Docler Privacy Policy

Last modified: May 24, 2018



When you decide to apply for a job position at the Docler group, you will share some personal information with us.

Since your privacy is important to us, we provide you with this Privacy Policy, which explains how we collect, use and share your personal information, and what are your choices regarding the use of your data.

This Privacy Policy applies to candidates applying for a job position at the Docler Group.

Please read this Privacy Policy carefully, we have tried to write it in a way, which is free of long boring sentences and legal terms.  You can contact us if you have any question about our privacy practices or about what we are doing with your personal information and we will be happy to provide you any assistance you may need.


1. WHO DECIDES “HOW” AND “WHY” YOUR PERSONAL DATA IS PROCESSED?

When you apply for a job position at the Docler group, the company, which decides how and why your personal data is processed, and which is called “Data Controller” is your potential future employer for the job in question, which is indicated in the job description or communicated to you by our recruiters. 


2. WHAT PERSONAL DATA DO WE PROCESS?

We collect certain personal information about you in the course of the recruitment process: 

2.1 When you apply for a position at the Docler Group either directly on our site, through email or mail, through a professional social network, or after having been contacted by a recruiter, we need the following minimum information about you in order to process your job application:

  • Your full name;
  • Your E-mail address;
  • Your Phone number;
  • Your CV / Resume;
  • The job position you are interested in, in case you did not apply directly on our site in response to a posted job offer.

For certain specific positions (such as in legal, finance or audit), we may also ask you to provide us with your criminal record.

In certain cases, when it is required for the job position to evaluate the candidates, we may ask you to do specific tests (such as language tests, IT competencies test, etc…). 

2.2. You may freely communicate us additional information on your own initiative, such as:

  • A cover letter; 
  • A photo;
  • Copies of your diploma, grade or language certificates;
  • Additional contact details, such as your Skype ID;
  • Your hobbies or interests;
  • Your potential start date.

 In very exceptional and justified cases, our recruiters may also ask you if you agree that she/he records the interview. You are fully free to accept it or not, your decision will have no consequence on the recruitment process. 

2.3. In the course of the recruitment process, you may also communicate some requests, such as your salary or bonus expectations or certain allowance request(s) (e.g. relocation allowance request). Please note that these specific requests are kept by the recruiter in charge of your recruitment process and only shared with the responsible manager(s) in case we would like to make an offer to you. 

2.4. When reviewing your application or meeting you in the course of an interview, our recruiters will also evaluate your profile and generate evaluation and/or interview notes. 

2.5. We may contact and receive information about you from your personal/professional reference, if provided by you.

2.6. We may also collect information about you from publically available sources in some cases, such as from your professional social network account (e.g. LinkedIn, Stackoverflow, Hubspot account).


 3. WHY DO WE PROCESS YOUR PERSONAL DATA?

We use the information we collect for the following purposes:

 3.1. Recruitment

We collect and process your personal information for recruitment purposes: to review your application, evaluate your profile, determine if you are a good fit for the position, and contact you in the course of the process to schedule interviews or discuss your profile. 

We process this information given our legitimate interest in finding new employees for our opened positions and processing your job application.

3.2. Future job opportunities 

In case you received a negative answer as regards the job you applied for, we will keep your personal information in our recruitment database for a period of two years. In this way, we will be able to contact you in order to communicate new job opportunities matching with your skills and your profile.

Please note that we are using a recruitment software that enables us to gather the profiles of our candidates and search in our recruitment database based on filter(s). For example, when we search for a candidate in our database for a new position, we may filter the result by skills. Your skills may have been documented by our recruiters in our database based on the prior recruitment process you had with them.

Be aware that you can object at any time to the storage and use of your personal data for future job opportunities, by sending us an email at the relevant email address, as indicated in 9. HOW TO CONTACT US.

We process this information given our legitimate interest in maximizing our recruitment process and providing you with job offer(s), which could be of interest for you.

