Privacy policy
PRIVACY POLICY FOR THE SUBMISSION AND EVALUATION OF APPLICATIONS
Last updated on 16.01.2020.
1. INTRODUCTION
1.1. We are committed to protecting your privacy. This privacy policy (“Privacy Policy”) describes why and how we collect and use Personal data and provides information about individuals’ rights.
1.2. Personal data is any information relating to an identified or identifiable living person. When we use “you” or “your” in this Privacy Policy, we are referring to the relevant individual who is the subject of the Personal data.
1.3. We process Personal data in accordance with applicable legislation, including the 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) ("GDPR") and the applicable national data protection laws.
2. TERMS
2.1. Application - application submitted by the Candidate to apply for a job vacancy at Sonarworks. Term “Application” includes any and all submitted documents and information (including, but not limited to CV).
2.2. Candidate (also “you”) - a natural person, who directly applies for a job vacancy at Sonarworks.
2.3. Sonarworks (also “we”) - SIA "Sonarworks", registration Nr. 40103611667, legal address: Smerla street 3, Riga, LV-1006, Latvia.
2.4. Personal data - any information that relates to the identified and/or identifiable natural person (data subject).
2.5. 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.).
2.6. Terms and Conditions - Terms and Conditions on applying for a job vacancy published under the online application form.
3. SONARWORKS ROLE IN THE PROCESSING
Sonarworks 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).
4. PURPOSE OF PROCESSING
We process your Personal data for the following purposes to:
- screen and select employees by evaluating your suitability for employment with Sonarworks, including through interviews, assessments and conducting background checks;
- hire and onboard employees by making an offer to the successful candidates and carrying out pre-employment screening checks.
5. LEGAL BASIS FOR PROCESSING
The legal basis for Processing your Personal data for the purposes mentioned above are the following:
- in connection with recruitment activities, we process your Personal data for our legitimate interests to attract and hire the best candidate to work with us;
- if you are a successful candidate and we are planning to conclude an employment contract with you, we process your data to take steps at your request prior to entering into a contract;
- we may process your Personal data also for compliance with the legal obligation if the applicable laws provide for an obligation to process Personal data.
6. CATEGORIES OF PERSONAL DATA
6.1. Personal data we process for the purposes of recruitment activities are the following:
- name, date of birth, nationality;
- contact details: email address(es), telephone number(s), postal address;
- professional experience and knowledge, such as job experience, education, academic and professional qualification included in CVs, motivation letter and publicly available information (such as LinkedIN);
- areas of interest: hobbies etc., if you have indicated it in your CV or motivation letter;
- any information provided as references from the referees whose contact information you have provided via email;
- interview and assessment results and feedback;
- bank account details if your Application is successful.
6.2. Provision of Personal data is required for examination of your Application and, if applicable, conclusion of an employment contract. Without Personal data, an Application cannot be considered.
6.3. We do not process special categories of Personal data, i.e., 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. Therefore please do not provide us with any special categories of Personal data as well as any information concerning pregnancy, family or marital status, previous conviction, religious conviction or belonging to a religious denomination, affiliation with a political party, employee trade union or other public organization, national or ethnic origin. If we are obliged by law to process such information, we will inform you about it separately.
7. DATA RETENTION
7.1. Your Personal data will be processed as long as the hiring process for the job you apply for is open. In case you were not recruited as an employee at Sonarworks, your Personal data will be stored for 12 (twelve) months from the date, on which you received a refusal letter according to the procedure stipulated in the Terms and Conditions. In case you were recruited as an employee, your Personal data will be stored according to our retention terms for Processing employees’ Personal data.
7.2. 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 Sonarworks, necessity to protect Sonarworks’ legitimate interest, etc.).
7.3. You may choose to allow us to retain your Personal data also to assess your suitability for a vacancy that may be available with Sonarworks 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.
8. RECIPIENTS OF PERSONAL DATA
8.1. Recipient of your Personal data primarily is Sonarworks and its respective employees.
8.2. To be able to offer you the best possible services and remain competitive in our business, we share certain data with other organizations. As a result, your Personal data may be transferred outside the countries where we or the data subject is located. This includes countries outside the European Union (“EU”).
8.3. We use contractual arrangements and security mechanisms as appropriate to protect the data and to comply with applicable laws including GDPR.
8.4. Where we transfer Personal data outside the EU to a country not determined by the European Commission as providing an adequate level of protection for Personal data, the transfers will be under an agreement which covers the EU requirements for the transfer of Personal data outside the EU, such as the European Commission approved standard contractual clauses. Please contact us to receive more detailed information about our processors!
8.5. Personal data processed by us may be transferred to:
- Third party organizations that provide applications/functionality, data processing or IT services to us or otherwise assist us in providing goods, services or information.
