Last updated: October 26, 2022
The confidentiality and safety of the information you entrust to us are of utmost importance. Please refer to this notice on the processing of personal data to find out more details about the personal data processing activities carried out by Asociatia Proiect Voiajor when accessing the platform available at the www.jobs4ukr.com (“Platform”).
THE PERSONAL DATA CONTROLLER
The controller is Asociatia Proiect Voiajor (hereinafter referred to as "Controller" or "Association"), a non-profit organisation headquartered in Bucharest, District 1, 4-6 Maior Alexandru Campeanu Street, registered at the Special Register under no. 87 / 26.07.2022, Tax Registration Code 46540300.
DEFINED TERMS USED IN THIS NOTICE
Personal data - means any information relating to an identified or identifiable natural person (‘data subject’); an identifiable natural person is one who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person.
Processing - means any operation or set of operations which is performed on personal data or on sets of personal data, whether or not by automated means, such as collection, recording, organisation, structuring, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, alignment or combination, restriction, erasure or destruction.
Controller - means the natural or legal person, public authority, agency or other body which, alone or jointly with others, determines the purposes and means of the processing of personal data; where the purposes and means of such processing are determined by Union or Member State law, the controller or the specific criteria for its nomination may be provided for by Union or Member State law.
Data subject (person of concern) - means an identified or identifiable natural person whose personal data is processed.
PRINCIPLES OF DATA PROCESSING
Association shall take all measures necessary to ensure that the processing of data is carried out in accordance with the principles set out in Regulation (EU) 2016/679 on the protection of natural persons with regard to the processing of personal data on the free movement of such data, and repealing Directive 95/46/EC ("GDPR") and the data protection legislation applicable in Romania. Thus, the following principles are fundamental in the processing of your personal data by the Platform:
Legality, equity, and transparency - we collect and process personal data only when we have a legal basis, and we use it exclusively for the purposes and under the conditions set out in this Privacy Notice. At the time of collecting and processing personal data, you will receive all necessary information related to the processing activities.
Purpose limitations - personal data is collected for well-defined, explicit and legitimate purposes and further processing will not be incompatible with these purposes.
Data minimization - we collect only adequate, relevant, and necessary data in relation to the processing purposes.
Data accuracy - we take the necessary steps to ensure that personal data is accurate and that inaccurate data, given the purposes for which it is processed, is deleted or rectified.
Storage limitations - personal data is stored in a manner that allows identifying the person only for the time necessary to fulfil the purposes for which the data is processed.
Ensuring integrity and confidentiality – personal data is processed in a manner that ensures its adequate safety, including protection against unauthorized or illegal processing against accidental loss, destruction, or damage, by taking appropriate technical or organizational measures.
PURPOSE AND LEGAL BASIS OF THE PROCESSING OF PERSONAL DATA
PROCESSED PERSONAL DATA
We do not collect, nor do we intend to collect, personal data regarding racial or ethnic origin, political, religious, philosophical or similar beliefs, trade union membership, or personal health or sex life data.
When you access or use the Platform, or when you register on the Platform, Association will process personal data about you.
The personal data we process includes the categories mentioned below.
Information provided directly
This refers to your e-mail address, phone number, name, surname, profile picture, billing address, home address, online identifiers, test results, candidates' skills, professional experience, studies, qualifications etc. - all this personal data is generally incorporated in the information necessary to deliver a product/service or to improve the relationship between us and our users. The personal data collected directly is stored to ensure the possibility of performing other activities on our website.
The refusal to provide data for the purposes exposed below may result in the inability of the Association to carry out its activity.
Automatically collected information about you
This is personal data, such as online identifiers, that is automatically stored by cookies and other session tools. For example, information about your shopping cart, your IP address, your shopping history (if any) etc. is part of this category of personal data.
At the same time, for the purpose of responding to you as quickly as possible and for remembering the preferences expressed by you in previous browsing sessions on any of our pages, for making our websites as intuitive as possible and adapted to the device you are using while browsing, but also for preventing and solving any problems you may encounter while browsing, we may process your personal data such as: IP address, cookies, other online identifiers, UUID (Unique Universal ID), browsing history, browsing searches, browsing dates and times, the device from which the browsing is performed, the type of Internet browser used for browsing, information about events occurring on your device (for example, navigation errors), information about the hardware settings of the browsing device, information about the location from which the browsing is performed.
PURPOSE OF PROCESSING YOUR PERSONAL DATA
We process your personal data for the following purposes and on the following grounds:
Execution of a contract to which the data subject (person of concern) is a party (GDPR - art. 6 paragraph 1 letter b)
In order to carry out the contractual relationship between you and the Association, we process your data for the following purposes:
- provide our services. This includes, for example, your identification, account registration, offering other products and services you have requested, promotional items that will be sent to you as a result of a request made by you in this regard, communication with you about such products and services, as well as to notify you about changes to any services;
- inform the Users regarding their Account situation;
- evaluate the Users’ skills and aptitudes during tests and games;
- assist, support, and guide Users with building a CV, finding the right employment and educational opportunities, and navigating the https://jobs4ukr.com platform
- collect socio-economic data which makes us better understand and serve our beneficiaries
- assist, support, and guide recruiters on hiring candidates via the https://jobs4ukr.com platform
Fulfilment of the legitimate interests pursued by the Association (GDPR - art. 6 paragraph 1 letter f)
To achieve the legitimate interests pursued by the Association, we process your data for the following purposes:
- managing business relations and improving the relationship between our Users and us;
- conducting market research;
- for statistical purposes;
- managing and analyzing our user base (visiting behaviour and history) in order to improve the quality, variety and availability of products/services offered/provided.
