UAB Web Peppers Baltic LTD (hereafter “Web Peppers”) is committed to protecting the privacy and security of your personal information.

This privacy notice describes how we collect and use personal information about you during and after your application process, in accordance with the General Data Protection Regulation 2016 (“GDPR”).

This privacy notice applies to all applicants based in the European Economic Area and Switzerland. We may update this privacy notice at any time. Where we can, we will notify applicants of substantial changes to the privacy notice.

We are required under data protection legislation to notify you of the information contained in this privacy notice.

This privacy notice does not imply in any way any contract of employment or contract for services or any other relationship between you and Web-peppers.

THE KIND OF INFORMATION WE HOLD ABOUT YOU

• Personal contact details such as name, title, addresses, telephone numbers, and personal email addresses;
• Date of birth;
• Your CV, professional social media profile if used as part of an application such as LinkedIn, cover letter, application forms and other information regarding your employment history such as dates of employment, job titles, job descriptions, skills, reason for leaving, previous salary and benefits information, any photographs of you contained in your CV, areas of interests, notice periods/availability for employment;
• Your salary expectations and details of any offers made by us to you and your responses;
• Interview history, questions, notes and technical assessment results;
• How we obtained your data – from an application by you, through an agency or from a third party website that you had used to seek employment.

HOW IS YOUR PERSONAL DATA COLLECTED?

We mainly collect personal information about applicants from:

• Directly from you, email applications, forms on our website;
• From third party websites and job boards that you have used to seek employment such as LinkedIn, Xing etc;
• From third party websites that help us obtain your contact details only from publicly available sources (if we do not already have it).

HOW WE WILL USE INFORMATION ABOUT YOU?

We only use your personal information for the following purposes and legal bases:

DATA SHARING

Given the nature of Web Peppers business, from time to time our clients would like to receive summary CVs of applicants like you. We aim to first provide anonymized summary CVs but this is not always possible. We will do our best to inform you of any such disclosure in advance.

We may also use third party communication providers to help us manage communications around our recruitment and information campaigns. Typically, we will only share your name and email address.

We may also need to use third party service providers, for example, to help host our websites or servers. We contractual terms in place to protect your personal data.

We may need to disclose all or any part of your personal information if required to do so by law, or pursuant to a request from a governmental or regulatory entity/body or if we believe in good faith that such disclosure is necessary to (1) comply with legal or regulatory requirements or for the purposes of compliance with legal process; (2) prevent crime; (3) prevent any terrorist activity or threat to national security; (4) protect the safety or wellbeing of users of our staff or any other person.

DATA SECURITY

We have put in place appropriate security measures to prevent your personal information from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your personal information to those employees, contractors and third parties who have a business need to know. They will only process your personal information on our instructions and they are subject to a duty of confidentiality.

We have put in place some procedures to deal with any suspected data security breach and will notify you and any applicable regulator of a suspected breach where we are legally required to do so.

DATA RETENTION

How long we will keep your information for?

We will only retain your personal information for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements. To determine the appropriate retention period for personal data, we consider the amount, nature, and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal requirements.

After an unsuccessful application, we will aim to keep some or all of your personal data to the extent we need to for a period of 6 months after the last activity to consider you for any other job openings across Web Peppers and for legal/record keeping purposes.

Web Peppers has asked you to consent to us storing your personal data after that initial period. Where you have given us your consent, we apply the following retention guidelines to your personal data:

• After 6 months of no activity, we will minimise your personal data but at a minimum will retain your CV and information contained in it.
• Within two years of no activity, we will aim to contact you to understand whether there are any roles fot you which may be suitable for you. We may also contact you at any point up to this period, if we consider we have a potential suitable position for you and if you have opted in to receive any information generally about our recruitment campaigns.
• If we do not hear from you, we will either delete your profile or archive your profile and create a dummy profile with only one data field (such as your email address) to help link any future applications.

You may withdraw your consent to Web Peppers retaining your personal data beyond the initial 6 months period after an unsuccessful application.

If you do not consent to the retention of your data as set out here or you withdraw your consent, after 6 months of no activity or unsuccessful application, Web Peppers will take reasonable steps to either delete your profile or archive your profile and create a dummy profile with only one data field (such as your email address) to help link any future applications. This will not affect your ability to receive information on our recruitment campaigns.

In some circumstances, we may anonymise your personal information so that it can no longer be associated with you, in which case we may use such information without further notice to you.

YOUR RIGHTS IN CONNECTION WITH YOUR PERSONAL DATA

Under certain circumstances, by law you have the right to:

• Request access to your personal information (commonly known as a “data subject access request”). This enables you to receive a copy of the personal information we hold about you and to check that we are lawfully processing it.
• Request correction of the personal information that we hold about you. This enables you to have any incomplete or inaccurate information we hold about you corrected.
• Request erasure of your personal information. This enables you to ask us to delete or remove personal information where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal information where you have exercised your right to object to processing.
• Object to processing of your personal information where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground. You also have the right to object where we are processing your personal information for direct marketing purposes such as our recruitment campaigns emails.
• Request the restriction of processing of your personal information. This enables you to ask us to suspend the processing of personal information about you, for example if you want us to establish its accuracy or the reason for processing it.
• Request the transfer of your personal information to another party.

If you want to review, verify, correct or request erasure of your personal information, object to the processing of your personal data, or request that we transfer a copy of your personal information to another party, please contact hr@web-peppers.com in writing.

No fee usually required

You will not have to pay a fee to access your personal information (or to exercise any of the other rights). However, we may charge a reasonable fee if your request for access is clearly unfounded or excessive. Alternatively, we may refuse to comply with the request in such circumstances.

What we may need from you

We may need to request specific information from you to help us confirm your identity and ensure your right to access the information (or to exercise any of your other rights). This is another appropriate security measure to ensure that personal information is not disclosed to any person who has no right to receive it.

QUESTIONS, REQUESTS AND COMPLAINTS

CONTACT DETAILS

By post:

Legal Team (Privacy)

UAB Web Peppers Baltic LTD

Email: hr@web-peppers.com

09/12/2019