Privacy Notice for Job Applicants.
This Privacy Notice explains how we, XTEN Limited, acting as a controller, our subsidiaries and affiliates (jointly referred to as XTEN, we, us, our, or similar derivatives) process personal information during our hiring activities. This Privacy Notice is directed at any person who is considered a job applicant, a candidate for a role or is otherwise engaging with us with respect to our hiring process (Candidate, you or any derivatives thereof).
The purpose of this Privacy Notice is to explain to you and other data subjects which personal information we collect, which processing principles apply, which legal basis for processing we rely on, how your personal information is processed, transferred and how long it is retained. This Privacy Notice also explains your rights with regard to your Personal Information.
We are a data controller in relation to your Personal Information. This means that we are responsible for deciding how we store and use personal information about you. We may engage other persons to process your personal information according to our instructions – data processors.
If you have any questions regarding this Privacy Notice or other data protection or privacy matters, please send an inquiry to privacy@strikerz.inc.
What Personal Information is Collected?
Your contact details:
Your full name or preferred referrals (if applicable);
Country and city of your residence;
Telephone number, primary email address, messengers contact details (if applicable).
Other personal details:
Gender, date of birth, marital status.
Educational and training information:
Academic educational background, degrees, diplomas, certificates;
Trainings and professional examinations;
Additional training information.
Professional experience:
Legal company names and their brand names (trade names), job titles, job descriptions.
Job preferences:
Job openings of your interest;
Salary, bonuses, and other benefits preferences;
Office location preferences;
Preferences for remote / hybrid / office mode of work.
Organizational details:
Information about your citizenships, residence and work permits obtained.
Other:
Any other information provided by you in your CV, resume, or cover letter;
Any information provided by you to us in your correspondence or phone calls, during interviews;
CCTV recordings (if visiting offices of XTEN for an on-site interview).
Collection of Sensitive Information.
We do not collect sensitive types of personal information (i.e., sexual orientation, religious beliefs, or political affiliation). We do not envisage that we will process criminal record information.
If you decide to disclose any information about your health, that information will be used for the sole purpose of adjusting the hiring process to meet your needs. We do not require mandatory disclosure of such information and do not retain it.
Why Do We Process Your Personal Information?
We will rely on four legal bases to collect, store, transfer or otherwise process your personal information for the designated purposes:
Processing is necessary for our legitimate interests
Assessment of your skills, qualifications, and suitability for the role.
Communication with you during the recruitment process.
Keeping records related to our hiring processes.
Your consent to processing of your Personal Information
Carrying our reference checks.
Retaining your CV in our HR database to inform you of other opening job opportunities.
Purpose of processing
Legal basis
Verification of your legal capacity to execute a contract.
Drafting and executing a service or employment contract.
Processing is necessary to execute a contract
Confirming whether you have necessary documents to commence employment in the chosen / agreed location.
Processing is necessary for compliance with our legal obligations
How Do We Collect Your Personal Information?
We collect personal information about candidates from the following sources:
You, the Candidate.
An employee who referred you to us by providing us with your CV and contact information.
Recruitment agencies that provide us with your CV and contact information.
Your publicly available profiles published on professional platforms, for example such as LinkedIn, Behance, ArtStation, etc.
What Will Happen If You Fail to Provide Personal Information.
If you fail to provide the requested information which is necessary for us to consider your application (such as evidence of your professional qualifications or employment history), we will not be able to process your application. For example, if we require references for the role and you fail to provide us with the relevant details, we will not be able to proceed with your application consideration.
Automated Decision-Making
You will not be subject to decisions that will have a significant impact on you based solely on automated decision-making.
When Do We Share Your Personal Information?
We may share and / or transfer your personal information in the following cases:
Internally. We will disclose your personal information to the personnel involved in our hiring and recruitment processes (to both, employees and external contractors).
Affiliates. We may share your personal information with our subsidiaries and affiliates.
Third-party service providers. We may share your personal information with our third-party service providers in connection with provision of the services related to recruitment and talent acquisition (i.e., our applicant tracking systems, email service providers, internal communication systems and messengers). We do not allow our third-party service providers to use your personal information for their own purposes. We only permit them to process your personal information for the specified purposes and in accordance with our instructions.
Public authorities. Your personal information may be disclosed to public authorities subject to a valid court order, warrant or subpoena.
Corporate transactions. Your personal information may be disclosed or transferred to relevant third parties in the event of, or as part of the due diligence for, any proposed or actual sale, merger, consolidation, joint venture, transfer, or other disposition of all or part of our business, assets, or stock (including in connection with any bankruptcy or similar proceeding). If a corporate transaction occurs, we will provide notification of any changes to the control of your information, as well as choices you may have.
When and where we may transfer your personal information to a third-party, we will do so subject to necessary safeguards and precautions, including verifying that the third party has necessary technical and organizational measures in place to ensure compliance with the GDPR.
During our ordinary course of business, we may share your personal information with entities located outside the European Economic Area. It may be in our legitimate interest to transfer your personal information to a country that does not provide the same level of personal information protection (legislation- or enforcement-wise) as EEA countries. Where this is the case, we will rely on appropriate safeguards, including standard contractual clauses as amended from time to time by the European Commission.
Data Security
We have put in place appropriate administrative, technical and physical security measures to prevent your personal information from being accidentally lost, misused, altered, disclosed or accessed in an unauthorized way.
In addition, we provide your personal information to employees, contractors and other third parties on a strict ‘need-to-know’ basis. They will only process your personal information under our instructions, and they are subject to confidentiality obligations.
We have put in place 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.
How Long Will We Retain Your Information?
We will retain your personal information for a period of 24 months after we have communicated to you our decision about your application. We retain your personal information for that period so that we can show, in the event of a legal claim, that we have not discriminated against candidates on prohibited grounds and that we have conducted the recruitment exercise in a fair and transparent way. After this period, we will securely destroy your personal information in accordance with the legal requirements.
If we wish to retain your personal information in our HR database so that we can contact you with regard to any future open job positions, we will write to you separately, seeking your explicit consent to retain your personal information for a fixed period for the designated purpose.
Your Rights to Your Personal Information
You have the rights to your personal information as described below and you can exercise them by contacting us at privacy@strikerz.inc. We shall consider your request under applicable legal provisions. In case we receive particular requests, we may be obligated to verify such request and thus, ask you to verify your identity before complying with the request to protect your privacy and security.
You have the right to:
Request access to your personal information. This enables you to receive a copy of the personal information we have about you and verify that it is processed lawfully.
Request correction of the personal information that we have about you. This enables you to have any incomplete or inaccurate information we have 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 legal reason for us to further process it.
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 of your personal information.
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 basis for processing it.
Request the transfer of your personal information to another party.
Withdraw consent. Once we have received notification that you have withdrawn your consent, we will no longer process your application and, subject to our retention policy, we will dispose of your personal information securely. Please be advised that we do not require your consent if we use your personal information to fulfil our legal obligations or exercise specific rights vested in by law.
If you want to review, verify, correct or request erasure of your personal information, object to the processing of it, request that we transfer a copy of your personal information to another party, or withdraw consent to processing, please contact us at privacy@strikerz.inc.
Your requests and grievances will be considered free of charge. We will take appropriate efforts to resolve your issues within one (1) month, unless the law establishes other deadlines, in which case we will inform you of such in writing.
If you believe that an infringement of GDPR has taken place, you may lodge a complaint with a data protection authority: the Commissioner for Personal Data Protection (http://www.dataprotection.gov.cy/, commissioner@dataprotection.gov.cy).