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Privacy policy for recruitment 

COMODULE OÜ (“COMODULE” "Controller" “we” “us” etc.) is, from time to time, recruiting people for various positions open in COMODULE. It is important that our applicants ("Applicants”) feel safe with, and are informed about, how we handle Applicant's personal data in the recruitment process. We strive to maintain the highest possible standard regarding the protection of personal data. We process, manage, use, and protect Applicant's Personal Data in accordance with this Privacy Policy ("Privacy Policy").

1. General

COMODULE OÜ (12699057; Dunkri 9, Tallinn, Estonia, 10123; privacy@comodule.com: ) is the controller in accordance with current privacy legislations. The Applicants’ personal data is processed with the purpose of managing and facilitating recruitment of employees to our business.

You need to read and accept this Privacy Policy if you want to apply for a job with us. From this Privacy Policy you will learn why and how we use your personal data and for how long we retain the data we collect on you. 

2. Data protection principles

We are committed to process personal data in strict compliance with the General Data Protection Regulation, namely that all personal information processed by us is:

1.      Used lawfully, fairly and in a transparent way.

2.      Collected only for valid purposes that we have clearly explained to you and not used in any way that is incompatible with those purposes.

3.      Relevant to the purposes we have explained you and limited only to those purposes.

4.      Accurate and kept up to date.

5.      Kept only as long as necessary or as specified in our Storage limitation clauses.

6.      Kept secure.  

3. Collection of personal data

We are responsible for the processing of the personal data that the Applicants contribute to us and for the personal data that we collect in other ways in the recruitment process

When and how we collect personal data  We collect personal data about Applicants when Applicants: 

  • make an application through our website or otherwise, including when they personal data about themselves; and
  • connect with our staff, adding personal data about themselves either personally or by using a third-party source such as Facebook or LinkedIn;
  • provide identifiable data in the chat (provided through the website that uses the Service) and such data is of relevance to the application procedure;
  • give us named referees with who we contact and request information about the dates of your previous employment or service, role, responsibilities and performance.

If you have applied for a job we may conduct a simple internet search on you from public information only. Purpose of this is to cross-check and assess your information whether you are good match with our team. We may store any findings as part of your application and inform you of such. You may object to further processing of such data by writing to us using the contact information below.  

The types of personal data collected and processed 

In the course of the recruiting process we collect personal data of Applicants that we need to process for choosing a right person for available positions. Types of personal data we collect are: name and contact information (address, email, phone number), gender, date of birth, education information and information about further qualifications, information about previous experiences, including places of work, position and duration of employment. You may also submit to us your CV or any accompanying letters or documents that may contain further information.

We also will hold some special categories of data about you if you provide us with details about your health, religious beliefs, sexual orientation, political views, marital status, criminal convictions and offences etc. Photos or videos made available to us may indicate information about your ethnical background. Such information will not be processed separately by us.

You have the possibility to include further personal data whereas we will decide of its relevance and inclusion to your applicant’s files.

Only data that is relevant for the recruitment process is collected and processed.

 

Purpose and lawfulness of processing 

The purposes of the collecting and processing of personal data are:

- to manage recruiting process and

- assess your qualifications and skills for available positions

- to be in contact with you during the recruitment process.

- to comply with legal and regulatory requirements

- to offer you a position and negotiate terms of employment.

The purposes of collecting and processing special categories of data are:

-        To assess if we need to take adjusted approach in the recruitment process to consider your special requirements or preferences due to health condition or disability;

-        Use of information about your race, national or ethnical origin, religious-, moral- or political beliefs, sexual orientation or other special data will be used to keep and fulfill justified equal opportunity monitoring and reporting program.

The lawfulness of the processing of personal data is our legitimate interest to simplify and facilitate recruitment and your consent given to us while submitting your application.

By submitting us information you confirm and take responsibility that the provided information is correct and complete, up to date and is not misleading or falsified.

Personal data that is processed with the purpose of aggregated analysis or market research is always made unidentifiable. Such personal data cannot be used to identify a certain Applicant. Thus, such data is not considered personal data.

 

The consent of the data subject 

The Applicant consents to the processing of its personal data with the purpose of Controller handling recruiting. The Applicant consents that personal data is collected when Applicants;

  • make an application through the website or via email, adding personal data about themselves, and that Controller may use external sourcing-tools to add additional information; and
  • when they use the website to connect to Controller’s recruitment department, adding personal data about themselves either personally or by using a third-party source such as Facebook or LinkedIn.

The Applicant consents to the personal data being collected in accordance with the above a) and b) will be processed according to the below sections Storage and transfer and How long the personal data will be processed.

