this Privacy Notice, such personal information is referred to as "Candidate Data".

This notice is provided at or before the point of collection and serves as our notice at collection for candidates in states that require one, including California. It does not form a contract of employment or engagement and does not alter the at-will nature of any employment relationship.

It applies to:

driver candidates, who are engaged as employees;
office, operations, dispatch, customer support, fleet, depot, HR, finance, legal, IT, marketing, management and other non-driver candidates;
candidates introduced through agencies, referrals, job boards, direct sourcing, recruitment events or the Green SM careers page;
candidates for full-time, part-time or fixed-term roles;
people who consent to remain in a Green SM talent pool.
This notice does not apply to workers engaged through and employed by a staffing agency. Those individuals receive a separate notice from the engaging entity.

3. What personal information we collect

Green SM collects Candidate Data progressively throughout the recruitment process and only to the extent reasonably necessary for the relevant recruitment stage. We limit collection to what is reasonably necessary Candidate Privacy Notice – Green SM | Page 1 and proportionate for the purposes described in this notice, keep it accurate, retain it only as long as needed, and protect it.

3.1 Information we may collect from all candidates

name and contact details (postal address, e-mail, telephone);
city, country and language preference where relevant;
role applied for or role interest;
CV / résumé, cover letter, portfolio, certificates, education and work history;
application source (career page, job board, agency, referral, event);
availability, expected start date and work-location preference;
job-related qualifications, skills, experience and interview answers;
interview notes, assessment results and hiring-manager feedback;
communication history with Green SM recruiters, HR, hiring managers and agencies;
offer details, acceptance or rejection status and relevant decision reasons;
indication of your authorization to work in the United States, and whether you will require visa sponsorship. Green SM does not request or examine work-authorization documents until after an offer is accepted, consistent with the Immigration Reform and Control Act and the anti discrimination rules on document requests.

3.2 Additional information for driver candidates

For driver candidates, Green SM may also process:

confirmation that you meet the minimum age required for the driver role under applicable law and our insurance requirements;
U.S. driver's license status, issuing state and expiration date. Green SM collects the license number or an image of the license where necessary to verify eligibility to drive, to order a motor vehicle record, or to satisfy a licensing or insurance requirement. Where a verification outcome is sufficient, Green SM records only that outcome rather than retaining an image of the license;
professional driving experience;
customer-service experience;
lawful shift availability;
depot / location preference where relevant;
language ability relevant to passenger service;
internal driving, EV-handling, app-use, navigation and service-quality assessment results;
training and onboarding completion status;
vehicle-handover readiness once employment and licensing conditions are met;
driving history and motor vehicle record information, including license status, violations, suspensions and accident history, obtained through a screening vendor;
criminal history information, requested only after a conditional offer has been made and only where permitted by applicable state and local law;
the results of a face-match identity verification during onboarding, as described in Section 4;
telematics, GPS and dashcam-derived location or trip data generated during any supervised test drive, trial period or onboarding session, used only to complete and assess that session. No road test or trial drive is recorded by audio or video.

3.3 Additional information for non-driver candidates

For non-driver candidates, Green SM may also process:

professional licenses or certifications relevant to the role;
technical, operational, managerial, legal, financial, HR, IT, marketing, fleet, depot, customer support or dispatch skills;
role-specific assignments, work samples or case-study results;
language ability where relevant to the role;
information needed to assess seniority, reporting line, role fit and business need.

3.4 Information collected only after a conditional offer, engagement or hiring

Green SM normally collects the following only after a conditional offer has been accepted, or where legally required during onboarding:

Social Security number or ITIN, collected only where required for tax reporting, payroll, employment eligibility verification or a background check;
bank account and routing information for direct deposit;
payroll and tax withholding information, including IRS Form W-4 and applicable state withholding forms;
identity and work-authorization documents you choose to present for Form I-9 employment eligibility verification, examined only after an offer is accepted. Green SM does not specify which documents you must present and retains copies only where permitted and applied consistently;
benefits and retirement plan enrollment information, including dependent or beneficiary details you choose to provide;
emergency contact information (if required by Green SM HR policy);
signed employment documents and onboarding records.

4. Sensitive information and information Green SM does not ask for

4.1 Information Green SM does not ask for Green SM does not ask candidates to provide:

health or medical details;
pregnancy or family-planning information;
marital status, family status or childcare arrangements (unless a later statutory benefits or retirement plan process specifically requires it);
race or ethnicity;
religion or belief;
political opinions;
union membership or activity;
sexual orientation or sex life;
biometric information, other than the face-match identity verification for driver candidates described below; • criminal history, other than as described in Section 7 and only where and when applicable state and local law permits;
prior deactivation from third-party ride-hailing platforms. We assess you on your own merits.
Any additional information prohibited by law.

