AS DelfinGroup

PRIVACY POLICY

DURING THE RECRUITMENT PROCESS

While taking care of the protection of your privacy and Personal Data, we, the team of AS DelfinGroup (hereinafter - DelfinGroup and we), take appropriate measures to ensure that your Personal Data are safe, and that your Personal Data is processed according to Regulation (EU) 2016/679 of the European Parliament and of the Council on the protection of natural persons with regard to the processing of Personal Data and on the free movement of such data, and repealing Directive 95/46/EC (General Data Protection Regulation) and other requirements and good practice guidelines specified in the legal acts of the European Union and the Republic of Latvia.

This privacy policy provides you with information regarding the processing of Personal Data in the recruitment process, giving you the opportunity to apply for and participate in job competitions.

Term	Description
You	You, as a natural person; we process your Personal Data
Controller	AS DelfinGroup, unified registration number 40103252854, registered address: Skanstes iela 50a, Riga, LV-1013, Latvia
Processor	a natural or legal person, public authority, agency or other body, which processes Personal Data on behalf of the Controller, for example, outsourced IT service providers
Processing	any activities we perform with your Personal Data (including the collection, registration, storage, viewing, use, disclosure, transmission, deletion or destruction of your Personal Data)
Regulation No. 2016/679	Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 on the protection of natural persons with regard to the processing of Personal Data and on the free movement of such data, and repealing Directive 95/46/EC (General Data Protection Regulation)
Privacy Policy	this privacy policy during the recruitment process
Personal Data	any information that is or may be relevant to you (e.g. your name, surname, address, telephone number, e-mail address)
Consent	any consent freely and knowingly provided by you by which you consent to the processing of your Personal Data for a specific purpose.
Data State Inspectorate	an institution that supervises the application of the Regulation in the Republic of Latvia.

WHO PROCESSES YOUR PERSONAL DATA?

The Controller of your Personal Data is AS DelfinGroup, unified registration number 40103252854, registered address: Skanstes iela 50a, Riga, LV-1013, Latvia, Phone: +371 66116688, e-mail address: [email protected]

Data protection officer contact details: [email protected].

In order to implement the personnel selection process, we may entrust the processing of your Personal Data to our Processors - companies that have the appropriate knowledge and skills required to provide specific services (for example, our (IT) system maintainers, marketing activity organisers, etc.). We are responsible for the processing of your Personal Data carried out by the Processors. The Processors can only process your Personal Data according to our instructions and cannot use them for other purposes. These companies are required to protect your Personal Data, in accordance with the law and our cooperation agreement.

