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Privacy policy

 HEADEX GROUP PRIVACY POLICY

We understand that the protection of your personal data is of utmost importance, therefore we collect and process your data solely within the scope that is necessary for the performance of our activities. We process personal data lawfully, transparently, and fairly, for pre-determined purposes and only to the extent necessary to achieve those purposes. When processing personal data, we strive to ensure that they are accurate, secure, confidential, properly stored and protected.

When processing your personal data, we comply with the requirements of the General Data Protection Regulation (hereinafter referred to as ‘the GDPR’), the Law on Legal Protection of Personal Data of the Republic of Lithuania, as well as requirements for personal data processing established by other legal acts.

The Privacy Policy applies to all persons whose data we process.

 

1. HOW DO WE COLLECT YOUR PERSONAL DATA?

1.1. We process your personal data obtained in the following ways:

(a) When you provide them to us. You provide us with your personal data when you send us your CV, cover letters, apply for a vacancy based on our job advertisements on job search portals, register on our websites, communicate with us by phone, e-mail or during meetings, fill in questionnaires submitted by us, complete assignments or tests, contact us through social networks (e.g., Facebook, Linkedin), use the zendesk chat app integrated on the website, share your success stories and provide feedback about us. Where you contact us in writing or electronically, we retain the data concerning the respective correspondence.

(b) When you use websites operated by us. When you use websites operated by us, certain information (such as the IP (Internet Protocol) address, the device and web browser used, the number of visits, the pages viewed on our website, the time spent on the website, and the websites you visited before accessing to our site) is collected automatically.

(c) When we receive your personal data from other persons in accordance with the procedure established by legal acts and/or this Privacy Policy.

1.2. We may combine personal data received from you with data collected by us from other public or available sources. For example, we may combine the personal data you provide with data obtained using cookies on websites, data collected in the course of provision our services to you, or data lawfully obtained from third parties. In exercising your rights, you will always be able to demand the correction of inaccurate personal data.

 

2. FOR WHAT PURPOSES AND ON WHAT GROUNDS DO WE PROCESS YOUR DATA?

2.1. Your personal data are processed in accordance with the following basic principles for personal data processing established by the GDPR:

(a) For the performance of a contract or for taking action at the request of the data subject prior to the conclusion of a contract;

(b) Having obtained the consent of the data subject;

(c) When the processing of data is necessary to fulfil a legal obligation to which we are subject;

(d) When personal data need to be processed in our legitimate interests or those of a third party.

2.2. We process your personal data for the following purposes:

(a) For the purpose of provision of services. We process your personal data to provide our services to you and others: to find and select candidates who meet the needs of our clients, assess whether the candidates are suitable for the job offered, and present the candidates to employers or employ them in our company.

For this purpose, we process your personal data provided to us by you (e.g., data provided on your CV, data collected during our communication and other required employment-related data), collected when you use our website and other websites and/or received from other persons (e.g., recommendations from current or former employers or acquaintances, social networks, media, etc.).

For this purpose, we provide or transfer your data to our partners and customers: employers who are looking for employees. Together with us, they will be the controllers of your personal data. The scope of your personal data transferred by us to the customers will not exceed the scope of your personal data that we process under this Privacy Policy. We have concluded agreements with our customers, based on which both parties undertake to protect your personal data.

For this purpose, we process your data while providing our services to you. If your personal data are processed while providing services to other persons, having received your consent, we process your personal data for 3 years of the date of receipt of your consent.

When providing services, upon receipt of your consent, we may carry out your (candidate’s) assessments and testing, as well as the filming of the assessments and testing. The videos and assessment/testing results may be passed on to our customer who has requested the respective selection procedure.

You have the right to view the videos and the results of tests and assessments related to you, and to request that the video be recorded on digital media.

