Privacy policy
1. Information on controller
Our name is AS “Eleving Consumer Finance”, registration number: 54103145421, legal address: Skanstes Street 52, Riga, LV-1013.
You can contact us by phone: +37122177880 or by writing to the following e-mail address: [email protected] or using the contact form on the website www.funderly.finance.
2. Contact details for personal data protection issues
If you have any questions regarding this notification or the processing of your personal data, you may contact us via the communication channels indicated in the previous paragraph (paragraph 1).
3. General description of our processing of personal data
This notice describes how we process the personal data of our candidates (candidates) for vacancies and other persons whose data may come into our possession in connection with the selection of personnel.
The purpose of this notice is to give persons wishing to apply for vacancies advertised by us and other companies in our group of companies, as well as those whose data have been provided to us by applicants (such as provider of referrals) to find out about our personal data and data processing rules.
This is the current version of the statement. We reserve the right to make changes and, if necessary, update this statement.
We recognize that personal data is your value and will process it in accordance with the requirements of confidentiality and taking care of the security of your personal data at our disposal.
4. For what purposes do we process your personal data and what is the legal basis for the processing of personal data?
We will only process your personal data for pre-defined legitimate purposes, including:
a) To ensure the selection process of employees and the realization of the rights and obligations arising from it -
For this purpose, we collect CVs (resumes) and accompanying documents from applicants, as well as from public sources and databases, we contact the applicant and the referrers indicated by the applicants to collect feedback, save the CV for other vacancies, as well as to in order to be able to defend our interests in legal proceedings, we retain data to respond to claims and lawsuits.
For this purpose and for the above purposes, we may need at least the following categories of personal data: the identity of the applicant, the applicant's contact details, the applicant's education and previous work experience, the persons who can provide referrals and their contact details, the referent's feedback and other information could be essential for the performance of the position in question and for the identification of the most suitable candidate.
The main legal basis used to achieve these objectives are:
- consent (Article 6, first paragraph, point (a) of the General Data Protection Regulation) regarding the submission of the CV;
- the conclusion of a contract with the data subject (Article 6, first paragraph, point (b) of the General Data Protection Regulation) - with regard to the processing of data of applicants who have been decided to conclude an employment contract;
- Fulfillment of legal obligations (Article 6, first paragraph, point c of the General Data Protection Regulation) - in certain cases for certain types of data, if regulatory enactments prescribe minimum requirements for a specific position;
- Legitimate interests of the controller (Article 6, first paragraph, point (f) of the General Data Protection Regulation) - regarding the provision of evidence, in case of possible claims, as well as the amount of information requested, selection of potential candidates, retention and addressing of specific vacancies.
b) For concluding an employment contract -
For this purpose, we collect the information that needs to be included in the employment contract and its annexes, perform your identification, check your qualification documents, and draw up the employment contract.
For this purpose, we may need at least the following personal data: employee identity data, contact information, data on the establishment and termination of employment, data on the employee's duties, data required for the calculation and payment of wages, health data required for employment.
The main legal basis used to achieve these objectives are:
- conclusion of an agreement with the data subject (Article 6, first paragraph, point (b) of the General Data Protection Regulation);
- Legal fulfillment of obligations (Article 6 (1) (c) of the General Data Protection Regulation) - with regard to the information to be included in the employment contract and the necessary qualification requirements, as well as reporting of employment to public authorities (eg to the State Revenue Service);
- the performance of the controller's duties and the exercise of employment rights (Article 9, second paragraph, point (b) of the General Data Protection Regulation), in relation to the processing of specific categories of data (health data, trade union data).
c) Prevention of threats to security, property interests and other important legitimate interests of us or third parties
For this purpose, we would need to perform video surveillance of our premises and other property, use personal data processors to provide various functions, if necessary, exchange information within a group of companies, use the rights granted by regulatory enactments to ensure our legitimate interests.
For this purpose, we may need to process at least the following personal data: data contained in video recordings, data recorded in access control systems on site visits, etc.
The main legal basis used to achieve these objectives are:
- The legitimate interests of the controller (Article 6, first paragraph, point (f) of the General Data Protection Regulation).
5. Who could access your personal data?
We take appropriate measures to process your personal data in accordance with applicable law and to ensure that your personal data is not accessed by third parties who do not have an appropriate legal basis for processing your personal data.
Your personal data could be accessed as needed by:
1) our employees and of other companies belonging to our group of companies or directly authorized persons who need it for the performance of their duties, such as colleagues, accountants, direct managers, employees of the personnel department;
2) processors of personal data in accordance with the services they provide and only to the extent necessary, such as auditors, financial management and legal advisers, database maintainer, other persons involved in the recruitment process of the controller and other companies in our group;
3) state and local government institutions in cases specified by legal acts, for example, law enforcement institutions, tax supervision institutions.
6. Which cooperation partners in the processing of personal data or personal data processors do we choose?
We take appropriate measures to ensure that your personal data is processed, protected and transferred to data controllers in accordance with applicable law. We carefully select the processors of personal data and, when transferring data, evaluate its necessity and the amount of data to be transferred. The transfer of data to processors is carried out in compliance with the requirements of confidentiality and secure processing of personal data.
We are currently able to work with the following categories of processors:
1) personnel selection companies, auditors;
2) IT infrastructure, database owner / developer / technical maintainer.
The processors of personal data may change from time to time, for which we will also make changes in this document.
