Updated 25 / 06 / 2023 (25th June 2023)

PRIVACY NOTICE / GDPR POLICY

  • DevologyX OÜ Limited is a Staffing & Recruiting Agency registered in Estonia (Company Code: 16335139).
  • Our Business and our Privacy Notice reflects our responsibilities when providing our services. Your privacy is important to us and we are committed to collecting, processing, storing and destroying all information in accordance with the General Data Protection Regulation (GDPR), UK data protection laws and specific data protection codes of conduct.

INTRODUCTION

  • This Privacy Notice / GDPR Policy explains what DevologyX OÜ do with your personal data, whether we are in the process of helping you find an opportunity, continuing our relationship with you once we have found you an opportunity, providing you with a service, receiving a service from you, using your data to ask for your assistance in relation to an opportunity we have or you are visiting our website.
  • It describes how DevologyX OÜ collect, uses and processes your personal data, and how, in doing so, we comply with our legal obligations to you.
  • This Privacy Notice applies to the personal data of our Website Users, Candidates, Clients, Suppliers, and other people whom we may contact in order to find out more about our Candidates or whom they indicate is an emergency contact, referral or reference.
  • Website Users: Any individual who accesses the DevologyX OÜ website. Our website contains links to other sites. Please be aware that DevologyX OÜ is not responsible for the privacy practices of such other sites.  We encourage our users to be aware when they leave our site and to read the privacy statements of each and every website that collects personally identifiable information.
  • Candidates: Includes applicants for all roles advertised or promoted by DevologyX OÜ, including permanent and freelance/contract roles with DevologyX OÜs’ Clients; as well as people who have supplied a speculative CV to DevologyX OÜ not in relation to a specific opportunity. This also includes any individual who is contacted through a third party supplier such as a Job Board Company.
  • Clients: This category covers our customers, clients, and others to whom DevologyX OÜ provides services in the course of its business.
  • Suppliers: Refers to partnerships and companies such as independent contractors and freelance workers who provide services to DevologyX OÜ.
  • Other people whom DevologyX OÜ may contact – these may include Candidates’ emergency contacts and referees. We will only contact them in appropriate circumstances.
  • Please be aware this Privacy Notice / GDPR Policy can be adjusted at any time without notification, in this context the date at the top of the page will indicate the date of adjustments/amendments.
  • If you are dissatisfied with any aspect of our Privacy Notice, please contact DevologyX OÜ – [email protected]).

WHAT KIND OF PERSONAL DATA DO WE COLLECT?

CANDIDATE DATA: 

  • In order to provide the best possible opportunities that are tailored to you, we need to process certain information about you. DevologyX OÜ only ask for details that will genuinely help us to help you, such as:
    • Name
    • Contact details including telephone numbers, email address and postal address
    • CV 
    • Work preferences including role, geographical area, salary / day rate / hourly rate expectations
    • Publicly available information or information provided by you, in relation to professional history, educational background, employment history, skills and experience, educational and professional qualifications
    • Emergency contacts and of course you may choose to share other relevant information with us.

WHERE APPROPRIATE AND IN ACCORDANCE WITH LOCAL LAWS/REQUIREMENTS, DevologyX OÜ MAY ALSO COLLECT INFORMATION INCLUDING:

  • Identification (Passport, Driving License and in some cases Work Permits/Visas)
  • Date of Birth
  • NI (National Insurance) Number
  • Outcome of criminal record checks and security clearance (Where applicable)
  • Medical information (Where applicable)
  • References
  • Financial information (including but not limited to payroll details and terms, HMRC data, pension scheme details, court orders and statutory payments)
  • Diversity Information
  • A log of our communications with you by email and telephone
  • IP address

CLIENT DATA: 

  • If you are a DevologyX OÜ customer, we need to collect and use information about you, or individuals at your organization, in the course of providing you services such as: (i) finding Candidates who are the right fit for you / your organisation.

SUPPLIER DATA: 

  • We need a small amount of information from our Suppliers to ensure smooth collaboration. We need contact details of relevant individuals at your organization so that we can communicate with you. 

