Applicants for vacancies privacy policy

In this personal data processing policy of vacancies applicants (hereinafter referred to as "Policy") we present in accordance with the European Union General Data Protection Regulation no. 2016/679 (EU) (hereinafter referred to as „Regulation“) mandatory information about personal data processing when you apply for vacancies published by UAB „Click2Sell“ (hereinafter - Cardinity) (i. e. what kind of personal data of the applicants and for what purpose we collect and process it, how long we keep it and etc.).

When you apply for vacancies published by Cardinity and submit to us your curriculum vitae (CV), cover letter also other documents and (or) data, regarding your vacancy application or conclusion of employment agreement with you, you acknowledge and agree, that:

-        You have read this Policy, understood it and agree with it;

-        You agree, that Cardinity would use and process your personal data for the purposes stated in this Policy;

Data processor, that sets out the purposes and means of your personal data, is Cardinity (company id – 300110581, reg. address - Saulėtekio ave. 15-1, LT-10224 Vilnius, Lithuania; phone number - +370 6444 6667). Regarding any matter related to processing of your personal data we advise you to contact Cardinity data protection officer via email [email protected].

Cardinity has the right to any time update and (or) change this Policy at its discretion. Updated or (and) changed Policy enters into force after it is published in our website. We advise you to regularly visit our website, so you would be up to date with the newest version of this document.

Terms that are used in this Policy are defined the same as in Regulation.

How do we process your personal data?

We process your personal data in accordance with the following principles:

-        Your personal data are processed in a lawful, fair and transparent manner (principle of legality, fairness and transparency);

-        Your personal data is stored for specified, explicit and legitimate purposes and are not further processed in a way incompatible with those purposes (purpose limitation principle);

-        Your personal data are adequate, relevant and only necessary for the purposes for which they are processed (data reduction principle);

-        the personal data processed are accurate and, where necessary, kept up to date (principle of accuracy);

-        Your personal data are stored in a form that allows the identification of the person for no longer than it is necessary for the purposes for which your personal data are processed (principle of limitation of the retention period);

-        Your personal data are processed in a way to ensure adequate security of personal data through appropriate technical or organizational measures, including protection against unauthorized or unlawful processing and against accidental loss, destruction or damage (principle of integrity and confidentiality).

What is the purpose of processing your personal data?

We process your personal data for the following purposes:

-        to select employees for the vacancies published by Cardinity (i.e. to assess your suitability for the vacancy; to contact you regarding the provision of additional information related to your candidacy; to assess your suitability for future recruitment);

-        to create and submit to you an offer to conclude an employment agreement (in case we decide that you are a suitable candidate for a vacancy).

What is the legal basis for the processing of your personal data?

The legal basis for the processing of your personal data is:

-        Your consent as a data subject to the processing of personal data, which you disclose to us by submitting your curriculum vitae (CV), cover letter, recommendations and/or other documents and/or data related to the application for a vacancy;

-        Your consent as a data subject to the processing of personal data you provide to employment, personnel selection and / or mediation services, which also includes the right to provide your personal data to potential employers (including Cardinity), enabling such potential employers to process your personal data during the selection of employees for vacancies and the evaluation of your candidacy;

-        an intention to conclude an employment agreement;

-        fulfilment of the obligations imposed on the company by law and ensurance of the legitimate interests of the company.

What kind of personal data do we process?

During the selection of employees, we collect and process the following personal data of you: first name, last name, date of birth, address of residence, phone number, e-mail address, education, work experience (workplace, period of work, duties, responsibilities), acquired competencies and skills, trainings / courses listened, languages ​​learned, computer skills, desired salary, personal characteristics, recommendations (name, surname, contact, content of the recommendation of the person providing the recommendation), other voluntary provided personal data contained in your CV and / or other documents submitted by you.

In case we decide you are the most suitable applicant for the vacancy and offer you to conclude an employment agreement, for the purposes of employment agreement conclusion we collect and process the following personal data about you: first name, last name, personal identification number, social security number, address of residence.

Where can we get your personal data?

