Candidate Privacy Policy

1. INTRODUCTION.

This Candidate Privacy Policy (hereinafter the "Policy") establishes the rules of Uniquent Malta Limited, the legal entity incorporated under the laws of Malta, registration number C102864, having its registered office at Level 3 (Suite No. 2998), Tower Business Centre, Tower Street, Swatar, Birkirkara BKR 4013, Malta; and Uniquent Holding Limited, the legal entity incorporated in the Republic of Cyprus, with its registration number HE430003, with its registered address at Archaias Lidras, 7 Geri, 2200, Nicosia, Cyprus (hereinafter the “Company”, “We”, “Us”, “Our”) in relation to the processing of personal data.

For the purposes of this Policy, the word "data" shall also mean "personal data" as defined by Article 4(1) of the GDPR, unless the context means otherwise.

The Company include two joint data controllers for the processing of your personal data in the hiring process.

2. PURPOSES OF THE POLICY.

The purpose of this Policy is to explain how we collect and process your personal data in the hiring process and give you information about the rights you have in relation to your personal data.

3. DEFINITIONS.

Data Subject: the individual, business, or other entity about which Personal data is collected. In the case of this Policy, the data subject is you, the Candidate.

Personal data: any information relating to an identified or identifiable natural person (‘data subject’); an identifiable natural person is one who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person.

For the purposes of this Policy, the word "data" shall also mean "personal data" as defined above and in Article 4(1) of the GDPR, unless the context means otherwise.

Processing of Personal data (“processing”): any operation or set of operations which is performed on personal data or on sets of personal data, whether or not by automated means, such as collection, recording, organization, structuring, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, alignment or combination, restriction, erasure or destruction.

Third Party: a natural or legal person, public authority, agency or body other than the data subject, controller, processor and persons who, under the direct authority of the controller or processor, are authorized to process personal data.

4. YOUR RIGHTS.

The Applicable Data Protection Laws, including the General Data Protection Regulation (“GDPR”), provide certain rights to individuals in relation to their personal data. Accordingly, we are happy to offer transparency and access controls to help users take advantage of those rights.

Your principal rights under the GDPR are:
- the right to be informed.
You have the right to be informed about the collection and use of Your Personal data. The Company is providing detailed information about the purposes, methods and means of our processing of Your Personal data in this Policy.

For more information, please read Article 13 and Article 14 of the GDPR.

- the right to access.
You have the right to confirmation as to whether or not the Company Processes Your Personal data and, where the Company does, access to the Personal data, together with some additional information, which includes details of the purposes of the Processing, the categories of Personal data concerned and the recipients of the Personal data.

For more information, please read Article 15 of the GDPR.

- the right to rectification.
Should Your Personal data be inaccurate, You have the right to rectification and, considering the purposes of the Processing, to have any incomplete Personal data about You properly completed.

For more information, please read Article 16 of the GDPR.

- the right to erasure (“the right to be forgotten”).
In some circumstances, You have the right to the erasure of Your Personal data without undue delay, except for the cases of compliance with legal obligation, establishment, exercise or defense of legal claims.

For more information, please read Article 17 of the GDPR.

- the right to restrict processing.
In some circumstances, You can exercise the right to restrict the Processing of Your Personal data with subsequent right of the Company to process it only on the basis of Your consent, for the establishment, exercise or defense of legal claims; for the protection of the rights of another natural or legal person; or for reasons of important public interest.

For more information, please read Article 18 of the GDPR.

- the right to data portability.
You have the right to receive Your Personal data from the Company in a structured, commonly used and machine-readable format in case the legal ground for the Company’s processing of Your Personal data is Your consent, legitimate interest to perform of a contract to which You are party, or legitimate interest to take steps at Your request prior to entering into a contract.

For more information, please read Article 20 of the GDPR.

- the right to object processing.
You have the right to object to our Processing of Your Personal data for direct marketing purposes (including profiling for direct marketing purposes). If You make such an objection, the Company will cease to Process Your Personal data for this purpose.