If you request reasonable accommodation to participate in the recruitment process, Green SM collects only the limited information needed to evaluate and arrange that accommodation. This information is kept confidential, stored separately from your application file consistent with the Americans with Disabilities Act, and is not used to assess your suitability for the role.

If you voluntarily provide information that Green SM did not ask for and does not need, Green SM will not use it for the recruitment decision and may delete it.

4.2 Sensitive personal information

Some of the information described in Section 3 is treated as "sensitive personal information" or "sensitive data" under state privacy laws. This includes your Social Security number and driver's license number. Green SM collects sensitive personal information only for the purposes described in this notice, does not use or disclose it to infer characteristics about you, and does not sell or share it.

4.3 Face-match identity verification (driver candidates only)

This clause applies only to driver candidates, because identity assurance for a person who will transport passengers is subject to state and local for-hire licensing and platform-safety requirements that do not apply to office-based roles.

During driver onboarding, Green SM asks you to take a photograph of yourself and compares it against the photograph on your government-issued driver's license to confirm that you are the licensed driver. This process creates a biometric identifier.

Green SM will not collect, capture or use this biometric identifier without first providing you with a separate written disclosure and obtaining your written consent, as required by the Illinois Biometric Information Privacy Act, the Texas Capture or Use of Biometric Identifier Act and comparable laws. That disclosure states the specific purpose and the retention period. Green SM does not sell, lease, trade or otherwise profit from biometric information, and destroys it when the verification purpose has been satisfied or within the period stated in the separate disclosure, whichever occurs first.

If you do not wish to complete face-match verification, contact us and Green SM will offer a manual identity-verification alternative where one is available for your market.

5. Where we obtain your information

We collect most Candidate Data directly from you.

We may also receive data from:

recruitment agencies, staffing providers or payroll providers;
job boards and professional platforms;
employee referrals (referrer should let you know);
recruitment events and job fairs;
references you provide or authorize us to contact (Green SM will contact references only after informing you and obtaining your prior consent. References are contacted only where relevant to the position applied for and only after interviews or at the conditional offer stage);
public professional profiles, where relevant and proportionate to the role. Green SM does not systematically screen private accounts and will tell you if a specific public source has influenced our assessment;
assessment providers and consumer reporting agencies (background-screening vendors), only where lawful and only after the disclosures and authorization described in Section 7;
educational institutions, licensing bodies and certifying organizations, where Green SM verifies a qualification, license or certification you have told us about. If you provide a reference’s contact details, you should inform that person that Green SM may contact them for recruitment purposes.

6. Why we use Candidate Data

Green SM does not sell Candidate Data and does not share it for cross-context behavioral advertising. Green SM uses Candidate Data only for the purposes listed above and for compatible purposes disclosed to you, and will provide a new notice before using it for a materially different purpose.

Where Green SM relies on your consent, such as for talent-pool retention, recruitment messages or face match verification, you may withdraw that consent at any time. Withdrawal does not affect processing already carried out, and Green SM will tell you if withdrawal means we can no longer consider you for a role.

7. Screening, references and public sources

Green SM verifies candidate information only where relevant to the role, and applies the rules set out below.

References are contacted only with your prior consent, normally at or around the offer stage, and only on job-related matters.
Background checks are ordered only where relevant to the position and only in compliance with applicable federal, state and local law.
Credit reports are not ordered for any role.
Social media: we do not systematically screen private accounts; we may consult public professional profiles where directly relevant, and we will tell you if a specific source has influenced our assessment.
No covert checks: Green SM does not carry out covert surveillance, undercover online screening or false-identity contact with candidates.

7.1 Consumer reports (all candidates)

Where Green SM uses a third-party screening vendor, the report it produces is a "consumer report" under the federal Fair Credit Reporting Act (FCRA). In that case, and before any report is ordered, Green SM will give you a clear and conspicuous written disclosure in a stand-alone document and obtain your written authorization, together with a summary of your FCRA rights and any additional notices your state requires.

If Green SM is considering taking adverse action based in whole or in part on a consumer report, Green SM will first send you a pre-adverse action notice with a copy of the report and the summary of rights, allow you a reasonable period to respond or dispute the information, and then send a final adverse action notice if the decision stands. You may request a copy of any report from the vendor at no charge.

