Company Name: Technological Investments Center, LLC
Place of business: 2 Pobedy str., Khalch, Gomel region, Vetkovsky district, Republic of Belarus.
Company correspondence address: 3 Chekhov str., 220035, Minsk, Republic of Belarus
UNP (Payer’s Identification Number) of the company: 491497109
(hereinafter – the Company)
Telephone numbers of the company: +375295323698
Website of the company: https://salary2.me/
Company’s application: teamconstructor.com
- website: _https://salary2.me/_ (hereinafter – the Website).
- application:_ com_ (hereinafter – the Application).
- email:_ firstname.lastname@example.org
The Company shall act as the Client’s personal data controller, as the Company shall decide for which purposes it needs personal data, and shall choose the services and tools for the personal data processing independently.
In accordance with article 27 of the GDPR, the Company has appointed a representative in Germany who will act as our representative of the GDPR in the EU (hereinafter – the GDPR Representative). The Client can contact the GDPR Representative by sending an email to the following address: email@example.com or by writing a letter to our GDPR Representative to the following address: Lietzenburger Str. 20A 10789, Berlin, Germany.
1. Terms and Definitions
Personal data means any information relating to the “data subject”, i.e. to an identified or identifiable natural person; an identifiable natural person is one who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person.
Controller means any legal person which, alone or jointly with others, determines the purposes and means of the processing of personal data.
Processor means a natural or legal person which processes personal data on behalf of the controller;
Consent of the data subject means any freely given, specific, informed and unambiguous indication of the data subject’s wishes by which he or she, by a statement or by a clear affirmative action, signifies agreement to the processing of personal data relating to him or her.
Personal data processing means any action (operation) or set of actions (operations) performed with personal data by using the automation means, including the collection, recording, organisation, structuring, accumulation, storage, adaptation or modification, downloading, viewing, use, disclosure by transmission, distribution or other type of access, comparison or combination, reduction, deletion or destruction.
Restriction of processing means the marking of stored personal data with the aim of limiting their processing in the future.
Pseudonymisation means the processing of personal data in such a manner that the personal data can no longer be attributed to a specific data subject without the use of additional information, provided that such additional information is kept separately and is subject to technical and organisational measures to ensure that the personal data are not attributed to an identified or identifiable natural person.
Anonymisation means the process in which the personal data are being changed in such a manner that they can never be retrospectively linked to a particular data subject. It includes, for example, deleting the first name, last name, address, date of birth, and other identification information.
Personal data breach means a breach of security leading to the accidental or unlawful destruction, loss, alteration, unauthorised disclosure of, or access to, personal data transmitted, stored or otherwise processed.
Sensitive information – the Company does not intend to collect confidential information through its Website, Application, e-mail and (or) during the provision of Services, such as racial or ethnic origin, political views, religious or philosophical belief, union membership, genetic data, biometric data relating to health, sexual life or sexual orientation of a natural person, as well as information regarding the existence of criminal records. The Company asks the Client not to provide the abovementioned information.
Biometric data means personal data resulting from specific technical processing relating to the physical, physiological or behavioural characteristics of a natural person, which allow or confirm the unique identification of that natural person, such as facial images or dactyloscopic data.
2. Methods of Collection and Processing of Personal D Personal Data Being Collected and Processed
2.1. The Company collects and processes Personal Data about the Client both by direct provision by the Client and automatically:
2.1.1. Client registration and (or) Client connection. The Client shall provide the Company with Personal Data, such as the first name, last name, residence address, e-mail address, as well as login and password necessary for creation of an account. In case of registration for receiving the paid Services, the Client shall specify the method of payment (for example, by bank card) and the payment details. If the Client is a Representative, the Client shall also specify the name of the company on whose behalf it acts, the identification number of the company and its location.
By registering and (or) connecting to the Website or the Application by using a third party service, the Client grants the Company permission to access and use the information from this service in accordance with the permission of this service, as well as to store the login information for entering this service.
