Last Updated On 11-May-2023
Effective Date 11-May-2023

This Privacy Policy describes the policies of Tech REC SRL, Bucuresti, Sector 2, str. Armeneasca, nr. 23, cam. 14, Romania 021042, Romania, email: dpo@techrec.ro on the collection, use and disclosure of your information that we collect when you use our website ( techrec.ro ). (the “Service”). By accessing or using the Service, you are consenting to the collection, use and disclosure of your information in accordance with this Privacy Policy. If you do not consent to the same, please do not access or use the Service.

We may modify this Privacy Policy at any time without any prior notice to you and will post the revised Privacy Policy on the Service. The revised Policy will be effective 180 days from when the revised Policy is posted in the Service and your continued access or use of the Service after such time will constitute your acceptance of the revised Privacy Policy. We therefore recommend that you periodically review this page.

Candidates

If you are a candidate or potential candidate for either permanent or temporary job/associate positions, we will process your data for the purposes of recruitment projects and processes on the basis of an agreement concluded with your potential employer/principal/associate (Article 6 (1) (b) of the GDPR). For this purpose, we will process your data in the scope defined by you – on the basis of information voluntarily included in your CV and application documents (Article 6 (1) (a) of the GDPR). We will also process your personal data for purposes attributable to our legitimate interests (Article 6 (1) (f) of the GDPR).

If you wish to participate in any further recruitment procedures or any projects in the future, or if the application documents contain any information that could be perceived as sensitive data, such information will be processed on the basis of your voluntary consent (Article 6 (1) (a) or Article 9 (2) (a) of the GDPR).

1. INFORMATION WE MIGHT COLLECT: We can collect and process the following personal information about you:
   1. Name
   2. Email
   3. Mobile
   4. Social Media Profile
   5. Work Experience/Employment history
   6. Professional Qualifications
   7. Education
   8. Financial Expectations
   9. business name (in the case of sole traders), as well as any other data provided in your application documents and CVs.
2. HOW WE COLLECT YOUR INFORMATION: We collect/receive information about you in the following manner:
   1. When a user fills up the registration form or otherwise submits personal information
   2. Interacts with the website/company emails or recruitment consultants
   3. From public sources
3. HOW WE USE YOUR INFORMATION: We will use the information that we collect about you for the following purposes:
   1. Marketing/ Promotional (Recruitment services, job offers)
   2. Creating user account
   3. Customer/candidate feedback collection
   If we want to use your information for any other purpose, we will ask you for consent and will use your information only on receiving your consent and then, only for the purpose(s) for which grant consent unless we are required to do otherwise by law.
4. HOW WE SHARE YOUR INFORMATION: Recipients of data may include service providers supplying IT, technical and organizational solutions, enabling the support and management of the organization (accounting, postal operators and couriers, internet service providers, including email, software, hosting), law firms and legal advisors providing legal services. Such recipients may include, in particular, potential employers – regardless of the form of contemplated employment or cooperation. We will share your personal data with potential employers/principals/partners who have engaged us to implement recruitment projects or informed us about vacancies in their businesses. Your personal data will be transferred to such entities only after we have received your prior consent to their disclosure. Such consent may be given by email (in this case, we will provide you with the relevant consent form) or by phone. To obtain your consent, we will inform you of the name of our client (company) and the job position for which we would like to present your person as a future employee. We require such third parties to use the personal information we transfer to them only for the purpose for which it was transferred and not to retain it for longer than is required for fulfilling the said purpose. We may also disclose your personal information for the following: (1) to comply with applicable law, regulation, court order, or other legal process; (2) to enforce your agreements with us, including this Privacy Policy; or (3) to respond to claims that your use of the Service violates any third-party rights. If the Service or our company is merged or acquired with another company, your information will be one of the assets that is transferred to the new owner. Such data will be stored throughout the recruitment, unless you consent to its further storage for the purposes of any future recruitment. In connection with the processing, you have the right to access and rectify your data, the right to limit its processing, the right to withdraw your consent at any time (which will not affect the lawfulness of any processing prior to its withdrawal), the right to object to processing, the right to delete data, and the right to lodge a complaint with the supervisory authority.
5. RETENTION OF YOUR INFORMATION: We will retain your personal information with us for 90 days to 2 years after users terminate their accounts or for as long as we need it to fulfill the purposes for which it was collected as detailed in this Privacy Policy. We may need to retain certain information for longer periods such as record-keeping / reporting in accordance with applicable law or for other legitimate reasons like enforcement of legal rights, fraud prevention, etc. Residual anonymous information and aggregate information, neither of which identifies you (directly or indirectly), may be stored indefinitely.

