We respect your privacy and are committed to protect your personal data and processing in compliance with applicable laws including but not limited to Regulation (EU) 2016/679) of the European Parliament and the Council of 27 April 2016 on the protection of natural persons with regard to the processing of personal data and on the free movement of such data, and repealing Directive 95/46/EC (General Data Protection Regulation) – the “GDPR”.
- Who We Are
- The Company acknowledges that, in collecting Your Personal Data, We are bound by the laws of Romania and Bulgaria respectively and will process Your Personal Data in accordance with the GDPR. For any further request or query about how We use Your Personal Data, You may address Our Data Protection Officer through the following email address: email@example.com.
- Any notice, demand, request or other communication which You address to the Company shall be sent by e-mail to firstname.lastname@example.org. All communication done by e-mail shall be deemed received on the business day following the day of transmission.
Capitalised terms in this Policy shall have the meaning assigned to them under the GDPR and shall be construed accordingly. Furthermore, the following definitions shall apply:
- User– accesses and browses the Website (‘You’, ‘Your’) in order to use the Service;
- Service – the service of recruiting and hiring
- Subject Matter
- Principles of Data Processing
We fully respect Your fundamental rights and consider protection of Your Personal Data to be a priority. Accordingly, when processing Your Personal Data, We follow the following basic principles:
- We submit Your Personal Data only for lawful and fair processing, and We maintain full transparency vis-à-vis the way We handle Your Personal Data;
- We process Your Personal Data only to the extent that it is necessary and appropriate to purposes for which it is collected;
- We make reasonable efforts to ensure that Your Personal Data is accurate and, where necessary, updated with regard to the purposes of the processing, taking all reasonable steps to immediately delete or correct it in case of inaccuracy; and
- We process Your Personal Data in a manner that guarantees its security by using appropriate technical and organizational measures.
In general, We comply with all applicable laws statutory obligations, as Data Controller of Your Personal Data.
- Collection of Personal Data
The Company may collect personal data about Users when Users;
- Submit an application through the Website, including any Personal Data in the User’s curriculum vitae and covering letter;
- Add Personal Data through third party platforms such as LinkedIn, Facebook and other public platforms.
- Types of Personal Data Collected
The Company may collect and process the following Personal Data. You are under no obligation to provide Personal Data. Provided that, certain Personal Data is essential for the provision of the Services we offer and we might not be able to carry out the Service if you do not provide the information required.
Personal Data upon access to the Website and submission of application:
- Full name, age, e-mail address and phone number.
- Technical Data, including internet protocol (IP) address, browser type and version, browsing actions and patterns, time zone and location, information about operating system, platform and other technologies on the devices you use to access our Websites.
- Usage Data, including information about how you use our Platform and/or Website.
- Device Data: We collect information from the device you use to access our Website. This includes IP address, language, device model, device operating system version.
- Profile data such as your interests and preferences based on our profiling activity, and your replies to survey. This information may include Personal Data we hold about You.
- Information from Linkedin, Facebook, Twitter and other social media platforms
- Any Personal Data provided in a Curriculum Vitae document & Cover letter.(I) Identity Data and Contact Data and Profile Data.
- Purposes and Legal Basis for Data Processing
The Company processes Your Personal Data to manage the recruitment process, to comply with its legal obligations and for the Collection, processing and performing statistical and other research and analysis of information for enhancement of the Service;
You have the right to withdraw Your consent to Our processing of Your Personal Data at any time in writing to Our contact details mentioned in this Policy. Withdrawal of Your consent does not affect the lawfulness of the treatment of Your Personal Data prior to its revocation.
- Aggregated Data
Aggregated data is non-identifiable personal data which would be data compiled through the Service. Aggregated data can consist of statistical or demographic data but does not used to identify individual persons and is not personal data.