To pursuit the objectives set out in this Policy, your personal data may be obtained by receiving it:

• directly from you, when you voluntarily provide your personal data to us and / or at the additional request of Cardinity (e.g. by sending your curriculum vitae (CV), by applying to our vacancy via job search portals, contacting us by phone, email, during meetings, etc.);
• from third-parties, when we receive your personal data from job search portals, recruitment companies, other entities that provide selection and/or mediation services.
• from your former employers (after informing you in advance, Cardinity may contact your previous employers and ask for their opinion on your qualifications, professional abilities and/or subject characteristics);
• from your current employer (after informing you in advance, Cardinity may contact your current employer and ask for opinion on your qualifications, professional abilities and/or subject characteristics);
• from publicly available sources (social networks, press, etc.);
• in accordance with legal procedures and for legitimate purposes from other sources (e.g. registers).

To whom can we transfer your personal data and in what territory do we process it?

In order to achieve the objectives set out in this Policy, we may transfer your personal data without your separate consent to:

• service providers/advisors (if any) who provide services related to personnel selection to Cardinity;
• to third parties, when required by law or when necessary to conclude an employment agreement with you or to protect the legitimate interests of Cardinity.

Your personal data may also be provided to third parties at your request.

We process your personal data within the European Union (EU) and the European Economic Area (EEA) and do not transfer it to third countries.

How long do we process and store your personal data?

We will process and store your personal data as an applicant during the selection of employees:

• until the end of the selection for the vacancy to which you have applied, but in all cases not longer than 3 (three) months from the date of receipt of your CV; or
• until the date of revocation of your consent to the processing of personal data, if you submit such revocation before the end of the selection or the expiry of the 3 (three) month period.

In case we wish to store your personal data after the specified deadline (for the purpose of submitting a job offer to you again), we will inform you about it and, with your consent, will protect your personal data for no longer than 1 (one) year after the end of the respective selection.

In the event that we decide that you are the most suitable candidate for a vacancy and offer you to conclude an employment agreement, we will protect your personal data related to the conclusion of the employment agreement for the entire term of the employment agreement and and after its expiration for a term specified by the law.  

How do we protect your personal data?

We protect your personal data by ensuring its confidentiality and limited access (i.e. your personal data can only be accessed and processed by authorized persons who select candidates for vacancies). We process your personal data in accordance with the requirements of the applicable legal acts of the EU and the Republic of Lithuania. We also use a variety of technological tools and procedures to protect your personal information from unauthorized access, use and disclosure.

What rights, as a data subject, do you have?

As a data subject, you have a right to:

• revoke your consent of the processing of your personal data and to not consent to the processing of personal data. Withdrawal of consent to the processing of personal data will not affect the lawfulness of the processing of your personal data carried out before such withdrawal;
• receive information on whether Cardinity processes your personal data and, if so, get acquainted with your personal data and how they are processed;
• require the correction of incorrect or, depending on the purposes for which the personal data are processed, the addition of incomplete and/or inaccurate personal data;
• in the circumstances stated in the Regulation (when personal data have been processed unlawfully, the basis for processing has disappeared, etc.) the right to request the destruction of your personal data or the suspension of the processing of your personal data (excluding storage). This right does not apply if the obligation to process this personal data for the company is established by law;
• request for data transfer;
• submit a complaint to the State Data Protection Inspectorate (address - L. Sapiegos St. 17, 10312 Vilnius (Entrance from the left), website address - www.vdai.lrv.lt/), if you think that your personal data has been processed in violation of your rights / legitimate interests.

All inquiries, requests and/or complaints related to the exercise of the data subject's rights must be provided in writing.

We will respond to an inquiry, request and/or complaint regarding the personal data subject‘s rights exercise stated in this Policy no later than within 30 (thirty) calendar days from the date of receipt of your inquiry, request and/or complaint.

In order to exercise the rights of your data subjects, it may be necessary to identify you. Without identity verification, it will not be possible to ascertain whether the person whose personal data are being processed is really applying, so it will not be possible to exercise your rights as a data subject.

An inquiry, request and / or complaint received from you in connection with the exercise of the data subject's rights may be refused, or an appropriate fee may be charged if the inquiry, request and/or complaint is manifestly unfounded or redundant, as well as in other cases specified by law.

In case you would like to exercise your data subject's rights or have other questions regarding the processing of your personal data, we advise you to first contact the Data Protection Officer of Cardinity at the contacts indicated at the beginning of this Policy.

Final Provisions.

The law of the Republic of Lithuania applies to this Policy and the relationship between the data subject and the data manager. All disputes arising from this Policy and the relationship between the data subject and the data controller shall be resolved through negotiations, and in case of their failure - in the competent court of the Republic of Lithuania in accordance to the registered office of Cardinity.