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Processing of (personal) data by the entity in charge of the online application process

PRIVACY POLICY – HUMAN RESOURCES AND RECRUITMENT DATA

1. ABOUT THIS POLICY 

At Rentle Oy (“Rentle”), we take data protection seriously. 
                   
We process the personal data of our employees to meet our legal and contractual obligations as an employer. Personal data of job applicants are processed for recruitment purposes. 

Please note that this Privacy Policy only applies to the processing of personal data carried out by Rentle as a data controller and only in a human resources context. 
                   
Occupational health care data is controlled by your occupational health care provider. 
                   
This Privacy Policy may be updated from time to time. We will not make substantial changes without prior notice. 
                   
2. CONTACT DETAILS OF CONTROLLER 

Name: Rentle Oy
Business ID: 2634632-5
Correspondence address: Otakaari 5, 02150 Espoo, Finland
Contact: info@rentle.io
Website: Rentle.io 
                   
3. PERSONAL DATA COLLECTED

Job applicants

For job applicants we may process the following information:

  • full name        
  • date of birth    
  • gender          
  • address and contact details 
  • application and curriculum vitae  
  • educational and professional background  
  • work permit or visa information (where necessary for confirming applicant is eligible to work in target country)  
  • qualifications and skills (for example language skills)      
  • results of any tests or evaluations carried out in connection with recruitment 
  • possible drug test results and credit status data in case permitted by applicable laws in order to assess the applicant’s performance and reliability 
  • possible consent given by the applicant for storing the data for future recruitment                          
  • possible non-disclosure agreement made in connection to recruitment process 
  • any other information provided by applicant during recruitment process and communication with us.
                                                                           
Employees

For employees we also process the following information: 
                     
  • identification information, such as name and title, social security number and photograph    
  • information needed for salary payment, such as bank account and tax information 
  • information collected during recruitment stage (please see above)  
  • responsibilities, qualifications, assignments and professional development 
  • start and (if applicable) end date of employment      
  • content of your employment contract  
  • content of any other employment-related contracts (e.g. non-disclosure  agreements or agreements made in connection to the termination of employment)  
  • Copy of visa or work permit (foreign employees)  
  • information on stock options, shares and related agreements 
  • information regarding tracking of working hours and absences 
  • information concerning the employee’s state of health, family or trade union membership when necessary for us to fulfil our legal obligations (e.g. to coordinate sick leaves or parental leaves) and IT information, such as user credentials, emails, access information, device information and associated data.
                           
We only collect information that is either relevant for filling in the position in question or necessary for the rights and obligations of either party in the context of establishing or managing an employment relationship. 
                           
4. SOURCES OF PERSONAL DATA 
                           
Primarily we receive personal data directly from you. 
                           
During the employment relationship we may collect information about you generated through our data systems and from Rentle’s other employees such as your supervisor (e.g. relating to performance reviews) as well as feedback from Rentle’s customers and stakeholders. 
                           
When legally allowed, we may also acquire certain information from relevant authorities or public registers. 

During a recruitment process we may, with your consent, contact a reference you have provided us with, such as your former employer. In this case we may get some information about you from such reference. 
                           
5. THE PURPOSE AND LEGITIMATE GROUNDS OF PROCESSING 

Employee data is processed to meet our legal obligations as an employer, such as the arrangement of occupational health care, as well as to fulfil our contractual obligations based on your employment contract, such as salary payment. 

Applicant data is processed on the basis of a pre-contractual relationship at your request and for our legitimate interests in order for us to assess the potential grounds for entering into an employment contract with you. 
                                                 
We also store both applicant and employee data for a certain period based on our legitimate interests in case of litigation, claims or regulatory investigations. 
                                                                             
6. STORAGE PERIOD 
                   
We store the data concerning employees for as long as it is necessary to meet the employer’s legal obligations or for other legitimate reasons, such as litigation or regulatory investigations. For example, we are required to provide you with a certificate of employment on request during 10 years of termination of the employment relationship. 
                   
Job applicant data is stored for recruiting purposes for the duration of the recruitment process, and after that for as long as required for legitimate reasons, such as regulatory investigation and litigation purposes. With your consent we may also store your information for future recruitment purposes. 
                   