- Data Recipients
The Personal Data collected through the Service is securely stored in the Company’s Website database and sent to the Human Resources Department via e-mail. Your Personal Data may be shared with other companies who support Us in managing and administering the recruitment process. Some of Our key service providers are Grepfrut SRL, a Romanian entity and Jobvite. Jobvite is located in the United States of America and is engaged by Us to help manage the recruitment and hiring process.
Whenever We engage other companies to process Your information outside of the European Economic Area, We recognise that they may not have the same standard of data protection as set out in GDPR. In those situations, We will always seek to ensure that an adequate level of protection of Your Personal Data is provided based on the existence of one of the following:
- The European Commission has determined that the respective third country, territory or a specified sector within that third country provides an adequate level of protection for data transfers; or
- The Service provider to who Your personal data is to be transferred provides appropriate safeguards and measures such as the use of standard contractual clauses approved by the EU Commission.
In the event that We are required by a court or other administrative authority, pursuant to an investigation relating to unlawful activities such as money laundering and in any other case that We are legally bound to do so, the Company may transfer Your Personal Data to public authorities to the extent specified by applicable law.
- Data Security and Confidentiality
In order to ensure the proper use and integrity of Your Personal Data and to prevent unauthorised or accidental access, processing, deletion, alteration or other use, the Company applies appropriate internal policies and takes all appropriate organizational, technical and procedural security measures, as well as technical standards, in accordance with applicable laws and regulations.
The processing of Your Personal Data by the Company is conducted in a manner that ensures confidentiality and security, taking into account the latest developments, implementation costs and the nature, scope, context and purposes of the processing, as well as the risks for Your rights and freedoms, which are applicable in each circumstance.
Your Personal Data is processed solely by authorised personnel of the Company, bound by strict obligations of confidentiality.
- Retention of Personal Data
We retain Your Personal Data for twenty-four (24) months from the date Your application is submitted on the Jobvite portal (“retention period”).At the lapse of the retention period, or if You request us to do so earlier, all of Your Personal Data will be deleted permanently.
Furthermore, the Company may retain Your Personal Data after the expiration of the relevant processing purposes in the following limited cases:
- In case that there is a legal obligation under a relevant statutory provision.
- In case of any claims against the Company, for as long as necessary to defend Our rights and legitimate interests before any competent court and any other public authority.
After the period of retention, Your Personal Data is erased from Our databases and systems.
For more information about data retention terms in relation to specific Personal Data, please contact Us at email@example.com.
- Your Rights
You have the right:
- To request access to Your Personal Data and information related to their processing and obtain a copy thereof.
- To request for the rectification of any inaccuracies or any of your missing Personal Data.
- To request for the erasure of Your Personal Data.
- To request for the restriction of the processing of Your Personal Data in cases explicitly provided for by law.
- To request for the portability of Your Personal Data to another Data Controller in a structured, commonly used and machine-readable format.
- To object to the processing of Your Personal Data in cases explicitly provided for by law.
- To object to a decision taken solely on the basis of automated processing, including profiling, which has impact on You or significantly affects You.
Any requests relevant to this Section 12 must be addressed in writing to firstname.lastname@example.org.
We will respond to any of Your requests within one (1) month from their receipt. Upon prior notice, this period may be extended by a further two (2) months if necessary, taking into account the complexity of the request and the number of any other pending requests. In case of rejection of Your request, We will provide relevant justification.
If Your request does not meet the requirements of applicable law, We reserve the right either to: (a) impose a reasonable fee, taking into account the administrative costs of providing the information or communicating or executing the requested action, or (b) reject Your request.
If there are any doubts as to the identity of the individual submitting the request, We reserve the right to request the provision of additional information necessary to confirm their identity.
If Your rights are infringed, You have the right to file a complaint with the National Supervisory Authority for Personal Data Processing at the following website: https://www.dataprotection.ro/index.jsp?lang=en&page=home
- Your Obligations
By providing Your Personal Data when submitting a job application with Us, You acknowledge that You are required to provide Your actual, accurate and complete data as requested by the Company. Furthermore, You must inform Us of any changes to Your information so as to ensure it is kept up-to-date and accurate.