WHAT KIND OF YOUR PERSONAL DATA DO WE PROCESS, FOR WHAT PURPOSE AND ON WHAT BASIS, AND WHAT IS THEIR STORAGE PERIOD? Name of the Personal Data set (category) and Description of types of Personal Data
Identification data	Name, surname, personal identification number, date of birth, etc.
Contact Information	Residence address, telephone number, e-mail address, etc.
Information related to the evaluation of the candidate for the position	Curriculum Vitae (CV), application letter, etc. Feedback from your previous employer(s), if any. Announcement of personnel selection results, etc.
Information related to professional activity and education	Information submitted for personnel selection: Work experience (employers), profession(s), position(s), type of occupation(s), length of service; Education, language skills, driving experience, additional education (training, courses, seminars, certificates obtained, etc.) and other skills; Membership in professional and other associations.
Information obtained during job interviews	Our written notes during the job interview, audio or video recordings during the job interview, remote job interviews in audio or video conferencing format.
Set (categories) of Personal Data	Legal basis	Description	Duration of storage
Purpose	Personnel selection (internal and/or external) and evaluation of adequacy for the vacant position
Identification data Contact Information Information related to the evaluation of the candidate for the position Information related to professional activity and education Information obtained during job interviews	The processing of your Personal Data is necessary for the observance of the legitimate interests of the Controller (Article 6(1), Paragraph 1, subparagraph (f) of Regulation No. 2016/679)	Implementation of legal (legitimate) interests of DelfinGroup or a third party. When selecting personnel, we choose the most suitable candidate for the position, evaluating your suitability for the vacant position: i.e. evaluating Curriculum Vitae, application letters, job interviews, feedback from a previous employer, etc.	At the end of the personnel selection process: we will keep the information and documents submitted by you for 12 months as regards a rejected candidate; we will keep the information and documents submitted as regards a recruited candidate in accordance with the deadlines set out in the external legislation and/or internal legislation of DelfinGroup.
Purpose	Participation in another competition for a vacant position
Identification data Contact Information Information related to the evaluation of the candidate for the position Information related to professional activity and education	The processing of your Personal Data is based on the Consent (Article 6 (1), Paragraph 1, subparagraph (a) of Regulation No. 2016/679)	Your Consent to re-use the submitted information (e.g. Curriculum Vitae) in another competition.	After the withdrawal of your Consent or 12 months after obtaining the Consent, whichever occurs first.
Purpose	Processing of requests and complaints received regarding the selection of personnel
Identification data Contact Information Information related to the evaluation of the candidate for the position Information related to professional activity and education Information obtained during job interviews	The processing of your Personal Data is necessary for the fulfilment of legal obligations referable to DelfinGroup or for the observance of the legitimate interests of the Controller and a third party (Article 6 (1), Paragraph 1, subparagraph (c) or subparagraph (f) of Regulation No. 2016/679)	Execution of legal obligations of DelfinGroup in response to your requests or complaints. Execution of requests from auditors and/or external consultants.	Until the request or complaint has been processed. Until the preparation and review of the audit opinion and/or the opinion of the external consultant.
Purpose	Implementation of requirements arising from the personnel selection process
Identification data Contact Information Information related to the evaluation of the candidate for the position Information related to professional activity and education Information obtained during job interviews	The processing of your Personal Data is necessary for the observance of the legitimate interests of the Controller and the third party (Article 6(1), Paragraph 1, subparagraph (f) of Regulation No. 2016/679)	Implementation of legal (legitimate) interests of DelfinGroup or a third party. DelfinGroup defends its rights in the event of a dispute with you during the recruitment process.	Until the claim is processed (e.g. litigation is closed)
Purpose	Processing of requests of state/municipal/investigation and other law enforcement authorities and other state institutions and officials specified in legal acts
Identification data Contact Information Information related to the evaluation of the candidate for the position Information related to professional activity and education Information obtained during job interviews	The processing of your Personal Data is necessary for the fulfilment of legal obligations referable to DelfinGroup (Article 6 (1), Paragraph 1, subparagraph (c) of Regulation No. 2016/679)	Information on the procedure of the recruitment process can be requested by various public authorities, e.g. State labour inspection.	Not applicable, because the processing of Personal Data transferred by the Controller, incl. storage period, shall be determined by the relevant authorities.
Purpose	Archiving
All Personal Data sets obtained during the recruitment process	The processing of your Personal Data is necessary for the fulfilment of legal obligations referable to DelfinGroup (Article 6 (1), Paragraph 1, subparagraph (c) of Regulation No. 2016/679)	The documents you submit can be archived, if you are hired by DelfinGroup.	During the employment relationship and/or during the terms specified in the regulatory enactments.

HOW DO WE COLLECT YOUR PERSONAL DATA?

We obtain your Personal Data from you and/or cooperation partners who specialise in personnel selection (for example, CV-Online Latvia, reg. No. 40003480317), state institutions that provide job search services (for example, the State Employment Agency), as well as from social networks (such as ss.com, LinkedIn, Facebook, etc.).

DO YOU HAVE AN OBLIGATION TO PROVIDE YOUR PERSONAL DATA?

You are not obliged to provide us with your Personal Data, however, if you choose not to provide us with your Personal Data, we will probably not be able to offer you a job with the company.

At the same time, we would like to remind you that you are responsible for providing true information and accurate Personal Data to us, incl. if during the personnel selection process any Personal Data previously provided by you becomes irrelevant, it is your duty to update your Personal Data with us.

TO WHOM DO WE TRANSFER YOUR PERSONAL DATA?

We transfer your Personal Data:

to our cooperation partners (Processors or individual controllers) related to the fulfilment of the purpose of Personal Data processing and provision of services. Your Personal Data is only processed by our partners in accordance with our instructions and may not be used for other purposes; we carefully evaluate our cooperation partners before starting cooperation;
to persons specified in external regulatory enactments (law enforcement institutions, court or other state and local government institutions) in order to fulfil a legal obligation; the transfer of Personal Data is implemented, if a written request is received and the legal basis for such processing of Personal Data is established; the transfer of Personal Data is performed in the manner and to the extent provided by the relevant regulatory enactment;
to third parties in the cases specified in regulatory enactments for the protection of their legitimate interests (for example, in a court proceeding).

DO WE TRANSFER YOUR PERSONAL DATA OUTSIDE THE EU/EEA?

Your Personal Data will not be transferred outside the European Union and the European Economic Area.

There may be situations, when your Personal Data is transferred to our Processors (for example, our (IT) system maintainers, organisers of marketing activities). We, as the Controller of your Personal Data processing, are responsible for the processing of your Personal Data carried out by the Processors. We cooperate with the Processors, if they comply with the Personal Data processing and security standards specified in external regulatory enactments. If our co-operation partners, whom we have assigned to process your Personal Data, perform their processing outside the EEA, then we will ensure that, as far as data security and technical requirements are concerned, the service providers involved will comply with the requirements of Regulation No. 2016/679, other regulatory enactments of the European Union and the Republic of Latvia, and guidelines of good practice.

Our cooperation partners only process your Personal Data in the Republic of Latvia - the transfer of your Personal Data outside the Republic of Latvia is not intended.

