Our Commitment Cerca Trova Ltd is committed to conducting its activities with integrity, transparency, and accountability. The company does not engage in lobbying activities or political advocacy intended to influence legislation, regulations, or public policy. Cerca Trova Ltd does not make political contributions or provide financial support to political parties, candidates, or political campaigns. Should the company participate in public policy discussions or advocacy in the future, it will do so only where such activities contribute to positive social, educational, or environmental outcomes, are supported by reliable evidence, and are consistent with the company's values, ethical standards, and commitment to responsible business practices. The company maintains a zero-tolerance approach to bribery, corruption, and unethical influence in all of its business activities. This statement is reviewed periodically by the Managing Director and forms part of the company's broader governance framework.

Our Commitment At Cerca Trova Ltd, we are committed to respecting internationally recognized human rights throughout our operations, business relationships, and educational programs. We believe that every individual should be treated with dignity, fairness, and respect, and we strive to ensure that our activities contribute positively to the well-being of our employees, participants, partners, suppliers, and the communities in which we operate. Accordingly, Cerca Trova Ltd publicly commits to respecting:

• The United Nations Guiding Principles on Business and Human Rights;
• The International Bill of Human Rights, including the Universal Declaration of Human Rights; and
• The International Labour Organization (ILO) Declaration on Fundamental Principles and Rights at Work, including the elimination of forced labor, child labor, discrimination in employment, and respect for freedom of association and collective bargaining.

How We Apply This Commitment We integrate respect for human rights into our business practices by: promoting equal opportunity and non-discrimination; maintaining safe, respectful, and inclusive working and learning environments; considering human rights in the selection and evaluation of program partners and significant suppliers; providing accessible grievance and reporting mechanisms for employees, participants, and other stakeholders; reviewing our policies and practices periodically to support continuous improvement. We expect our employees, host organizations, contractors, suppliers, and business partners to uphold these principles and to comply with applicable laws and internationally recognized human rights standards. This commitment is approved by the Managing Director and applies to all operations of Cerca Trova Ltd.

Our Commitment Cerca Trova Ltd is committed to conducting its activities ethically, responsibly, and transparently. We encourage employees, participants, host organisations, suppliers, universities, contractors, local communities, and other stakeholders to raise concerns if they believe our actions or those of our representatives are inconsistent with our policies, legal obligations, or ethical standards. We are committed to reviewing all concerns fairly, impartially, and confidentially where appropriate, without retaliation against anyone who raises a concern in good faith. What Can Be Reported? Stakeholders may raise concerns relating to, including but not limited to:

• Human rights
• Discrimination or harassment
• Bullying or inappropriate behaviour
• Health and safety
• Environmental practices
• Animal welfare (where applicable)
• Business ethics, bribery or corruption
• Conflicts of interest
• Privacy or data protection
• Supplier or partner conduct
• Any other conduct inconsistent with our policies or applicable laws

How to Submit a Concern Stakeholders may submit a grievance or concern use our Contact Form and select "Grievance / Complaint" as the subject (or clearly indicate that your submission is a grievance). What Happens Next? Upon receiving a grievance, Cerca Trova Ltd will:

• acknowledge receipt where contact details are provided;
• review the information objectively;
• investigate where appropriate;
• communicate the outcome or next steps where possible; and
• maintain records of grievances and corrective actions.

All concerns are handled confidentially to the extent reasonably possible. Non-Retaliation No stakeholder will suffer retaliation, discrimination, or adverse treatment for raising a concern honestly and in good faith.

GENERAL Cerca Trova (CT) wants you to benefit from the information and services available on our website – www.ctrova.eu (the “Site”) – secure in the knowledge that we have implemented fair and transparent information policies and practices designed to protect your privacy. This Privacy Notice describes our policies and practices regarding our collection and use of personal data about users of the Site and sets forth your privacy rights. CT is headquartered in: Blvd. Al. Stamboliyski 55, Sofia, 1000, Bulgaria and with VAT No: BG204499976. Our internal data protection officer can be contacted using the form provided under the “Contact Us” page in case you have any questions or concerns about our personal data policies or practices. Under applicable law, CT is considered the “data controller” of the personal data we collect pursuant to this Privacy Notice. WHY WE COLLECT PERSONAL DATA AND HOW WE USE YOUR INFORMATION Any information collected on this site is used only to facilitate a more personal experience for the user. We do not sell any information about our users to outside organizations, and we only share information as described in this Privacy Notice. You can use our website without divulging any personally identifiable information, including your email address. Our site only collects identifiable information about individuals when such individuals specifically provide such information on a voluntary basis in the following cases: Creating an account, Signing up for updates, Completing a contact form, Completing our on-line application. Any data we collect is used for the following purposes:

• Providing you with information or services you request, including newsletters and notifications;
• Providing you with information and suggesting programs or services that match your interests and other criteria you have identified, or that we otherwise believe may be of interest to you;
• Streamlining the application process by pre-filling information you have already provided;
• Improving our programs, services, and operations;
• Performing statistical, demographic, and marketing analyses of users of the Site and their behavioral patterns;
• Securing the Site;
• Complying with any procedures, laws, law enforcement orders, and regulations which apply to us where it is necessary for our legitimate interests or the legitimate interests of others; and
• Establishing, exercising, or defend our legal rights where it is necessary for our legitimate interests or the legitimate interests of others.

