December 2022
Since one of the essential principles of the GDPR is transparency, we have prepared this document, hereinafter called “Privacy Policy”, by which we want to inform you about how we collect, use, transfer and protect your personal data when you interact with us in connection with our services, including through our website.
The basic document to which we refer in terms of ensuring compliance requirements is Regulation (EU) 679/2016 of April 27, 2016 on the protection of natural persons with regard to the processing of personal data and on the free movement of such data and repealing the Directive CE 46/1995 (GDPR), completed with the Romanian legislation in force.
The owner of this website is S.C. TECH STREAM DIGITAL CONSULTING SERVICES S.R.L. hereinafter called “TALENT SPOTTER”, a company specialized in specific services for human resources departments, as well as in IT consulting services. This Privacy Policy applies to information collected by TALENT SPOTTER, regardless of how it is collected or stored, and describes, among other things, the types of information collected, how the information may be used, when the information may be disclosed, how you can control the use and disclosure of information and how your information is protected.
During the course of our business processes we may have access to the following categories of data:
a. Personal data related to the hiring process, execution and termination of the legal employment relationship: name, surname, photo, CNP, identity card, passport, driver’s license, gender, date and place of birth, nationality, home address, telephone, e -mail, information on family situation, information on marital status, children or other dependents, medical information on health status, medical leaves, maternity leaves, accidents, tax information on payroll, premiums and compensations, fines and penalties, bank account, education information, work experience, schools completed, diplomas, qualification and specialized courses, legal information about criminal record, signature samples, GPS location information, etc.;
b. Personal data about candidates obtained during the recruitment process, as part of the services provided for clients: name, surname, facial image, date and place of birth, nationality, home address, telephone, email, , education information, schools completed, previous qualifications, specializations, jobs and salaries;
c. Personal business data of representatives of clients or partners, obtained during the performance of IT consulting services: name, first name, position, company, company address, phone and email address, signature, images (occasionally).
We also collect other types of information from you or other sources, which may include, but are not limited to:
• Information collected through the online forms present on our website;
• Information from legal databases or public sources, such as business cards, Web pages, catalogs, company lists, recommendations as contact persons, social networks, etc.;
• Information about your use of our services, such as usage data;
• Information about the approximate physical location (eg, city or zip code) of a computer or device derived from the IP address of such computer or device.
We note with all responsibility that we do not collect or process sensitive data, included by the General Data Protection Regulation in special categories of personal data. We also do not collect or process personal data of minors under the age of 16.
Regardless of the positioning in the processing of personal data (operator or processor/authorized), TALENT SPOTTER declares and assumes full responsibility that the personal data collected is used only for the following purposes:
• Administration of own human resources;
• The recruitment process and the selection of candidates within the services provided for clients;
• For the purpose of the smooth development of commercial relations and consulting services with TALENT SPOTTER suppliers and partners
In accordance with the provisions of Art. 6 (1) GDPR, the processing of personal data at TALENT SPOTTER is carried out on the basis of the following legal grounds:
• the existence of a contract – such as the employment contract with employees or documents with contractual value related to the provision of services;
• the existence of a legal obligation – of a commercial or legal nature, associated with certain types of activities;
• the existence of a public interest – related to compliance with certain rules of conduct or public preventive measures;
• the existence of a vital interest – related to protecting the physical integrity of employees;
• the existence of a legitimate interest – for the performance of service provider-client business relationships in the best conditions and the increase of the quality of services;
• the existence of a consent – freely given, specific, informed, clearly expressed and resulting from a clear affirmative action, requested in particular in the case of commercial relations with new customers or for the purpose of the smooth running of marketing activities.
We may collect or obtain information about you in the following ways:
• directly from you (for example, if you contact us by telephone, email, post or courier services), in the course of our interactions with you;
• when you send us your identification data by completing online forms or to the addresses on the contact page;
• when interacting with anything
• content owned by a third party.
• we may also retain information about you simply by keeping track of interactions with you, such as e.g. details about the commercial history, the record of the services provided, the acceptance of cookies when browsing the site, etc.
TALENT SPOTTER is not responsible for the personal information you voluntarily provide about yourself through phone, email or website bid requests. This policy also does not cover the practices of third parties who may provide information about you to TALENT SPOTTER.
TALENT SPOTTER retains information for such periods as it deems useful or as required by contract, applicable laws or regulations. Information provided to TALENT SPOTTER is stored within internal systems or outsourced service providers. For recruitment services, as a general rule we will store your CV throughout the recruitment process. You can ask us to delete certain information or withdraw consent at any time, and we will comply with such requests, subject to the retention of certain information where applicable law or our legitimate interests require it, such as the law relating to the archiving of commercial documents, the prevention of legal action or special measures requested by the competent authorities in accordance with current legislation.
TALENT SPOTTER takes reasonable steps to ensure compliance with HDPR principles regarding processing fairness, relevance and limited to what is absolutely strictly necessary, minimization of collected data and retention period.
TALENT SPOTTER pays particular attention to the consent received from you regarding the processing of personal data. In this spirit, we have implemented a special consent administration procedure, which in the spirit of the GDPR must meet the 5 validity criteria:
• Freely given – the data subject must not be pressured to give consent or suffer any harm if they refuse
• Specific – the consent of the person must be requested for each individual data processing activity;
• Informed – the person must be explained what is being asked of him and what he must agree to;
• Clearly expressed – the language must be clear and simple, and the answer clearly formulated, unambiguous, unequivocal;
• Clear affirmative action – the person must expressly affirm by doing or saying something in the affirmative.
