PRIVACY NOTICE
DATA CONTROLLER(S)
• UAB “SIMPLIKA”, based in Narbutas str. 5, Vilnius, Lithuania.
telephone n.: +37065431013, e-mail: lithuania@grafton.com
• UAB “CVO RECRUITMENT”, based in Narbutas str. 5, Vilnius, Lithuania.
telephone n.: +37065431013, e-mail: lithuania@grafton.com
The Companies have entered into an agreement to assume joint controllership of the data processing, pursuant to Article 26 of the GDPR, under which a number of measures will be jointly established, in particular with regard to:
• Purposes and methods of processing of Personal Data;
• Procedures for providing timely feedback to requests by data subjects in the exercise of their rights;
• Security measures appropriate to the processing of Personal Data and data breach management procedures;
• Content of privacy notices.
You may also request to see the essential content of the joint controllership agreement by sending an e-mail to lithuania@grafton.com
DATA PROTECTION OFFICER (“DPO”)
Rasa Muleronkienė, DPO, Smolensko g. 6-407, Vilnius, e - mail: rasa@privacypartners.lt
CATEGORIES OF PERSONAL DATA AND DATA SOURCES
For the purposes set out below, the Joint Controllers will collect the following categories of data:
• Identification Data: Name, surname, date of birth.
• Contact Details: address, email, phone number.
• Experience: CV, certificates, education.
• Login data: IP address, browser type, operating system, device type, referring URL.
• Other informationyou choose to provide (e.g. photo).
• Special categories of data:
Regardless, please do not indicate any special categories of data in your curriculum vitae (personal data revealing racial or ethnic origin, political opinions, religious or philosophical beliefs, or trade union membership, genetic data, biometric data intended to uniquely identify a natural person, data concerning a person's health or sex life or sexual orientation).
Personal data are collected in the following ways:
• Registration to the Datacruit personal area carried out from the websites of the Companies (hereinafter also "Site").
• Websites of any third-party companies and social networks;
• E-mail;
• During an interview at one of the agencies.
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WHY ARE YOUR PERSONAL DATA PROCESSED AND WHAT IS THE CONDITION THATMAKES THE PROCESSING LAWFUL? |
HOW LONG DO WE KEEP YOUR PERSONAL DATA? |
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1. PORTAL REGISTRATION |
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Your data are processed for registration in the Datacruit personal area, to be carried out to create a personal profile on the portal that allows you to review our job offers and apply to them. The legal basis applicable to the processing of your personal data for the Portal Registration Purpose, takes place because the processing is necessary for the performance of a contract pursuant to Article 6(1)(b) of the GDPR. |
For 30 months since you use our services or until you object to this processing. |
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2. APPLICATION TO A JOB OFFER AND CANDIDATE SELECTION PROCESS |
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Your data are processed both in case of application in response to a specific advertisement published on the Site and in case of voluntary application through the Site for the pursuit of the purpose of search and selection of candidates, in particular: a. for placement on a temporary basis at our client user company b. for direct placement at our third-party customer company c. for the implementation of measures or in the framework of collaborations and/or partnerships with public and private market operators. The legal basis applicable to the processing of your personal data for the Information Purposes in is the execution of pre-contractual measures taken at your request pursuant to Article 6(1)(b) of the GDPR. |
For 30 months since you use our services or until you object to this processing. |
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3. INFORMATION PURPOSE |
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Your data are also processed to send you communications strictly related to the purpose of search and selection of candidates by traditional or automated contact methods. The legal basis applicable to the processing of your personal data for the Information Purposes in is the execution of pre-contractual measures taken at your request pursuant to Article 6(1)(b) of the GDPR. |
For 30 months since you use our services or until you object to this processing. |
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4. PROPOSAL OF JOB OFFERS |
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Your data may be processed to propose searches and selections of personnel in line with your profile in order to provide job placement, including by sending job offers by traditional or automated contact methods. The legal basis applicable to the processing of personal data concerning you for the proposal of job offers purpose is your consent pursuant to Article 6(1)(a) of the GDPR. Should you withdraw your consent to such processing, your data shall be processed exclusively in the context of the specific selections for which you have applied. |
For 30 months since date of your consent or until you withdraw your consent. |
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5. AGGREGATE ANALYSES |
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Your data may be processed: a. for analyses of aggregate data for statistical purposes, not aimed at detecting the behaviour of data subjects and without direct effects on the data subjects, and for analyses of data for the purpose of verifying and forecasting business results and for internal and external auditing purposes, which do not affect the legal sphere of the data subjects. Such analysis activities may also be carried out through the use of IT and artificial intelligence tools; b. in an aggregate manner for the maintenance and improvement of the systems used to perform the services, in a manner not aimed at detecting the behaviour of the persons concerned and without direct effect on them. The legal basis applicable to the processing of your personal data for the Aggregation and Analyses purpose is the legitimate interest of the Company (maintenance and improvement of company systems) pursuant to Article 6(1)(f) of the GDPR. |
For 30 months since you use our services or until you object to this processing.