HOW WE COLLECT YOUR INFORMATION The information we collect about our Site users comes to us in several different ways. While parts of the Site do not require you to provide information that can directly identify you by name (such as if you choose to browse the website without logging in), the specific types of information we collect will depend upon the features you use, how you use them, and the information you choose to provide. Information you provide to us: When you submit a contact form, create an account or complete our student application, you may choose to disclose information about you, including:

• Your name
• Physical address
• Email address
• Phone number
• Date of birth and gender
• Passport information
• Citizenship information
• Criminal background check
• Demographic information
• Medical information
• Academic information and credentials
• Photograph
• Social media account profiles
• Information regarding your interests and interests relating to our programming Financial information for payment of services

Certain pieces of this information may be required to create an account and/or submit an application. We collect limited financial information, such as a credit card number or bank account information for ACH transfer (electronic, bank-to-bank money transfers), as required. User financial information will be transmitted as necessary and required to banks and credit card or other financial transaction means for the processing of such payments to our accounts. Financial information will be maintained by us and the banks, credit card, or other financial transaction processes as necessary and required for the processing of transactions and for auditing, legal, or other similar business purposes. Such financial information will not be transmitted to unrelated third parties and will be encrypted as applicable. Information that is automatically collected: The information we collect automatically includes:

• The Internet domain from which you access our website
• Your Internet Protocol (IP) address
• The type of browser used to access our site;
• The operating system used to access our site;
• The date and time you access our site;
• Time on a page;
• The Universal Resource Locators (URLs), or addresses, of the pages you visit;
• Your username, if it was used to log in to the website;
• If you visited this website from another website, the URL of the forwarding site.
• Whether certain specific actions were taken, i.e. downloading a form.

