This Privacy Policy provides a framework of understanding about the personal data that are collected by the Data Controller (as defined below), as required by law, including the provisions of the European Union’s General Data Protection Regulation (‘GDPR’). Personal data will be controlled and processed by the Data Controller in accordance with the terms of this Privacy Policy.
This Privacy Policy applies to:
The Privacy Policy describes the types of personal data or personal information we collect, how we use the information, how we process and protect the information, we collect, for how long we store it, with whom we share it, to whom we transfer it and the rights that individuals can exercise regarding our use of their personal data. We also describe how you can contact us about our Privacy practices and to exercise your rights. Our Privacy practices may vary among the countries in which we operate to reflect local practices and legal requirements and you can view specific local terms by going to local websites.
Information We Collect
We may collect personal data about you in variety of ways, such as through our Sites and social media channels; at our events; through phone and mail; through job applications; in connection with in-person recruitment; or in connection with our interactions with clients and vendors. We may collect a selection of personal data dependent on the nature of the relationship, including, but not limited to:
In addition, if you are an associate or job candidate, you apply for a position or create an account to apply for a position, we may collect the following types of personal data:
and where required by law and/or an explicit consent has been provided by you:
In addition, we may collect information you provide to us about other individuals, such as, information related to emergency contacts and the age of your children.
How We Use the Information, We Collect
The Data Controller collects and uses the data gathered for the following purposes (as permitted under local law):
All processing will be carried out based on adequate legal grounds which may fall into a number of categories, including:
In addition to the activities listed above, if you are an associate or job candidate and you apply for a position or create an account to apply for a position, as permitted under local law, we use the information described in this Privacy Policy for the following purposes:
Legitimate Interest
The Data Controller may process personal data for certain legitimate business purposes, which includes some of all of the following:
Whenever we process data for these purposes, we will ensure that we keep your rights in high regard and take account of these rights.
How We Process and Protect Personal Information
We process the personal data we collect, also by automated means, for the purposes defined above and for a specific period of time, which complies with our internal retention policy, in order to ensure that the personal data are not kept longer than necessary.
We maintain administrative, technical and physical safeguards designed to protect the personal data you provide against accidental, unlawful or unauthorized destruction, loss, alteration, access, disclosure or use. In order to ensure the appropriate security and confidentiality of the personal data, we apply to the following security measures:
How long we Store the Data We Collect
We store in our systems the personal data we collect in a way that allows the identification of the data subjects for no longer than it is necessary in light of the purposes for which the data was collected, or for which that data is further processed.
We determine this specific period of time by taking into account:
Information We Share
We do not disclose personal data that we collect about you, except as described in this Privacy Policy or in separate s provided in connection with particular activities. We may share personal data with vendors who perform services on our behalf based on our instructions. We do not authorize these vendors to use or disclose the information except as necessary to perform services on our behalf or comply with legal requirements. We also may share your personal data (i) with our subsidiaries and affiliates; (ii) if you are a job candidate, with clients who may have job opportunities available or interest in placing our job candidates; and (iii) with others with whom we work, such as job placement consultants and subcontractors, to find you a job.
In addition, we may disclose personal data about you (i) if we are required to do so by law or legal process; (ii) to law enforcement authorities or other government officials based on a lawful disclosure request; and (iii) when we believe disclosure is necessary or appropriate to prevent physical harm or financial loss, or in connection with an investigation of suspected or actual fraudulent or illegal activity. We also reserve the right to transfer personal data we have about you in the event we sell or transfer all or a portion of our business or assets (including in the event of a reorganization, dissolution or liquidation).
Data Transfers
We also may transfer the personal data we collect about you to countries outside of the country in which the information originally was collected. Those countries may not have the same data protection laws as the country in which you initially provided the personal data. When we transfer your information to other countries, we will protect that data as described in this Privacy Policy and such transfers will be in compliance with applicable law.
Your Rights as Data Subject
When required by applicable law, a data subject can exercise following rights:
a) Right of access: A data subject has the right to access his or her personal data concerning which in order to verify that his or her personal data is processed in accordance to the law.
b) Right to rectification: A data subject has the right to request the rectification of any inaccurate or incomplete data held about him or her, in order to protect the accuracy of such information and to adapt it to the data processing.
c) Right to erasure: A data subject has the right to request that the Data Controller erases information about him or her and to no longer process that data.
d) Right to data portability: The data subject has the right to request the data portability meaning that the data subject can receive the originally provided personal data in a structured and commonly used format or that the data subject can request the transfer of the data to another Data Controller.
e) Right to lodge a complaint: If you have any inquiries regarding how we process your personal data, or would like to lodge a complaint, please contact us by using the form below. If you lodge a complaint our data Privacy Policy officer will get in touch with you. You also have the right to lodge a complaint with a supervisory authority if you consider that the processing of personal data infringes GDPR.
Whenever the processing is based on the consent, the data subject may withdraw their consent at any time.
Updates to Our Privacy Policy
This Privacy Policy may be updated periodically to reflect changes in our Privacy practices and legal updates. For significant changes, we will notify you by posting a prominent notice on our sites indicating at the top of each Policy when it was most recently updated.
How To Contact Us
If you have any questions or comments about this Privacy Policy, or if you would like to exercise your rights, please contact us using one of the methods indicated on the Feedback page of the Site or using the contacts indicated on the Site.
Address: 77-A Volodymyrska St., 01033 Kyiv, Ukraine