We will process the data relating to such videos and results of tests and assessments as long as the respective selection procedure lasts or, having obtained your consent, for a longer period of time specified in this Privacy Policy for the purpose of administering the candidate database. If we determine that there is reason to believe that a criminal or other illegal activity has been captured on a video or if an internal investigation has been initiated, the video will be retained until the end of the relevant investigation and/or legal proceedings.

(b) For the purpose of administering the candidate database. At the end of the respective selection procedure for the participation in which you have submitted your data, having obtained your consent, we process your personal data for the purpose of having the possibility to offer you jobs and career opportunities in the future, to find and select candidates who meet our customer’s needs, to assess their suitability for the job, and present the candidates for a job to respective employers.

For this purpose, we process the same personal data as for the purpose of providing the services, provide them to the same persons, and store them for 3 years of the date of receipt of your consent.

(c) We also process the data of the person you recommended for the purpose of selection for a job offered by us or our partners, and your data (data of the recommending person) for the purpose of administering the bonus for the person recommended.

For this purpose, we process the following data of the person recommended: name, surname, telephone number, e-mail address, work experience, qualities, talents, and other information provided; data of the person providing recommendation: name, surname, telephone number, e-mail address, data necessary for the payment of the bonus, the IP address of the e-mail sender’s server, the IP address of the device from which the e-mail was sent, and data source (where the data came from, source name, date of data receipt, person who entered the data).

We will process the data of the recommended person for 10 years of the date of consent. We will process the data of the person who provides the recommendation throughout the selection process applicable to the recommended person (if the recommended person is not employed through the selection process) or within 3 years after the payment of the bonus (if the recommended person is employed).

The personal data of the person you recommend submitted by you for the purpose of selecting the person for a job offered by Headex and/or its partners Headex may transfer to companies of the Headex Group and/or potential employers worldwide, including those in countries whose legal acts do not ensure the level of legal protection of personal data applicable in Lithuania. When transferring personal data to a recipient in such a country, Headex and the recipient of personal data will apply appropriate safeguards to protect the personal data from unlawful processing. We may also transfer the minimum required amount of the personal data specified in the consent to the third party providing services to Headex or a company the Headex Group, including legal, tax, business or HR administration, and accounting advisers, as well as competent state authorities in accordance with the procedure established by legal acts.

More information on the conditions for getting paid the bonus can be found here: projektai.headex.eu/rekomendacijos/visos-taisykles/ ir projektai.headex.eu/rekomendacijos/duk/.

(d) For the purpose of service quality control (recording of telephone conversations). When you call us or we contact you, we record our conversation to ensure the quality of service and control the provision of services.

For this purpose, we process the following of your personal data: name, surname, telephone number; recording of the telephone conversation (the data provided during the conversation), date and time of the telephone conversation, name and surname of the person consulting you.

For this purpose, we receive your personal data directly from you or obtain them while you are using our services.

For this purpose, we store your data for 3 years.

(e) To administer the work activities of employees. To the extent required or permitted by law, we process the personal data of our employees in accordance with our internal rules.

(f) To improve the websites, we manage and to offer you better and more personalised services. We use your personal data, including the personal data we receive from you through our websites, to improve and develop these websites and to offer you better and more personalized services. For this purpose, we use your personal data obtained from you, obtained while you are using our websites, as well as obtained from other persons.

The information on how we use cookies and similar technologies can be found in Section 7 of this Privacy Policy below.

(g) For direct marketing purposes. Having obtained your consent, we process your personal data to offer you services provided by us, our partners and related persons as well as to improve our services.

For this purpose, we process the following data: name, telephone number, e-mail address; Data on visitors to websites operated by the company and third parties collected in connection with the use of such websites.

For this purpose, we process your data for 3 years of the date of receipt of your consent.

(h) For the purpose of direct communication and improvement of service quality. For this purpose, we process your personal data that you provide when contacting us on the zendesk chat app, posting feedback about us or sharing your success story in the feedback section of the website. For this purpose, we process the following of your personal data: e-mail address, your name indicated on Facebook, feedback/success story text, and query text.