We may aggregate and/or anonymize any information collected through the Site so that such information can no longer be linked to you or your device. We may use such information for any purpose. Cookies A cookie is a small data file that can be placed on your hard drive when you visit certain websites. Cookies are used to collect and store information, such as the type of computer you are using and how often you log on to a site. Our Site uses both “session cookies,” to improve your navigation across the Site and to remember you over the course of a single visit, and “persistent cookies,” which are stored on your computer until they expire or are deleted and help us provide better service to you over multiple visits to the Site. You can always delete or disable cookies through your browser. If you disable cookies, you may not be able to sign in or take advantage of certain features of the Site that require cookies. We may use cookies to help us deliver marketing campaigns and track their performance. Similarly, our partners may use cookies to provide us with information about your interactions with their services but use of those third-party cookies would be subject to the service provider’s policies. Cookies and other ad technology such as pixels and tags help us market more effectively to users that we and our partners believe may be interested in CT. They also help provide us with aggregated auditing, research, and reporting, and know when content has been shown to you. Third Party Tracking Tools; Google Analytics The Tracking Tools we use include services we obtain from third parties. The information generated by these analytics services will be transmitted to and stored by the third parties and will be subject to their privacy policies. We do not control these third parties’ tracking technologies, how they may be used, or the information they may collect, and we are not responsible for these third parties’ privacy policies. One of the third-party Tracking Tools we use is Google Analytics. The information generated by Google Analytics will be transmitted to and stored by Google and will be subject to Google’s privacy policies. Learn more about Google’s partner services and how to opt out of tracking of analytics by Google. WHEN AND HOW WE SHARE PERSONAL DATA WITH OTHERS Except as described in this Privacy Notice, CT will not share your personal data with third parties, rent or sell its mailing list, or share your personal data with third parties for their direct marketing purposes. Service Providers: We have service providers that perform functions on our behalf, including hosting, content management, customer relationship management, social media integration, marketing, analytics, insurance, billing, online fundraising tools and customer service. These entities may have access to personal data if necessary or useful to performance of their functions. If obtaining such access, these third parties will be subject to confidentiality and security obligations with respect to such data. Partners: CT may share information about you with our partner organizations in order to provide you with information, programs, and services that you have requested or that we believe may be of interest to you. For example, we may share information in the course of evaluating your application or facilitating your placement in a program and to maintain your health and safety during a program. Law Enforcement / Protection: CT reserves the right to share information about you where CT believes, in good faith ,that such disclosure is necessary to comply with a legal requirement, such as a subpoena or court order, or to protect the rights or property of CT, you, or third parties. Consent: CT may share your information in any other manner to which you consent. Business Change: If we become involved in a merger, acquisition, or other transaction involving the sale of some or all of our assets, in contemplation of such a transaction, or in the event of an insolvency or bankruptcy, the information, including personally identifiable information, collected from you through your use of the Sites may be included in the transferred assets. Should such an event occur, we will use reasonable measures to notify you, either through e-mail and/or a prominent notice on the Sites. To promote our participant programs. Feedback, reviews, testimonials and photographic images and videos you provide to us, along with your name and details of your program, may be used for marketing and promotion purposes. LEGAL BASES FOR USING YOUR INFORMATION The laws in some jurisdictions require us to tell you about the legal ground we rely on to use or disclose your information. Where those laws apply, our legal grounds are as follows: To perform our obligations under a contract with you: For example, to comply with the terms of service of our Site, which you accept by browsing and using the Site, or when you register for an account; Consent: Where required by law and in some other cases, we collect and use your information on the basis of your implied or express consent. To further our or our partners’ legitimate interests: For example, to provide security for the Site, operate the Site, comply with legal requirements, and prevent fraud. PROTECTION OF YOUR INFORMATION CT undertakes efforts to guard your personal data against accidental loss and from unauthorized access, use, alteration, and disclosure. We update and test our security technology on an ongoing basis. We restrict access to your personal data to those employees who need to know that information to provide benefits or services to you. In addition, we train our employees about the importance of confidentiality and maintaining the privacy and security of your information. We commit to taking appropriate disciplinary measures to enforce our employees’ privacy responsibilities. Unfortunately, the transmission of information via the internet is not completely secure. Although we take measures to protect your personal data, we cannot guarantee its security. Any transmission of personal information to or using our Site is at your own risk. We are not responsible for circumvention of any privacy settings or security measures contained on the Site. The safety and security of information also depends on you. If we have provided you with (or you have chosen) a username and password for access to certain parts of our Site, you are responsible for keeping such information confidential. Please do not share your username and password with anyone. YOUR CHOICES ABOUT YOUR PERSONAL DATA Our Site allows you to create a profile, including personal information. You may update or correct this information at any time to ensure its continued accuracy. You may also delete your profile by reaching out to using the form in the “Contact Us” page. Additionally, CT provides you choices regarding the way we use the personal data you have provided us. For example, you may sign up to receive newsletters or email notification regarding particular products or services. You may opt out of receiving these optional communications at any time, by clicking the ‘Unsubscribe’ link in the footer of these emails. Please note, some emails like account password resets or legal notices will continue to be emailed regardless of unsubscribe settings. If you would like further information in relation to your legal rights under applicable law or would like to exercise any of them, please reach out to us by using the form in the “Contact Us” page at any time. Your local laws (e.g., in the EU) may permit you to request that we:

• Provide access to and/or a copy of certain information we hold about you;
• Prevent the processing of your information for direct-marketing purposes (including any direct marketing processing based on profiling);
• Update information which is out of date or incorrect;
• Delete certain information which we are holding about you;
• Restrict the way that we process and disclose certain of your information;
• Transfer your information to a third-party provider of services;
• Revoke your consent for the processing of your information

We will consider all requests and provide our response within the time period stated by applicable law. Please note, however, that certain information may be exempt from such requests in some circumstances, which may include if we need to keep processing your information for our legitimate interests or to comply with a legal obligation. We may request you provide us with information necessary to confirm your identity before responding to your request. If you wish to discuss any aspect of our processing of your personal data, please reach out to us by using the form in the “Contact Us” page at any time. DATA STORAGE AND RETENTION Your personal data is stored by CT on its servers, and on the servers of the cloud-based database management services CT engages, located in the United States. The CT retains data for the appropriate amount of time to fulfill the purposes set forth in this Notice unless a longer retention period is required or permitted by applicable law. For more information on where and how long your personal data is stored, please reach out to us by using the form in the “Contact Us” page at any time. CHILDREN’S PRIVACY Our Site is not intended for use by children under the age of 13 in the United States or under 16 in the European Union, and we do not knowingly collect personal information from children under the age of 13 in the United States or under 16 in the European Union. LINKS This Privacy Notice applies only to information collected by this Site and not to other websites that you may link to from here. CT is not responsible for the privacy practices of other sites. Please be aware that when you leave this Site, you should read the privacy policies of other websites that ask you to provide personal data. NOTIFICATION OF CHANGES Any changes to this Privacy Notice will be posted on this Site. Any information that we collect from you will be used in accordance with the version of this Privacy Notice in effect at the time that the information was collected, unless we receive your consent to change our practices with respect to previously collected information. For further information or comments on our Privacy Notice, please contact our data privacy officer via the form provided in the “Contact Us” page.