DATA WE RECEIVE FROM CANDIDATES AND STAFF, SUCH AS REFEREES, REFΕRRALS OR EMERGENCY CONTACTS: 

  • In order to provide Candidates with suitable opportunities DevologyX OÜ needs some basic information. We only ask for very basic contact details, so that we can get in touch with you.

WEBSITE USERS: 

  • DevologyX OÜ collects a small amount of data from our Website Users. This includes information such as how you use our website, the frequency with which you access our website, otherwise known as cookies.
  • A number of elements of the personal data DevologyX OÜ collect from you are required to enable us to fulfill our contractual duties to you or to others. Where appropriate, some are required by statute or other laws. Other items may simply be needed to ensure that our collaboration is in good standing.
  • Depending on the type of personal data in question and the grounds on which DevologyX OÜ may be processing it, should you decline to provide us with such data, we may not be able to fulfill our contractual requirements to candidates/clients.

THE LEGAL BASES WE RELY UPON TO OFFER OUR SERVICES TO YOU ARE:

  • Consent
  • Legitimate interest
  • Legal obligation
  • Contractual obligation

HOW DO WE COLLECT YOUR PERSONAL DATA?

CANDIDATE DATA: 

  • There are two ways in which DevologyX OÜ collect your personal data:
  • Directly from you
  • From third parties such as other Candidates (networking / referrals) or a Job Board Company

CLIENT DATA: 

  • There are two ways in which DevologyX OÜ collect your data:
  • Directly from you
  • From third parties such as our Candidates and other publicly available sources

SUPPLIER DATA: 

  • DevologyX OÜ collects your personal data during the course of our collaboration to aid our deliverables. 

DATA RECEIVED FROM CANDIDATES SUCH AS REFEREES, REFFERALS OR EMERGENCY CONTACTS: 

  • DevologyX OÜ collects your contact details only where a candidate puts you down as their emergency contact or where a Candidate gives them to us in order for you to serve as a referee. Likewise, this is the same procedure for a referral; where a candidate recommends you for a position that we are recruiting for. 

WEBSITE USERS: 

  • We collect your data automatically via cookies when you visit our website, in line with cookie settings in your browser.

HOW DO WE USE YOUR PERSONAL DATA?

CANDIDATE DATA: 

  • DevologyX OÜ uses your personal details too help you find work opportunities that might be suitable for you. 
  • The more information we have about you, your skillset and your ambitions, the more bespoke we can make our service.

CLIENT DATA: 

  • DevologyX OÜ uses information about clients is to ensure that the contractual arrangements between us can properly be implemented to ensure a smooth collaboration. 
  • This may involve identifying candidates who we think will be the right fit for you or your organization. The more information we have, the more tailor-made we can make our service to you.

SUPPLIER DATA: 

  • The main reasons for using your personal data are to ensure that the contractual arrangements between us can properly be implemented to ensure a smooth collaboration and to comply with legal requirements.

PEOPLE WHOSE DATA WE RECEIVE FROM CANDIDATES AND STAFF, SUCH AS REFEREES, REFFERALS OR EMERGENCY CONTACTS: 

  • DevologyX OÜ use referees’ personal data to help our candidates to find employment which is suited to them. If we are able to verify their details and qualifications, we can make sure that they are well matched with prospective clients. 
  • We may also use referees’ or referrals’ personal data to contact them in relation to opportunities that may be of interest to them. 
  • We use the personal details of a candidates’ emergency contact in the case of an accident or emergency affecting that candidate.

WEBSITE USERS: 

  • DevologyX OÜ use your data to help us to improve your experience of using our website, for example by analyzing your recent search criteria to help us to present opportunities to you that we think you’ll be interested in. 
  • If you are also a Candidate or Client of DevologyX OÜ, we may use data from your use of our website to enhance other aspects of our collaboration/service to you.

WHO DO WE SHARE YOUR PERSONAL DATA WITH?

CANDIDATE DATA: 

  • Primarily we will share your information with prospective Clients to increase your chances of securing the opportunity you want. 
  • We may also share your information with associated third parties such as our service providers where we feel this will help us to provide you with the best possible service.