For this purpose, we process your data for 1 month from the beginning of the correspondence.

For the above stated purpose, we also process your personal data provided by you while communicating with us using the Messenger, Viber or WhatsApp. For this purpose, we process the following of your personal data: telephone number, information provided during correspondence, and your name indicated in the Messenger, Viber or WhatsApp.

We store the history of such correspondence for 1 year from the beginning of the correspondence.

You can find out how the Messenger, Viber or WhatsApp process your personal data in the privacy notices published by these apps.

i) Processing of personal data for the purpose of controlling the spread of COVID-19 (coronavirus) infection and the selection of persons, who are authorised to work after they have been tested and/or who are tested regularly for communicable diseases, for which a state of emergency and/or quarantine has been declared nationwide.

To this end, the Company will process your forename, surname and check, whether you have been fully vaccinated against coronavirus (COVID-19); information on whether you have a history of coronavirus (COVID-19) disease

Your personal data shall be processed in accordance with Article 6(1)(c) and Article 9(2)(b) of the Regulation (Resolution No. 544 of the Government of the Republic of Lithuania of 7 May 1999 and Resolution No. 645 of the Government of the Republic of Lithuania of 8 August 2021) to determine the compliance of persons with the specified criteria, the above documents and the personal data contained therein are only reviewed and not further processed.

Your personal data specified will be processed by the Employer for the duration of the employment relationship between you and the employer or for the duration of the legislation establishing coronavirus (COVID-19) disease prevention measures applicable to the Employer, whichever period expires earlier.

2.3. Where your personal data are processed on the basis of your consent, your personal data is no longer processed when your consent is revoked or expires, except for the storage of the data confirming the fact of your consent which we will store for a period of up to ten (10) years to raise a claim, enforce or defend our legal requirements.

2.4. We do not process your personal data for any other purpose incompatible with the purposes listed above.

 

3. HOW DO WE USE COOKIES?

3.1. We collect information about you using cookies and similar technologies. Cookies are small files that are temporarily stored on the hard drive of your device and allow us to recognize you during your other visits to websites, save your browsing history and preferences, customize content, speed up website searches, create a convenient and user-friendly website environment and deliver it more efficiently and reliably. Cookies are common web browsing practice that makes it easier to use the website.

3.2. We may collect the following information using cookies: the IP (Internet Protocol) address, the device and web browser used, the number of visits, the pages viewed on our website and time spent on the website, as well as the websites you visited before accessing our website.

3.3. We use the information obtained using cookies for the following purposes:

(a) To ensure the functionality of the websites (e.g., so that you can use the personalization of the websites);

(b) To analyse the use of the websites;

(c) To be able to improve and develop the websites to meet your needs to be best extent possible;

(d) To develop the services;

(e) For the targeted orientation of marketing activities.

3.4. We may, without violating the law, combine information obtained using cookies with information obtained about an individual by other means (e.g., the information about the use of websites with personal data provided by you, etc.).

3.5. The following cookies may be used on websites:

(a) ‘Technical cookies’ are the cookies that are necessary for the operation of websites;

(b) ‘Functional cookies’ are the cookies that, although not necessary for the operation of websites, significantly improve its operation, quality and user experience;

(c) ‘Analytical cookies’ are the cookies used for the statistical analysis of website visitors’ navigation methods; the data collected by these cookies is used anonymously;

(d) ‘Targeted or advertising cookies’ are the cookies that are used to display offers or other information that may be of interest to you;

e) ‘Social media cookies’ are the cookies that are necessary for the use of website information in your social media profile account.

3.6. You can consent to the use of cookies in the following ways:

(a) Not deleting them and/or not changing the settings of your internet browser so that it does not accept cookies;

(b) By clicking on the ‘Accept’ option on the link (bar) concerning the use of cookies on websites;

(c) By stating your consent at the time of registration to access websites.

