Privacy Policy

This Privacy Policy describes how Recruitment Software OÜ, (registry code: 14936047, address: Harju County, Tallinn, City Centre city district, Järvevana tee 9, 11314), hereinafter also referred to as the Administrator or We) processes the personal data of its Clients, Client representatives, Users, Candidates and other data subjects (hereinafter also You) in connection with their use of the RecruitLab Platform and Services. This Privacy Policy applies if you use, have used, or have expressed an intention to use the Platform and/or Services by Recruitment Software OÜ or RecruitLab, including in trial or demo version. This Privacy Policy also applies to potential clients of the Administrator. Capitalized terms and concepts used in this Privacy Policy are also defined in the Terms of Use of Recruitment Software OÜ.

In the cases described, we act as the controller of your personal data and are responsible for their processing. This Privacy Policy does not apply to personal data processed by Clients of the Administrator in the Content of the Platform and when using the Services. In such a case, the Client acts as the processor of such personal data and is responsible for their processing. The Administrator processes such personal data on behalf of the Client, and we act as an authorized processor of the data (see clause 7 of the Administrator’s Terms of Use).

Personal data must be understood as any information concerning an identified or identifiable natural person (data subject).

Collection of your personal data.

We collect your personal information in the following ways:

  • You provide the Administrator with your personal data yourself;
  • Your personal data is provided to the Administrator by the Client’s (of your company) representative or another User;
  • Your personal data will be provided to the Administrator by a third party (for example, if a third-party payment service provider confirms whether your payment was successful or not);
  • Content created on the Platform by you or your users contains personal information of third parties (such as your Candidates)
  • Automatically, including as defined in the Administrator’s Cookies Policy. Such processing also includes the collection of data from potential client (trial or demo clients, potential clients, and their representatives) from public registers.

Personal data to be processed, purpose and legal basis for processing.

We process your personal data mainly for concluding and fulfilling the Agreement with the Client. This includes providing the Service, providing customer support, and contacting you for other reasons related to the Platform and the Services. We process the following personal data for the above purposes:

  • identification data (name, date of birth, picture);
  • contact information (work address, work phone number, work e-mail address);
  • data concerning the work (Client’s company, position in the Client’s company);
  • communication data (e-mail, messages sent to the Administrator);
  • Data related to the use of the Administrator’s Platform and Services;
  • Personal data of Candidates of Clients of the Administrator, such as CVs, s and other personal data submitted to the Client for applying for a job, as well as personal data that Clients enter the Platform themselves as Content.

If you are a Client,

the basis for the processing of your personal data is the performance of the Agreement or the application of measures at your request before concluding the Agreement. If you are a representative of the Client or a User, our legitimate interests are the legal basis for the processing of your personal data to enable use of the Platform and the Services, or the Client’s legitimate interests in using the Platform and the Services as requested by the Client.

If you are a potential client

(trial or demo client, potential client or their representative), we process your personal data for the marketing and sales purposes of the Platform and the Services, and for your company to enter into an Agreement with the Administrator. In order to achieve the above, we may process the following personal data: name, work e-mail address, work telephone number, Client’s company, position in the Client’s company, communication data, data related to the use of the Platform and the Services. The legal basis for the processing of your personal data is our legitimate interests in the marketing of Platform and Services of the Administrator. Considering that this is a B2B platform or platform for businesses, and that we process data related to your business and/or work, we assume that your right to privacy does not take precedence over our legitimate interests.

If you are Candidate of the Client or a Potential Client of the Administrator, or Potential Candidate and/or if the Client

of the Administrator has entered your data on the Platform himself/herself either manually or automatically, or enabled the entry of your data through automatic application forms or job portals and interfaces with other such environments or platforms, then your data will be treated as Content created by the Client and/or User. Thus, the Administrator processes the personal data contained in the Content on behalf of the Client only in order to offer the Platform and provide the Services to the Client, and acts as an authorized processor of such personal data, while the Client acts as the controller of such personal data (as defined in clause 7 of the Terms of Use).

In addition, the Administrator may process your personal data to protect the Administrator’s rights (to identify, file and protect legal claims). The legal basis of the latter is the administrator’s legitimate interest in acting in this way.

The controller does not process any special categories of personal data. As the Platform and Services are not available to persons under the age of 18 in accordance with our Terms of Use, we do not process personal data of persons under the age of 18.

Processing on consent.

We may also process your personal data with your consent (e.g. for direct marketing purposes). If the processing is based on consent, you can withdraw your consent at any time by contacting us at the contact details below or by clicking on the ‘unsubscribe’ link at the end of each email. Withdrawal of consent shall not affect the lawfulness of processing based on consent which took place before the withdrawal of consent.

Authorized data processors

We use carefully selected service providers (authorized data processors) to process your personal data. By doing so, we remain fully responsible for your personal data.

We use the following categories of data processors: data collection, management and storage service providers, e-mail service providers, messaging service providers, customer relationship management and feedback service providers, direct marketing service providers, payment service providers, accountants and legal and other advisers, user experience analysis and improvement service providers, web and server hosting service providers, Platform software bug monitoring service providers.

For more detailed information on the authorized processors used by the Administrator (e.g. their names and locations), please contact us using the contact details below.

Third parties.

We will only share your personal information with third parties if it is set out in this document, if required by applicable law (e.g. if we are required to share personal information with public authorities) or with your consent.

