GDRP – Privacy Policy (for recruitment)

Last Updated: Apr 28, 2023

Privacy Policy for recruitment

Cloudvisor group entity (hereinafter ’Cloudvisor’) is a remote-only company, details of which can be found here https://cloudvisor.co/. This Privacy Policy is issued on behalf of the Cloudvisor, so when we mention “Cloudvisor”, “we”, “us” or “our” in this policy, we are referring to the relevant company in the Cloudvisor responsible for processing your data.

Cloudvisor is committed to protecting and respecting your privacy. This Privacy Notice (together with any other documents referred to herein) sets out the basis on which the personal data collected from you, or that you provide to Us, will be processed by Us in connection with Our recruitment processes. Please read the following carefully to understand Our views and practices regarding your personal data and how We will treat it.

Scope of this Privacy Notice

This privacy notice aims to give you information on how Cloudvisor collects and processes your personal data and tells you about your privacy rights and how the law protects you when your personal information is used for recruitment purposes.

We use Greenhouse, a hiring software, to assist with Our recruitment process. We use Greenhouse to process personal information as a data processor on Our behalf. Greenhouse is only entitled to process your personal data in accordance with Our instructions.

Where you apply for a job opening posted by Us, these Privacy Notice provisions will apply to Our processing of your personal information in addition to Our other Privacy Notice, which has been provided to you separately or is available on Our Website.

Where you apply for a job opening via the application function on a job site or similar online service provider (“Partner”), you should note that the relevant Partner may retain your personal data and may also collect data from Us in respect of the progress of your application. Any use by the Partner of your data will be in accordance with the Partner’s Privacy Notice.

Personal data categories

Personal data, or personal information, means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymous data).

During the recruitment process, we may collect and process the following personal data from you:

  • Identity Data such as first name, last name, username, or similar identifier.
  • Contact Data such as an address, email address, and telephone numbers.
  • Job Data such as your CV, previous work history, and other related information
  • Skills and Competencies Data such as your level of education, certificates, language skills, data from assessments, and other related data.
  • Admission Test Data (if conducted during the process) such as results of written and oral test.
  • In addition, we collect and process personal data you provide to us via interviews (including interviews conducted through electronic means).

We do not generally collect any special categories of personal data about you (this includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health, and genetic and biometric data).

In limited situations, we may collect background information, such as information on credit checks and criminal convictions and offenses. In the limited cases where we do process such data, we do this in accordance with the applicable legislation and if possible, we will inform you about such collection and ask for your consent.

 

Your Personal Information

Information we collect from You

We collect and process some or all of the following types of information from you:

  • Information that you provide when you apply for a role. This includes information provided through an online job site, via email, in person at interviews, and/or by any other method.
  • In particular, We process personal details such as name, email address, address, telephone number, date of birth, qualifications, experience, information relating to your employment history, skills and experience that you provide to Us, as well as your video in case you conduct your interview using the Video Interview feature.
  • If you contact Us, We may keep a record of that correspondence.
  • A record of your progress through any hiring process that We may conduct.
  • Details of your visits to Greenhouse’s Website including, but are not limited to, traffic data, location data, weblogs and other communication data, the site that referred you to Greenhouse’s Website, and the resources that you access.

Information we collect from other sources.

Greenhouse provides Us with the facility to link the data you provide to Us, with other publicly available information about you that you have published on the Internet – this may include sources such as LinkedIn and other social media profiles.

Greenhouse technology allows Us to search various databases – some publicly available and others not, which may include your personal data (include your CV or Resumé), to find possible candidates to fill Our job openings. Where We find you in this way We will obtain your personal data from these sources.

We may receive your personal data from a third party who recommends you as a candidate for a specific job opening or for Our business more generally.

Uses Made Of Your Information

Lawful basis for processing

We rely on legitimate interest as the lawful basis on which We collect and use your personal data. Our legitimate interests are the recruitment of staff for Our business.

Where you apply for a job opening through the Apply functionality, We rely on your consent, which is freely given by you during the application process, to disclose your personal data to Indeed on the basis described below.

Purpose and legal basis of processing

We will only use your personal information when the law allows us to. We have set out below, in a table format, a description of all the ways we plan to use your personal data and which of the legal bases we rely on to do so. We have also identified what our legitimate interests are where appropriate.

Note that we may process your personal data for more than one lawful ground depending on the specific purpose for which we use your data. Please contact us at contact@cloudvisor.co if you need details about the specific legal ground we are relying on to process your personal data where more than one ground has been set out in the table below.

Purpose/ActivityLawful basis for processing
To consider you for a role for which you have applied and communicate with you in respect of the recruitment process.1. Necessary for our legitimate interests (to assess your suitability for an open position) 2. Performance of a contract with you 3. You have given consent to the processing of your personal information for one or more specific purposes.
To consider you for future open positions for a specified time period within the Cloudvisor group.You have given consent to the processing of your personal information for one or more specific purposes.
To improve the recruitment experience and process through surveys and data analytics.1. Necessary for our legitimate interests (to improve the recruitment experience and process) 2. You have given consent to the processing of your personal information for one or more specific purposes.
Administrative reasons and legal compliance, such asdiversity and inclusion requirements and practicesrecordkeeping1. Necessary for our legitimate interests (for the purposes of satisfying any legal, accounting, or reporting requirements) 2. Necessary to comply with a legal obligation
To help Our service providers (such as Greenhouse and its processors and data providers) and Partners (such as the job sites through which you may have applied) improve their services.1. Necessary for our legitimate interests (to improve the recruitment experience and process)

 

Automated decision-making/profiling

We may use Greenhouse technology to select appropriate candidates for Us to consider based on criteria expressly identified by Us, or typical in relation to the role for which you have applied. The process of finding suitable candidates is automatic; however, any decision as to whom We will engage to fill the job opening will be made by Our staff.