2.1.2. Uploading of CV by the Client. The Client will be asked to upload his CV in Word, PDF, or other text formats, which shall contain, for example, the following Personal Data:
- last name, first name;
- city and country of residence;
- job title;
- date and place of birth;
- e-mail address and (or) telephone number;
- education background: name of educational institution, year of graduation, educational level;
- information about other education;
- level of English proficiency;
- level of knowledge of other languages;
- skills and abilities;
- work experience: name of the company, place of registration of the company, date of commencement of work in the company, date of completion of work in the company, last position, other positions held in the company;
- technologies, skills and abilities used when working at the current and (or) at the last workplace;
- description of projects on which the Client worked;
- information about what kind of work is the Client looking for;
- information about the salary of the Client: the amount of salary at the last or at the current place of work, the desired amount of salary at the new place of work;
- any additional information that the Client provides in his/her CV.
The Company does not collect sensitive information about the Client. Please do not include sensitive information in your CV.
2.1.3. Filling out the forms on the Website and in the Application of the Company. The Company collects the Client’s Personal Data when the Client fills out, provides and places them in the course of using the Company’s Services (for example, when filling out a form with salary information, filling out a vacancy placement form). The Client is not obliged to fill out, provide or place the Personal Data in the forms indicated, however, their non-filling out may make the Company not being able to provide the Services.
2.1.4. System members. The Company receives the Client’s Personal Data when the Client uses the services of other Clients and (or) when the Company provides Services to the Clients.
2.1.7. Logging into the Client’s account. When the Client logs into the account to use the Services or logs out of the account, the Company collects the following data:
-URL-address of the website from which the Client logged into, the website to which the Client went and the time of visit, as well as the pages visited;
— information about the Client’s network and device (for example, about the IP address, proxy server, operating system, web browser, add-ons, device identifier and features, cookie identifiers and / or the Internet service provider or mobile operator);
— when using the Company’s Services from a mobile device, this device sends the Company information about the Client’s location based on the phone’s settings. The Company will ask the Client (you) to give your consent for the use of GPS or other means that allow to determine the exact location of the Client;
2.1.8. Communication. The Company receives Personal Data at the time of sending, receiving messages from the Client and (or) during any other communication between the Company and the Client;
2.1.9. Third party websites and services. The Company receives information about the Client’s visits of the third party services and interaction with them when logging into via the Website and (or) the Application or when visiting the third party services that contain some advertisements, cookies and similar technologies of the Company.
By registering and (or) connecting to the Website or the Application using a third party service, the Client gives the Company permission to access and use the information from this service in accordance with the permission of this service, as well as to store the logging information for logging into this service. For example, if the Client gains access to the Website or the Application through the social network site, the Client agrees that the Company can access, store and provide any information and data that the Client provides in the relevant account on the social network site within the Application, the Website, and the CV Database, so this information is available in the Client’s account registered with the Company. The Client agrees that the Company is not responsible for any Personal Data that are provided to the Company in violation of the Client’s privacy settings on the corresponding social network site.
2.3. If the information listed in this section is aggregated and (or) anonymised, and therefore it cannot reasonably be correlated with an identified or identifiable data subject, the Company has the right to use it for any commercial purposes.
3. Purposes of Collecting and Processing of Personal Data of the Client
3.1. The Company collects and processes the Client’s Personal Data for all or some of the purposes listed below:
3.1.1. for providing, supporting and personalising the Services to the Client, as well as for analysing and improving the quality, speed and efficiency of the provision of Services to the Client;
3.1.2. for creating, managing and maintaining the Client’s account;
3.1.3. for managing and administrating of the Company’s Website and Application, for their improvement, ensuring their security and ensuring the most effective presentation of the content on the Client’s device;
3.1.4. for interacting with the Client and (or) for answering the Client’s letters and requests, for exchanging information with the Client, for informing the Client about the Company Services. For communication with the Company, the e-mail, mobile phone, notifications on the Website or in the Application, and other communication methods included in the Services will be used. The Company will send messages to the Client (you) regarding the availability of the Services, security and other aspects of the provision of Services.
