Latest Update: October 2023

Adaptfy B.V., headquartered at Alpha Tower, De Entree 69, 1101 BH Amsterdam (“Adaptfy”, “we” or “us”) is committed to protecting and respecting your privacy and your personal data. Jobs at Adaptfy is a page on Adaptfy’s website where (“page”) where Adaptfy posts all the employment job opportunities for internal positions and offers you the possibility to apply for any position in a domain, country and/or entity. As a candidate, you can search and apply for any position available in Adaptfy career website. Following your job application submission via our page, these are processed by Adaptfy and are accessible to all members of the recruitment team of Adaptfy globally. Under this Candidate’s Privacy Policy Adaptfy would like to let you know which personal data of yours we collect and why, as well as how we use and disclose personal information. For the purposes of the present Policy, you will be referred to as “the candidate” or “you”.

It is important for you to know that “personal data” means any information relating to an identified or identifiable natural person (“data subject”) according to the General Data Protection Regulation (GDPR).

So, any reference to “personal data”, “data”, “personal information”, or “your data” in this Policy means information that relates to you as candidate and that allows us to identify you directly or in combination with other information we have.

• When you apply for a job post, we will collect any information you provide to us, and indicatively name and other personal information such as gender, date and place of birth contact information, such as address, telephone number, and e-mail address; past employment history (including previous employers, job titles, or positions) and employment references for evaluation purposes; other academic, professional, and training information, such as academic degrees and professional qualifications; your CV/résumé (which may include details of any memberships or interests). Kindly note that the fields marked with an asterisk (*) are mandatory, because we need this information to process your job application. Other information you share with us when applying for a position is in your sole discretion.
• During the recruitment procedure, we collect information from the interviews and phone-screenings with you, if any; details of the type of employment you are or may be looking for, current and/or desired salary and other terms relating to compensation and benefits packages, willingness to relocate, or other job preferences; details of how you heard about the position you are applying for; information from publicly available sources, including any social media platforms or other information available online (LinkedIn, Facebook, Twitter etc.); information relating to previous applications you have submitted to Adaptfy, information concerning your application and our assessment of it; we transfer data to third parties (see below).
• When you are successfully selected and you are about to work with us, we will collect national identifiers such as nationality/ies, national IDs/passport, social security / insurance numbers, immigration information, and visa status, so that you enter into an employment contract with a Adaptfy entity.
• When you navigate our Website, we also store strictly necessary and performance cookies, in case you accept their storage. For more information see our Privacy and Cookie Policy.
• Moreover we will process you data as stated above to perform statistical and analytical research in the site, for example to measure the effectiveness of our candidates’ placement between different domains and locations and seek to identify factors that can influence any differences we identify
• Where necessary, we will process your data to comply with any legal or statutory obligation.

• Your data will be processed to the extent necessary to carry out the pre-contractual obligations for entering into a contract with you.

• We have a contractual relationship with you in effect.

• It is necessary for our legitimate interests when conducting research and such interests in each case not being overridden by your privacy interests. You can object to this processing at any time (see section 8 below).

• In some cases, it is necessary to meet our legal or regulatory responsibilities, or for establishing, exercising or defending legal claims, such as disclosures to authorities, regulators or government bodies;

• We will process your personal data, sometimes, with your consent. (e.g. If you have agreed that we may process your data for other job offers than the one you have specifically applied for). You will always notified specifically for providing your consent. You can revoke this consent at any time with effect for the future by contacting us at privacy@adaptfy.com. Withdrawal of your consent will not affect the lawfulness of any processing based on your consent before the receipt of the withdrawal.

• We do not proceed to any solely automated decision including those based on profiling, that have a legal or similarly significant effect on you.

We will retain your information as a candidate for one year after last contact. If you will work with us, we will need to keep your personal information for a longer period in order to comply with our legal and contractual obligations that each entity has.

For information about the cookies storage retention and other data stored while browsing our website, please see our Cookie and Privacy Policy

We will only share your personal information with others when we are legally permitted to do so. When we share data with others, we put contractual arrangements and security mechanisms in place as appropriate to protect the data and to comply with our data protection, confidentiality and technical and organizational security standards.