As appropriate, we may transmit or provide access to certain of your personal data to the following categories of recipients/third parties:
• service providers associated with the human resources department
• logistics and courier service providers;
• providers of payment/banking services;
• to clients benefiting from recruitment and IT consultancy services.
We ensure that access to your data by third-party legal entities under private law is carried out in accordance with the legal provisions on data protection and information confidentiality, based on contracts concluded with them, which include the necessary confidentiality and data protection clauses personal. According to the legislation in force, the data can be disclosed without the user’s consent to the state institutions empowered in this regard, but only following an official and legal request addressed to the operator by them.
TALENT SPOTTER takes reasonable steps to ensure the security of personal data by implementing appropriate technical and organizational measures to secure your information and protect it against unauthorized or illegal use and accidental loss or destruction, including:
• sharing and providing access to data, to the minimum extent necessary, subject to confidentiality restrictions where appropriate and anonymously whenever possible;
• personal data collected by the TALENT SPOTTER operator are stored on secure systems;
• verifying the identity of any person requesting access to information, before granting them access to information;
We follow generally accepted standards to store and protect the personal data we collect, both during transmission and once received and stored, including the use of encryption where appropriate.
For customers in Romania, TALENT SPOTTER does not transfer personal information to other locations in other countries. Currently, we store and process your personal data only on the territory of Romania. We will always take steps to ensure that any international transfer of personal data is handled carefully. Transfers to service providers and other third parties will always be protected by contractual commitments and, where appropriate, other safeguards, such as standard contractual clauses issued by the European Commission or existing certification schemes.
Under the conditions provided by the European Union Regulation 679 of 2016 for the protection of individuals with regard to the processing of personal data and the free movement of such data, as data subjects, you benefit from the following rights:
The right to information, respectively the right to receive details regarding the processing activities carried out by TALENT SPOTTER as described in this document;
The right of access to data, respectively the right to obtain confirmation from TALENT SPOTTER regarding the processing of personal data, the provision of copies of the data held, as well as details of the processing activities;
The right to rectification, respectively the right to obtain the correction, without justified delay, by TALENT SPOTTER of inaccurate/unjustified personal data, as well as the updating of incomplete data;
The right to erasure of data, (“the right to be forgotten”), without undue delay, if one of the following reasons applies:
• the data are no longer necessary for the purposes for which they were collected or processed;
• if consent is withdrawn and there is no other legal basis for processing;
• if the data subject objects to the processing and there are no legitimate reasons to prevail;
• if the personal data were processed illegally;
• if personal data must be deleted to comply with a legal obligation;
The right to restrict processing, insofar as:
• the person contests the accuracy of the data, for a period that allows us to verify the correctness of the data;
• the operator no longer needs the personal data for the purpose of processing, but the data subject requests them for establishing, exercising or defending a right in court;
The right to data portability, respectively:
• the right to receive personal data in a structured way, commonly used and in an easy-to-read format;
• the right for this data to be transmitted by TALENT SPOTTER to another data operator, to the extent that the conditions stipulated by law are met.
The right to opposition:
• it can be exercised by submitting a request as indicated below;
• at any time, for reasons related to the particular situation in which the data subject finds himself, that the data concerning him be processed on the basis of the legitimate interest of TALENT SPOTTER or on the basis of the public interest, except in cases where TALENT SPOTTER can demonstrate that it has legitimate and compelling reasons that justify the processing of the collected data and that prevail over the interests, rights and freedoms of the data subjects or that the purpose is to establish, exercise or defend a right in court;
The right not to be subject to an automated individual decision, i.e. the right not to be the subject of a decision taken solely on the basis of automated processing activities, including the creation of profiles, which produce legal effects that concern the data subject or affect him in a similar way in -a significant measure.
The right to withdraw consent, i.e. withdrawal of permission to use personal data for any processing activity carried out by TALENT SPOTTER for which you have given your consent. It is important to understand that the withdrawal of consent for a certain type of personal data processing refers only to the processing carried out from the moment of the notification of the withdrawal of consent, not affecting the data processing carried out during the existence of the consent and will not affect the consent given for other activities or services.
The right to address the National Supervisory Authority for the Processing of Personal Data (ANSPDCP) in Romania, which can receive notifications from the persons concerned at: B-dul G-ral. Gheorghe Magheru no. 28-30, Sector 1, postal code 010336, Bucharest, Phone: +40.318.059.211, E-mail: anspdcp@dataprotection.ro or through the online platform www.dataprotection.ro
The right to address the Court, for the defense of any rights guaranteed by this law, which have been violated, as well as for situations in which you consider that the operator of personal data or the Competent Authority did not pay the necessary attention to your request to exercise the stated rights.
Through this policy, TALENT SPOTTER assures you that we will always attach the utmost importance to respecting your fundamental rights as a data subject. We are confident that any request you send us will be resolved as soon as possible, in accordance with the provisions of domestic and international legislation and the requirements of the GDPR. In this spirit, TALENT SPOTTER has developed and implemented a special procedure for resolving data access requests from data subjects (customers and partners).
We remind you that you can contact us at any time by sending your request by post or courier to the address of the TALENT SPOTTER headquarters in the city of Chitila, Șos. Banatului 14, bl. 33, sc. 1, apartment 389, Ilfov county or to the email address: alina@talentspotter.ro