Green SM follows applicable "ban-the-box" and fair-chance laws, which in many states and cities require that criminal history be requested only after a conditional offer and be assessed individually against the duties of the role. Green SM will not automatically disqualify you because of a record, and where a fair chance law requires an individualized assessment, Green SM will carry one out and give you the notices that law requires.

7.2 Driving records and safety screening (driver candidates only)

This clause applies only to driver candidates. It is separate from the general screening rules because driving record and safety checks are required by applicable law and by our insurers, and are not applied to non driver roles.

For driver candidates, Green SM obtains a motor vehicle record through a screening vendor, and reviews license validity, violations, suspensions and accident history against the safety standards that apply in your market. Green SM may re-run driving-record checks periodically after you are engaged, where required by law or by our insurance arrangements; if so, that will be disclosed to you separately.

Driver candidates are required to undergo pre-engagement drug and alcohol testing as part of the recruitment and onboarding process. The testing is limited to determining the presence of prohibited drugs and alcohol in accordance with applicable law and company requirements.

Test results are disclosed solely to designated members of the Driver Acquisition Team of Green SM for purposes of evaluating candidate eligibility, onboarding, regulatory compliance, and related workforce administration activities. Access to test results is restricted on a strict need-to-know basis and is granted only to personnel authorized to perform these functions.

Drug and alcohol testing records are maintained as confidential records, stored separately from personnel files and general recruitment records, and protected through appropriate administrative, technical, and organizational safeguards designed to prevent unauthorized access, use, disclosure, alteration, or loss. Such records are retained only for as long as necessary to fulfill the purposes for which they were collected and to comply with applicable legal, regulatory, and record-retention requirements.

Green SM does not require medical examinations or U.S. Department of Transportation (DOT) physical examinations as part of its driver recruitment process.

8. Automated tools and human review

Green SM uses recruitment systems to receive applications and manage workflow. Green SM does not use artificial-intelligence or algorithmic tools to screen, rank, score or reject candidates, and does not make hiring decisions by automated means.

All shortlisting, interview and hiring decisions are made by human recruiters and hiring managers. If Green SM later adopts AI-assisted recruitment tools such as ranking, matching or scoring features, Green SM will update this notice and provide any advance notice, bias-audit information or opt-out that applicable state or local law requires before those tools are used on candidates.

Green SM does not use facial-expression analysis, voice-emotion analysis, personality inference from video or voice, or automated rejection in recruitment. The only biometric process Green SM uses is the face match identity verification for driver candidates described in Section 4.3, which confirms identity and is not used to assess suitability.

9. Recruitment communications

Green SM may contact candidates who apply, sign up through a Green SM form, meet Green SM at a recruitment event, are referred, or otherwise request recruitment contact.

Text-message, WhatsApp, e-mail and direct-message recruitment outreach is used only where:

you have given prior express written consent to receive automated or bulk recruitment text messages at the number you provided, as required by the Telephone Consumer Protection Act, and that consent is not a condition of being considered for a role;
Green SM identifies itself in every message;
the message explains the purpose;
every message includes a clear opt-out (for example, replying STOP to text messages or an unsubscribe link i e-mail), honored promptly as required by the CAN-SPAM Act and the Telephone Consumer Protection Act;
Green SM can evidence the consent and the opt-out.

Green SM does not use bought, scraped or unverified contact lists for recruitment outreach.

10. Who we share Candidate Data with

Green SM shares Candidate Data only with parties that need it for recruitment, onboarding, compliance, security or legal purposes. Recipients may include:

Green SM recruiters, HR, hiring managers, interviewers and operational managers (need-to-know);
Green SM group entities and group support functions, including our headquarters in Vietnam, where access is necessary for recruitment approval, IT support, reporting or governance, as described in Section 11;
recruitment agencies, staffing providers, payroll providers, accounting providers, assessment providers and background-screening providers (where lawfully engaged);
ATS, HRIS, CRM, cloud, e-mail, document-management and security providers;
video-conferencing providers used for interviews;
government agencies, courts, regulators and law enforcement, where required by law or valid legal process.

Green SM does not sell Candidate Data and does not share Candidate Data with third parties for their own marketing.

Vendors that handle Candidate Data on our behalf are engaged under written agreements that limit them to our instructions, prohibit retaining or using the data for their own purposes, and require appropriate safeguards, as state privacy laws require for service providers, processors and contractors.