3.1.5. in order to comply with legal regulations to satisfy regulatory requirements for the provision of information to state authorities, the police, the courts and supervisory authorities for the proper detection and prevention of fraud, the adoption of measures to combat money laundering and other illegal activities;
3.1.6. for making researches and developments in order to improve the Services. This allows us to provide our Clients with better, more efficient and personalised Services, as well as to expand the audience of our Clients and to increase their interest in the Services. The Company uses the available Personal Data to study socio-economic trends and industry trends, such as job opportunities, skills and policies that they need to bridge the gap in various industries and regions. In some cases, the Company conducts such studies together with trustworthy third parties, while implementing a set of measures aimed at protecting the privacy of the Clients. The Company and third parties conduct surveys and questionnaires as part of the Services. The Client is not obliged to participate in surveys and questionnaires, and he can choose what information to provide. The Client may refuse to participate in surveys;
3.1.7. for collecting debts, for responding to complaints and questions regarding the Services, as well as for resolving and reviewing them;
3.1.9. for any other purposes disclosed to the Client during the collection of Personal Data.
4. Children’s Privacy
The Company services are intended for a wide audience. The Company does not consciously collect Personal Data of natural persons under 18 years old (hereinafter referred to as the children) without the consent of their parents or guardians. In case the Company finds out that it has collected the Personal Data of children without the consent of their parents or guardians, the Company will delete this Personal Data as soon as possible.
5. Legal Grounds for the Processing of Personal Data
5.1. The legal grounds of the Company for the Processing of Personal Data described above will depend on the relevant Personal Data and the specific purpose of collecting the Personal Data.
5.2. The legal grounds include:
5.2.1. Consent of the Client. In some cases, for example, when receiving job alerts by e-mail, the Company relies on the explicit consent of the Client.
5.2.2. Necessity of the execution of the Agreement. The Company needs to implement Processing for the execution of the Agreement, which is being concluded with the Client and to which the Client the party is, to provide the latter with the Services and to take the measures at the Client’s request before concluding the Agreement.
5.2.4. Legal obligation. In some cases, the Company may also have a legal obligation to store the Client’s Personal Data, for example, to store the information regarding tax and financial statements.
5.3. In case the Company relies on the Client’s consent to the Processing of Personal Data, the Client shall have the right to withdraw his or her consent at any time, and in case the Company relies on legitimate interests, the Client shall have the right to appeal this reason. However, this shall not affect the lawfulness of Processing performed before the Client’s withdrawal of his/her consent.
6. Categories of Recipients of the Personal Data
6.1.1. the Clients who can access the CV database;
6.1.2. the third party agents, service (work) providers who provide services to the Company to maintain the Company’s operations and (or) to assist in providing Services to the Clients (for example, for maintenance, analysis, payment, fraud detection and development). They shall have access to the Client’s Personal Data to the extent reasonably necessary to perform these tasks on behalf of the Company. They are bound by their obligation towards the Company not to disclose or use this data for any other purposes;
6.1.3. the professional advisors such as lawyers, bankers, auditors and insurers who provide the Company with advisory, banking, legal, insurance, financial, auditing and accounting services to enable the Company to carry out its business activities;
6.1.4. the recipient to whom the Personal Data is transmitted by force of law. The Company will be obliged to disclose information about the Client as required by law, upon receipt of a summons letter, or by any other legal process, as well as in cases when the Company has reason to believe that disclosure of information is necessary for:
- investigating, preventing or taking action against the alleged or actual offences or assisting the state law enforcement agencies;
- enforcing the terms of any agreements with the Client;
- investigating and defending against any claims or allegations made by third parties;
- ensuring the security and integrity of the Services;
- exercising or protecting the rights and security of the Company, the Clients and the employees of the Company or other persons.
The Company shall endeavour to notify the Clients of the duly stated requirements with respect to their Personal Data, when it considers it appropriate, unless prohibited by law or court order, and if the request is not urgent. The Company may, at its discretion, challenge such claims if it considers these requests to be overly wide-ranging, unclear or not having proper authority;
6.1.6. the employees of the Company who are in contact with the Client;
6.1.7. any other person in case of presence of the Client’s consent to the processing of Personal Data;
All third parties to which the Company transmits the Client’s Personal Data shall receive only the minimum amount of Personal Data that is reasonably necessary for them to provide the services and (or) the works of the Company. All third parties to whom the Company transmits the Personal Data are obliged to protect the Personal Data transmitted in accordance with all relevant laws and regulations as the Company, to protect them and to process Personal Data only in accordance with the Company’s instructions and to transmit the same obligations to its sub-processors.