LEGITIMATE INTERESTS

In addition to the aforementioned instances, in certain cases, we may process your data for other purposes. These may involve e.g. an extension of the storage period of your data.

For the purposes related to the need to comply with our legal obligations (Article 6 (1) (c) of the GDPR), we will process your data:

• for the duration of the performance of any legal obligations imposed on us by applicable laws, including tax law, social security law, etc., and
• for the period in which certain laws require us to store data (these laws may provide for a different period of data storage).

Furthermore, we may process your data for other reasons attributable to our legitimate interests (Article 6 (1) (f) of the GDPR), consisting in:

• archiving and maintaining documentation,
• correspondence,
• asserting, pursuing and defending against claims, including selling our receivables to any other entity,
• creating statements, analyses and statistics.

In certain cases, your personal data will not be processed on the basis of our legitimate interests, if your rights and freedoms take precedence over them.

RIGHTS

The right to access and obtain a copy of personal datas (Article 15 of the GDPR)

At your request, we will provide you with the information as to whether we process your personal data. We are also required, upon a separate request, to provide you with more detailed information on: the purposes of processing, categories of personal data, data recipients or their categories, the period of personal data storage or the criteria for its determination, sources from which such data is obtained, automated processing of personal data and the consequences of such data processing for you. In the case of transfer of personal data to a third country, at your request, we will also inform you on the security measures applied for such transfer. At your request, we will also make a copy of your personal data. It will be made available to you in the popular IT file format. The first copy will be provided free of charge. However, we may charge a fee for each subsequent copy, the amount of which is to be determined by us based on the provisions of the GDPR. In any other cases, we have the right to charge a fee in the amount corresponding to the cost of preparing our reply or a copy of the requested data.

The right to rectify data (Article 16 of the GDPR)

Should your personal data prove to be incorrect, we will rectify any inaccuracies. This will be done on our own initiative – or, if such incorrectness is brought to our attention by you – at your request.

The right to delete data, including “the right to be forgotten” (Article 17 of the GDPR)

If you do not wish your personal data to be processed and we find that there are no other legal grounds enabling us to process your data – we will delete it from our databases. However, it should be remembered that deleting some data may prevent us from providing services to you – this applies to those services which require us to process the provided personal data. For instance, we will not be able to answer your questions if you request that your email address be deleted. Despite such a request, we will be able to process some personal data in compliance with the terms and conditions stipulated in the GDPR.

The right to limit processing (Article 18 of the GDPR)

In cases provided for in the GDPR, at your request, we will limit the processing of your personal data. In simple terms, restricting the processing of personal data prevents its use other than its storage. In this case, any other activities on the data subject to processing restrictions may only be performed with your consent.

The right to transfer data (Article 20 of the GDPR)

Under the terms of the GDPR, you can request the transfer of your personal data stored in a standard machine-readable file format. If you wish to transfer them to any other data controller, we will send a file containing your personal data directly to them.

The right to object (Article 21 of the GDPR)

In some cases, even if we process personal data in accordance with the law, without your consent, you may request us to cease such processing by objecting to it. In order to demonstrate the rationale behind such a request, you may show that our actions, although lawful, still infringe your interests, rights or freedoms.

The right not to be subject to automated decisions in individual cases, including profiling (Article 22 of the GDPR)

You have the right not to be subject to decisions that would be based solely on automated processing, including profiling, if they could affect you in legal terms or otherwise in a significant manner.

The right to withdraw consent at any time (Article 7 (3) of the GDPR)

In a situation where we requested your consent, you may withdraw such consent at any time. If we do not have a separate basis for processing, we will cease using your personal data for the purpose for which the consent was given.

The right to lodge a complaint with the supervisory authority (Article 77 of the GDPR)

Should you believe that our activities related to the processing of personal data have violated your rights, you may lodge a complaint with the supervisory authority, i.e. an independent public authority responsible for monitoring of compliance with the GDPR.

The rights listed above may be limited in certain situations, for example, when we are able to demonstrate that we are legally obliged to process your data. If you wish to exercise any of your rights, all you need to do is submit a request using the contact details indicated in point 1.

To exercise these rights, you can write to us at dpo@techrec.ro. We will respond to your request in accordance with applicable law. You may opt-out of communications or the profiling we carry out for legitimate purposes by writing to us at dpo@techrec.ro.Do note that if you do not allow us to collect or process the required personal information or withdraw the consent to process the same for the required purposes, you may not be able to access or use the services for which your information was sought.

