PRIVACY POLICY 

In accordance with the obligations of the General Data Protection Regulation (EU) 2016/679, of the European Parliament and of the Council, of 27 April 2016, together with those included in Organic Law 3/2018, of 5 December 2018, on the Protection of Personal Data and Guarantee of Digital Rights, RECREWIT GLOBAL, S.L., places at your disposal through this website (www.recrewit.com) this Privacy Policy with the aim of informing you of the processing to which your personal data are subject, the measures aimed at protecting your privacy and the information provided by you.

In the event of any modification of the Privacy Policy, RECREWIT will communicate it through this website or by any other means so that you may be aware of the new Privacy conditions.

DATA CONTROLLER

Data controller: RECREWIT GLOBAL, S.L. (hereinafter, “the Data Controller”, “the Controller”, or “RECREWIT”).

Representative: Alejandro Bello Perez

Tax Identification Number (NIF): B16452344

Registered office: C. León y Castillo, 321, 35006 Palmas de Gran Canaria

E-mail address: [email protected]

Business activity: Search and selection of qualified personnel

PERSONAL DATA PROCESSED

RECREWIT will process users’ personal data in order to render the contracted services, as well as to offer the best user experience. Likewise, in the event that the User provides third party personal data, RECREWIT declares having obtained their consent and undertakes to inform the third party of the content of this Privacy Policy. RECREWIT will not assume any type of responsibility in this respect. However, RECREWIT may carry out periodic checks to verify this fact, adopting the corresponding diligence measures in accordance with data protection regulations.

RECREWIT will process the following data categories:

1. Identification data: name, surname and national identity number and card or equivalent document for natural person or of the representative of the legal entity.
2. Contact data: e-mail address, telephone number, identification data (as mentioned above), postal address, etc.
3. Technical data: IP addresses, cookies, login data, browser type and version used to access the website, etc.
4. Economic and financial data: bank details (credit card, bank account number) or any other data necessary for invoicing purposes.
5. Education and training data: university studies, skills, grades, qualifications, etc.
6. Employment-related data: retribution, current pension and benefits, current position/wished position, job-related areas of interest, third-party references, assessments, etc.
7. Personal situation-related data: when relevant and necessary for the candidate qualification’s process, any information about family, health conditions, references etc., so, any personal circumstance that can impact on the capability to take the job offered.

PROCESSING OF SPECIAL CATEGORIES OF PERSONAL DATA

During the recruitment process or in the course of the services we provide, we may collect personal data that is considered sensitive or special categories of personal data. We will only collect sensitive personal data in accordance with the applicable data protection regulations, including where you have given your explicit consent to the processing or when required by law.

PURPOSES AND LEGAL BASIS FOR PROCESSING

RECREWIT will collect and process the User´s personal data for the following purposes and in accordance with the following legal basis:

PURPOSES	LEGAL BASIS
–       Conducting background checks in accordance with our legal obligations. –       Comply with our legal and regulatory requirements in relation to taxation and financial compliance. –       Cooperate with public authorities. –       Comply with any other obligations to which we are subject under applicable laws and regulations, including record keeping and data retention.	Legal obligations: we process your personal data in order to comply with a legal or regulatory obligation.
–       Recruit staff internally –       Enter into or perform our agreement with you if you are an external supplier or consultant.	Contract execution: we process your personal data in order to carry out and perform our obligations to you under a contract we may enter into or have entered into with you.
–       To offer and provide you with our recruitment services and assess your skills against our clients’ vacancies. –       Provide you with marketing material to help you in your job search. –       Handling complaints and legal claims. –       Sharing your personal data with our third-party service providers. –       Sharing your personal data with prospective employers and with our clients, who may offer you employment opportunities in their organizations. –       To keep clients and candidates informed about our service.	Legitimate interests: when the processing of your personal data is necessary for the purposes of pursuing our legitimate business interests and provided that your interests and fundamental rights do not override them.
–       When creating an account on our website. –       Storage of candidates´ personal data for the purpose of job finding/new opportunities. –       Sharing your personal data with our clients, who may offer you employment opportunities in their organizations. –       To keep clients and candidates informed about our service.	Consent: where you have given us your consent to use your personal data for one or more permitted purposes. All consents obtained for the aforementioned purposes are independent and the User may revoke only one of them without affecting the others.

Depending on our relationship with you, we may rely on one or more of the above legal bases for processing your data. If you would like to know which legal basis we use to process your personal data, you may contact us in this regard.

COLLECTION OF PERSONAL DATA

RECREWIT collects your personal data as follows:

• Through the information you provide us directly, for instance, via phone, message, social media, e-mails, etc.
• Information we automatically collect about you, for example via cookies from our website.
• Information we obtain from third parties, such as references or client leads.
• Information we obtain from third party applications.
• Public sources, for example, from job search platforms.

RECIPIENTS

RECREWIT does not share personal data of its clients or users of the website and social networks, except for those cases in which it is strictly necessary to comply with a legal obligation or for the execution of the service contract with the users. 

