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GROUP SENIOR ACCOUNTANT @ Sun Finance Recruitment

Privacy policy


Last updated on 12.11.2019.

The purpose of this Privacy policy is to inform you about how Personal data (as defined below) will be processed by the Company. You must read this Privacy policy carefully before you submit your Personal data to the Company. If you do not agree with the procedure of Personal data processing described herein, you must not submit any Personal data to the Company.


1.1.    Affiliate (also Affiliates) – any entity that directly or indirectly controls, is controlled by or is under common control with the Company.

1.2.    Application - Application submitted by the Candidate directly or indirectly to apply for a job vacancy with the Company. Term “Application” includes any and all submitted documents and information (including, but not limited to CV).

1.3.    Candidate – at least one of the following persons:

(a) natural person, who directly applies for a job vacancy with the Company and/or Affiliate; or

(b) Referral.

1.4.    Controller - natural or legal person, public authority, agency or other body which, alone or jointly with others, determines the purposes and means of the Processing of Personal data.

1.5.    Company (also “we”) - AS "Sun Finance Group", registration Nr. 40203205428, legal address: Skanstes iela 52, Riga, LV-1013.

1.6.    DPO (Data Protection Officer) – person appointed by the Controller and who supervises compliance of Processing with the applicable laws in the undertaking.

1.7.    EU/EEA – European Union/ European Economic Area.

1.8.    GDPR – Regulation (EU) 2016/679 of the European Parliament and of 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).

1.9.    Group (also “Sun Finance Group”) – “Sun Finance” Group of undertakings that consists of the Company and its Affiliates.

1.10. Personal data - any information that relates to the identified and/or identifiable natural person (data subject).

1.11. 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, storage, alteration, use, disclosure, erasure, etc.).

1.12. Referral – Candidate who indirectly submits the Application to the Company. “Indirect submission” means the situation when the Application is submitted to the Company via “Refer a Friend” option by a person other that the Candidate him/herself.

1.13. Special Categories of Personal Data – data revealing racial or ethnic origin, political opinion, religious or philosophical belief, trade union membership, genetic data, biometric data, data concerning health, data concerning sex life or sexual orientation.

1.14. Supervisory authority – independent public authority which is responsible for monitoring the application of the GDPR in the EU/EEA member state.

1.15. Terms and Conditions - Terms and Conditions on applying for a job vacancy published under the online application form.

1.16. You – at least one of the following persons:

(a)   Candidate; or

(b)   person who submits the Application on behalf of the Candidate, using “Refer a Friend” option.


1.1.   The Company is the Controller of Personal data, meaning that it defines the purposes of Processing (i.e., “why” Personal data are processed) and means of Processing (i.e., “how” Personal data are processed).

1.2.   The Company has appointed a DPO, who can be contacted with about all matters related to the Processing conducted by the Company.

1.3.   All contact details are indicated in Clause 12 below.


We process Personal data for several purposes and based on several legal bases indicated below:

2.1. Purpose: Assessing Candidate’s suitability for a job vacancy.

Legal basis:

(a)   Candidate’s consent in relation to the information/Personal data submitted by the Candidate directly or indirectly.

(b)   Company’s legitimate interest in relation to the information/Personal data collected by the Company independently (Company’s legitimate interest is to assess, whether the Candidate is suitable for the job vacancy).

2.2. Purpose: Protecting Company’s and/or Affiliate’s legitimate interest in case of a legal dispute

Legal basis: Company’s and/or Affiliate’s legitimate interest to protect its rights and legitimate interests in case of a legal dispute.

2.3. Purpose: Internal administrative purposes and organizational management

Legal basis: Legitimate interest in administrating and managing internal human resources (HR) and recruitment matters centrally on a group level.

2.4. Purpose: Assessing Candidate’s suitability for a vacancy that can be available in the future and contact the Candidate about such vacancy

Legal basis: Candidate’s consent (a candidate may freely choose, whether to allow the Company to keep his/her Personal data and contact him/her if there is an open vacancy with the Company or the Affiliate).

2.5. Purpose: Complying with Company’s and/or Affiliate’s legal obligation if the applicable laws provide for an obligation to process Personal data.

Legal basis: Compliance with the legal obligation to which the Company and/or Affiliate is subject.


3.1. The Company receives information about the Candidate in two ways:

(a)   directly from the Candidate, when he/she fills-in and submits the Application;

(b)   indirectly from the Candidate, when:

(i)  the Application is submitted by the other person on Candidate’s behalf (upon his/her consent); and/or

(ii) the Company independently collects the information about the Candidate.

3.2. In order to collect the information necessary for the assessment of Candidate’s suitability for the job, the Company is entitled to:

(a)   contact Candidate’s ex-employers, asking for a reference (Candidate can provide a list of ex-employers whom he/she would like the Company to contact with);

(b)   look into the information/Personal data published in Candidate’s social media accounts (for instance, LinkedIN);

(c)    fulfill a practical task; and/or

(d)   ask the Candidate to provide additional information.


