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Privacy policy

We attach great importance to the protection of your personal data and we only collect and process your personal data to the extent necessary for conducting our activities. We process your personal data lawfully, fairly and in a transparent manner, for pre-determined purposes and to the extent necessary for those purposes. When processing your personal data, we seek to ensure accuracy, security and confidentiality as well as appropriate storage and protection of your personal data.

We process your personal data in accordance with the General Data Protection Regulation (hereinafter referred to as “GDPR”), the Law on Legal Protection of Personal Data of the Republic of Lithuania as well as other statutory requirements for the processing of personal data.

The Privacy Policy applies to all individuals whose personal information is processed by us.

 

1. HOW WE COLLECT YOUR PERSONAL DATA

1.1. Your personal data that we process is obtained in the following ways:

   a) When you provide it directly to us. You provide your personal data to us in connection with sending your resume or cover letter to us, applying to vacancies advertised by us on job posting sites, registering on our website, communicating with us by phone, email or during meetings, completing our questionnaires, performing tasks or tests given to us or contacting us through social networking sites (e. g. Facebook, LinkedIn). When you contact us in writing or by e-mail, we collect the information relating to any communication that you send to us.

   b) When you use websites managed by us. When you use websites managed by us, some information (e. g. your internet protocol (IP) address, the access device used, the browser used, number of visits, the pages viewed on our website, the time you spend on the website, and the sites you visited before accessing our website) is collected automatically.

   c)  When we obtain your personal data from third parties in the manner established by statutory regulations and/or this Privacy Policy.

1.2. We may merge personal data received from you with other data that we have collected from other public or publicly accessible sources. For example, we may merge personal data that you have provided with the data obtained through website cookies, data collected for the purposes of providing our services to you, or the data legally obtained from third parties. In exercising your rights, you are entitled to request us to rectify any inaccurate personal data that relates to you.

 

2. FOR WHAT PURPOSES WE PROCESS YOUR PERSONAL DATA

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

   a) For the provision of services. We process your personal data for the purpose of providing services to you or other persons: for identifying the candidates that meet the requirements of our clients; selecting and screening them to determine if they are fit for the position offered; and introducing them to employers or offering them employment with our company.

For this purpose, we process your personal data that you have provided to us (e. g. your resume details, any data relating to our communication with you or other information required for employment), data collected during your use of our website or other websites and/or data obtained from other sources (e. g. recommendation letters from current or former employers or acquaintances; social networking sites; media outlets).

For this purpose, we provide or transmit your information to our partners or clients, i. e. employers who are on the lookout for candidates. They will be the data controllers of your information together with us. We will not transfer your personal data to our clients except for the data processed on the basis of this Privacy Policy. We have contracts in place with our clients whereby both parties are required to safeguard your personal data.

For this purpose, we process your personal data for as long as we provide you with our services. If your personal data is processed in providing services to other persons, we, upon receipt of your consent, will keep your personal data for 2 years from the date of receipt of such consent.

Subject to your prior consent, we may, in providing our services, conduct your (candidate) assessment and testing and video record the assessment and testing process. We may pass the videos and assessment/testing results to the client who requested us to conduct a relevant screening process.

You are entitled to view the videos relating to you and to access the testing and assessment results or to request that the video be copied to your personal storage device.

We will process any videos or testing/assessment results for as long as we conduct a relevant screening process or, subject to your prior consent, for a longer period specified in this Privacy Policy for the purpose of managing the candidate database. If we have reasonable grounds to believe that a crime or other illegal acts have been captured on video or an internal investigation has been initiated, the video will be kept until a relevant investigation and/or court proceedings are terminated.

   c) For the management of our candidate database. After the completion of a specific screening process for which you have provided your personal data, we will process your personal data so that in the future we are able to offer you a job or career opportunities, to recruit and select candidates that fit our clients’ needs, to assess whether those candidates are a good fit for the position offered and to introduce them to employers.

For this purpose, we process the same personal data that is processed for the provision of services, we transfer it to the same persons and we store it for the period of 2 years from receipt of your consent.

   c) For monitoring the quality of our service (recording of telephone calls). When you communicate with us by phone, we record our telephone conversation with you in order to ensure service quality and monitor the provision of our services. 

For this purpose, we process the following personal data: your name, your telephone number, your phone call record (data provided during the telephone conversation), date and time of the call, and name of the person who provides telephone consultation.

For this purpose, we receive your personal data directly from you or we generate it during your use of our services.

We store your personal data for a period of 2 years for this purpose.

   d) For managing work activities of our employees. To the extent permitted or required by law, we process the personal data of our employees in accordance with our internal rules of procedure.

   e) For the purpose of improving the websites managed by us and offering you better services tailored to your needs. We use your personal data, including any personal information that we receive during your use of our websites, are used for the purpose of improving and developing these websites and offering you better services tailored to your needs. For this purpose, we use personal data provided to us by you; personal data that we receive from you during your use of our websites; and personal information about you that we obtain from third parties.

