Candidate Privacy Notice

Viseven, its subsidiaries and/or affiliates (hereinafter – “Viseven”, “us” or “we”) are committed to respecting your privacy and protecting your personal data.

1. Purpose

This notice (the “Notice”) is designed to provide you with information regarding your personal data processing if you use Viseven’s online career resources, when you apply for a job at Viseven, undertake pre-hire and/or onboarding actions, background check and after your application process, in accordance with the General Data Protection Regulation (the “GDPR”) or other locally applicable data privacy legislation. The Notice does not imply in any way any contract of employment or contract for services or any other corresponding contractual relations between you and Viseven.

The data controller of any information collected according to this Notice is a Viseven company constituting a party to a binding agreement which establishes any contract of employment or contract for services or any other corresponding contractual relations between you and such Viseven company. For example, if you apply for a role in Poland, Viseven’s Polish entity, Viseven Poland sp. z o. o., is the data controller. We may share your personal information within Viseven group, and the Notice applies to any Viseven entity processing your personal data as a data controller.

Viseven, its subsidiaries and/or affiliates that are part of Viseven group are listed in Viseven`s Privacy Policy (https://viseven.com/privacy-policy/, the “Privacy Policy”). The Notice should be read in conjunction with the Privacy Policy.

We are required under data protection legislation to notify you of the information contained in the Notice. It is important that you read the Notice so that you are aware of how and why we use your personal data.

2. Scope of personal data we collect, the purpose and legal basis for processing that data

As defined in Section 2 of the Privacy Policy, personal data is any information which is related to an identified or identifiable natural person.

You provide us with certain personal information for recruitment purposes, as well as for conducting a background check to better assess your suitability for the job offered. We assure you that the information you provide for us will only be used to assess your candidacy in recruiting for the applied position at Viseven. Therefore, we only collect and process data that is necessary and relevant to the performance of the job you have applied for. Viseven is responsible for the processing of personal data, including maintaining the confidentiality of the submitted data.

The information that we may collect and process you as part of our recruitment and background check procedures may contain the following:

When we receive your application: The information appears from your application, your CV and any enclosed documents.

This typically includes the following information (the list is non-exhaustive): name, address, date of birth, gender, phone number, email address, marital status, educational background, professional qualifications, career history, language qualifications and other relevant qualifications and written recommendations/references.

In general, we use Article 6(1)(b) and Article 6(1)(f) of the GDPR as the legal basis for processing, because we need to process this information in order to determine whether you are the right candidate for the position you are interested in and applied for, and for the future contract negotiation/preparation stage.

When we consider your application: If we agree to a job offer, we will register your name, address, date of birth, phone number, email address, national identification number, and if you have provided it, written recommendations/references.

In general, our legal basis for processing is Article 6(1)(b), 6(1)(c) and 6(1)(f) of the GDPR. We may also, depending on the circumstances, use Article 6(1)(a) or Article (9)(2)(a) of the GDPR. In cases where the nature of the data we will collect about you is based on Article 6(1)(a) or Article 9(2)(a) of the GDPR, we will separately request your consent for such processing.

At job interviews: We may make a note of some of the information disclosed during the interview(s) for the purpose of the final evaluation of the applicants for the position. We will only use relevant information when determining whether to offer you a job.

In general, we use Article 6(1)(b) and Article 6(1)(f) of the GDPR as the legal basis for processing. It is necessary for us to process such information in order to determine whether you are the right candidate for the position.

Information from social media: When recruiting for positions with us, it may be relevant to obtain additional information from the Internet, including social media, e.g. LinkedIn, Facebook, Instagram, Twitter, etc. We do that in order to determine if your profile suits our business and the specific position.

We use Article 6(1)(f) of the GDPR as the legal basis for processing when we obtain information about applicants from social media. It is necessary for us to process such information in order to determine whether you are the right candidate for the position.

References: For some positions, it is necessary to obtain references from former employers. We do that in order to check that the information you have provided to us during the employment process is correct and true. If we want to obtain information about you from your current or former employer, we will ask you for the contact details of representatives from your current or former employer who can confirm your professional skills and qualities.

The legal basis for processing is our legitimate interest, cf. Article 6(1)(f) of the General Data Protection Regulation.

In addition, we may collect, and process information about you obtained from public sources, including information that you have yourself made public or which is made public on the basis of any applicable laws (such as but not limited to publicly accessible social networks, blogs, public registers, court judgements (except criminal), official notices, journalistic articles, etc.). In case we collect and process such information, then you will be notified of any such information and sources thereof.