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6. LEGAL DEFENSE |
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Your data may also be processed to ascertain, exercise or defend a right of ours in court. The legal basis applicable to the processing of your personal data for the legal defense purpose is the legitimate interest of the Companies (exercise or defence of a right in court) pursuant to Article 6(1)(f) of the GDPR. |
The data shall be processed for this purpose until the end of the relevant legal proceedings. |
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7. MARKETING |
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Your data may also be processed, with your consent, for the purpose of sending information and promotional communications relating to the services offered by the Companies (in particular, training initiatives, career development, coaching), or carrying out studies and statistical and/or market research relating to employment services, using both traditional and automated contact methods (e.g., e-mail, SMS, instant messaging systems, operator calls, paper mail). The legal basis applicable to the processing of personal data concerning you is your consent pursuant to Article 6(1)(a) of the GDPR. |
For 30 months since date of your consent or until you withdraw your consent. |
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8. MARKETING OF OTHER GROUP COMPANIES |
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Your data may also be processed, with your consent, for the purpose of sending information and promotional communications relating to the services offered by other Group companies (in particular, training, career development, coaching, outplacement support, personnel search and selection and executive search initiatives), or the performance of statistical and/or market studies and research relating to employment services, using both traditional and automated contact methods (e.g., e-mail, SMS, instant messaging systems, operator calls, paper mail). The legal basis applicable to the processing of personal data concerning you is your consent pursuant to Article 6(1)(a) of the GDPR. |
For 30 months since date of your consent or until you withdraw your consent. |
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After the aforementioned retention periods have elapsed, Personal Data will be destroyed, deleted or anonymised, subject to technical deletion and backup procedures. |
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NATURE OF DATA PROVISION AND CONSEQUENCES OF REFUSAL
The provision of the data marked with an asterisk in the registration form for the Datacruit area is necessary to allow the Companies to complete your registration (Portal Registration purpose); therefore, any refusal to provide the requested data will prevent the Companies from completing your registration to Datacruit.
The provision of the data marked with an asterisk in the data collection form on the Site or requested from the agencies is necessary to allow the Companies to pursue the search and selection purposes; therefore, any refusal to provide the requested data shall prevent the Companies from carrying out the search and selection activity and shall not allow your application to be taken into consideration.
The provision of data for the Marketing purposes is optional. Any refusal to provide data or consent will have no consequence on your registration to Datacruit and will not prevent the Companies from carrying out search and selection activities.
DATA RECIPIENTS
Your data may only be processed by employees of the company departments authorized to process them as they are assigned to the pursuit of the aforementioned purposes. These employees have received adequate operational instructions in this regard.
Your personal data may be communicated by the Companies, in pursuance of the purposes set out above, to the following entities:
• Client companies or entities;
• Authorised public authorities;
• Legal advisors.
• Group companies.
Your personal data may also be processed by parties, expressly appointed as data processors, which provide the Companies:
• Site operation and maintenance services;
• Candidate database management and maintenance services;
• Archiving services;
• Communication mailing services;
• Market research services;
• Assessment and training service;
• Event organisation services;
• Marketing services.
An up-to-date list containing the addressees is available by sending us the e-mail address: lithuania@grafton.com
Personal data provided by candidates will not be disseminated.
EXTRA EEA DATA TRANSFERS:
Your personal data is processed by the Companies in the European Economic Area (EEA) and is not disclosed. If necessary, for technical or operational reasons, the Companies may transfer your personal data to countries outside the EEA, which are subject to decisions of the European Commission on suitability or on the basis of appropriate safeguards (e.g. standard contractual conditions) or specific derogations provided for provisions in accordance with the applicable data protection regulation.
DATA SUBJECTS RIGHTS
Data subjects are granted the rights set out in Articles 15 to 22 of the GDPR, where applicable.
In particular, data subjects may request from the Data Controllers access to the data, their deletion, the rectification of inaccurate data, the integration of incomplete data, as well as the restriction of processing in the cases provided for in Article 18 of the GDPR.
Data subjects have the right to object, at any time, in whole or in part, to the processing of data necessary for direct marketing purposes and for the pursuit of the legitimate interests of the Data Controllers.
Data subjects also have the right to receive the data provided to data controllers in a structured, commonly used and machine-readable format, and, if technically feasible, to pass them on to another data controller without hindrance, if the conditions for exercising the right to portability set out in Article 20 of the GDPR are met.
These rights may be exercised by writing by post to the addresses indicated above, or by e-mail to the following e-mail address: lithuania@grafton.com is understood that where the request is made by electronic means, the information will be provided in a commonly used electronic format.
Data subjects have the right to lodge a complaint with the competent supervisory authority (in particular in the Member State where they habitually reside or work or in the State where the alleged infringement occurred).