7. INTERNATIONAL DATA TRANSFERS 
                   
Employee and job applicant data is primarily stored within the European Economic Area. 
                   
However, in certain cases we may transfer or access personal data outside the European Economic Area. In such cases we provide adequate protection for the transfers of personal data to countries outside of the European Economic Area through a series of agreements with our service providers based on the Standard Contractual Clauses or through other appropriate safeguards, such as the Privacy Shield Framework. 
                   
8. THE RECIPIENTS OF PERSONAL DATA 

We do not share personal data with third parties outside of our group companies unless one of the following circumstances apply: 
                   
For legal reasons 
                   
We may share personal data with third parties outside our organization if access to the personal data is reasonably necessary to: (i) meet taxation, any applicable law, regulation, and/or court order (ii) detect, prevent or otherwise address crime and/or security issues. 
                   
To authorized service providers 
                   
We may share personal data to authorized service providers who perform services for us. Such service providers are for example our accounting and payroll service providers and data storage service providers. Our agreements with our service providers include commitments that the service providers agree to limit their use of personal data and to comply with privacy and security standards at least as stringent as the terms of this Privacy Policy. 
                   
For other legitimate reasons 
                   
If Rentle is involved in a merger or acquisition, we may transfer your personal data to the third party involved. However, we will continue to ensure the confidentiality of all personal data. We will give notice to all those concerned when the personal data are transferred or become subject to a different privacy policy as soon as reasonably possible. 
                   
With your explicit consent 
                   
We may share personal data with third parties outside of our organization for other reasons than the ones mentioned before, when we have your explicit consent to do so. You have a right to withdraw such consent at any time. 
                   
9. YOUR RIGHTS 
                   
Right to access 
                   
You have the right to access your personal data processed by us and to request a copy of your personal data undergoing processing. 
                   
Right to withdraw consent 
                   
In case the processing is based on a consent granted by you, you may withdraw the consent at any time. The withdrawal of consent does not affect the lawfulness of processing based on consent before its withdrawal. 
                   
Right to correct 
                   
You have the right to have incorrect or incomplete personal data we have stored about you corrected or completed. 
                   
Right to deletion 
                   
You may also ask us to delete your personal data from our systems. We will comply with such request unless we have a legitimate ground to not delete the data. Please note that during the term of employment personal data is processed primarily due to legal obligations and therefore we may not be able to delete it. 
                   
Right to restriction of processing 
                   
You may request us to restrict processing of personal data for example when your data erasure, rectification or objection requests are pending and/or when we do not have legitimate grounds to process your data. 
                   
Right to object 
                   
You may object to the processing of personal data on grounds relating to your particular situation if such data are processed for our legitimate interest. In case we do not have compelling legitimate grounds to continue processing such personal data, we shall no longer process the personal data after your objection.  
                                                       
Right to data portability 
                                                                             
You have the right to receive some of the personal data you have provided us with in a structured and commonly used format. 

How to use your rights 
                   
If you want to use your rights, please contact your supervisor (if you are an employee) or send us a letter or secure e-mail (if you are an applicant). 
                   
We may reject requests that are unreasonably repetitive, excessive or manifestly unfounded. 
                   
10. INFORMATION SECURITY 
                   
We use administrative, organizational, technical, and physical safeguards to protect the personal data we collect and process. Our security controls are designed to maintain an appropriate level of data confidentiality and integrity. 
                   
The personal data stored under this Privacy Policy shall only be processed on a need-to-know basis. The use of personal data is protected by appropriate user rights and passwords. 

11. LODGING A COMPLAINT
 
In case you consider our processing of personal data to be inconsistent with the applicable data protection laws, you have a right lodge a complaint with the local supervisory authority for data protection. 

In Finland the competent authority is the Data Protection Ombudsman (www.tietosuoja.fi ).