For more information, please read Article 21 of the GDPR.

- rights related to automated decision-making including profiling.
You have the right to object, in certain cases, to processing by means of automated decision-making including profiling.

For more information, please read Article 22 of the GDPR.

Important: please note that these rights are subject to restrictions and exceptions as stipulated in the GDPR and/or Applicable Data Protection Laws and as such, this list serves as an illustrative example and is not intended to be exhaustive.

If you want to exercise any of your other rights, or if you have any questions about how we
process your personal data, please contact us by emailing [email protected].

5. COLLECTED PERSONAL DATA.

When you apply for a job, the types of information we collect and process may include, but
are not limited to, the following categories:

  • Contact information: your name, email address, phone number, city, country, and any other contact information provided by you;
  • Background details: your CV or resume, including cover letter, academic qualifications, work experience, transcripts, and/or similar;
  • Reference information and information received from background checks (if applicable for the position you have applied for, and as permitted by applicable laws);
  • Information required to prepare the contract: date of birth, address, personal identification number and registration details;
  • Interview information: details from interviews and outcomes of any recruiting exercise you complete, including tests;
  • Employment information: information about the type of employment you are looking for or may be interested in, including targeted compensation, benefits and other job
  • preferences;
  • Publicly available information: profile information, academic qualifications and work experience from publicly available sources relevant for the hiring process, e.g. your LinkedIn profile; and
  • Any other information provided by you within the interview.

6. PURPOSES OF COLLECTING PERSONAL DATA.

We will use the information we collect about you for the following purposes:

  • To communicate with you throughout the hiring process;
  • To assess your qualifications, skills, and suitability for the considered job;
  • To verify your information and carry out reference checks;
  • To prepare your contract if you are offered a job at the Company;
  • To comply with applicable laws, regulations, legal processes or enforceable governmental requests.
  • To add you to our talent base and communicate with you for other future positions.

7. LEGAL BASIS FOR THE PROCESSING.

When you apply for a role at the Company, we process information about you in order to take steps necessary to enter into a possible contract with you.

Further, we collect and process information about you as necessary for our legitimate interest to assess if you are suitable for the position you have applied for at the Company and also to understand, maintain and improve our hiring process.

In case you have consented to, we collect and process information in our HR system in order to add you to our talent base and communicate with you for other future positions.

8. SHARING YOUR PERSONAL DATA.

We share your personal data with other companies in the group in order to carry out the activities specified in this Policy. We may also transfer your personal data to third party service providers such as recruiters and providers of recruiting tools.

Where personal data collected within the EU/EEA is transferred to and processed by third parties located in a country outside of the EU/EEA, the Company ensures that the transfer of your personal data is carried out in accordance with Applicable Data Protection Laws and, in particular, that appropriate contractual, technical, and organizational measures are in place such as the Standard Contractual Clauses approved by the EU Commission.

9. DATA SECURITY AND INTEGRITY.

The Company will take reasonable precautions to protect Personal data in its possession secure against the risk of loss, misuse, unauthorized access, disclosure, alteration and destruction.

The Company periodically reviews its security measures in an effort to ensure the privacy of Personal data.

The Company will take reasonable precautions to ensure Personal data is used only in ways that are compatible with the purposes for which the data was collected or subsequently authorized by the You. While the Company will take reasonable steps to ensure that Personal data is relevant to its intended use, accurate, complete, and current, the Company also relies upon you to assist in providing accurate updates of your Personal data.

10. DATA RETENTION AND DELETION.

If you are successful in your job application, relevant information we collect about you during the hiring process will become a part of your record and retained in accordance with our privacy policies for staff data.

If your application is unsuccessful, we retain your personal data for as long as necessary to comply with our legal obligations, but no more than 10 (ten) years.

11. CONTACT INFORMATION.

Thank you for reading our Policy. If you have any questions about this Policy, please contact us by emailing [email protected].

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