INTRODUCTION
This Privacy Policy defines the way in which AKT RECRUITMENT S.R.L. collects, stores and uses your personal data when you access or interact with the website
www.aktrecruitment.com and its correspondence channels (
email,
telephone,
contact form ) – by where we obtain or collect your data.
We consider ensuring the right to the protection of personal data as a fundamental commitment of our portal, therefore we will make every effort to process your data in full accordance with Regulation (EU) 2016/679 and Law no. 190/2018, as well as any other legislation related to the processing of personal data applicable on the territory of Romania. Since one of the essential principles of this legal framework is transparency, we have prepared this document to inform you about how we collect, use, transfer and protect your personal data when you interact with us through our website web.
We reserve the right to update and amend this Privacy Policy from time to time to reflect any changes to the way we process your personal data or any changes to legal requirements.
In the event of any such change, we will display the modified version of the Privacy Policy on our website, so please check the contents of this Privacy Policy periodically
CATEGORIES OF PERSONAL DATA
For the Processing purposes mentioned in point III below, we process your personal data, hereinafter referred to as “Personal Data”. Personal Data will include, as appropriate, both your Personal Information and Special Categories of Personal Data, as defined below. “Personal information” refers to: name and surname, telephone number, e-mail address, IP address, marital status data, place of residence, Personal Number, CV as well as any other data related to the interaction with us. We collect your Personal Data directly from you in certain circumstances, including:
- When you contact us through the contact form, at your initiative through which
- When you browse, request information or interact on our website (including your IP address, geographic location, browser type and version, operating system, referral source, visit duration, page views and paths site navigation)
- When you voluntarily communicate to us, for any reason, your Personal Data.
E-mail
When you send a message to the email address displayed on our website, we collect your email address and any other information you provide in that email (such as your name, telephone number and the information contained in any signature block in the email).
Legal basis for processing: our legitimate interests (art. 6 paragraph. (1) letter f) of the General Data Protection Regulation);
Legitimate interest: To respond to inquiries and messages we receive and to keep records of correspondence.
Contact form
When you contact us using the contact form, we collect your name, telephone number, CV and email address. We also collect any other information you provide us when you fill out the contact form.
If you do not provide the mandatory information required by the contact form, you will not be able to submit the contact form and we will not receive your request.
The legal basis for processing: our legitimate interests (art. 6 paragraph. (1) letter f) of the General Data Protection Regulation);
Legitimate interest: to respond to questions and messages we receive, to keep records of correspondence, and to contact you with a view to concluding a mediation contract for the search for a job abroad.
PURPOSES OF PROCESSING
We process your Personal Data to the extent permitted or required by applicable law for the following purposes:
- improving the use of this website, including by identifying any errors that occur while visiting/using it by users;
- providing anonymous statistics on how this website is used to AKT RECRUITMENT S.R.L.
- to answer your questions and requests;
- to contact you with a view to concluding a mediation contract for the search for a job abroad – contacting you takes place based on your prior agreement expressed by sending a request through the website’s contact form;
- protecting the security and managing access to our premises, IT and communication systems, online platforms, websites and other systems, preventing and detecting security threats, fraud or other criminal activities;
- for the purpose of complying with court orders and exercising and/or defending our legal rights;
- and for any purpose related and/or ancillary to any of the above.
We do not intentionally process your sensitive personal data. Sensitive personal data is that which reveals your racial and ethnic origin, political opinions, religious and philosophical beliefs, trade union affiliation, genetic data, biometric data, health data or life data or sexual orientation.
You may, in exercising your right to petition, intentionally or accidentally disclose sensitive personal data to us. If you send us sensitive information, we will consider that you have given us your express consent to process the sensitive personal information in accordance with Art. 9 para. (2) lit. a) from the GDPR Regulation. We will use and process your sensitive personal information for the purpose of erasure.
BASIS OF PROCESSING YOUR PERSONAL DATA
Any operation that amounts to a Processing of your Personal Data will be carried out on the basis of one or more of the legal bases below:
- Processing is based on your consent as the legal basis for the collection, storage and use of your Personal Data as permitted by applicable law;
- The processing is necessary for the execution of a contract to which you are a party, or the said Processing is necessary for the conclusion of a contract with you;
- The processing is necessary in order to comply with a legal obligation;
- The processing is necessary in order to protect the vital interests of you or another natural person;
- The processing is necessary for the purposes of the legitimate interests of AKT RECRUITMENT S.R.L., or of a third party, except in cases where your interests or fundamental rights and freedoms prevail over these interests. We use your Personal Data for our legitimate interests, namely to exercise our obligations and rights deriving from a contract concluded with you, to improve our performance and way of working and for administrative and fraud detection purposes.
In cases where the applicable legal provisions require your prior and explicit consent for the Processing of Special Categories of Personal Data, we will process that data only on the basis of your prior and explicit consent.
DATA TRANSFERS, RECIPIENTS AND THE LEGAL BASIS OF THESE TRANSFERS
In the course of our business, we may transfer your Personal Data to:
- telephone service providers;
- email service providers;
- IT service providers;
- the website developer; – ……………..
- specific platforms, including social media;
We may also transfer your Personal Data to our agents, mainly service providers, in order to Process the Personal Data for the permitted purposes, on our behalf and only in accordance with our instructions. The Portal Owner will retain control over your Personal Data and will use appropriate safeguards, in accordance with applicable law, to ensure the integrity and security of your Personal Data in relation to those proxies.