This Privacy Policy was updated on 25.5.2022

Processing of (personal) data by the operator of the recruitment website

General information

This recruitment website is operated by Personio SE & Co. KG, which offers a human resource and candidate management software solution (https://www.personio.com/legal-notice/). Data transmitted as part of your application will be transferred using TLS encryption and stored in a database. The sole controller of this data within the meaning of article 24 of the GDPR is the enterprise carrying out this online application process. Personio’s role is limited to operating the software and this recruitment website and, in this context, being a processor under article 28 of the GDPR. In this case, the processing by Personio is based on an agreement for the processing of orders between the controller and Personio. In addition, Personio SE & Co. KG processes further data, some of which may be personal data, to provide its services, in particular for operating this recruitment website. We will refer to this in more detail below.

The controller

The controller under data protection law is:
Personio SE & Co. KG
Seidlstraße 3
80335 München
Tel.: +49 (89) 1250 1004
Entry in the commercial register
Commercial register entry number: HRA 115934
Registration Court: Amtsgericht München
Data Protection Officer contact: privacy@personio.com

Access logs (“server logs”)

Each access to this recruitment website automatically causes general protocol data, so-called server logs, to be collected. As a rule, this data is a pseudonym and thus does not allow for inferences about the identity of an individual. Without this data, it would, in some cases, be technically impossible to deliver or display the contents of the software. In addition, processing this data is absolutely necessary under security aspects, in particular for access, input, transfer, and storage control. Furthermore, this anonymous information can be used for statistical purposes and for optimizing services and technology. In addition, the log files can be checked and analyzed retrospectively when unlawful use of the software is suspected. The legal basis for this is §25 subsection 2 Sentence 2 TDDDG. Generally, data such as the domain name of the website, the web browser and web-browser version, the operating system, the IP address, as well as the timestamp of the access to the software is collected. The scope of this log process does not exceed the common log scope of any other site on the web. These access logs are stored for a period of up to 7 days. There is no right to object to this.

Error logs

So-called error logs are generated for the purpose of identifying and fixing bugs. This is absolutely necessary to ensure we can react as quickly as possible to possible problems with displaying and implementing content (legitimate interest). As a rule, this data is a pseudonym and thus does not allow for inferences about the identity of an individual. The legal basis for this is §25 subsection 2 Sentence 2 TDDDG. When an error message occurs, general data such as the domain name of the website, the web browser and web-browser version, the operating system, the IP address, as well as the timestamp upon occurrence of the respective error message and/or specification is collected. These error logs are stored for a period of up to 7 days. There is no right to object to this.

Use of cookies

So-called cookies are used on parts of this recruitment website. They are small text files which are stored on the device with which you access this recruitment website. As a general rule, cookies serve the purpose of ensuring secure access to a website (“absolutely necessary”), implementing certain functionalities such as standard-language settings (“functional”), improving the user experience or the performance of the website (“performance”), or placing targeted advertisements (“marketing”). On this recruitment website, we generally use only cookies that are absolutely necessary, functional or performance-related, in particular for implementing certain default settings such as language, for identifying the job advertising channel, or for analyzing the performance of a job advert via which a user accessed this recruitment website. The use of cookies is absolutely necessary for providing our services and thus for the performance of the contract (article 6 (1) b) of the GDPR). Period of storage: up to 1 month or until the end of the browser session Right to object: You can determine via your browser settings whether you allow or object to the use of cookies. Please note that deactivating cookies may result in limited or completely blocked functionalities of this recruitment website.

Rights of data subjects

If Personio SE & Co. KG as the controller processes personal data, you as the data subject have certain rights under Chapter III of the EU General Data Protection Regulation (GDPR), depending on the legal basis and the purpose of the processing, in particular the right of access (article 15 of the GDPR) and the rights to rectification (article 16 of the GDPR), erasure (article 17 of the GDPR), restriction of processing (article 18 of the GDPR), and data portability (article 20 of the GDPR), as well as the right to object (article 21 of the GDPR). If the personal data is processed with your consent, you have the right to withdraw this consent under article 7 III of the GDPR. To assert your rights as a data subject in relation to the data processed for the purpose of operating this recruitment website, please refer to Personio SE & Co. KG’s Data Protection Officer (see item B).

Concluding provisions

Personio reserves the right to adjust this data privacy statement at any point in time to ensure that it is in line with the current legal requirements at all times, or in order to accommodate changes in the services offered, for example when new services are introduced. In this case, the new data privacy statement applies to any later visit of this recruitment website or any later job application.