6.3. List of the companies
Digital Ocean, LLC (USA). The Company stores the Client’s Personal Data using the servers of the Digital Ocean LLC company. The address: 101 Avenue of the Americas, 10th Floor New York, NY 10013. Digital Ocean LLC certified in the US-EU Privacy Shield program and undertakes to comply with EU data protection requirements (https://www.privacyshield.gov/participant?id=a2zt0000000TQNgAAO&status=Active,
7. Transmission of Personal Data to Third Countries
7.1. The Client’s Personal Data may be transmitted and processed in countries other than the country in which the Client resides. These countries may have data protection laws that differ from those of the Client’s country and provide less effective data protection. In such cases, the Company relies on legal mechanisms for cross-border data transmission.
In addition, the Clients who access the Personal Data may also be in another country and accordingly other laws may apply to the Personal Data Processing. By using the Website and the Application, the Client confirms his/her consent to the Processing of Personal Data in a country that may not have the same level of privacy protection as the Client’s country of residence. If the Client withdraws this consent, the Client shall delete his/her account and agree that the Client will not use or visit the Website or the Application, and use the Services after the withdrawal of such consent.
7.3. The Personal Data Storage and Processing Center of the Company, in which the Personal Data of the Clients are stored, is currently located in the United States of America. In such case the Company transmits data only to a company that complies with the requirements of the Privacy Shield agreements (privacy protection programs) concluded between the European Union and the USA and between the USA and Switzerland, in the manner prescribed by the US Department of Commerce regarding the collection, use and storage of Personal Data being transmitted to the USA from the countries of the European Union and Switzerland.
8. The Period for Which Personal Data Will be Stored. Account Closure
8.1. The Company keeps Personal Data until the Client closes his account, or until it is necessary to provide Services to the Client, or until the Company needs to fulfill its legal obligations, or until the Company has a legitimate interest. Even if the Client uses the Company’s Services every few years, the Company keeps the Client’s Personal data and stores the account until the Client closes his account.
8.2. The Company has the right to anonymise the Client’s Personal Data so that it is not possible to identify the Client, and in such case the Company may use such data without prior permission and at its sole discretion.
8.3. Account closure. If the Client decides to close his account, the Personal Data usually stop to be displayed to other Clients within 24 hours. The Company deletes the data of the closed account within 30 days from the date of closing the account, with the exception of the cases listed below. The Company stores the Client’s Personal Data even after the account is closed, if it is reasonably necessary to fulfill the legal obligations of the Company, or while the Company has a legitimate interest (for example, to resolve disputes, ensure security, prevent fraud or excessive use) or to fulfill the Client’s request for refusal from receiving further messages from the Company. The Company keeps some basic information about the Client in order to avoid sending unwanted messages in the future.
8.4. The Company draws attention to the fact that the Company cannot control the data that other Clients copied when using the Company Services. The Company draws attention to the fact that even if the account was successfully deleted, the Voters who have paid for access to the CV database could save a copy of the CV in their own files or databases. The Company cannot control the savings, use or privacy of the CVs that have been uploaded by other Clients, and the Client may delete the Personal Data that are stored by other Clients only by contacting them directly.
9. The Client’s Rights in Relation to the Processing of Personal Data
9.1. Being the data subject (a person whose Personal Data are being processed), the Client has several rights under the GDPR:
9.1.1. Right of access (article 15 of GDPR). The Client shall have the right to obtain from the Company confirmation as to whether or not personal Data concerning him or her are being processed, and, where that is the case, access to the personal Data and the following information:
- the purposes of the Processing;
- the categories of Personal Data concerned;
- the recipients or categories of recipient to whom the Personal Data have been or will be disclosed, in particular recipients in third countries or international organisations;
- where possible, the envisaged period for which the Personal Data will be stored, or, if not possible, the criteria used to determine that period.