DATA SOURCES

As a rule, most of the data we process is information that you have voluntarily provided to us.

However, in some rare cases we may process personal data that we are able to conclude about you based on any other information that you provide to us and that we obtain in the course of our relationship. Such data will not be processed longer than necessary for the purpose for which they were collected or will be immediately deleted.

Where personal data has not been obtained directly from you, we would like to advise you that:

• the data may have been obtained from the person or entity that indicated you as a representative or contact person;
• the data may have been obtained from online resources, including social networks, in which you have posted your professional profiles yourself, e.g. LinkedIn, Xing, GitHub, a business website on Facebook or your own business site;
• the data may have been obtained from your work colleagues – sometimes people to whom we present a job offer are recommended to us by other people known by them and who, in their opinion, have the proper skills and abilities to work in the offered position.

TECHNICAL AND ORGANIZATIONAL MEASURES

We are committed to the adequate protection of your personal data in accordance with the adopted internal policies, orders, procedures and standards, so that the personal data is protected against any unauthorized use or access, unlawful modification, loss or destruction.

Your personal data will not be stored for longer than is necessary for the purpose for which it was collected, including the need to comply with our legal obligations and to settle any disputes, assert or defend against any claims.

As part of ensuring the security of personal data processed, we agree to take into account the following:

• confidentiality – we will protect your data against accidental disclosure to any third party,
• integrity – we will protect your data against any unauthorized modification,
• availability – we will provide with access to you data only to authorized persons and only if necessary.

Your personal data may be processed by any third party only if such entity agrees to provide appropriate technical and organizational measures to ensure the security of personal data processing, as well as to maintain the confidentiality of such data.

Each of our employees or associates with access to personal data has been properly authorized and is obliged to maintain confidentiality.

The personal data that you provide on our website is encrypted and protected by an SSL certificate. It secures data transmission within the domain and confirms its authenticity.

INTERNATIONAL DATA TRANSFER

Your personal data may be transferred to third countries:

• on the basis of an adequacy decision by the European Commission (Article 45 of the GDPR);
• subject to adequate safeguards, including standard data protection clauses, an approved code of conduct, an approved certification mechanism (Article 46 of the GDPR);
• in accordance with binding corporate rules (Article 47 of the GDPR);
• subject to exceptions in specific situations (Article 49 of the GDPR).

In connection with the IT systems and organizational solutions used, your data may be received by Manatal Co.,Ltd, a company registered in Thailand, with its registered office at 16th Floor, 26/58 Orakarn Building, Lumphini, Pathum Wan, Bangkok 10330, Thailand. In this case, personal data will be transferred subject to adequate safeguards in the form of standard contractual clauses.

COOKIES

To learn more about how we use these and your choices in relation to these tracking technologies, please refer to our Cookie Policy.

SECURITY

The security of your information is important to us and we will use reasonable security measures to prevent the loss, misuse or unauthorized alteration of your information under our control. However, given the inherent risks, we cannot guarantee absolute security and consequently, we cannot ensure or warrant the security of any information you transmit to us and you do so at your own risk.

THIRD PARTY LINKS & USE OF YOUR INFORMATION

Our Service may contain links to other websites that are not operated by us. This Privacy Policy does not address the privacy policy and other practices of any third parties, including any third party operating any website or service that may be accessible via a link on the Service. We strongly advise you to review the privacy policy of every site you visit. We have no control over and assume no responsibility for the content, privacy policies or practices of any third party sites or services.

GRIEVANCE / DATA PROTECTION OFFICER

If you have any queries or concerns about the processing of your information that is available with us, you may email our Grievance Officer at Tech REC SRL, Bucuresti, Sector 2, str. Armeneasca, nr. 23, cam. 14, email: dpo@techrec.ro. We will address your concerns in accordance with applicable law.

FINAL NOTES

We reserve the right to amend this Privacy Policy, where such amendments may:

• be due to the need to adapt the provisions of the Privacy Policy to applicable law or decisions of competent public authorities;
• result from a change in the interpretation of generally applicable provisions of law (affecting the content of the Privacy Policy);
• result from court judgments, decisions, or recommendations of authorities or bodies competent in a specific area;
• be due to the need to remove mistakes or typographical errors contained in the Privacy Policy;
• be due to the change of details, including e.g. address and telephone details, names, contact details or links contained in this Privacy Policy.