3.7. You can revoke your consent concerning the use of cookies at any time. You can do this by changing your web browser settings so that it does not accept cookies. The method of doing this depends on your operating system and web browser. You can find detailed information about cookies, their use and the options for opting-out at: http://AllAboutCookies.org or http://google.com/privacy_ads.html.

3.8. In some cases, especially where technical and functional cookies are disabled, consent to use them is not given or trey are deleted, this may slow down browsing, restrict the functionality of certain websites or even block access to websites.

3.9. All information you provide on social media (including messages, the use of the ‘Like’ and ‘Follow’ fields, and other communications) is controlled by social network operators. We recommend that you read the privacy notices of social network operators and contact them directly concerning the issues related to the use of your personal data. You can learn more about the privacy policies of social network operators here: https://wwww.facebook.com/policy.php (Facebook); https://www.linkedin.com/legal/privacy-policy (LinkedIn).

3.10. Cookies used:

Cookie name

Cookie type

Supplier

Validity period

Data processed

guest_id

Social media

twitter.com

2 years

Browsing data

personalization_id

Social media

twitter.com

2 years

Browsing data

presence

Social media

facebook.com

Session

Browsing data

fr

Marketing

facebook.com

3 months

User and browser unique identifier

_fbp

Marketing

facebook.com

1 month

User and browser unique identifier

datr

Functional

facebook.com

2 years

User and browser unique identifier

c_user

Social media

facebook.com

1 year

User and browser unique identifier

spin

Social media

facebook.com

1 day

User and browser unique identifier

m_pixel_ratio

Marketing

facebook.com

Session

User and browser unique identifier

xs

Social media

facebook.com

1 year

User and browser unique identifier

x-refer

Social media

facebook.com

Session

User and browser unique identifier

sb

Social media

facebook.com

1 year

User and browser unique identifier

CM14

Marketing

adform.net

Week

Unique identifiers

C

Analytical

adform.net

1 month

Unique identifiers

TPC

Analytical

adform.net

Week

Unique identifiers

uid

Analytical

adform.net

2 months

Unique identifiers

DigiTrust.v1.identity

Marketing

adform.net

1 day

Unique identifiers

CM

Marketing

adform.net

1 day

Unique identifiers

DSID

Marketing

doubleclick.net

Week

Unique identifiers

IDE

Marketing

doubleclick.net

8 months

Unique identifiers

RUL

Marketing

doubleclick.net

9 months

Unique identifiers

_Secure-3PSIDCC

Marketing

google.com

1 year

Randomly generated identification number

OGPC

Marketing

google.com

1 year

Unique identifiers

_Secure-3PSID

Marketing

google.com

2 years

Randomly generated identification number

Consent

Marketing

google.com

17 years

User preferences and other information, such as the language selected, the number of search results displayed on the page, and turning Google SafeSearch on or off

S

Marketing

google.com

Session

Unique identifiers

SAPISID

Marketing

google.com

2 years

User preferences and other information, such as the language selected, the number of search results displayed on the page, and turning Google SafeSearch on or off

