Privacy - candidates

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Applicant Privacy Policy
Issuer: Orbico Beauty s.r.o. organizačná zložka
Published: 25 May 2018
Validity: 25 May 2018

1. General

1.1. This Applicant Privacy Policy (hereinafter referred to as “Applicant Privacy Policy”) governs the protection of your personal data, as well as your privacy if you applied to a job position in our Company, whether this job position was advertised or not (hereinafter referred to as “you”). This Applicant Privacy Policy is issued by Orbico Beauty s.r.o. organizačná zložka, Kutlíkova 17, Bratislava 5 - 851 02, Reg. No. 318 122 10 (hereinafter referred to as “Company” or “Us”). We act as the controller of your personal data.

1.2. Our range of activities is wide, that’s why we have more privacy policies. This one refers to you as an applicant, but other may apply to you as well (if applying to a job position is not the sole reason of our communication).

2. What personal data do we process?

2.1. We process your personal data which you provided us with in your job application, as well as your personal data that we collected in the recruitment process i.e. the following data:
2.1.1. Your identification data: Name, last name, address and citizenship;
2.1.2. Your contact data: Phone number, E-mail address;
2.1.3. Information about your education and title;
2.1.4. Information about your age and current and previous work experience;
2.1.5. Information about test results (if testing is done as a part of the recruitment process) and our interviews (summary relevant for the job position we are considering you);
2.1.6. Other data that may be relevant for a job position e.g. certificates and other skills.

3. What are the purposes for which we process your personal data?

3.1. We process your personal data for the following purposes:
3.1.1. If you applied for a job position, we process your data to find out if you are the right candidate. In such case, the basis for processing your personal data is our legitimate interest;
3.1.2. If we think you might be the right candidate, we process your data in order to make you an offer and enter into the relevant contract. In such case, the basis for processing your personal data is processing necessary for entering into a contract;
3.1.3. If you applied for a job position, but we have not made you an offer or you rejected our offer, we might process your data for future job positions in our Company. In such case we will separately notify you about such processing and you will be given the opportunity to object. If you do not object, the basis for our processing of your personal data is our legitimate interest;
3.1.4. We might process your personal data for other purposes such as confirming whether the recruitment process was managed fairly and transparently, confirming whether the information you gave us was true, in order to answer to your request or in order to protect our interest in a court or other proceeding. In such case, the basis for our processing of your personal data is our legitimate interest.

4. How do we protect personal data?

4.1. All our personnel accessing your personal data must comply with the internal rules and processes in relation to the processing of personal data to protect them and ensure their confidentiality. They are also required to follow all technical and organisational security measures put in place to protect your personal data.

4.2. We have also implemented adequate technical and organisational measures to protect your personal data against unauthorized, accidental or unlawful destruction, loss, alteration, misuse, disclosure or access and against all other unlawful forms of processing. These security measures have been implemented taking into account the state of the art of the technology, their cost of implementation, the risks presented by the processing and the nature of the personal data, with particular care for sensitive data.

5. Who has the access to your personal data?

5.1. Within the Orbico Group
5.1.1. In limited and necessary instances, we may provide access to personal data by other Orbico companies, to complete the purposes indicated in section above. Access to personal data will only be given to authorised individuals, such as HR managers or IT administrators. Certain executives, managers and employees at other Orbico companies may also have access to certain personal data, only on a need to know basis and if there is a legitimate business purpose.

5.2. Outside the Orbico Group

5.2.1. We may also consider it necessary to transfer personal data to third parties outside the Orbico Group to complete the purposes listed in section above, or as may be required by law, including:
• third party service providers, such as our IT systems providers, our hosting providers, cloud service providers, database providers, consultants (including lawyers, tax accountants, labour consultants) and third parties who carry out pre-employment or preengagement checks on prospective employees - each of these service providers has signed contracts to protect your personal information and are obligated to only use personal data for the specific purposes stated by Orbico;
• any national and/or international regulatory, enforcement or exchange body or court where we are required to do so by applicable law or regulation or at their request.

5.3. Is my personal data transferred to third countries?
5.3.1. If we transfer your personal data to a third country (outside the EEA or other jurisdiction NOT recognized by the EU Commission as providing the adequate level of protection), we previously request your explicit consent to do so or we sign a contract with a specific party that guarantees the same level of protection, i.e. it contains and applies contractual clauses approved by the EU Commission.

6. How long do we keep your personal data?

6.1. Personal data we process based on our legitimate interests are kept as long as there is a legitimate interest and we delete them in a period of one year from when our legitimate interest ceased to exist.

6.2. Personal data that we process based on your consent, we keep as long as we have your consent. In the event of withdrawal of your consent, we will delete your personal data in the shortest possible time. If consent is given for a specific period of time, after the expiration of that period, your data will be deleted as soon as possible, within a reasonable time.

7. Your rights

7.1. You can exercise your rights (see below) by submitting your request to privacy.orbicobeautysk@orbico.com. Please make sure that you (1) enter "Request of the data subject" as the title of the message and in the text tell us (2) who you are so that we can identify  you and (3) what right you want to exercise. Upon receipt of the message, we will send you a confirmation that we have received your request.

7.2. You can exercise your rights free of charge. However, if you frequently request (for example, if you requested to exercise your rights less than 6 months ago) or excessively request (for example, you are looking for all your personal information in writing) access or transfer of your personal data, we have the right to ask you to settle our costs before carrying out such actions.

7.3. Access to your personal data
You have the right to ask for a confirmation that we process your personal data, as well as access to your personal data we process.

7.4. Rectification of inaccurate personal data
You have the right to request the rectification of your incorrect personal data, as well as the right to have incomplete personal data completed.

7.5. Data portability

You have the right to take over and request the transfer of your personal data (when we process your data based on your consent or for the purpose of entering into the contract).

7.6. An objection about the processing or handling your personal data
You have the right to object to the processing of your personal data, as well as our general manner of handling your personal data.

7.7. The right to withdraw the consent
You are entitled, at any time, to withdraw the consent for the further processing of your personal data – but for the personal data that we process based on your consent (and not when we have different legal basis). The withdrawal does not affect the processing carried out on the basis of the consent prior to its withdrawal.

7.8. The right to complaint to the authority
At any time, you have the right to complain to the competent body for the protection of personal data – Úrad na ochranu osobných údajov Slovenskej republiky, www.dataprotection.gov.sk, in relation with processing and protection of your personal data.

8. Changes to the Applicant Privacy Notice

8.1. The Applicant Privacy Notice may be subject to amendments (changes, additions or similar). Any future amendments to how we process your personal data described in the Applicant Privacy Notice will be communicated to you through an appropriate channel, depending on how we normally communicate with you. Be sure to check the actual version published on http://www.orbicobeauty.sk/.

9. Contact

9.1. If you have any questions regarding the processing of your personal data or if you believe your privacy rights have been violated, please address your request to the following address: privacy.orbicobeautysk@orbico.com
Orbico Beauty s.r.o. organizačná zložka, Kutlíkova 17, Bratislava 5 - 851 02