WHAT ARE YOUR RIGHTS REGARDING THE PROCESSING OF PERSONAL DATA THAT WE PERFORM?

As a part of our compliance with the privacy and Personal Data protection laws, we act in accordance with your rights, if you submit a written request to us:

Rights	Description
Access your Personal Data	You have the right to receive confirmation from us as to whether or not your data is being processed, and if they are being processed, to access and receive the following information about your data: purposes for data processing; categories of Personal Data; Personal Data recipients or categories of recipients; duration of storage of Personal Data or the criteria according to which the storage period is determined.
Rectify own Personal Data	You have the right to ask us to correct your data, if you find that the information we hold about you is incorrect or incomplete.
Delete your Personal Data	You have the right to request the deletion of your data, and we will comply with this request without delay if at least one of the following conditions is met: data are no longer necessary for the purposes for which they were collected or otherwise processed; You withdraw your consent to the processing of the data and if there is no other legal basis for the processing of the data; if data processing is justified by the legitimate interests of us or a third party, however, the protection of your interests, fundamental rights and freedoms is more important than our or a third party's legitimate interests; if the data have been processed unlawfully; to ensure the fulfilment of a legal obligation specified for us in regulatory enactments.
Restrict the processing of your Personal Data	You have the right to request a restriction on the processing of your Personal Data in our possession, for example if you believe that the data we process is inaccurate.
Object to the processing of your Personal Data	You have the right to object to the processing of your Personal Data, that is based on our legitimate interests.
Receive and send your Personal Data	You have the right to request the issuance of a copy of your Personal Data processed by us, and also to request the transfer of your submitted Personal Data to another controller, if the processing of such Personal Data is based on your Goods purchase agreement and it is technically possible.

Your request as a data subject (hereinafter - the Request) must be in written form or in a form that can be considered as a written form in accordance with the regulatory enactments, for example, an electronic document signed with a secure electronic signature.

In addition, we inform you that no automated individual decisions are made in the personnel selection process.

HOW LONG WILL WE TAKE TO PROCESS YOUR REQUEST?

We will respond to your request without undue delay no later than one month from the date of receipt of your request; if necessary, taking the scope of your request into account, we have the right to extend the deadline for execution of the request by two months. In this case, we will inform you of the reasons for the extension and delay within one month of receiving the request.

HOW WILL WE PROVIDE INFORMATION AT YOUR REQUEST?

We will provide you with information on your request, taking into account, as far as possible, the method of receiving the response to your request, as well as evaluating the security requirements for the transfer of information prepared for you.

WHAT SHOULD YOU DO IF YOU CONSIDER THAT WE HAVE INFRINGED YOUR RIGHTS IN THE PROCESSING OF PERSONAL DATA?

We ensure the processing of your Personal Data in accordance with Regulation No. 2016/679, other requirements specified in the regulatory enactments of the European Union and the Republic of Latvia, and the Privacy policy. If you believe that we have violated your rights to Personal Data protection by processing your Personal Data, you have the right to submit a complaint to us as your Personal Data Controller, to the Data State Inspectorate, or to submit a claim to court in accordance with the regulatory enactments.

HOW DO WE ENSURE THE SECURITY OF YOUR PERSONAL DATA?

We guarantee the non-disclosure and security of your Personal Data by taking appropriate technical and organisational measures, ensuring the physical and environmental security of your Personal Data, restricting access rights to your Personal Data, transmitting your Personal Data in encrypted form, protecting your computer network, personal devices, data backup etc. protection measures, thus also ensuring the protection of your Personal Data against unauthorised access, use or disclosure. As part of the processing of your Personal Data carried out by us, access to your Personal Data is restricted to authorised employees of ours and our partners who need it for the performance of their duties and who only process your Personal Data in accordance with the purposes and grounds of Personal Data processing specified in these Terms, observing Personal Data protection law. Service providers (Processors), to whom we have entrusted the processing of your Personal Data, have been carefully assessed and informed of the set of measures they need to take to ensure the processing, confidentiality and protection of your Personal Data in accordance with legal requirements.

The processors to whom we have entrusted the processing of your Personal Data will ensure the fulfilment of your Personal Data processing and protection requirements in accordance with the laws and regulations, and will not use your Personal Data for other purposes.

HOW DO YOU CONTACT US?

In the case of issues related to the processing of your Personal Data, you can contact us by writing to the e-mail address: [email protected] or our appointed Personal Data protection specialist, by writing to the e-mail address [email protected].

HOW DO WE PROVIDE UP-TO-DATE INFORMATION ABOUT THE PROCESSING OF YOUR PERSONAL DATA?

In order to always have up-to-date information about the processing of your Personal Data, we will ensure the regular review and updating of this Privacy policy in accordance with the requirements of regulatory enactments. Therefore, we encourage you to periodically review the current version of this Privacy policy on our website.