If you are a representative of the User or the Client, we will share your personal data with the Client, as it is necessary to fulfil our obligations to the Client arising from the Agreement. The legal basis for such sharing is our legitimate interests to enable the use of the Platform and the Services, or the Client’s legitimate interests in the use of the Platform and the Services as requested by the Client. We may share your personal information with our auditors. The legal basis for such sharing is our respective legal obligation.

Transfer of personal data outside the European Union (EU) – We only transfer and store your personal data outside the EU if we have a legal basis to do so, including to the recipient of the data who is: i) in a country where an adequate level of protection of personal data is ensured; or ii) falls under a measure that meets EU requirements for the transfer of personal data outside the EU.

If you need more detailed information about the transfer of your personal data outside the EU (e.g. the names of the recipients and the exact legal basis for such transfer), please contact us using the contact details below.

Cookies Policy

For the website to function properly, the website stores small files – so-called cookies – on the device of this user (hereinafter user). A cookie is a small text file that a website stores on a user’s computer or mobile device when a user of the website visits a service provider’s website. This allows the website to remember user actions and preferences (such as username, language, text size, and other similar display preferences) for a period of time. This way, the user does not have to re-enter them each time they return to the page or browse the pages. The legal basis for the use of cookies is our legitimate interest in ensuring the technical functionality and functioning of the website in accordance with the user’s preferences. Cookies are usually valid for a short period of time (day, week or month), in some cases they can be valid for up to a year. We may use cookies and cookie-like tools to provide and improve service quality and to improve the user experience. Cookies may also be used by third parties whose services we use. Cookies are used for several reasons:

  • to personalize content and ads;
  • to provide social media features;
  • to analyze the use of websites.

We may also provide our social media, advertising and analytics partners with information about how the website is used. The use of such cookies is not directly necessary for the functioning of the website, but it ensures a better browsing experience. Cookies can be deleted or blocked, but in this case not all functions of the website may work as intended. Cookies help us to offer our services better.



Control of cookies.

The user can check and / or delete cookies as desired (see www.youronlinechoices.com/). The user may delete all cookies already on the computer and reject the cookies at any time by changing the settings of their web browser (if the web browser allows it) or by terminating the use of the website. Please be aware that certain features of the website can only be provided using cookies and if you refuse cookies, these features may not be available to you. You can disable cookies in your browser settings or by visiting websites:

Google Analytics.

We may use Google Analytics, a web analytics service provided by Google, Inc. (1600 Amphitheater Parkway, Mountain View, CA 94043, USA; “Google”). Google Analytics uses cookies to analyze how a user uses your website. As discussed above, the user can disable the storage of cookies on the user’s computer with the settings of the web browser, but in this case the user will not be able to use all the functions of the website. The user may disable the collection of their data by Google Analytics at any time. To do so, the user must download and install the appropriate browser add-on from the following website: tools.google.com/dlpage/gaoptout?hl=en. For more information about how Google Analytics handles user data, see: https://support.google.com/analytics/answer/6004245?hl=en.

Website logs.

The server hosting our website may store queries made by the user to the server (web address opened by the user, browser and device used by the user, IP address, access time). This data is used only for technical purposes to ensure the operation and security of the website and to detect security incidents.

Security.

We implement technical and organizational security measures to protect your personal information, taking into account (i) the state of the art, (ii) the cost of implementation, (iii) the nature, extent, context and purposes of the processing, and (iv) the risks you bear. Such security measures include, but are not limited to, encrypted storage and access control.

Data retention.

We retain your personal data for as long as is necessary for the purpose of collecting it, as long as it is necessary to protect the interests of the Administrator or as long as required by applicable law.

If you are a potential Client (trial or demo Client, potential Client or their representative), we will retain your personal information for 12 months from the end of the respective trial or demo period, or from the moment your personal data was collected for marketing purposes based on the legitimate interests of the Administrator (see above). Unless otherwise agreed, if you decide not to continue using the Platform under the price package after the end of the trial period, the trial version of the Content, including the personal data contained therein, will be retained for 90 days after the end of your trial period.

If you are a paying Client or their representative or user, we will store your personal information as follows:

  • in accordance with Estonian accounting and taxation laws, information related to invoices is stored for seven years from the end of the respective financial year;
  • in accordance with applicable (Estonian) law, we retain personal data related to such claims for a maximum of 10 years from the date on which the claim becomes collectible.

Your rights.

You have all the rights of the data subject regarding your personal data to the extent required by the applicable data protection rules. These rights include:

  • requesting access to your personal data;
  • receiving a copy of your personal data;
  • correction of incorrect or incomplete personal data;
  • deletion of personal data;
  • restrictions on the processing of personal data;
  • transfer of personal data;
  • an objection to the processing of personal data based on a legitimate interest and processed for direct marketing purposes.

If it appears that your rights have been violated, you have the right to lodge a complaint with a data protection authority or a court. To exercise your rights, please contact us using the contact details below.

Changes to the Privacy Policy.

If our personal data processing practices change or if there is a need to change the Privacy Policy in accordance with applicable data protection rules, other applicable legislation, case law or guidelines issued by the competent authorities, we reserve the right to unilaterally change the Privacy Policy at any time. In this case, we will notify you by email within a reasonable time before the changes take effect.

Applicable law.

The law of the Republic of Estonia applies to the processing of your personal data.

Contact details.

If you have any questions regarding the processing of your personal data or if you wish to exercise your rights as a data subject, please contact us at: hello@recruitlab.ee.

The privacy policy is updated on 01.06.2021 and is valid from 01.07.2021

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