We use third parties to support us in providing our services and to help provide, run and manage our internal IT systems. For example, providers of information technology, cloud based software as a service providers, identity management, website hosting and management, data analysis, data back-up, security and storage services, as well as organizations which provide us marketing activities or events and manage customer communications, prepare reports and statistics, printing materials and designing products, place advertisements on apps, websites and social media.
- Auditors and professional advisers.
We may share your data with our auditors if it is necessary for the provision of audit, with professional advisers, for example, law firms, as necessary to establish, exercise or defend our legal rights and obtain advice in connection with the running of our business.
- Government authorities.
To comply with our regulatory obligations we may disclose data to the relevant authorities to check that we are complying with applicable law and regulation, for example supervisory authorities, tax authorities, judicial/investigative authorities such as police, public prosecutors, courts on their express and legal request.
8.6. In all of these cases, we ensure the third parties can only access Personal data that is necessary for their specific tasks.
9. INDIVIDUALS’ RIGHTS AND HOW TO EXERCISE THEM
9.1. You as a data subject have certain rights over your Personal data and we as a controller of Personal data are responsible for fulfilling these rights. Please see below further information about these rights, when they are available and how to exercise them.
9.2. Your right of access to Personal data
You have the right to obtain a copy of your Personal data as well as other supplementary information. It helps you to understand how and why we are using your data, and check we are doing it lawfully.
9.3. Your right to rectification/amendment of Personal data
You have the right to request for your Personal data to be amended or rectified where it is inaccurate (for example, if you change your name or address) and to have incomplete Personal data completed.
9.4. Your right to erasure/right to be forgotten
9.4.1. You have the right to have Personal data erased, but this right is not absolute and only applies in certain circumstances.
9.4.2. You have the right to have your Personal data erased if:
- the Personal data is no longer necessary for the purpose which we originally collected or processed for;
- we are relying on consent as legal basis for holding the data, and you withdraw your consent;
- we are relying on legitimate interests as legal basis for Processing, and you object to the Processing of your data, and there is no overriding legitimate interest to continue this Processing;
- your Personal data have been processed unlawfully;
- your Personal data must be erased to comply with a legal obligation which we are subject to.
9.5. Your right to restrict the Processing
You have the right to restrict the Processing of your Personal data, that is, to limit the way that we use your data, in the following circumstances:
- for a period enabling us to verify the accuracy of your Personal data where you have contested the accuracy of the Personal data;
- the data has been unlawfully processed and you request restriction instead of erasure;
- when your Personal data are no longer necessary in relation to the purposes for which they were collected and processed you can request restriction to establish, exercise or defend legal claims;
- for a period enabling us to verify whether the legitimate interests relied on by us override your interests where you have objected to the Processing based on legitimate interests.
9.6. Your right to object to Processing
9.6.1. The right to object to the Processing allows you to ask us to stop the Processing your Personal data.
9.6.2. You have the absolute right to object to the Processing of your Personal data if it is for direct marketing purposes.
9.6.3. You have the right to object to the Processing of your Personal data also when there are other legitimate interests for Processing, but then we have to verify whether your interests override the legitimate interests relied on by us.
9.7. Your right to data portability
9.7.1. The right to data portability gives you the right to receive your Personal data you have provided to us in a structured, commonly used and machine readable format. It also gives you the right to request that we transmit this data directly to another controller.
9.7.2. The right to data portability only applies when:
- legal basis for Processing these Personal data is consent or for the performance of a contract;
- we are carrying out the Processing by automated means.
9.8. Your right to withdraw consent
Where we process Personal data based on your consent, you have a right to withdraw consent at any time.
10. SONARWORKS’ CONTACT INFORMATION
SIA “Sonarworks”, registration No. 40103611667, (“Sonarworks”, “we”),
Address: Smerla street 3, Riga, LV-1006, Latvia.
Phone: +371 67 223 131
E-mail: [email protected]
11. RIGHTS TO LODGE A COMPLAINT
If you have a complaint on how we use your Personal data, please contact us via email: [email protected]. We will review and respond to all complaints received.
You also have the right to lodge a complaint with the supervisory authority in your country of residence, place of work or the country in which an alleged infringement of data protection law has occurred. The data protection supervisory authority in the Republic of Latvia is the Data State Inspectorate, contact information:
Blaumana Street 11/13-11,
Riga, LV-1011, Latvia
Phone: +371 67 223 131
E-mail: [email protected]
web page: www.dvi.gov.lv
12. SCOPE OF THE PRIVACY POLICY
We may amend the Privacy Policy at any time without giving a personal notice to remain compliant with any changes in law and/or to reflect changes in the Processing of Personal data by us.