To learn more about how we use cookies and similar technologies, see section 7 of this Privacy Policy.

   f) For direct marketing purposes. Having obtained a consent from you, we process your personal data in order to offer you our services and the services of our partners or other parties involved with us as well as to improve our services.

For this purpose, we process your name, your telephone number, and your e-mail address; we also process the data about the visitors of the websites of the Company or third-party websites relating to the use of such websites.

For this purpose, we will store your data for a period of 2 years from the receipt of your consent.

2.2. If processing of your personal data is based on your consent, and you revoke your consent or it expires, we will terminate the processing of your personal data with the exception of data that prove your consent to be kept for no longer than 10 (ten) years for the purpose of pursuing, enforcing or defending our legitimate claims.

2.3. We will not process your personal data for purposes not compatible with those listed above.

 

3. HOW WE USE COOKIES

3.1. We collect information about you through the use of cookies and similar technologies. Cookies are small text files which can be temporary stored on the hard drive of your device. Cookies are used to recognise you when you return to a website, to remember your browsing history and your site preferences, to provide you with personalised content, to speed up your searches on websites, to create a convenient and user-friendly online environment and to help make it reliable and effective. The use of cookies is a common practice in web browsing which makes it easier for you to navigate the site.

3.2. We use cookies to collect the following information: your internet protocol (IP) address, the access device used, the browser used, number of visits, the pages viewed on our website, the time you spend on the website, and the sites you visited before accessing our website.

3.3. We use the information that we collect by means of cookies to:

   a) ensure proper site functions (to provide you with personalised features);

   b) analyse your browsing habits;

   c) improve and develop our websites to make them better tailored to your needs;

   d) develop our services;

   e) target direct marketing to data subjects.

3.4. Without prejudice to applicable law, we may merge the information obtained by means of cookies with the information collected about a person through other means (e. g. web browsing information, personal data provided by you to us, etc.).

3.5. Websites may use the following types of cookies:

   a) technical cookies are cookies that are essential for the correct functioning of the website;

   b)  performance cookies are cookies, that, while not necessary for the functioning of the website, they help to significantly improve the performance, quality and user experience of the website;

   c) analytical cookies are cookies used for the statistical analysis of users’ browsing methods; this type of cookie collects data in anonymous form;

   d) targeting or advertising cookies are cookies used to display you relevant advertising or other information which may be of interest to you;

   e) social media cookies are cookies that are necessary to share website information on one’s social media account.

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

   a) by not deleting them and/or not changing your browser settings so that cookies cannot be placed;

   b) by clicking the “Accept” button on the cookie bar that show up on websites;

   c) by expressing your consent at the time of registration.

3.7.  You may withdraw your cookie consent at any time. You can do this by changing your browser settings so that cookies cannot be placed. Instructions may vary depending on your operating system and the type of your web browser. More information about cookies, their use and how to refuse are available at http://AllAboutCookies.org or http://google.com/privacy_ads.html.

3.8. In some cases, disabling some cookies, especially technical and performance cookies, refusal to accept cookies or their deletion may slow down your browsing, prevent you from using certain functions within a website or even accessing certain websites.

3.9. All information provided by you on social media sites (including messages, the use of Like and Follow buttons and other communication) is controlled by the managers of social networking sites. We recommend that you read the privacy notices of the managers of social networking sites and contact them directly regarding the use of your personal information. For more information about the privacy policies of the managers of social networking sites, see: https://wwww.facebook.com/policy.php(Facebook); https://www.linkedin.com/legal/privacy-policy (LinkedIn).

 

4. WHOM WE SHARE YOUR PERSONAL DATA WITH

4.1. We guarantee that we will not sell or otherwise provide your personal information to third parties without legal basis and that we will not use it for purposes others than what it was collected for. We will not provide your personal data to third parties in ways other than those specified in this Privacy Policy and in applicable statutory regulations. However, we reserve the right to disclose your personal information if required by law or when requested by legal authorities or prosecution bodies.

4.2. We may transfer your personal data to the companies that are part of the HEADEX Group as well as companies that are engaged in our activities (partners, clients, suppliers). We require that our partners only process your personal data on our instructions and in accordance with applicable laws that ensure the protection of your personal information. We enter into agreements with them whereby parties are strictly required to adhere to personal data protection requirements.

4.3. The above-mentioned service providers have limited opportunities to use your personal data as they are not allowed to use this data for purposes other than those relating to the provision of services.

4.4. A non-exhaustive list of persons and their categories to whom we transfer your personal data is provided in paragraph 2.1 of this Privacy Policy for each purpose of the use of personal data.

 

5. HOW LONG YOUR PERSONAL DATA WILL BE KEPT

5.1. We store your personal data no longer than is necessary for the purposes for which the personal data is processed or as long as we are required by law if a longer data retention period is provided for in applicable laws.

5.2. We aim not to store outdated or irrelevant personal information thus we make sure only relevant information is retained after updating it (e. g. after the account details are revised or modified.). We keep historical data if we are required to do so by law or if it is necessary to conduct our activities.