CLIENT DATA: 

  • We will share your data primarily to ensure that we provide you with a suitable pool of Candidates.

SUPPLIER DATA: 

  • Unless you specify otherwise, DevologyX OÜ may share your information with any of our associated third parties such as our service providers and organizations to whom we provide services.

WEBSITE USERS: 

  • Unless you specify otherwise, DevologyX OÜ may share your information with providers of web analytics services, marketing automation platforms and social media services to make sure any advertising you receive is targeted especially to you to enhance your online experience.

HOW DO WE SAFEGUARD YOUR PERSONAL DATA?

  • DevologyX OÜ is committed to ensuring that your information is secure.  In order to prevent unauthorized access or disclosure, we have put in place suitable physical, electronic and managerial procedures to safeguard and secure the information we collect. 
  • Our service is hosted from a Data-Centre within the European Union which is ISO27001 certified. 
  • We undertake regular vulnerability scans of our website and services to ensure your data is safe.

HOW LONG DO WE KEEP YOUR PERSONAL DATA FOR?

  • Your data will be held for as long as DevologyX OÜ are providing a service to you. 
  • You have control over your option to delete your database record. 
  • When requested, DevologyX OÜ will remove your details from their database (all personally identifiable information will be completely removed from our systems) within 30 days (unless we believe that the law or other regulation requires us to preserve it).

HOW CAN YOU ACCESS, AMEND OR TAKE BACK THE PERSONAL DATA THAT YOU HAVE GIVEN TO US?

  • Even if DevologyX OÜ already holds your personal data, you still have various rights in relation to it. 
  • To get in touch about these, please contact (DevologyX OÜ – [email protected]
  • We will seek to deal with your request ASAP in accordance with the requirements of any applicable laws. Please note that we may keep a record of your communications to help us resolve any issues raised in this process.

RIGHT TO OBJECT: 

  • If DevologyX OÜ are using your data because we deem it necessary for our legitimate interests to do so, and you do not agree, you have the right to object. We will respond to your request within 30 days (although we may be allowed to extend this period in certain cases). Typically, we will only disagree with you if certain limited conditions apply.

RIGHT TO WITHDRAW CONSENT: 

  • Where DevologyX OÜ have obtained your consent to process your personal data for certain activities (for example, for profiling your suitability for certain roles), you may withdraw your consent at any time.

DATA SUBJECT ACCESS REQUESTS (DSAR): 

  • You have the right to ask us to confirm what information DevologyX OÜ hold about you at any time and you may ask us to modify, update or delete such information. 
  • At this point we may comply with your request or additionally do one of the following:
  • We may ask you to verify your identity, or ask for more information about your request; 
  • Where we are legally permitted to do so, we may decline your request, but we will explain why if we do so.

RIGHT TO ERASE YOUR DATA:

  • In certain situations (for example, where DevologyX OÜ have processed your data unlawfully), you have the right to request us to “erase” your personal data. 
  • DevologyX OÜ endeavor to respond to your request within 30 days and will only disagree with you if certain limited conditions apply. 
  • If we do agree to your request, we will delete your data but will generally assume that you would prefer us to keep a note of your name on our register of individuals who would prefer not to be contacted. 
  • DevologyX OÜ, in this case minimize the chances of you being contacted in the future where your data are collected in unconnected circumstances. If you would prefer us not to do this, you are free to say so.

RIGHT OF DATA PORTABILITY: 

  • If you wish, you have the right to transfer your data from us to another data controller.
  • DevologyX OÜ will help with this – either by directly transferring your data for you, or by providing you with a copy in a commonly used readable format (.doc/.docx/PDF).

