PRELIMINARY INFORMATION

Beverenjob.ro is a platform that collects applications from people looking for jobs offered by the employers for whom we are mediate, throughout Europe. In return for a fee, we provide employers with details of potential persons suitable to fill the advertised position, following a process of non-automated analysis of the compatibility between the two parties – employer and applicant, depending on relevant criteria.

The confidentiality, integrity and security of your personal data are the primary pillars in the implementation of appropriate technical and organizational measures to ensure that your rights are respected.

Who we are

This privacy policy (hereinafter referred to as „the Privacy Policy”) implements the principle of transparency and describes how the collection, use, dissemination, storage and disposal of your personal data is carried out by the owner of this domain– ROUTE 68 LIMITED, with its headquarters in 4 Hadleigh Business Centre 351 London Road, Hadleigh, Benfleet, Essex, United Kingdom, SS7 2BT, registered with Companies House under number: 09090675 (hereinafter referred to as „beaveronjob.com” or „we”), as a personal data controller, in relation to (i) access to and use of the website available at URL https://beaveronjob.com/ (hereinafter referred to as „the workforce recruitment platform”), and in connection with (ii) the provision of our services through and outside of it (hereinafter referred to as „the Services”).

DESCRIPTION OF PERSONAL DATA WE PROCESS, THE PURPOSES AND LEGAL GROUNDS FOR PROCESSING

1. Personal data used within the workforce recruitment platform

The workforce recruitment platform is operated using computer systems and software modules that generally obtain some personal data; the transmission of this data is done by default so that online communication protocols return optimal platform usage results.

This information is not collected to be linked to identified individuals, but due to its nature it may allow, through processing and integration with certain data stored by third parties, the identification of users. This information includes IP addresses, the time of the request, the method used to send the request to the server, the size of the file obtained in response, and other parameters related to the user’s operating system. The databases that are uploaded with your data through the website are stored on secure servers in Romania.

To the extent that such information leads to the identification of a user, the provisions of this Privacy Policy become applicable.

2. Personal data provided on the workforce recruitment platform

   1. Identification and contact details: full name, your e-mail address, phone number, postal address, company, time zone, website language, computer IP.

   2. Data about your professional profile: by filling in the contact form, when you apply for a specific job or just send us your application for inclusion in our database, you provide us with the details you consider relevant as well as your CV attached in pdf format. The usual practice in this field is to include in your CV all the data that make up your professional profile – studies completed and specializations acquired, volunteering sessions, previous jobs, periods of time and your role in each of these jobs, information on skills acquired, additional knowledge, hobbies or future projects.

   3. Data about on-site behaviour: job searches performed, list of preferred ads, values entered when using the filters used to sort ads (including min/ max salary), time spent on the site and other data collected through external modules attached to the site (e.g. Google Analytics)

The data listed above is stored by us and will be shared with the companies offering the jobs that our platform publishes, as well as with other potential employers in the applicant’s field of reference.

3. Purpose and basis of processing

We use this data only to obtain anonymous statistical information on the use of the site, to check its correct functioning and to be able to benefit from the products offered as a customer on beaveronjob.com.

• For the construction and functionality of the platform, the legal basis for the processing of your data is given by the fulfillment of the legal duties relating to the security aspects of our systems, according to Art. 6 (1) (c) of the EU regulation 679/2016 and Art. (3) of Act 506/2004 (Romania);

• For the provision of the data that make up your professional profile, including the CV that you communicate to us in electronic format, as well as for data transmissions carried out with employers whose recruitment needs we mediate, the legal basis for processing your personal data is fulfilled by obtaining your explicit, informed and freely expressed consent, on the basis of Art. 6 (1) (a) and in compliance with the consent requirements contained in Arts. 7 and 8 of EU Regulation 679/2016.

4. How to contact beaveronjob.com and how we provide assistance

You can contact us in different ways: by e-mail, by phone or via the contact form. In this case, we may process the following personal data: name(s), surname, e-mail address, phone number, company and any other information you provide voluntarily when contacting us. We recommend that you only provide us with the information that is necessary for us to be able to help you with your request.

5. How our specialists contact customers

In the course of providing our services, we will use your e-mail address, phone number, first name(s), surname to validate your application and the applicant’s interest in the job openings in the industry of interest.

6. Commercial communications

We will not send you commercial communications via e-mail, nor will we pass on your data to other entities than the employers with whom we have a collaboration agreement.

PROVISION OF PERSONAL DATA

We are careful to maintain compliance with the principle of data minimization, but you should be aware that you may refuse to provide certain personal data (indicated above) but in such a case you may not be able to benefit from certain services specific to the contractual relationship described in this Privacy Policy.

AUTOMATIC PROCESSING OF PERSONAL DATA

Your personal data will not be processed for the purpose of generating decisions based solely on automated processing that would have legal effects on you or significantly affect you.

DURATION OF PROCESSING

We intend to keep your personal data only as long as necessary in accordance with National Archival Nomenclature and the Internal Archival Nomenclature.

The data that make up your professional profile will be stored for a maximum period of 12 months from the date of the lase use/ transmission to the relevant employers, after which it will be deleted from our information system.

If you agree to your data being used for direct marketing purposes, please note that the period for which personal data will be stored is 2 years. The processing will cease as soon as you exercise your right to object or withdraw your consent (given that such processing is based solely on your consent). We will periodically conduct review sessions of the personal data processed to ensure that the data or certain categories of personal data processed are not retained for longer than is actually necessary.

In certain circumstances, we may retain personal data for longer periods of time, for example where we are required to do so by legal, regulatory, tax or accounting requirements.