In order to provide the requested service, third parties acting as suppliers of RECREWIT may have access to personal information in order to carry out the service for which they have been contracted, acting as data processors (legal and accounting assistance, auditors, destruction of documents/information and information technology service providers, for example, data hosting and email service). It should be emphasized that the above shall not be considered as a transfer of personal data. These providers will access your personal data in accordance with the instructions of RECREWIT and will not use it for any other purpose, keeping your personal information strictly confidential. RECREWIT undertakes to select suppliers who comply with the current regulatory framework for the protection of personal data.

The competent authorities and bodies, to the extent necessary to comply with legal obligations, will also be considered recipients for these purposes.

In the development and fulfillment of the contracted services and its professional activity, international data transfers may occur when, in order to carry out the above communications, personal data must be transferred to any of these recipients that are not within the European Economic Area, United Kingdom and Switzerland, and, therefore, do not comply with European regulations on data protection. In these cases, RECREWIT shall ensure that international transfers comply with the safeguards set out in European data protection law, by adopting appropriate safeguards in the event that the country to which the personal data is transferred does not have an adequacy decision. Moreover, RECREWIT will make sure that third parties that RECREWIT shares certain personal data with have previously accredited the adoption of adequate technical and organizational measures for the correct protection of such data.

STORAGE PERIOD

RECREWIT will only keep your personal data for the period of time necessary to fulfil the purpose for which they were collected, to comply with legal obligations and to attend to possible responsibilities that may arise from the fulfilment of the purpose for which the data were collected, and in any case as permitted by the applicable legislation.

In the specific cases of “registration form” to request the registration of the User in this website, the personal data will be kept until the User requests the deletion of their data.

In any case, and as a general rule, RECREWIT will keep your personal data for as long as there is a contractual relationship that links it to you or you do not exercise your right to suppression and/or limitation of processing, in which case, the information will be blocked without being used beyond its conservation, while it may be necessary for the exercise or defense of claims or any type of responsibility may arise that needs to be attended.

In those cases, in which we act as data processors for our clients, we will retain your personal data in accordance with the storage periods prescribed by our clients.

RIGHTS OF INTERESTED PARTIES

Users of the website may exercise the following rights before RECREWIT, insofar as they are applicable:

• The right of access by the data subject.
• The right to rectification.
• The right to erasure or the right to be forgotten.
• The right to restriction of processing.
• The right to data portability.
• The right not to be subject to an automated individual decision-making; and
• The right to object.

In accordance with current legislation, these rights must always be free of charge, except in the case of manifestly unfounded or excessive requests. In this case, RECREWIT may charge a fee proportional to the administrative costs incurred or refuse to act. Furthermore, they must be exercised directly by the interested party or through their legal representative or volunteer.

RECREWIT must reply to your request within one month, although, depending on the complexity and number of requests, this period may be extended by up to two months. In the event of not acting on your request, RECREWIT will inform you, within one month at the latest, of the reasons for its failure to act and the possibility of lodging a complaint with the Spanish Data Protection Agency.

You must be provided with all the necessary information on the means of exercising these rights, which must be accessible. You may not be denied the exercise of the right simply because you choose a different means. If the request is made by electronic means, the information should be provided by electronic means where possible, unless you ask us to do otherwise.

Users may exercise these rights by duly identifying themselves with their ID number and by sending a letter or e-mail to the addresses indicated in the ʻData controllersʼ section. The request must be signed, and the subject line must indicate ʻExercise of GDPR Rightsʼ.

USER LIABILITY

By providing their data to RECREWIT through electronic channels, the User guarantees to be over 18 years of age and that the data provided to RECREWIT are true, exact, complete and up to date. To this effect, the User takes responsibility for the veracity of the data communicated and for keeping this information suitably updated so that it corresponds to reality, taking responsibility for any false or inaccurate provided data, as well as for any damages, direct or indirect, that may arise.

DATA SECURITY

RECREWIT informs you that the necessary technical and organizational security measures have been implemented to guarantee the security of your personal data and to avoid its alteration, loss and unauthorized processing and/or access, taking into account the state of technology, the nature of the data stored and the risks to which they are exposed, whether these arise from human action or from the physical or natural environment. All in accordance with the provisions of the GDPR.

Likewise, RECREWIT has established additional measures in order to strengthen the confidentiality and integrity of the information in its organization and to continuously maintain the supervision, control and evaluation of the processes to ensure respect for data privacy.

MODIFICATIONS TO THIS PRIVACY POLICY

RECREWIT reserves the right to modify, at any time, the present Policy in order to adapt it to new legislation or jurisprudence, as well as to industry practices. In such cases, the Data Controller will announce on this page the changes introduced with reasonable notice of their implementation. Likewise, RECREWIT recommends that this Privacy Policy be reviewed periodically in order to be aware of the latest version of the same.