Otherwise, we will only pass on your Personal Data when you instruct us or give us permission, or when we are required to do so by applicable law or by requests from judicial or official bodies.
We may transfer your Personal Data outside the country. Some recipients of your Personal Data may be located in countries in relation to which the European Commission has not issued a decision to ensure an adequate level of data protection, namely: the United States of America or some of the non-European locations.
Some recipients outside the European Economic Area (“EEA”) are certified under the EU-US Privacy Shield, and others are located in countries for which the European Commission has issued compliance decisions [Andorra, Argentina, Canada (for private organizations subject to the Canadian Personal Information Protection and Electronic Documents Act), Switzerland, the Faroe Islands, Guernsey, Israel, Isle of Man, Jersey and New Zealand]. In each case, the transfer is recognized as providing an adequate level of data protection from the perspective of European data protection legislation (Art. 45 GDPR).
We can conclude data transfer contracts based on the Standard Contractual Clauses (European Commission Decision 2010/87/EU and/or European Commission Decision 2004/915/EC), according to Art. 46 (5) GDPR or using other appropriate means, ensuring- that all other recipients outside the EEA will provide an adequate level of data protection for the Personal Data, and that there are adequate technical and organizational security measures in place to protect the Personal Data against accidental or unlawful destruction, loss or alteration accidental, unauthorized disclosure or access and against all other unlawful forms of Processing.
SECURITY OF YOUR PERSONAL DATA
Together with the developers of the portal, we have implemented appropriate technical and organizational measures to preserve the confidentiality and security of your Personal Data, in accordance with internal procedures regarding the storage, transmission and access of Personal Data. Personal Data may be stored on our Personal Data technology systems or in hard copy.
The transfer of information over the Internet is not entirely secure and if you send us information over the Internet (by email, through our website or through any other means of contact and correspondence), you do so entirely at your own risk. We cannot be liable for any expense, loss of profit, damage to reputation, damages, liabilities or any other form of loss or damage suffered by you as a result of your decision to submit information to us by such means.
RETENTION PERIODS
The personal data processed for the purposes mentioned herein will be kept only as long as necessary, but not more than 60 calendar days, as well as subsequently for the retention periods required by the applicable legislation, as the case may be. If a legal action is initiated, the Personal Data may be kept until the end of this action, including any appeal or appeal periods, and then it will be deleted or archived, according to the provisions of the applicable legislation.
In principle, we will retain your Personal Data for as long as required or permitted by applicable law. Subsequently, upon expiry of these periods or upon the exercise of one of your rights in accordance with the law, we will remove/delete your Personal Data from our systems and records and/or take steps to anonymise it so that you can no longer be identified based on them.
YOUR LEGAL RIGHTS
If you have declared your consent to Processing activities, you can withdraw this consent at any time with future effect. Such withdrawal will not affect the lawfulness of the Processing prior to the withdrawal of consent. As a general rule, in cases where you withdraw your consent, the Processing of your Personal Data will no longer be permitted and appropriate steps will be taken to delete any records of your Personal Data. However, if the Processing is strictly necessary and the Processing could be based on other legitimate grounds provided by applicable law, we will proceed with that Processing and will inform you accordingly.
Under the terms of applicable law, you have the following rights:
- The right of access: You have the right to be informed, upon request, if your Personal Data is being processed, and if so, you have the right to request access to it. The information includes, among other things, the purposes of the Processing, the categories of Personal Data affected and the recipients or categories of recipients to whom your Personal Data has been or will be transmitted. You have the right to obtain a copy of the Personal Data processed.
- Right to rectification: You have the right to obtain from us the rectification of your incorrect Personal Data. Depending on the purpose of the Processing, you have the right to complete incomplete Personal Data, including by means of an additional statement.
- Right to erasure (“right to be forgotten”): You have the right to ask us to erase your Personal Data.
- The right to restriction: You have the right to request the restriction of the Processing of your Personal Data. In this case, the respective data will be marked and can be processed by us only for certain purposes.
- The right to data portability: You have the right to receive your Personal Data that you have provided to us in a structured, common and machine-readable format, and you have the right to transmit this data to another entity without objections from us.
- Right to object: You have the right to object, on grounds related to your situation, at any time to our Processing of your Personal Data, and we may be asked to stop processing your Personal Data. If you have the right to object and you exercise it, we will no longer process your Personal Data for that purpose. Exercising this right is free of charge.
This right may be invalidated in particular if the Processing of your Personal Data is necessary for the formalities related to the conclusion of a contract or for the fulfillment of a contract already concluded.
AKT RECRUITMENT S.R.L. does not knowingly contact or collect information from persons under the age of 18, except in the case where – in compliance with the age criteria and the conditions of validity of the mediation reports provided by the legal provisions – through the contact form the minors express their the intention to participate, as interns, during the period allocated for this purpose by the company.
If we come into possession of such information and are made aware of it, we will obtain appropriate parental consent to use this information or, where this is not possible, we will delete the information from our databases.
You can exercise your aforementioned rights and learn more about these rights by submitting a written request to us, as the data controller, by email to
info@aktrecruitment.com
You also have the right to file a complaint with the National Supervisory Authority for the Processing of Personal Data.
VERSIONS OF THIS PRIVACY POLICY
This Privacy Policy enters into force on 26.06.2024.