Recruitment Privacy Policy

PRIVACY POLICY for the recruitment process

This Privacy Policy explains how CUSTOMERTIMES CORP (“CT”, “we”, “us”) processes information about you during the recruitment process when you apply for a vacancy at CT or any of our group entities or affiliates (together – “Customertimes Corp”). You will also find information about your rights regarding the personal data you provide to us. If you have any questions regarding this Privacy Policy, contact our data protection officer at data.privacy@customertimes.com

Your personal data controller is CT and that Customertimes Corp entity to whose vacancy you have applied.

1. What personal data we process and why?

When you apply for a position at CT or Customertimes Corp, we may process different types of personal data for multiple purposes. In some cases, when the particular position requires it, we may ask for additional information.

Reviewing your application

During the recruitment process, we process your personal data to evaluate your application and suitability for a particular position. For this purpose, we process the following data:

·    your name, surname,

·    contact details,

·    other personal data in your CV, application or cover letter,

·  information on your skills, experience, qualification and other information you have made publicly available on social networking sites such as LinkedIn,

·    any other information you have added to the application, practical task and provided to us during the job interview or when you communicate with us.

We will process this information based on your consent and our legitimate interests to carry out the recruitment process and evaluate your application.

We do not require special category data revealing racial or ethnic origin, political opinions, religious or philosophical beliefs, trade union membership, genetic, biometric, health data or data concerning person's sex life or sexual orientation. If you choose to provide such information, it will not be considered during the recruitment process, and we will process it according to this Privacy Policy.

Collection of references

If you have provided such information, we may contact your previous colleagues or other referees to find out more about your suitability for a particular vacancy. We will only contact the referees you have indicated. For this purpose, we will process the name, surname, contact details of the referee and the information provided about you.

Protecting our interests and legal rights

In case we need to enforce or defend our legal rights or take part in any other legal process, we may process your name, surname, contact details and other personal data we may have collected about you during the recruitment process. We will process this information based on our legitimate interests to protect our rights, resolve disputes, prevent illegal activities such as fraud or abuse and protect our legal interests.

Conducting in-depth assessment of your professional reputation

Certain laws and regulations, which are applicable to us, stipulate those certain positions (for example, board members, risk managers, money laundering and anti-terrorist and anti-proliferation financing specialists) may not be held by persons with previous criminal convictions. Thus, if you apply to such position, we may ask you to provide details of your criminal conviction record and carry out an in-depth assessment of your professional reputation. During such assessment we may process information, which reveals:

·       Whether your act or omission has led to the declaration of bankruptcy or revocation of the license of another institution due to a decision of a financial supervisory authority,

·       Whether you have been convicted of a criminal offense and your criminal record has not been deleted from the Criminal Registry,

·      Whether you are covered by a legal or court order prohibiting you from doing business, holding a certain position, operating in a certain field of activity, or doing certain business.

We will process this information to exercise our rights as an employer in the field of employment as well as based on our legitimate interests to ensure the requirements for specific positions as set in the applicable laws and to ensure the protection of the company's interests and activities. We may obtain the information from the documents and information submitted by you, as well as by carrying out our assessment of your professional reputation, including using publicly available data and other sources of information.

Given that this information is considered as special category of personal data, we carry out this processing with special care, ensuring limited access, security and performing impact and risk assessments.

3. Who can receive your personal data?

Your personal data will be available to that Customertimes Corp company, to whose vacancy you have applied. If you have submitted a general application to any open vacancy, your data may be used in other recruitment processes of that Customertimes Corp company, who has an open vacancy most suitable for you.

Your personal data may be shared with third parties who provide services during the recruitment process (for example, hosting and data storing services, HR tools, legal, IT and other advisors, when reasonably required). These service providers may only receive the minimum required amount of personal data and only when necessary. We will share your personal data only with such service providers who have undertaken to comply with confidentially requirements as well as obligations set out in applicable data protection laws and our cooperation agreements.

If any of the service providers are located outside the European Union or there are other legitimate reasons, we may need to transfer data outside the European Union. In such case, the personal data will be transferred in compliance with the requirements of the General Data Protection Regulation.

If there are any complaints about the recruitment process or we need to protect our legal rights, we may also share information with the relevant public authorities. We may need to share your information if we are required to do so in accordance with the applicable laws or we have received such request from a public authority.

4. How long do we keep your personal data?

If you have indicated that you are interested in other suitable vacancies or submitted a general application, then we will retain your personal data for 2 years. After this period, we will erase or anonymize your data and use it only for statistical purposes.

If you have indicated that you are not interested in other suitable positions, or you have revoked your consent, we will erase or anonymize your personal data 4 months after the end of the particular recruitment process.

We may continue to store copies of your personal data when reasonably necessary to comply with our legal obligations, to resolve disputes between us and/or to protect our legal interests.

5. Your rights

As a data subject you have certain rights in relation to the processing of your personal data.

You have the right to request access to your personal data. If you believe that the data, we have on you is outdated, incorrect or incomplete, you have the right to correct or amend it. You also have the right to data portability and receive your data for transmission to another controller. Under certain circumstances, you have the right to request restriction of processing.

If we process your personal data based on our legitimate interests, you have the right to object to such processing. If we receive such objection, we will no longer process your personal data, unless we can demonstrate compelling legitimate grounds for the processing which override the interests, rights, and freedoms of the data subject or for the establishment, exercise, or defense of legal claims.

You have the right to withdraw your consent for the processing of your data, which is based on consent. Revoking of consent will not affect the lawfulness of processing based on consent before its withdrawal.

You can request erasure of your personal data. Please note that we will not be able to delete the data, which we are obliged to retain in accordance with applicable laws or which we require for the establishment, exercise, or defense of legal claims.

You can exercise your rights by submitting your request in a written form to the email address data.privacy@customertimes.com.

We will evaluate such requests in accordance with the applicable law and will respond within 30 days.

Please note that we will need to verify your identity before we disclose any information, therefore we may ask you give us additional information.

Furthermore, if you believe that we have unlawfully processed your personal data, you have the right to submit a complaint to your respective data protection supervisory authority.

The version of this Policy is effective as of 30 April, 2024.