SEARCH_SAMESITE

Marketing

google.com

6 months

Unique identifiers

NID

Marketing

google.com

6 months

Unique identifiers

APISID

Marketing

google.com

1 year and 9 months

Unique identifiers

ANID

Marketing

google.com

1 month

Unique identifiers

1P_JAR

Marketing

google.com

1 month

Unique identifiers

HSID

Functional

google.com

1 year and 9 months

Unique identifiers

SIDCC

Marketing

google.com

1 year

Unique identifiers

SID

Analytical

google.com

2 years

Unique identifiers

_Secure-3PAPISID

Marketing

google.com

1 year and 9 months

Unique identifiers

OTZ

Marketing

google.com

1 month

Unique identifiers

DV

Marketing

google.com

1 day

Unique identifiers

SSID

Marketing

google.lt

1 year and 9 months

Various unique variables

_Secure-3PSID

Marketing

google.lt

2 years

Randomly generated identification number

APISID

Marketing

google.lt

1 year and 9 months

Randomly generated identification number

UULE

Marketing

google.lt

1 day

Randomly generated identification number

_hjAbsoluteSessionInProgress

Statistical

headex.eu

1 day

Randomly generated identification number

_hjid

Statistical

headex.eu

1 year

Randomly generated identification number

__zlcmid

Marketing

headex.eu

1 year

Unique identifiers

_hjTLDTest

Statistical

headex.eu

Session

Link

_glc_au

Marketing

headex.eu

3 months

Unique identifiers

_gid

Analytical

headex.eu

1 day

Unique identifiers

_ga

Analytical

headex.eu

2 years

Unique identifiers

PHPSESSID

Marketing

headex.eu

Session

Unique identifiers

SutinkaSuTeisemis

Necessary

headex.eu

1 day

User agreement to the Privacy Policy

Gdpr_cookies

Necessary

headex.eu

Session

User preferences concerning cookies

 

4. WHO DO WE PROVIDE YOUR PERSONAL DATA TO?

4.1. We guarantee that your personal data will not be sold, provided, or otherwise transferred to third parties in the absence of a legitimate basis, as well as used for purposes other than those for which they were collected. We will not transfer your personal data in any way other than that provided for in this Privacy Policy and in the legal acts. However, we reserve the right to provide information about you if we are required to do so in accordance with the procedure established by laws or if required to do so by lawful authorities or prosecuting authorities.

4.2. For the purposes set out in this Privacy Policy, we may transfer your personal data to companies managed by the Headex Group, as well as to companies that help us to carry out our activities (partners, customers, and suppliers). We require such partners to process your data strictly in accordance with the instructions given by us and the applicable legal acts governing the protection of your data. We enter into agreements with these persons, which obliges the parties to such agreements to adhere strictly to requirements concerning the protection of personal data.

4.3. The use of your data by the above-mentioned service providers is limited: they may not use this data for purposes other than providing services to us.

4.4. A non-exhaustive list of persons and the categories of persons to whom we transfer your personal data is provided in Clause 2.2 of this Privacy Policy separately for each purpose for which personal data are used.

 

5. HOW LONG DO WE STORE YOUR PERSONAL DATA?

5.1. We store your personal data for a period not exceeding the time limit that is required based on the purposes of the processing, or as required by law, if it provides for a longer retention period.

5.2. We strive not to store any outdated, not relevant personal data, thus, upon updating personal data (e.g., corrections, change in the information, etc. in your account), only relevant information is retained. The information concerning personal data history is stored only where it is required by law or for the performance of our activities.

5.3. Clause 2.2 of the Privacy Policy specifies the individual terms of storage of your personal data based on each purpose of use of personal data.

 

6. HOW DO WE PROTECT YOUR PERSONAL DATA?

6.1. The data we collect from you will be within the European Union area but may be transferred or stored outside the EU. The data may also be processed by our staff or our suppliers’ staff working outside the EU. When transferring your data outside the EU, we will take all necessary steps to ensure that your data are processed securely and in accordance with the present Privacy Policy.

6.2. Unfortunately, the transmission of information over the Internet is not completely secure. Although we make every effort to protect your personal data, we cannot guarantee data security when you transfer data to websites: you assume the risks associated with transferring data to websites. Once we have received your data, we apply strict procedures and security measures to protect your data from unauthorized access.

6.3. Should unlikely circumstances arise where we become aware of your personal data security breach that could seriously jeopardize your rights or freedoms, we will notify you immediately after becoming aware of it and having determined what information has been accessed.

 

7. EXTERNAL WEBSITES

7.1. The websites may contain links to external websites, such as websites of our business partners or websites that promote our services. When making use of such links to access any of the websites, please note that these sites and the services accessed through them are governed by their own separate privacy policies and we do not accept any responsibility or liability for these policies or for any personal data collected on these sites or collected for provision of their services, such as contact details or location data. We kindly ask you to review the said policies before submitting personal data on these sites or using any services provided there.

