RECRUITMENT PRIVACY NOTICE

This Recruitment Privacy Notice (hereinafter “PrivacyNotice”) explains how Clickwork Games OÜ (hereinafter “we”, “us” or “Clickwork Games”) processes the personal data of candidates, including potential candidates for employment,and other individualswho we may come into contact during the recruitment process (e.g., recommenders) at Clickwork Games (hereinafter “you”, “candidate” or the “data subject”).

We have created this Privacy Notice to:

       Provide all necessary information about how we collect and use your personal data in the recruitment process,

       Demonstrate our commitment and accountability to protect and respect your rights to data protection and privacy,

       Describe the processing of personal data by us as a data controller under the EU General Data Protection Regulation (hereinafter the “GDPR”) - this means that we individually or along with others determine the purposes and means of the processing of personal data, and

       Assist you to understand what rights you have with respect to processing of your personal data by us.

If you are not sure how this Privacy Notice applies to you or if you have any other questions related to this Privacy Notice, please contact our Data Protection Officer using the contact details found below.

1.      DATA CONTROLLER

Clickwork Games OÜ

Registry code: 14825796

Address: Roseni 9-5, 10111 Tallinn, Estonia

Email: info@clickworkgames.com

Contact details of data protection officer: privacy@clickworkgames.com

2.      PERSONAL DATA WE PROCESS

We process the following personal data:

-        Recruitment-related personal identification information and contact data – such as name and surname, phone number and email address.

 

Sources of collection of data: we get this data from youat the beginningor during the recruitment process, we also might get this information from third party recommenders or recruitment platforms.

 

-        Information about experience, education and training – such as diplomas, certificates and licenses, training attendance, skills and competencies and other work-related qualifications.

 

Sources of collection of data: we get this data from you at the beginning or during the recruitment process.

 

-        Generalrecruitment communications – such as recruitment-related e-mail correspondence or other communications, where permissible.

 

Sources of collection of data: this data is generated during the recruitment process.

 

-        Compliance and risk management information – such as background check reports, information about complaints and disciplinary sanctions, and where permissible, information about violation of laws or breach of company policies.

 

Sources of collection of data: we may collect the information for background checks from publicly available sources on the Internet. The information about complaints may be received from our employees or third-party complainant(s).

 

-        Social media data – such as publicly available information on data subject’s social media platforms (for example, LinkedIn, Facebook etc.),e.g., previous work experience, education or other information that is public and might be relevant in the recruitment process.

 

Sources of collection of data: we may collect this information when scouting possible candidates for employment, when receiving a job application or a recommendation about you from a third party.

 

 

-        Recruitment and hiring related information – such as information that was provided or created during the recruitment and hiring process, including your motivational letter, recommendations (please note that it is your responsibility to obtain consent from your recommenders prior to providing us personal information about them), interview details and copies of relevant documents.

 

Sources of collection of data: we get this data from you at the beginning of the recruitment process.

3.      THE PURPOSES AND THE LEGAL GROUNDS FOR THE PROCESSING OF PERSONAL DATA

We only process personal data when we have defined a relevant purpose and legal ground for the processing. Your personal data will be used only in a manner consistent with the purpose.The purposes and the legal grounds for the processing of personal data are the following.

3.1.           Legitimate interests

In some cases, we rely on our legitimate interests when processing your personal data. You have the right to ask clarifications regarding the processing based on the legitimate interests by sending the request atprivacy@clickworkgames.com. You also have the right to send the objection, if you find that processing of your data for the purposes provided below prejudice your rights.

Purposes of processing

Categories of data

Identifying potential candidates for open or future positions:

-        Processing of information provided by the candidate to determine who they are, what background they have and whether they should be considered for open or future positions

-        Processing of publicly available online information in connection with scouting and recruitment prior to engagement with a candidate

-        Recruitment-related personal identification information and contact data 

-        Information included in your CV about experience, education and training

-        Social media data

 

Protecting our rights and fulfilling the professional requirements, for example:

-        to decide whether to offer employment,

-        to make decisions about salary and benefits,

-        to assess training needs,

-        to defend legal claims against us, and

-        to send you notifications about your progress and other vacancies which are relevant to you

 

-        Recruitment-related personal identification information and contact data

-        Information about experience, education and training

-        Recruitment and hiring related information

-        General recruitment communications

-        Compliance and risk management information

-        Social media data

Conducting background checks:

-        using information gathered from various sources, such as publicdirectories and publicly available online personal or professional profiles, to checkidentities of candidates to make sure they have proper background and no intention to deceive us

-        Verifying data you submit through recommenders.

 

Regarding candidate:

-        Recruitment-related personal identification information and contact data

-        Information about experience, education and training

-        Recruitment and hiring related information

-        General recruitment communications

-        Compliance and risk management information

-        Social media data

Regarding recommender:

Name, surname, place of work, position, phone number and/or email address.

3.2.           Processing necessary for the actions necessary prior to entering into employment contract

We process personal data on this legal ground where it is necessary for the actions prior to entering into employment contract.