RIGHT TO LODGE A COMPLAINT WITH A SUPERVISORY AUTHORITY: 

  • You also have the right to lodge a complaint with your local supervisory authority, details of which can be found here.
Privacy Information to be given to the individual:Where the Company collects data from the individual:Where personal data has not been obtained from the individual
The identity and contact details of the Company and where applicable the controller’s representatives and/or data champion.Yes Yes
The purposes of processing and the legal basis for the processing.YesYes
The legitimate interest of the data controlleror third party, where applicable.YesYes
The categories of personal data.No Yes
Recipients or categories of recipients of personal data.YesYes
Details of transfers to third countries and the safeguards in place.YesYes
The retention period of the data or the criteria used to determine the retention period.YesYes
The existence of individual’s rights including the right of access, rectification, erasure, restriction of processing, objection to processing and the right to data portability.YesYes
The existence of the right to withdraw consent where it has been given and relied upon.YesYes
The right to lodge a complaint with the Information Commissioner’s Office or any other relevant supervisory authority.YesYes
The source the personal data originates from and whether it came from publicly accessible sources.NoYes
Whether the provision of personal data form part of a statutory or contractual requirement or obligation and possible consequences of failing to provide the personal data.YesNo
The existence of automated decision-making, including profiling and information about how decisions are made, the significance and the consequences.YesYes

HOW DO WE STORE AND TRANSFER YOUR DATA INTERNATIONALLY?

  • DevologyX OÜ is a global organization and in order for us to continue operating in this way, we may have to transfer your data internationally. In order to provide you with the best service and to carry out the purposes described in this Privacy Notice/GDPR Policy, your data may be transferred:
    • To a DevologyX OÜ client which is located overseas.
    • To clients who may, in turn, transfer your data internationally;
    • To a cloud-based storage provider regarding our recruitment database / server.
  • DevologyX OÜ ensures that your data are stored and transferred in a way which is secure. 
  • DevologyX OÜ will therefore only transfer data outside of the European Economic Area or EEA (to be clear, the Member States of the European Union combined with Norway, Iceland and Liechtenstein) where it is compliant with data protection legislation and the means of transfer provides adequate safeguards in relation to your data, for example:
  • By way of data transfer agreement, incorporating the current standard contractual clauses adopted by the European Commission for the transfer of personal data by data controllers in the EEA to data controllers and processors in jurisdictions without adequate data protection laws; or
  • By signing up to the EU-U.S. Privacy Shield Framework for the transfer of personal data from entities in the EU to entities in the United States of America or any equivalent agreement in respect of other jurisdictions;
  • Transferring your data to a country where there has been a finding of adequacy by the European Commission in respect of that country’s levels of data protection via its legislation.
  • Where it is necessary for the conclusion or performance of a contract between ourselves and a third party and the transfer is in your interests for the purposes of that contract (for example, if we need to transfer data outside the EEA in order to meet our obligations under that contract if you are a Client of ours);
  • Where you have consented to the data transfer.
  • To ensure that your personal information receives an adequate level of protection, DevologyX OÜ have put in place appropriate procedures with the third parties we share your personal data with to ensure that your personal information is treated by those third parties in a way that is consistent with and which respects the GDPR regulations.

WHAT ARE COOKIES AND HOW DO WE USE THEM?

  • A ‘cookie’ is a bite-sized piece of data that is stored on your computer’s hard drive. They are used by nearly all websites and do not harm your system. 
  • We use them to track your activity to help ensure you get the smoothest possible experience when visiting our website. 
  • We can use the information from cookies to ensure we present you with options tailored to your preferences on your next visit. 
  • We can also use cookies to analyze traffic and for advertising purposes.
  • If you want to check or change what types of cookies you accept, this can usually be altered within your browser settings.

CONTACT:

  • If you wish to contact us about this privacy notice / GDPR policy or any of the procedures, please contact DevologyX – [email protected] 

Please note: You also have the right to raise concerns with Information Commissioners Office if you believe that your data protection rights have not been adhered too. 

DevologyX OÜ
Harju maakond, Tallinn, Lasnamäe
linnaosa,
Vaike-Paala tn 1, 11415

+372 6359999
[email protected]
DevologyX Limited
Nakawa Business Park
Kampala
Uganda

+256206300922
[email protected]

DevologyX Pty Ltd
Tijger Park 3
Willie van Schoor Drive
Belville
Cape Town
7530

[email protected]