The Applicant also consents to the Controller collecting publicly available information about the Applicant and compiles them for use in recruitment purposes.

The Applicant has the right to withdraw his or her consent at any time, by contacting Controller using the contact details listed under 10. Using this right may, however, mean that the Applicant cannot apply for a specific job.

Automated decision making

Applicant’s personal data  will not be used in automated decision making processes.

Storage and transfers 

The personal data collected in the recruitment process is stored and processed inside the EU/EEA.

How long the personal data will be processed 

If a Applicant does not object, in writing, to the processing of their personal data, the personal data will be stored and processed by us until we have successfully filled the position you have applied for plus 4 months should we need to re-consider your first choice. If you as an Applicant wish not to have your Personal Data processed for this purpose (future recruitment) please contact us using the contact details in paragraph 10.

 

4. Applicants’ rights

Applicants have the right to request information about the personal data that is processed by us, by notifying in writing, us using the contact details below under paragraph 10 below. Applicants have the right to one (1) copy of the processed personal data which belongs to them without any charge. For further demanded copies, Controller has a right to charge a reasonable fee on the basis of the administrative costs for such demand.

Applicants have the right to, if necessary, rectification of inaccurate personal data concerning that Applicant, via a written request, using the contact details in paragraph 10 below.

The Applicant has the right to demand deletion or restriction of processing, and the right to object to processing based on legitimate interest under certain circumstances.

The Applicant has the right to revoke any consent to processing that has been given by the Applicant to Controller. Using this right may, however, mean that the Applicant cannot apply for a specific job.

The Applicant has under certain circumstances a right to data portability, which means a right to get the personal data and transfer these to another controller as long as this does not negatively affect the rights and freedoms of others.

Applicant has the right to lodge a complaint to the supervisory authority regarding the processing of personal data relating to him or her, if the Applicant considers that the processing of personal data infringes the legal framework of privacy law.

5. Security

We prioritize the personal integrity and therefore works actively so that the personal data of the Applicants are processed with utmost care. We take the measures that can be reasonably expected to the make sure that the personal data of Applicants and others are processed safely and in accordance to this Privacy Policy and the GDPR-regulation.

We have measures in place to prevent personal information from accidental loss, unauthorized access, alterations or disclosure.

However, transfers of information over the internet and mobile networks can never occur without any risk, so all transfers are made on the own risk of the person transferring the data. It is important that Applicants also take responsibility to ensure that their data is protected. 

6. Transfer of personal data to third party

We will not sell or otherwise transfer Applicants’ personal data to third parties.

We may transfer Applicants’ Personal Data to;

  • our contractors and sub-contractors, acting as our processors and sub-processors in accordance with our instructions, for the provision of the Service;
  • authorities or legal advisors in case criminal or improper behaviour is suspected; and
  • authorities, legal advisors or other actors, if required by us according to law or authority’s injunction.

We will only transfer Applicants’ personal data to third parties that we have confidence in. We carefully choose partners to ensure that the Applicant’s personal data is processed in accordance to current privacy legislations. We cooperate with the following categories of processors of personal data; server and hosting companies, e-mail reference companies, video processing companies, information-sourcing companies, analytical service companies and other companies with regards to suppling the Service.

7. Aggregated data (non-identifiable personal data)

We may share aggregated data to third parties. The aggregated data has in such instances been compiled from information that has been collected through the Service and can, for example, consist of statistics of internet traffic or the geological location for the use of the Service. The aggregated data does not contain any information that can be used to identify individual persons and is thus not personal data.

8. Cookies

When Applicants use the Service, information about the usage may be stored as cookies. Cookies are passive text files that are stored in the internet browser on the Applicant’s device, such as computer, mobile phone or tablet, when using the Service. We use cookies to improve the Applicant’s usage of the Service and to gather information about, for example, statistics about the usage of the Service. This is done to secure, maintain and improve the Service. The information that is collected through the cookies can in some instances be personal data and is, in such instances, regulated by our Cookie Policy.

Applicants can at any time disable the use of cookies by changing the local settings in their devices. Disabling of cookies can affect the experience of the Service, for example disabling some functions in the Service.

 

9. Changes

We have the right to, at any time, make changes or additions to the Privacy Policy. The latest version of the Privacy Policy will always be available on our website. A new version is considered communicated to the Applicants when the Applicant has either received an email informing the Applicant of the new version (using the e-mail stated by the Applicant in connection to the use of the Service) or when the Applicant is otherwise informed of the new Privacy Policy.

10. Contact

 For questions, further information about our handling of personal data or for contact with us in other matters, please use the below stated contact details; COMODULE OÜ email privacy@comodule.com



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