The Company will provide a copy of the processed Personal Data to the Client if: (1) the Client provides the Company with an identity authentication, (2) this does not adversely affect the rights and freedoms of other persons. When the Client sends to the Company a request asking for a copy of the processed Personal Data via e-mail, the Client shall use the e-mail specified by him/her during registration. The first copy will be provided to the Client free of charge, and for any subsequent copies the Company may charge a reasonable fee, depending on the associated administrative costs. If the Client submits a request electronically, the information shall be provided in a generally accepted electronic form, unless the Client requests otherwise.
The Company will respond to the Client’s request asking for a copy of the processed Personal Data without undue delay within one month from the receipt of the request. If necessary, this period may be extended for another two months due to the complex nature of the request or the number of requests. Within one month from the receipt of the request, the Company must inform the Client of such an extension of the term, indicating the reasons for the delay.
9.1.2. Right to rectification (article 16 of GDPR). The Client shall have the right to obtain from the Company without undue delay the rectification of inaccurate Personal Data concerning him or her. Taking into account the purposes of the processing, the Client shall have the right to have incomplete Personal Data completed, including by means of providing a supplementary statement.
9.1.3. Right to erasure (“right to be forgotten”) (article 17 of GDPR). The Client shall have the right to obtain from the Company the erasure of Personal Data concerning him or her without undue delay and the Company shall have the obligation to erase Personal Data without undue delay where one of the following grounds applies:
- the Personal Data are no longer necessary in relation to the purposes for which they were collected or otherwise processed;
- the Client withdraws consent on which the processing is based and where there is no other legal ground for the processing;
- the Client objects to the processing pursuant and there are no overriding legitimate grounds for the processing;
- the Personal Data have been unlawfully processed;
- the Personal Data have to be erased for compliance with a legal obligation in Union or Member State law to which the Company is subject;
There are cases when the Company has the right to save a copy of the Client’s Personal Data, which the Client requested to delete, namely:
- in order to comply with a legal obligation that requires Processing in accordance with the law of the Union or of the Member State to which the Company is subject;
- for the assertion and implementation of legal requirements and claims or for their challenging.
9.1.4. Right to restriction of processing (article 18 of GDPR). The Client shall have the right to obtain from the Company restriction of processing where one of the following grounds applies:
- the accuracy of the Personal Data is contested by the Client, for a period enabling the Company to verify the accuracy of the Personal Data;
- the processing is unlawful and Client opposes the erasure of the Personal Data and requests the restriction of their use instead;
- the Company no longer needs the Personal Data for the purposes of the processing, but they are required by the Client for the establishment, exercise or defence of legal claims;
- the Client has objected to processing pending the verification whether the legitimate grounds of the Company override those of the Client.
Where processing has been restricted under the terms described above, such Personal Data shall, with the exception of storage, only be processed with the Client’s consent or for the establishment, exercise or defence of legal claims or for the protection of the rights of another natural or legal person or for reasons of important public interest of the Union or of a Member State.
9.1.5. Right to receive information about the recipients (article 19 of GDPR). If requested by the Client to provide such information, the Company shall inform the Client of the recipients of his/her Personal Data.
9.1.6. Right to data portability (article 20 of GDPR).
The Client shall have the right to receive the Personal Data concerning him or her, which he or she has provided to a Company, in a structured, commonly used and machine-readable format and have the right to transmit those data to another company, where:
- the processing is based on consent pursuant or on a contract;
- the processing is carried out by automated means.
Wherever technically feasible, the Client may require that the Company transmit these data directly to another company. The right of the Client referred to in this subclause shall not affect the rights and freedoms of others.
9.1.7. Right to object (article 21 of GDPR). On the basis of the grounds related to his/her specific situation, the Client has the right to raise an objection to the Processing of his Personal Data anytime based on the legitimate interests of the Company. The Company shall no longer process the Personal Data unless the Company demonstrates compelling legitimate grounds for the processing which override the interests, rights and freedoms of the Client or for the establishment, exercise or defence of legal claims.