Disclosure of Your Information

As set out above, We pass your information to Our third-party service providers, including Greenhouse, who use it only in accordance with Our instructions and as otherwise required by law.

Where you have applied for a job opening through the Apply functionality and where you have consented to this disclosure, We will disclose to Indeed certain personal data that We hold, including but not limited to a unique identifier used by Indeed to identify you, and information about your progress through Our hiring process for the applicable job opening, as well as tangible, intangible, visual, electronic, present, or future information that We hold about you, such as your name, contact details and other information involving analysis of data relating to you as an applicant for employment (collectively “Disposition Data”). Indeed’s Privacy Notice in respect of Indeed’s use of the Disposition Data is available on Indeed’s website.

Where you have applied to a job opening through another service provider, We may disclose data similar to the Disposition Data defined above to such service provider. The service provider shall be the data controller of this data and shall therefore be responsible for complying with all applicable laws in respect of the use of that data following its transfer by Us.

How We Store Your Personal Data

Security

We take appropriate measures to ensure that all personal data is kept secure, including security measures to prevent personal data from being accidentally lost, used, or accessed in an unauthorized way. We limit access to your personal data to those who have a genuine business need to know it. Those processing your information will do so only in an authorized manner and are subject to a duty of confidentiality.

We also have procedures in place to deal with any suspected data security breach. We will notify you and any applicable regulator of a suspected data security breach where We are legally required to do so.

Unfortunately, the transmission of information via the internet is not completely secure. Although We will do Our best to protect your personal data, We cannot guarantee the security of your data transmitted through any online means; therefore, any transmission remains at your own risk.

Where We store your personal data

Where We store your personal data in Our own systems within the EU.

The data that We collect from you and process using Greenhouse Services may be transferred to, and stored at, a destination outside the European Economic Area (“EEA”). It may also be processed by staff operating outside the EEA who work for Us or for one of Our suppliers. Such staff may be engaged in, among other things, the fulfillment of your orders, the processing of your payment details, and the provision of support services. By submitting your personal data, you agree to this transfer, storing, or processing.

In particular, your data may be accessible to i) Greenhouse staff in the EU; or ii) may be stored by Greenhouse hosting service provider in the EU. Greenhouse represents a GDPR-compliant hiring software, designed to help safeguard your privacy rights and give you remedies in the unlikely event of a misuse of your personal data.

If we transfer any of your personal information to countries outside of the EU/EEA which do not provide an adequate level of protection according to applicable data protection legislation, we will always ensure that appropriate safeguards to protect your information are in place. In this respect, we may rely on standard data protection clauses adopted by the European Commission or Privacy Shield certification (only relevant to the US). If you would like more information about the measures in place to protect your data, please contact us using the contact details specified in section 10 below.

How long We keep your personal data

We will hold all the data for 6 months.

Your personal information will be deleted on one of the following occurrences:

  • deletion of your personal information by you (or by another person engaged by the Customer); or
  • receipt of a written request by you (or another person engaged by the Customer) to us.

Your rights

Under the General Data Protection Regulation you have a number of important rights free of charge. In summary, those include rights to:

  • access to your personal data and to certain other supplementary information that this Privacy Notice is already designed to address
  • require Us to correct any mistakes in your information that We hold
  • require the erasure of personal data concerning you in certain situations
  • receive the personal data concerning you that you have provided to Us, in a structured, commonly used, and machine-readable format and have the right to transmit those data to a third party in certain situations
  • object at any time to processing of personal data concerning you for direct marketing
  • object to decisions being taken by automated means which produce legal effects concerning you or similarly significantly affect you
  • object in certain other situations to Our continued processing of your personal data
  • otherwise restrict Our processing of your personal data in certain circumstances
  • claim compensation for damages caused by Our breach of any data protection laws.

For further information on each of those rights, including the circumstances in which they apply, see the Guidance from the UK Information Commissioner’s Office (ICO) on individuals rights under the General Data Protection Regulation.

If you would like to exercise any of those rights, please:

  • contact Us using Our Contact details here,
  • let Us have enough information to identify you,
  • let Us have proof of your identity and address, and
  • let Us know the information to which your request relates.

How to complain

We hope that We can resolve any query or concern you raise about Our use of your information.

The General Data Protection Regulation also gives you right to lodge a complaint with a supervisory authority, in particular in the European Union (or European Economic Area) state where you work, normally live or where any alleged infringement of data protection laws occurred. The supervisory authority in the EU is the EU’s Independent Data Protection Authority who may be contacted at https://edps.europa.eu/data-protection/our-role-supervisor/complaints_en.