At the end of the two-years retention period, we will only keep your personal information in our recruitment database in order to contact you in case of future job opportunities, if you consented to such storage and use of your information.

3.3 Comply with any legal requirements and enforce our legal rights

We may rely on a legal obligation to process your personal data. We may also use your information to respond to requests of competent authorities or to establish, exercise or defend legal claims.

We may combine your information with information lawfully obtained from other third party sources and use it for the above purposes.


4. HOW DO WE PROTECT YOUR PERSONAL DATA?

We implement serious security measures to grant maximum protection to your personal information against unauthorized access, modification, disclosure or deletion. Your data is always protected by our highly sophisticated security systems.

We actively implement data loss prevention systems against leakage, theft and data breach in order to ensure that our entire IT infrastructure is updated against the latest network security vulnerabilities. We periodically test our IT systems and do sophisticated penetration tests.

In addition, we have in place strict access controls to candidates data. The access to your information is limited on a need to know basis and our recruiters are subjects to strict confidentiality obligations.


5. WITH WHOM DO WE SHARE YOUR DATA?

We share your data with the following parties:

5.1. Entities of Docler group 

Depending on the job location you applied for, your job application may be processed by different entities of our Group (a) for their own account or (b) on behalf of another company of our group in the same country or (c) on behalf of another company of our group to which they are providing recruitment services:

  • If you apply to a job position located in Luxembourg, or in any other countries (except Hungary and the US), your job application will be processed by the recruiters of Docler Holding S.à r.l., 44, Avenue John F. Kennedy, L-1855, Luxembourg, Grand Duchy of Luxembourg.
  • If you apply to a job position located in Hungary, your job application will be processed by the recruiters of Docler SSC Kft, Expo tér 5-7, H-1101, Budapest, Hungary.
  • If you apply to a job position located in the US, your job application will be processed by the recruiters of Docler Media LLC, 8000 Beverly Blvd, Los Angeles, CA 90048, USA. 

We will also share your personal information with the responsible manager(s) having the skills to interview you and/or decide about the outcome of your application. The responsible manager(s) might be employed by a different entity of our group. 

5.2. Service providers 

We contracted with Recruitee B.V. established in the Netherlands for the use of a recruitment software.  

Recrutee B.V. acts as a data processor and we have contractually binding obligations in place in order to ensure that they process information we share with them in accordance with our instructions, this Policy and all applicable data protection laws.

5.3. Law enforcement agencies or governmental authorities

We may also share information with law enforcement agencies or authorities, if such disclosure is reasonably necessary to (a) comply with our legal obligations, (b) respond to information requests for fraud investigations and alleged illegal activities, and/or (c) protect our rights or defend ourselves against any claims.


6. HOW DO WE TRANSFER YOUR PERSONAL DATA OUTSIDE OF THE EUROPEAN ECONOMIC AREA?

In the course of the recruitment process, your personal information may be transferred outside of the European Economic Area ("EEA") to our affiliated companies, for the purposes specified in this Privacy Policy.

If we transfer your personal data outside of the EEA, we endeavor to ensure that your rights and freedoms in respect of the processing of your personal data are adequately and appropriately protected. For this purpose, we utilize the Standard Contractual Clauses approved by the European Commission that you can find here.


7. WHAT ARE YOUR RIGHTS REGARDING YOUR PERSONAL DATA?

We did our best to explain what your rights are and how you can exercise them. If, despite of our below explanations, you are still unsure about the actions you can take or the conditions of exercise of your rights, do not worry, our HR department will provide you with all the assistance you need when exercising your rights. 

You may also contact us, at any time, before exercising any of your rights, and we will reply to your request as quickly as possible.

Our HR department will provide you with information on actions taken within 30 days of the day we receive your request. Only in exceptional circumstances, when we face complex or a high number of requests, we may extend this period of response up to 60 days.

Please note that rights may be exercised free of charge. However, unfounded or excessive requests, in particular because of their repetitive character, will lead to the payment of a fee.