 

8. WHAT RIGHTS DO YOU HAVE?

8.1. When processing personal data, we ensure your rights in accordance with GDPR and the Law on Legal Protection of Personal Data of the Republic of Lithuania. As a personal data subject, you have the following rights:

(a) Know (be informed) about the processing of your personal data;

(b) Access your personal data that we process;

(c) Request the rectification or supplementation, correction of incorrect, inaccurate, incomplete personal data;

(d) Request the erasure of personal data where they are no longer necessary for the purposes for which they were collected;

(e) Request the erasure of personal data if they are processed unlawfully or if you withdraw your consent to the processing of personal data or do not give such consent, which is necessary;

(f) Object to the processing of personal data or to withdraw prior consent;

(g) Revoke your consent to the processing of personal data where, for specific purposes, personal data are processed with your consent;

(h) Request the suspension (other than storage) of your personal data processing in the event of a dispute or verification of the lawfulness of the data processing or the accuracy of the data, as well as in cases where we no longer need your personal data but you do not want us to erase them;

(i) Request that, where technically possible, your personal data collected with your consent or for the purposes of performing the contract be provided in an easily readable format, or request such personal data be transferred to another controller.

8.2. We will make every effort to guarantee your rights as a personal data subject and to create all conditions for the effective exercise of these rights, however, we reserve the right not to comply with your requests when it is necessary to ensure the following:

(a) The performance of the legal obligations imposed on us;

(b) National security or defence;

(c) Public order, and the prevention, investigation, detection or prosecution of criminal offenses;

(d) Important economic or financial interests of the State;

(e) Prevention, investigation and identification of violations of official or professional ethics;

(f) Protection of your rights and freedoms and that of other persons.

8.3. You can submit your requests related to the exercise of your rights to us in person, by post or by electronic means of communication. Upon receipt of your request, we may ask you to provide proof of identity, as well as any additional information we require regarding your request.

8.4. Upon receipt of your request, we will respond to you no later than within 30 calendar days of the receipt of your request and the date of submission of all documents required to provide the response.

8.5. If we deem it necessary, we will suspend the processing of your data, other than storage, until your request has been resolved. If you lawfully withdraw your consent, we will immediately but not later than within 30 calendar days terminate the processing of your personal data, except for the cases provided for in Clause 8.2 of this Privacy Policy and cases established by legal acts, i.e., where the applicable legal acts, our legal obligations, court decisions or mandatory instructions given to us by the authorities oblige us to further process your data.

8.6. If we refuse to comply with your request, we will clearly state the grounds for such refusal.

8.7. Where you do not agree with our actions or the response to your request, you may appeal against our actions and decisions to the competent public authority.

 

9. WHERE CAN YOU APPLY?

9.1. Should you need more information on any issues covered by this Privacy Policy, please contact Headex Group by emailing to: duomenuapsauga@headex.eu

9.2. If you wish to make a complaint about the processing of data, please submit it in writing, providing as much information as possible and using the contact details provided at the end of this document. We will cooperate with you and will make every effort to resolve any issues promptly.

9.3. If you believe that your rights established by the GDPR have been violated, you can lodge a complaint with our supervisory authority – the State Data Protection Inspectorate, although we will first and foremost try to resolve any disputes with you by reaching a mutual agreement.

 

10. HOW WILL CHANGES TO THIS PRIVACY POLICY BE MADE?

10.1. All changes to our Privacy Policy will be posted on the websites. Where necessary, we will notify you of such changes. Any new terms and conditions of this Privacy Policy may also be posted on the websites, and you may need to read and agree to them in order to continue using the websites and/or our Services.

 

Privacy Policy release date: 25 May 2018

The Privacy Policy modified on 3 September 2021.

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