At the same time, we may retain personal data for longer periods of time so that we have an accurate record of your relationship with us in the event of any complaints or if we reasonably believe that there is a prospect of litigation related to the processing of your personal data.

TRANSFER OF PERSONAL DATA

We may transfer personal data, to the extent necessary, to the following categories of recipients:

• contractual partners – employers in search for workforce;

• subcontractors – possible outsourced services;

• marketing companies;

• public authorities, courts or arbitral tribunals, as well as authorities competent to investigate criminal offences.

These recipients may be located in the European Union and/ or the European Economic Area. Where recipients are located outside the European Union and the European Economic Area, including in countries that are not recognized as providing an adequate level or protection, the transfer of personal data shall only be carried out if there are appropriate safeguards in accordance with the applicable law. In this regard, we rely on several safeguards, such as standard contractual clauses issued by the European Commission.

SECURITY OF PERSONAL DATA

The security of your personal data is important to us. Therefore, your personal data will be processed by applying reasonable technical and organizational measures to protect personal data, such as limiting access to personal data, encrypting or anonymizing personal data, storage on secure media. However, despite our best efforts, we cannot always guarantee the effectiveness of the security measures implemented, and therefore cannot guarantee the security of personal data at all times.

YOUR RIGHTS REGARDING THE PROCESSING OF PERSONAL DATA

Your rights

In accordance with applicable law, you have the following rights:

Right of access: You have the right to obtain confirmation from us that your personal data is being processed by us, as well as information on the specifics of the processing such as: purpose, categories of personal data processed, period for which personal data is retained, whether we transfer it abroad and how we protect it, your rights, the right to lodge a complaint with the supervisory authority, where we obtained the personal data from.

Right to rectification: You have the right to request rectification of your personal data, provided that the applicable legal requirements are met. In the event of errors, after notification, we will immediately correct your personal data.

Right to erasure: In certain circumstances, you have the possibility to request the erasure of personal data: (i) it is no longer necessary for the purposes for which we have collected and processed it; (ii) you have withdrawn your consent to the processing of personal data and we can no longer process personal data on other legal grounds; (iii) personal data are processed unlawfully; (iv) you exercise a legal right to object. We will not be able to comply with your request for erasure if the processing of personal data is necessary for compliance with a legal obligation, or for the establishment, exercise or defense of a right in court. There are also other circumstances in which we are not obliged to comply with this request for erasure of personal data.

Restriction of processing: You may request that we restrict the processing of your personal data in the following situations: (i) if you dispute the accuracy of the personal data, for a period that allows us to verify the accuracy of the personal data in question; (ii) if the processing is unlawful, and you object to the erasure of personal data, requesting instead the restriction of its use; (iii) if we no longer need the personal data for the purpose of processing, but you request it from us for a legal claim; (iv) if you have objected to the processing, for the period of time during which it is verified whether our legitimate rights as a controller override those of the data subject. We may continue to use personal data following a restriction request if: (i) we have your consent; (ii) to establish, exercise or defend a right in court; or (iii) to protect the right of another natural or legal person.

Right to data portability: Insofar as personal data are processed on the basis of your consent or for the performance of the contract and the processing is done by automated means, you have the right to have your personal data provided to you in a structured, commonly used and machine-readable format and you have the right to transmit this personal data to another controller. This right does not adversely affect the rights and freedoms of others.

Right to object: In certain situations, such as when we process your personal data on the basis of a legitimate interest, you have the right to object to our processing of your personal data. In case of unjustified objection, beaveronjob.com is entitled to further process the personal data.

Right to object to direct marketing: You can also object to the processing of your personal data for the purpose of sending commercial messages.

Withdrawal of consent: Insofar as we process your personal data on the basis of your consent, you may withdraw your consent at any time, without affecting the lawfulness of the processing based on your consent prior to the withdrawal of your consent.

Right to opt out of individual decisions: In certain circumstances, you have the right to opt out of a decision based solely on automated processing, including profiling, that produces legal effects concerning you or similarly affects you to a significant extent. This right does not apply where the decision: (i) is necessary for the conclusion or performance of a contract between you and us; (ii) is authorized by law, which also provides adequate safeguards for your rights and freedoms; (iii) is based on your explicit consent.

Right to complain to the supervisory authority: You have the right to lodge a complaint with the National Authority for the Supervision of Personal Data Processing (“ANSPDCP”) in relation to any violation of your rights regarding the processing of your personal data. ANSPDCP contact details are: B-dul G-ral. Gheorghe Magheru 28-30, Sector 1, cod poștal 010336 București, Romania; e-mail: anspdcp@dataprotection.ro.

Exercise of your rights

The Data Protection Officer (DPO) has the role of facilitating communication between you, us and the National Supervisory Authority (ANSPDCP), and is an extension of the ANS in the personal data processing activity of the data controller, in order to comply with the GDPR requirements. Feel free to call on his expertise in defense of your right to privacy with regard to the processing of your personal data at dpo@beaveronjob.com and by phone: +44 7399 531344

Identity verification: We pay the outmost attention to the confidentiality of all personal data and reserve the right to verify your identity if you make a request regarding personal data.

Fees: As a rule, you can exercise your rights free of charge. However, we reserve the right to charge a reasonable fee if your requests are manifestly unfounded or excessive, in particular because of their repetitive nature.

Response time: We make every effort to respond to your request within one month of receiving it. This period may be extended by two months where necessary, taking into account the complexity and number of requests, in which case we will inform you of any such extension and the reasons for the delay.

CONTACT

If you have any questions or concerns about this Privacy Policy or its implementation, you can contact us by email at dpo@beaveronjob.com and by phone: +44 7399 531344