11. Transfers to Vietnam and other countries

Green SM is part of a group headquartered in Vietnam. Candidate Data is stored in the United States and is also transferred to, or accessed remotely from, Vietnam.

Transfers to Vietnam are limited to what is necessary for group administration and facilitation of the recruitment process, such as approval of a requisition or offer, group-level workforce reporting, IT and system support, and internal audit or investigation. Green SM does not transfer Candidate Data to Vietnam for marketing or for any purpose unrelated to those activities. Green SM applies the following safeguards to those transfers:

an intra-group data transfer agreement between the U.S. entity and the Vietnam headquarters that limits the purposes for which Candidate Data may be used, imposes confidentiality and security obligations, and requires the Vietnam entity to support your rights requests;
role-based access restrictions, encryption in transit, and access logging, so that only named personnel with a defined business need can view Candidate Data from outside the United States.

You should be aware that Vietnam and other countries to which Candidate Data may be transferred have data protection frameworks that differ from those in the United States, and that government authorities in those countries may in some circumstances be able to access data under their own laws. Green SM cannot eliminate that risk, but limits it through the safeguards above. You may request further information about these arrangements by contacting v.driver.us@greensm.com.

12. How long we keep Candidate Data

When retention expires, Green SM deletes or anonymises the data.

13. Security

Green SM implements reasonable administrative, technical and physical safeguards designed to protect Candidate Data against unauthorized access, destruction, use, modification or disclosure, consistent with applicable state data-security laws, including:

role-based access controls;
confidentiality obligations on all personnel and vendors;
encryption in transit and, where appropriate, at rest;
secure cloud hosting and logging;
vendor due diligence and written data protection agreements;
retention and deletion controls;
incident response and breach escalation;
security training for personnel handling recruitment data. Candidate Data must not be stored in personal inboxes, private devices, unmanaged messaging apps or informal spreadsheets unless approved controls are in place.

14. Your rights

Depending on the state in which you reside, you may have some or all of the following rights, exercisable free of charge. California, Colorado, Connecticut, Virginia, Texas, Oregon, Montana and a growing number of other states grant these rights to residents; California and Colorado expressly extend them to job applicants:

confirm whether we process your personal information and obtain a copy of it;
correct inaccurate personal information;
delete your personal information, subject to exceptions where we must retain it by law;
limit our use and disclosure of sensitive personal information (California);
opt out of any sale of personal information, sharing for cross-context behavioral advertising, or profiling in furtherance of decisions with legal or similar effects, none of which Green SM carries out with Candidate Data;
receive your personal information in a portable format, where technically feasible;
withdraw consent at any time;
request information about the safeguards applied to transfers of your personal information outside the United States, as described in Section 11;
appeal a denial of a request, where your state provides an appeal right, and raise concerns with your state Attorney General or, for California residents, the California Privacy Protection Agency.

To exercise your rights, contact v.driver.us@greensm.com. Green SM may ask for reasonable information to verify your identity, and you may use an authorized agent where your state permits. We will respond within forty-five (45) days of a verifiable request, extendable by a further forty-five (45) days where reasonably necessary, and will tell you if an extension applies.

You will not be discriminated against or retaliated for exercising your rights. In some cases, deletion, objection or withdrawal of consent may affect Green SM’s ability to continue considering you for a role; Green SM will explain that consequence to you.

14.1 Additional notes for California candidates

California residents may also request the categories of personal information we collected, the sources, our business purposes, and the categories of third parties to whom we disclosed it. Sections 3, 5, 6 and 10 provide that information. Green SM does not sell personal information and does not share it for cross context behavioral advertising, so there is no "Do Not Sell or Share My Personal Information" mechanism for Candidate Data.

If Green SM orders an investigative consumer report about you, California law entitles you to request a copy at the time the report is ordered and to receive additional notices under the Investigative Consumer Reporting Agencies Act.

14.2 Additional notes for driver candidates

This clause applies only to driver candidates, because their information is subject to the FCRA and biometric consent processes described in Sections 4.3 and 7. In addition to the rights above, driver candidates may dispute the accuracy of a motor vehicle record or background report directly with the screening vendor. If you withdraw that consent, Green SM may be unable to complete identity verification and therefore unable to engage you as a driver.

15. Changes to this notice

Green SM may update this notice from time to time. The current version will show its effective date.

Material changes will be communicated through the relevant recruitment channel and/or the Green SM careers site. Where a change is material and you are an active candidate, Green SM will inform you directly.

Version: 1.0

Effective Date: 16, September, 2026