Consent of the data subject (person of concern) (GDPR - art. 6 paragraph 1 letter a)
Based on your express consent, we process your data for the following purposes:
- the communication of results of the skills and aptitudes assessments, as well as of the CVs to the Employers - if you consent to the communication of this data to the Platform Employers, the data will be transmitted to them, who will then process this data as controllers, in compliance with their own personal data processing policies and procedures;
- sending periodic alerts, using electronic services (e-mail, SMS).
Fulfilment of a legal obligation incumbent on Association (GDPR - art. 6 paragraph 1 letter c)
We may process some of your data for the purpose of providing services on the basis of legal obligations (e.g. for tax reporting or anti-money laundering purposes) or obligations imposed to the Platform through the applicable law.
In the event that we subsequently process the personal data for a purpose other than that of which you have already been informed and which is not compatible with the purposes for which your data were initially collected and which were brought to your attention, Association will provide information regarding that secondary purpose and any additional relevant information.
RECIPIENTS OF PERSONAL DATA
We do not use your personal data in the relationship with third-party companies, partners, or other persons outside the Association. Our policy is to not disclose, share, sell or rent data to third parties, other than as set forth in this Privacy Notice.
The personal data regarding the candidates registered on the Platform will be communicated to the Employers, only based on the express consent of the respective candidate.
We will not disclose your personal data to third parties or public institutions unless we are legally obliged to do so, the provisions of the previous paragraph of this section being applicable. We may disclose your personal data to third parties if you have given your consent or if there are other legal reasons for doing so.
SECURITY OF PERSONAL DATA
Association has implemented reasonable security policies and procedures to protect personal data against loss, misuse, alteration or unauthorized destruction.
To protect your data, we have taken technical and organizational measures, in particular against the loss, alteration or unauthorized access. The measures adopted shall be checked regularly and shall be constantly adapted to the latest applicable technical standards.
We use secure protocols for communication and data transfer (such as HTTPS), we use anonymization and pseudonymization, monitoring our systems for possible vulnerabilities and attacks.
Even if we try our best, we cannot guarantee the security of the information. We commit to notifying the competent authorities of any data protection breach, and we will notify you immediately if there is a threat to your rights or interests. We will do everything reasonably available to prevent the breach of security and to assist the authorities in the event that violations will occur.
Access to your personal data is limited to those who have a real need to know it. The persons who have access to the data have the obligation to maintain its confidentiality.
If you have an account on the Platform, bear in mind that you must keep your username and password secret.
THE RIGHTS OF THE DATA SUBJECT (PERSON OF CONCERN)
In relation to the processing activities carried out by Association that concern you, you have the following rights:
- Withdrawal of consent - if you have been asked for express consent for particular processing, you may withdraw your consent at any time without the withdrawal affecting the lawfulness of the processing carried out on the basis of your consent before it was withdrawn.
- Access - you may request access to your personal data. If you send us such a request, we will provide you with all the information about the purposes of the processing, the categories of data processed, the categories of recipients, the data retention period, your rights to rectify, delete or restrict the data accessed, if applicable.
- Rectification - you may request the rectification of inaccurate data concerning you or the completion of data insofar as it is incomplete.
- Erasure (right to be forgotten) - you may request the erasure of your data if one of the following reasons applies: (1) if your personal data is no longer necessary for the purpose of the processing; (2) if you have withdrawn your consent to the processing of data, in the case of processing based on consent and there is no legal ground for the processing; (3) if you have objected to the processing of the data and there are no legitimate reasons prevailing with regard to the processing; (4) if the data must be erased in order to fulfil an applicable legal obligation; (5) if the personal data have been unlawfully processed.
- Restriction - you may request a restriction on the processing (1) if you challenge the accuracy of the data, for the period necessary to verify the accuracy of the data, (2) if the processing is unlawful and you choose to restrict personal information, and not to delete it, (3) if you wish for us to retain your personal data, when you need such data to defend a right in court, or (4) if you objected to the processing, for the time period in which it is verified whether the legitimate rights of the operator prevail over those of that person.
- Portability - if technically feasible, you may obtain a copy of the personal information we have registered about you.
- Object - you may object the processing of your personal data for reasons related to your particular situation, within the limits and under the conditions established by law.
- Automatic processing - you have the right to object to any automatic processing of your personal data, including profiling, as well as the possibility to oppose a decision based solely on automatic data processing, which may be exercised whenever there is a result of the profiling that produces legal effects that affect or may significantly affect the data subject (person of concern).
- Complaint - you have the right to submit a notification or complaint to the National Authority for the Supervision of Personal Data Processing (www.dataprotection.ro).
In order to exercise your aforementioned rights, please send us your request by e-mail to [email protected].
STORAGE PERIOD OF PERSONAL DATA
Personal data processed for the purposes mentioned above will only be stored for the period strictly necessary to fulfil those purposes or until the consent is withdrawn, to the extent that personal data is processed on the basis of your consent.
Your billing information, as well as other information collected about you, will be stored for as long as necessary for accounting purposes or other obligations arising out of legal terms but not more than 5 years.
Exceptionally, we storage your data for the establishment, exercise or defence of a legal right in court proceedings, administrative proceedings or other official proceedings in which Association is involved, as well as for the resolution of your requests or complaints.
At the end of the storage period we will remove/delete your personal data from Association systems and records, and/or we will take steps to anonymize it so that you can no longer be identified based on it.
Occasionally, this notice on the processing of personal data may be updated. The changes are displayed on our website so that you may have permanent access to updated details on the processing activities related to the use of the Platform. The current version will always be the one displayed on the website.
If you have any questions or need additional information about this Privacy Notice, please contact us at [email protected] and we will do our best to answer as soon as possible.