In particular, we share your information with others in the cases below:

• To client that are involved in the recruitment process. We will transfer your data, if we have your consent to do so. Otherwise we will share your data in an anonymous version.
• To partners, suppliers, contractors and agents, either companies or individuals, that we engage or employ from time to time to perform functions on our behalf (such as, for hosting the website, provide maintenance services, store the information). Such recipients will only have access to your personal information as required by them to perform their functions and are not permitted to use such personal information for any other purposes. These recipients will be subject to contractual confidentiality obligations. Please note that we process your application through Recruitee platform as processor within the meaning of the GDPR. However, the data application is not linked to the CV database available on the Internet at https://www.recruitee.com. CVs that are processed by us in the data application are not published on the Recruitee website.
• To government, law enforcement authorities, and regulatory agencies as required by, and in accordance with, applicable law or regulations

Your personal information can be transferred and processed in one or more other countries outside of Europe. For more information see section 5 “Do we share your personal information with others?”. We shall only transfer your data outside of Europe to countries which provide an adequate level of data protection as defined by the applicable data protection laws, or where Adaptfy has put in place appropriate safeguards to preserve the privacy of your information, including the United States and the United Kingdom. We endeavour to take all measures reasonably necessary to ensure that your personal information is treated securely and with regard to this Policy.

We take the protection of all data we are processing very seriously. That is why we have taken appropriate technical and organizational security measures, as well as strict operational procedures to guarantee a risk-adjusted security level and to prevent any unauthorized access, change, deletion or transmission of this personal information. Please note that although we will do our best to protect your personal information, you should be aware that the transmission of information via the internet is not completely secure and we cannot guarantee the security of your personal information transmitted to the Website or any third party. Thus, any transmission of information is at your own risk. If you have any reason to believe that your interaction with us is no longer safe, please notify us immediately according to the information provided below under the How can you contact us? Section.

You have certain rights over your personal data with regard to their processing by us under the applicable data protection laws.

Please see below which are these rights, when they are available and how to exercise them:

Your right to access your personal data

You have the right to request confirmation as to whether we process any personal data about you, receive a copy of your personal data held by us and obtain certain other information about how and why we process your personal data.

Your right to correction/ rectification of your personal data

You have the right to request for your personal data to be amended or rectified where it is inaccurate or not up to date (for example, if you change your name or email address) and to have incomplete personal data completed.

Your right to erasure / right to be forgotten

In certain circumstances, you have the right to have your personal data erased. You may submit such a deletion request at any time and we will evaluate if your request should be granted; however this right is subject to any legal rights or obligations we may have to retain data. When in accordance with the law, we determine that your request to have your personal information erased must be granted, Adaptfy will delete your data without undue delay.

Your right to restrict processing

You have the right to request the restriction of the processing of your personal data in the following cases:

(a) when you contest the accuracy of your personal data, and pending verification of the accuracy of your data; (b) when you oppose the erasure of your personal data and you request the restriction of their use instead; (c) when your personal data are no longer needed for the purposes of the processing, but they are required by you for the establishment, exercise or defence of legal claims, and (d) when you have objected to the processing and pending verification that our legitimate grounds for processing override those for which you object to the processing.

Your right to object to processing

You have the right to object to our processing of your personal data in the following cases:

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• our legal grounds for processing is that the processing is necessary for a legitimate interest pursued by us or a third party; or in case, our processing is for direct marketing purposes.

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Your right to data portability

You have a right to receive your personal data provided by you to us and have the right to send the data to another organization or ask us to do so, if technically feasible, where our lawful basis for processing the personal data is consent or necessity for the performance of our contract with you and the processing is carried out by automated means.

Your right to withdraw consent (where processing is based on consent)

Where we process personal data based on consent, you have a right to withdraw consent at any time. Withdrawal of your consent will not affect the lawfulness of any processing based on your consent before the receipt of your withdrawal.

If you want to exercise your rights, please email us at privacy@adaptfy.com. We aim to respond to any requests for information promptly, and in any event within the legally required time limits.

You can also lodge a complaint about our processing of your personal information with the data protection authority of the Member State of your habitual residence, of your place of work, or the place of an alleged infringement of your rights.

The terms of this Policy may change from time to time, for example because our Website or the rules for cookies change. We shall publish any material changes to this Policy on this Website.

Do you have any questions, comments and requests regarding this Policy? You are welcome and should address these to privacy@adaptfy.com.