4.1. We will process the following categories of Personal data:

(a)   Name, surname;

(b)   Contact details (phone number, e-mail address);

(c)    Information about your working experience;

(d)   Information about your education;

(e)   Information related to the recruitment process and communication with you (for instance, interview dates, results of the interview, results of practical tasks, etc.);

(f)    Other information that you indicate in CV or other submitted documents;

(g)   Other information that is necessary to assess Candidate’s suitability for the job vacancy.

4.2. Please make sure that Candidate’s Application (including, but not limited to, CV) includes only such information that is relevant to the assessment of Candidate’s suitability for the job. You are responsible for the content and scope of information and Personal data that you submit. The act of submission of the information and Personal data is considered Candidate’s consent for Processing according to the purposes listed above.

4.3. We do not need your personal code at this stage, therefore, please make sure that CV/other submitted information does not contain it. Please also do not submit any Special Categories of Personal Data as well as any information concerning pregnancy, family or marital status, previous conviction (if we are obliged by law to process such information, we will inform you about it separately), religious conviction or belonging to a religious denomination, affiliation with a political party, employee trade union or other public organization, national or ethnic origin.

4.4. We may ask the Candidate to submit information on his/her state of health and occupational preparedness if it is of significance for entering into an employment contract and for performance of the intended wok. In this case the Candidate will be informed about it individually.


5.1. If it is legally justified in each particular case, your Personal data may be disclosed to the following recipient categories:

(a)   Company’s employees and officials, who are involved in the recruitment process;

(b)   Affiliates;

(c)    Service providers (Processors and other controllers) that provide certain services to the Company or Affiliates (for instance, IT services, data storage services, e-mail service providers, etc.);

(d)   Competent state institutions (for instance, the Supervisory authority, court, etc.);

(e)   Other recipients, if there is an appropriate legal basis and purpose.

5.2. We mainly process Personal data within the EU/EEA. However, when using Service providers or sharing information with the Affiliates, transfer of Personal data outside of the EU/EEZ may occur. In this case we will ensure that all GDPR requirements on transfers of Personal data outside the EU/EEZ are complied with. You can receive more detailed information by addressing us, using the contact details indicated in this document.


6.1. Personal data and other information about you will be included and stored in the Group-wide recruitment data base shared among the Company and the Affiliates.

6.2. If the Company and/or its Affiliate has another open vacancy that is available at the time when the Candidate directly/indirectly submits the Application, the Company may use the submitted information to evaluate Candidate’s suitability also for such other vacancy available at the time.

6.3. Your Personal data will be processed as long as the competition for the job the Candidate applies for is open. In case the Candidate was not recruited as an employee with the Company or Affiliate, your Personal data will be stored for 4 (four) months from the date, on which you received a refusal letter according to the procedure stipulated in the Terms and Conditions. In case the Candidate was recruited as an employee, your Personal data will be stored according to our retention terms, which will be presented to the Candidate at the later stage.

6.4. Your Personal data can be stored for a longer period if there is an appropriate legal basis and purpose (for instance, in case there is a dispute between you and the Company, necessity to protect Company’s legitimate interest, etc.).

6.5. You may choose to allow us to retain your Personal data also to assess your suitability for a vacancy that may be available with the Company and/or Affiliate in the future and to contact you about such job vacancy. In this case your Personal data will be retained until you revoke your consent but not longer than for 3 (three) years from the day, on which the consent was given.

6.6. In any case, the Company will process (including storing) your Personal data, considering Personal data Processing principles provided in the GDPR Article 5 (for instance, storage limitation principle, data minimization principle, etc.).


7.1. Under the GDPR you (as the data subject), in respect of your Personal data have the right to request from the Controller (Company) access to and rectification or erasure of Personal data or restriction of processing concerning the data subject or to object to processing as well as the right to data portability. You also have the right to revoke the consent at any time, if the Processing is based on consent as the legal basis (NB! Revocation of consent does not affect lawfulness of processing based on consent before its withdrawal).

7.2. You can exercise the aforementioned rights by addressing the Company or its DPO, using the contact information indicated in Clause 12 below.

7.3. Please note that not all of the said the rights are absolute - applicable laws provide for several exemptions and limitation to the exercise thereof.


If you believe that your Personal data are processed in violation of the applicable laws, you can submit your complaint to the Company or its DPO, using the contact information indicated herein, or to the Supervisory authority (Data State Inspectorate in case of Latvia).


It is up to you to decide whether you are willing to apply for a job with us. If you do wish to apply, then you must provide the requested information about you, otherwise we will not be able to evaluate your suitability for the job.


Neither automated-decision making, nor profiling takes place to assess your suitability for the job.


The Company can make changes to this Privacy policy at any time. In case of any material changes the Company may notify you about such changes, using the contact information provided by you.


12.1. Company’s contact information:

(a) E-mail: [email protected]

(b) Legal address: Please see Clause 1.5. of the Privacy policy.

12.2. DPO’s contact information:

(a) E-mail address: [email protected]