Where Personal Data are processed for direct marketing purposes, the Client shall have the right to object at any time to processing of Personal Data concerning him or her for such marketing, which includes profiling to the extent that it is related to such direct marketing.
9.1.8. Automated individual decision-making, including profiling (article 22 of GDPR).
The Client shall have the right not to be subject to a decision based solely on automated processing, including profiling, which produces legal effects concerning him or her or similarly significantly affects him or her. However, this right of the Client does not apply if:
(a) the Client gives the Company his explicit consent to use his Personal Data for making a decision; (b) the company is permitted by law to make a decision; or (c) the automatic decision is necessary so that the Company can conclude a contract with the Client.
By placing his/her CV, the Client understands and agrees that his/her CV will be evaluated by artificial intelligence and can be evaluated by a Recruitment Consultant. The use of artificial intelligence by the Company is necessary for the Company to conclude an Agreement with the Client.
9.1.9. Right to withdraw the consent (article 7 of GDPR). The Client shall have the right to withdraw his or her consent at any time. The withdrawal of consent shall not affect the lawfulness of processing based on consent before its withdrawal and shall not affect the Processing of the Client’s Personal Data carried out on legal grounds other than the consent.
9.1.10. Right to information (article 14 of GDPR). The Client has the right to receive any available information about the origin of data if the Personal Data are not received from the data subject. The Client has the right to request information on whether the Personal Data relating to the Client are transmitted to a third country or international organization. In this context, the Client may request information on the relevant guarantees.
9.1.11. Right to lodge a complaint with a supervisory authority (article 77 of GDPR). Without prejudice to any other administrative or judicial remedy, every Client shall have the right to lodge a complaint with a supervisory authority, in particular in the Member State of his or her habitual residence, place of work or place of the alleged infringement if the Client considers that the processing of Personal Data relating to him or her infringes GDPR. For more information, please contact your local (Client’s) data protection authority. A list of relevant data protection agencies can be found on the website https://ec.europa.eu/info/policies/justice-and-fundamental-rights_en.
9.2. If the Client wishes to exercise his rights in relation to the processing of his/her Personal Data and (or) if the Client has any questions about the protection of his/her Personal Data, the Client may contact the Company by telephone at +375295323698 or by email at firstname.lastname@example.org, or by writing at the following address for correspondence: Lietzenburger Str. 20A , 10789, Berlin, Germany
10. Security of the Client’s Personal Data
10.1. The Company has taken appropriate organizational, technical and administrative measures to protect Personal Data within the organization, including the security measures to prevent unauthorized access to the Company’s systems. The Company is regularly checking its systems for the presence of vulnerabilities and attacks.
10.2. The Company protects the Client’s Personal Data using the security standards such as data encryption, SSL, secure communication channels, and control of physical access to the Company’s premises. Also, the company allows access to the Personal Data only to those employees who are needed to perform the work.
10.3. Although the Company takes reasonable measures to protect the Client’s Personal Data from loss, destruction, interference and unauthorized access, alteration and transmission of the Personal Data, the Client should be aware that no security procedures or protocols will ever guarantee 100 percent protection and there are always the abovementioned risks associated with the provision of the Personal Data on the Internet.
Since the Internet is not a 100% secure environment, the Company cannot guarantee the complete security of the Personal Data. The Client must take into account and remember that:
— the Client shall be responsible for his/her username and password, and he/she is obliged to keep them secret and secure and shall not transmit them to third parties;
— if the Client has the reasons to believe that his interaction with the Company is no longer safe (for example, if the Client believes that the security of his account has been violated), the Client is obliged to inform the Company of this fact immediately by telephone at +375295323698 or by email at email@example.com.
11. Links to Other Services
If the Client clicks on a link to any of these third party services, third parties, goods, services or other events or actions that are not owned and not controlled by the Company, these third parties may use their own cookies, web beacons and other tracking technologies aimed at the independent collection of information about the Client and may request the Client’s Personal Data.
13. Our Contact Details