7. Is your personal data to be sent to countries outside the European Union (EU) or the European Economic Area (EEA)?
Considering that our group of companies consists of companies that are located and provide services outside the EU / EEA member states, incl. For countries for which the European Commission has not decided on the adequacy of the level of protection, we may need to inform colleagues within the group about your identity, position and contact details in order to be able to fulfill your responsibilities.
Also, if your work involves business trips, we will need to disclose the necessary information to the relevant service providers to ensure arrival and accommodation in the country during business trips or business trips.
In each case of data transfer, we assess the existence of additional legal basis under the General Data Protection Regulation, in most cases using the following additional legal basis:
1) the transfer is based on a decision of the European Commission on the adequacy of the level of data protection (Article 45 of the General Data Protection Regulation)
2) the transfer is made to a recipient with whom a contract has been concluded with standard data protection clauses specified by the European Commission (Article 46, Paragraph two, Subparagraph c) of the General Data Protection Regulation);
3) the transfer is necessary in order to fulfill the data subject's obligations under the employment contract (Article 49, first paragraph, point (b) of the General Data Protection Regulation)
8. How long will we keep your personal data?
Your personal data is stored for as long as it is necessary for the relevant purposes of the processing of personal data and in accordance with the requirements of applicable law.
When evaluating the retention period of personal data, we take into account the requirements of applicable laws and regulations, aspects of the performance of contractual obligations, your instructions (eg in case of consent), as well as our legitimate interests. If your personal data is no longer required for the specified purposes, we will delete or destroy it.
For example, we will keep your CV and the documents attached to it for a specific job vacancy until the end of the competition, as well as for at least 6 months after that, to protect against possible claims and legal proceedings against us. In turn, if you have submitted your CV and the documents attached to it without addressing a specific job vacancy or have given your consent to use the CV and the documents attached to it for later selections, we will keep your CV and the documents attached to it for 2 years. You always have the right to withdraw your consent to the storage of such data.
If an employment contract is concluded with you, then the CV and the documents attached to it, if necessary, can be attached to your employee's file and kept for the entire period of validity of the employment contract. When concluding an employment contract, you will be introduced to a data processing notice addressed to employees, which will provide more detailed information about the processing performed during the employment relationship.
9. What are your rights as a data subject with regard to the processing of your personal data?
Restoration of personal data
If there has been a change in the personal data you have provided to us, such as a change in contact address, telephone number or e-mail, please contact us and provide us with up-to-date data so that we can achieve the relevant purposes of processing personal data.
Your right to access and correct your personal data
In accordance with the provisions of the General Data Protection Regulation, you have the right to access your personal data in our possession, request their rectification, erasure, restriction of processing, object to the processing of your data and the right to data portability in the cases and according to the General Data Protection Regulation.
We respect your right to access and control your personal data, so if we receive your request, we will respond to it within the legal deadlines (usually no later than one month, unless there is a specific request that takes longer to prepare). response) and, if possible, we will correct or delete your personal data accordingly.
You may obtain information about your personal data held by us or exercise your other rights as a data subject in any of the following ways:
1) by submitting a relevant application in person and identifying ourselves in our office at the address: Skanstes Street 52, Riga, LV-1013, every working day during our working hours;
2) by submitting a relevant application, sending it to us by post to the following address: Skanstes Street 52, Riga, LV-1013.
3) when submitting a relevant application, sending it to our e-mail: [email protected], it is recommended to sign it with a secure electronic signature.
Upon receipt of your application, we will evaluate its content and the possibility of your identification, and depending on the situation, we reserve the right to ask you to additionally identify yourself in order to ensure the security and disclosure of your data to the person concerned.
Withdrawal of consent
If the processing of your personal data is based on your consent, you have the right to withdraw it at any time and we will no longer process your personal data which we have processed on the basis of the consent for that purpose. However, we inform you that the withdrawal of consent may not affect the processing of personal data that is necessary to meet the requirements of regulatory enactments or that is based on a contract, our legitimate interests or other grounds specified in regulatory enactments for lawful data processing.
You may also object to the processing of your personal data if the processing of personal data is based on a legitimate interest.
10. Where can you make a complaint about personal data processing issues?
If you have any questions or concerns regarding the processing of your personal data by us, please contact us first.
However, if you believe that we have not been able to resolve the issue with each other and you believe that we are still violating your right to the protection of personal data, you have the right to lodge a complaint with the Data State Inspectorate.
11. Why would you give us your personal data?
Mainly we collect your information in order to carry out the personnel selection process, to fulfill our legal obligations and to pursue our legitimate interests. In these cases, obtaining certain information from us is necessary to achieve the respective purposes, therefore, failure to provide such information may endanger your participation in the vacancy competition and the commencement of employment. If the data is not required, but its submission could help to improve the working environment or your employment conditions, we will indicate that the provision of data is voluntary.
12. How do we collect your personal data?
We may collect your personal information in one of the following ways:
1) from you, by submitting to us an application and CV for participation in the competition for the vacant position;
2) by selecting and addressing you from public sources (including databases) on our initiative;
3) from the applicant, if he has indicated your personal data for receiving feedback on him;
4) in the process of concluding a mutual agreement, obtaining data from you;
5) from you, if you submit any applications, e-mails to us, you will call us;
6) from you, if you provide information about the applicant;
7) where applicable, from video surveillance records and access control systems.
13. Is your personal data used in automated decision making?
We do not use your data for automated decision making.