3. Who has access to your personal data

As a rule, access to your personal data will be restricted to minimize the number of people in Viseven’s global organization who need it for the purposes set out in this Notice, which may include your potential future managers, personnel in HR, IT, Legal, and Finance.

Your personal data may be transferred to another Viseven entity from Viseven group. Moreover, where there is a need, Viseven may share your personal data with third-party service providers (such as recruitment consultants, background screening services vendors, etc.) to assist us with the recruitment and selection. The list of certain third-party service providers we cooperate with is posted in Section 6.4. of the Privacy Policy. Any service

providers to whom your personal data is disclosed are expected and required to protect the confidentiality and security of your personal data and may only use your personal data in compliance with applicable data protection laws.

Unless you are otherwise notified, any transfers of your personal data from within the European Economic Area to third parties outside the European Economic Area (EEA) will be based on an adequacy decision or are governed by the EU standard contractual clauses (a copy of which can be obtained by contacting Legal@viseven.com). Any other, non-EEA originating, international transfers of your personal data will take place in accordance with the appropriate international data transfer mechanisms and safeguards. To the extent your consent is required in your country to transfer your personal data from your country to another country or to a third party, your agreement with this Notice is considered as your consent to transfer your personal data to such country and/or third party. The equal approach is used in relations with Viseven`s affiliates who act as data processors for your personal data.

4. Your rights related to processing of your personal data

Privacy legislation provides you with a wide range of rights related to your personal data control (e.g., the right to request access to the personal data we process about you; request a rectification of your personal data; object to the processing of your personal data; request the erasure of your personal data; request portability of your personal data, etc.). Please refer to Section 10.2 of the Privacy Policy to review the detailed list of your rights.

5. Data Retention

We will only retain your personal information for as long as necessary to fulfil the purposes we collected it for, including for the purpose of satisfying any legal, accounting, or reporting requirements and conducting the recruitment process. 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 unauthorized 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.

If you are given and accept an offer of employment by Viseven, personal data collected during your pre-employment period will become part of your Viseven personnel records, to be retained throughout and for a period after your employment with Viseven.

If Viseven does not employ you, Viseven may nevertheless continue to retain and use personal data collected during the recruitment process in order to consider you for new positions based on your consent.

Viseven determines the retention period of your information based on the following retention criteria:

Viseven retains your personal data as long as it has an ongoing relationship with you;
Viseven retains your personal data to match them against future open roles that you may want to be informed about based on your consent to join Viseven Alumni Club;
Viseven retains your personal data where it is required to do so by a legal obligation to which it is subject;
Viseven retains your personal data where this is advisable to safeguard or improve Viseven’s legal position (for instance in relation to statutes of limitations, litigation, or regulatory investigations).

6. Viseven Alumni Club

We may offer you the possibility to join a talent pool (“Viseven Talent Pool”) and receive e-mails about open positions and events at Viseven. You may unsubscribe from these emails at any time by following the unsubscribe link on any recruitment campaign email from us.

7. Contacting Us

Any communication or correspondence regarding the Notice or any other questions regarding processing of your personal data should be addressed to: privacy@viseven.com

Please note that we are legally obliged to confirm your identity before we can process your request, so you may be asked to provide some further information.

8. Complaints to Supervisory Authority

You have the right to make a complaint at any time to the supervisory authority regarding data protection issues in your home country. A current list of the supervisory authorities in the EU can be accessed here.

Estonia

Estonian Data Protection Inspectorate (Andmekaitse Inspektsioon)
Väike-Ameerika 19
10129 Tallinn
Tel. +372 6274 135
Fax +372 6274 137
e-mail: info@aki.ee
Website: http://www.aki.ee/en

Cyprus

Commissioner for Personal Data Protection
1 Iasonos Street,
1082 Nicosia
P.O. Box 23378, CY-1682 Nicosia
Tel. +357 22 818 456
Fax +357 22 304 565
e-mail: commissioner@dataprotection.gov.cy
Website: http://www.dataprotection.gov.cy/

Poland

The Bureau of the Inspector General for the Protection of Personal Data – GIODO
ul. Stawki 2
00-193 Warsaw
Tel. +48 22 53 10 440
Fax +48 22 53 10 441
e-mail: kancelaria@giodo.gov.pl; desiwm@giodo.gov.pl
Website: http://www.giodo.gov.pl/

9. Version

This version of the Notice was published on October 01, 2024