5.3. Paragraph 2.1 of this Privacy Policy lists retention periods of your personal data for each purpose of the use of personal data.

 

6. HOW WE PROTECT YOUR PERSONAL DATA

6.1. The data we collect from you will be stored within the European Union but it may be transferred or stored outside the EU. Your data may also be processed by our employees or the employees of our suppliers who are based outside the EU. When transferring your data outside the EU, we will take every necessary step to ensure that your data is processed in a safe and secure manner pursuant to this Privacy Policy.

6.2. Unfortunately, the transmission of information via the internet is not completely secure. Although we will do our best to protect your personal data, we cannot guarantee the security of your data transmitted to our sites; any transmission is entirely at your own risk. Once we have received your information, we will use strict procedures and security features to try to prevent unauthorised access.

6.3. In the unlikely event of a personal data breach where that breach is likely to result in a high risk to your rights and freedoms, we will inform you of the breach without delay after we become aware of the breach and after we identify the type of information affected by the breach.

 

7. EXTERNAL WEBSITES

7.1. Our websites may contain links to external websites including the websites of our business partners or websites advertising our services. When clicking through to any of those websites, take note that these websites or services available through them are subject to their own privacy policies and we shall not be responsible or liable for the privacy policies of those external websites or for the personal data (e. g. contact details or local information) collected on those websites or in the course of providing services through those websites. Please make sure you read the privacy policy of any of those websites before providing your personal data on those sites or before using the services offered on them.

 

8. YOUR RIGHTS

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

   a) the right to be informed about the processing of your personal data;

   b) the right to request a review of your personal data processed by us;

   c) the right to request rectification of incorrect, inaccurate or incomplete personal data;

   d) the right to request that your personal data be deleted or destroyed if such data it is not longer necessary for the purposes for which it was collected;

   e) the right to request that your personal data be deleted or destroyed if the processing of such data is unlawful or if you withdraw or decline your consent for the processing of personal data where such consent is required;

   f) the right to object to the processing of personal data and to withdraw the consent you have previously given;

   g) the right to revoke any consent previously given for the processing of personal data where the processing of your personal data for specific purposes is performed on the basis of your consent;

   h) the right to request that the processing activities (except for storage) of your personal data be suspended in the event of disputes or in cases where the lawfulness of data processing or the accuracy of data must be verified or where your personal data is no longer necessary and you do not want us to erase it;

   i) the right to request that (if it is technically feasible) your personal data collected on the basis of your consent or for the performance of the contract be provided in a machine-readable format or request that such data be transmitted to another data controller.

8.2. We will do our best to safeguard your data subject rights and to ensure all necessary conditions for the efficient exercise of those rights. However, we reserve the right to decline your requests where we need to ensure:

   a) the performance of legal obligations imposed on us;

   b) national security and protection of the state;

   c) public order and crime prevention, investigation, detection or prosecution;

   d) important national economic or financial interests;

   e) prevention, investigation and detection of the breaches of professional ethics;

   f) protection of your rights and freedoms of the rights and freedoms of other persons;

8.3. You may submit your requests relating to the exercise of your rights in person, by post or via electronic means. Once we receive your inquiry, we may ask you to provide documentary evidence to verify your identity or other necessary information relating to your request.

8.4. After we receive your request, we will respond to you no later than within 30 calendar days from the receipt of your request and from the submission of all documents necessary for us to respond you.

8.5. If we deem it necessary, we will suspend the processing activities of your personal data with the exception of data storage until your request is resolved. If you withdraw your consent by legitimate means, we shall, without delay and in any event no later than within 30 calendar days, terminate any processing activities of your personal data except for the cases set out in paragraph 8.2 of this Privacy Policy and those set forth in applicable laws, i. e. where further processing of your personal data is required by law or where we are compelled to do so by legal obligations, court decisions or mandatory orders issued to us by relevant authorities.

8.6. If we decline your request, we will provide you with clear reasons for this decision.

8.7. If you do not agree with our actions or our response to your request, you may challenge our actions or decisions by filing a complaint to a competent state authority.

 

9. HOW TO CONTACT US

9.1. For more information on the issues discussed in this Privacy Policy, please contact HEADEX Group at duomenuapsauga@headex.eu

9.2. If you want to submit a complaint regarding our processing of your personal data, you may provide it in writing using the contact details listed at the end of this Privacy Policy. Make sure to include as many relevant details as possible. We will be happy to cooperate with you and we will make every effort to resolve all issues as soon as possible.

9.3. If you believe that your rights have been violated pursuant to the GDPR, you may file a complaint to our local supervisory authority, the State Data Protection Inspectorate. In any event, we will do our best to resolve any disputes through mutual cooperation with you.

 

10. CHANGES TO THE PRIVACY POLICY

10.1. All changes to this Privacy Policy will be published on our websites. If necessary, we will notify you of these changes. New terms and conditions of this Privacy Policy may also be posted on our websites and you may need to read and agree to them so that you can continue using our websites and/or our services.

  

Date of publication: 25 May 2018

Date of revision: 6 March 2019

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