If you wish to exercise any of your rights below, please send us an email, as indicated in 9. HOW TO CONTACT US.

7.1.Data access and data portability 

You have the right to access the personal information that we hold about you by requesting a copy of your personal data free of charge.

Upon verification of your identity, your request will be processed by our HR Team.

If we consider that your request is manifestly unfounded or excessive (for example, because you requested a copy of your data numerous times in a short period of time), we may refuse to act or charge a reasonable fee taking into account the administrative costs for providing you the information.

In certain cases, you may also be entitled to request copies of personal information that you have provided to us in a structured, commonly used, and machine-readable format and/or request us to transmit this information to another controller (where technically feasible). 

7.2.Rectification of inaccurate or incomplete data 

You have the right to request that we correct any inaccuracies in your personal data. 

7.3. Data retention and erasure 

We will retain your personal information during two years from the day you applied for a job position at the Docler Group. At the end of these two-years retention period, we will erase or anonymize your personal information from our systems, unless you agree to a longer storage and use of your personal information.

If you got a position at the Docler Group, please note that the retention of your personal data will be governed by our employees privacy policy.

If you no longer want us to use your information, you can request that we erase your personal information from our systems.

Please note that in case you request the erasure or if we decide ourselves to start the erasure process at the end of our retention period(s), we may have to retain and use some of your personal information to the extent necessary to comply with any relevant legal obligations. 

7.4.Right to object

We process your data for the reasons explained in 3. WHY DO WE PROCESS YOUR PERSONAL DATA? Applicable law may entitle you to require us not to process your personal information for certain specific purposes where such processing is based on legitimate interest. If you object to such processing we will stop processing your personal data for these purposes.

In specific situations, we may have to refuse the execution of your request. This would be the case where we have legitimate grounds to continue such processing or if we have to establish, exercise or defend legal claims.

This means that you have the right to object to the continuance of an-going recruitment process or to the storage and use of your personal information that enables us to contact you for future job opportunities.

7.5. Right to restriction of processing

You have the right to request that we hold your personal data in “limbo”, while other challenges are resolved.

Basically, you can ask us to put on hold the use of your data in 4 cases:  

  • If you contest the fact that the personal data we hold about you is accurate: in this case, the processing operations in relation to this data will be put on hold for the period during which this is verified. 
  • You have objected to a processing activity based on legitimate interest(s): in this case, you can require the processing operation to be put on hold while we verify the grounds for processing.
  • You consider that the processing is unlawful but you object to erasure and request restriction, instead. 
  • We have no further need for the data but you require it to establish, exercise, or defend legal claims.

Despite your request, we may still continue the processing of your personal data if we have to establish, exercise, or defend legal claims. We will notify you before lifting a restriction.

7.6. Right to lodge a complaint with a supervisory authority

If you consider that our processing of your personal data infringes the GDPR or any other applicable national laws, you have the right to lodge a complaint with a supervisory authority, (in particular in the Member State where you live, place of work or of an alleged infringement of the GDPR).


8. CHANGES TO OUR PRIVACY POLICY

We may occasionally amend this Privacy Policy to reflect changes in our recruitment processes and the way we handle your personal information or changes in the applicable laws.

If we make changes we consider important, we will let you know by placing a notice on our site and/or contact you using other methods such as email. 

To the extent permitted by applicable law, such changes will be applicable from the time they are published on our site, unless we specify a date of entry into force. Your continued use of our site from that day on will be subject to the new Privacy Policy. 


9. HOW TO CONTACT US?

If you have any comments or questions about this Policy or our privacy practices, or you want to exercise one of your privacy rights, please send an email to the competent HR department, which will get quickly back to you. We are always glad to talk about our privacy practices.

 

→ for Luxembourg and all positions worldwide, excluding Hungary and US 

for all positions located in Hungary

for all positions located in the US

We are also happy to inform you that we have an employee dedicated to ensuring your privacy, our Data Protection Officer. You can directly reach our Data Protection Officer via email at dataprotectionofficer@doclerholding.com