Purposes of processing

Categories of data

Determining your qualifications for employment and reaching a recruitment decision

 

-        Recruitment-related personal identification information and contact data

-        Information about experience, education and training

-        Recruitment and hiring related information

-        General recruitment communications

Informing you, via e-mail, phone or otherwise about the progress of your application for employment with us

-        Recruitment-related personal identification information and contact data

-        General recruitment communications

Preparation of a job offer and/or contract (e.g., preparation of an offer letter)

-        Recruitment-related personal identification information and contact data

-        Information about experience, education and training

-        Recruitment and hiring related information

-        General recruitment communications

3.3.           Consent

In some limited cases, we need your consent for data processing. You always have the right to withdraw the consent by sending us respective note at privacy@clickworkgames.com. Withdrawal of the consent does not affect the legality of the processing of your personal data prior to withdrawal.

Purposes of processing

Categories of data

Evaluating your suitability for other employment vacancies in the future. For this purpose, we keep a record of your application information in case you are not selected to assess your suitability in the future

 

-        Recruitment-related personal identification information and contact data

-        Information included in your CV about experience, education and training

-        Recruitment and hiring related information

-        General recruitment communications

Informing you, via e-mail, phone or otherwise about our other vacancies that we consider you suitable to make an application of employment for

-        Recruitment-related personal identification information and contact data

4.      CATEGORIES OF RECIPIENTS OF PERSONAL DATA AND TRANSFER OF PERSONAL DATA TO THIRD COUNTRIES

Our staff has access to your personal data on a strictly need-to-know basis and such access is usually limited by function, role and department of the employee. To the extent necessary, your personal data is transferred to certain recipients who are categorized as follows:

4.1.   Partners who provide various services to us, and who process the personal data on our behalf (data processors), e.g.:

(a)           Providers of ICT services, e.g., standard and recruitment software, cloud services, communication services;

(b)           Various contractors, e.g., IT support services, software developers, recruitment companies.

4.2.   Public authorities and supervisory bodies, e.g., court, law enforcement authorities, Tax and Customs Board, Data Protection Inspectorate. We transfer your personal data to public authorities and supervisory bodies only in compliance with applicable law or court order or in connection with judicial proceedings or other legal process.

We generally do not transfer your personal data outside of the European Union (EU) or the European Economic Area (EEA), nor to such third country or international organization, the level of data protection of which the European Commission has not considered adequate. If your personal data is transferred outside of the EU or EEA, such transfer of personal data will take place only upon appropriate legal basis, and we will take appropriate protective measures.

You have the right to obtain additional information about the transfer of your personal data by sending the relevant request at privacy@clickworkgames.com.

5.      RETENTION OF PERSONAL DATA

We retain your personal data for the period necessary for the achievement of purposes stated in this Privacy Notice or until it is required by the law.

Unsuccessful application data (i.e., data which is set out in section 2 of this Privacy Notice) without your consent to contact you for other positions, will be deleted after 1,5 years (18 months), taking into consideration our need to answer queries or resolve problems and comply with legal requirements under the applicable laws.

 

In addition to using your data for the position for which you have applied, we retain and use your application data (i.e.,data which is set out in section 2 of this Privacy Notice)to consider you for other positions, but only with your consent for a maximum period of 1 year.

In case of your application being successful, your data will be retained according to our Employee Privacy Notice.

For more detailed information about the retention of your personal data, you can send an email at privacy@clickworkgames.com.

6.      YOUR RIGHTS REGARDING THE PROCESSING OF YOUR PERSONAL DATA

Depending on the situation, you have the following rights.

-        Right of access to your data: you have the right to know, whether personal data concerning you are being processed or not, what is the purpose of processing and what are the categories of personal data. Besides, to whom the personal data is disclosed (especially the recipients in third countries), for how long the personal data is retained and what are your rights concerning rectification, erasure and restriction of the processing.

-        Right of rectification: you have the right to demand rectification of the personal data concerning you if the data are inaccurate or incomplete.

-        Right of erasure: in some cases, you have the right to demand erasure of the personal data concerning you, for example in case when you withdraw your consent and there are no other legal grounds for the processing of the personal data.

-        Right to restrict the processing: in some cases, you have the right to restrict processing of the personal data concerning you for a certain time (e.g., if you have objected the processing of personal data).

-        Right to object: you have the right to object the processing of personal data, which is processed based on the legitimate interest, including profiling. Upon objection, we will no longer process the personal data unless we demonstrate compelling legitimate grounds for the processing which override your interests, rights and freedoms.

-        Right to data portability: if processing of your personal data is based on your consent or the contract with us and the data processing is carried out by automated means, then you have the right to receive the personal data concerning you, which you have provided to us, in a structured, commonly used and machine-readable format. Also, you have the right to claim to transmit those personal data to another data controller if it is technically possible.

-        Right to turn to us, supervisory authority, or a court: if you want to exercise the above-mentioned rights or make a complaint, please send us an email at privacy@clickworkgames.com. If you find that your rights have been breached, you have the right to turn to the Data Protection Inspectorate (AndmekaitseInspektsioon) and/or court. The contact details of the Data Protection Inspectorate are available atwww.aki.ee.

7.      AMENDMENT OF THIS PRIVACY NOTICE

From time to time, we may need to amend this Privacy Notice to keep it accurate and up to date. We will notify of amendment of this Privacy Notice on our intranet, by email or in other manner.