SIGNIUM - STEIN & PARTNER Privacy Policy

SIGNIUM – STEIN & PARTNER Privacy Policy

General Matters

Stein & Partner Management Consulting SRL (hereinafter referred to as Signium – Stein & Partner), headquartered in 20 Barbu Delavrancea Street, 011355 Bucharest, aims for a long term partnership with all of its collaborators, both companies in search for the right person for a certain job position and natural person candidates and prospective candidates looking for the most adequate positions (“Targeted individuals”).

For us, your private life, your interests, the confidentiality of the information we receive from you, (such as contact details, the data included in your CV, other details that you willingly provide us with) (“Personal Data”) are of the utmost importance for us and their security stands for values which we never ignore.

We aim at achieving maximum transparency in our business, particularly in the way we process the Targeted Individuals’ Personal Details. Thus, once you’ve decided to send us your personal details, your thoughts and expectations regarding any future position, we’d like you to understand exactly how we are to use such information and how we shall protect it, so that your decision is made on a well-informed basis.

We wish to provide you with the best services, while complying with any and all legal dispositions in the personal data protection field, particularly with the General Data Protection Regulation no. 679/2016 (“GDPR”) and with the principles duly stipulated by the latter, namely: legality, accuracy and transparency; limitation to specific purposes; data minimization; details accuracy; limitation of storage; integrity and confidentiality; responsibility.

Consequently, the present Privacy Policy is aimed at providing you with full information to this end and it shall be mandatory for you to become aware of it before applying for any open position we may have, before sending us your CV and / or prior to stating your express agreement regarding the receipt of information on any labor market news, or on any new positions within Signium – Stein & Partner which might be of interest to you and other such relevant information regarding the recruitment processed, the labor market and the available jobs, as well as any news on Signium – Stein & Partner business.

You have to be aware that your Personal Data, once disclosed to our clients or other third parties, duly involved in the recruitment process, (e.g.: service providers for various personality tests, and not only), in view of going on with the recruitment process at the latter’s level, it shall be processed by the latter, by virtue of their own data protection policies, regarding which Signium – Stein & Partner shall bear no liability whatsoever. We hereby advise you to ask for information from any potential employers or from other third parties that you may get in contact with, related to your Personal Data processing.

Since we take pride in our transparency, to the extent we shall use your public contact details in view of contacting you, as the latter details are displayed on social media networks; upon our first contact we shall inform you on the source of your contact details and we shall never send you any public messages, but private messages only, using the private message technology made available by such networks.

It is also highly relevant in view of protecting your and other people’s legal interests, that the Personal Details you provide us with shall be accurate, up to date and that it belongs to you. Should it not be the case, you should possess the prior agreement of the individuals who these Personal Data belong to, prior to your supplying it to us (e.g.: contact details of any individuals we may contact in order to get references, etc).

The present Privacy Policy, together with the relevant Terms and Conditions, shall hereby fully define and describe our collaboration relation.

Personal Data processed by us

Anytime you may access and wish to go on with your search on our website, while you find yourself at the sections “apply now”, “ send CV” or “subscribe to newsletter”, we shall ask you to supply your Personal Data, following that this data shall be duly processed by Signium – Stein & Partner according to the present Privacy Policy.

Your Personal Data shall also be processed if you contact us by using our email address from the contact page, or any other such email address belonging to Signium – Stein & Partner employees which you may have got from various sources, including in the event you contact us at our head offices mentioned on the said contact page.

“apply now” is the section which shall provide you with information on the job available with Signium – Stein & Partner clients. If you are interested in any one of such available positions, in order to apply for it, we shall ask you for the following Personal Data: name and surname, telephone number, email address, location and country where you live; one of the fields in this particular section enables you to send a personal message to Signium – Stein & Partner which shall accompany your CV. There is another “browse” field which shall enable you to upload your CV into Signium – Stein & Partner database.

Since you’re in total control over the contents of the personal message you are to send, if in such message you may include any information which can be characterized as Personal Data, Signium – Stein & Partner shall also process that information in compliance with the present Privacy policy;

“send CV” is the section you shall use in order to send your CV to Signium – Stein & Partner. Thus, the information you send us shall be uploaded into our database for the purpose of contacting you, in the case there is any position that matches your professional background and which might be of interest to you.

The present section shall enable you to upload your CV, which shall trigger the processing of the Personal Data included in that CV, your name and your email.

Anytime you send us your CV, the latter may include, at your own choice, such Personal Data regarding the following and without limitation to it: full address, age or data of birth, family status, sex, professional background, previous jobs, studies and education, hobbies, preferences. Such information shall also be processed by Signium – Stein & Partner, in compliance with the present Privacy Policy.

“subscribe to newsletter” is the section you may use if you wish to get newsletters / information reports with all the news on the labor market, the jobs available at Signium – Stein & Partner, as well as any other such relevant information on the recruitment process, the labor market and the available job positions, as well as news on our company (“Newsletters”).

The absence of your agreement as to the receipt of such Newsletters shall have no impact whatsoever on the running of the relevant recruitment process that you may have applied for, this being only an option and not an obligation on your part.
If you wish to receive such newsletters, we shall ask for one valid email address, where we could send you such information.

You may unsubscribe at any time whatsoever and thus, you shall no longer receive our information reports, by clicking the “unsubscribe” button from the newsletter you get from us or by sending us an email to office@steinandpartner.com.

You may also state your wish to get such Newsletters by checking the adequate box in the sections “apply now” and “send CV”.

Moreover, upon collecting your Personal Data from our website, we shall also collect and record on our servers that information relating to the IP addresses of the devices you may be using, however any such information shall not be used for any other purpose but for acknowledging the address in case of any future records, or so as to review the Signium – Stein & Partner website performance.

Our contact details may be used both for sending CVs and for the purpose of delivering any other messages to us, in which case the Personal Data you are to forward us may be: name and surname, contact details (email, telephone number, address) or any other such information you may include in the notifications you may send us and which is under your control.

Processing purpose

Given that Signium – Stein & Partner provides professional staff recruitment services for the filling of job positions within our clients’ organizational structures, the relevant Personal Data processing shall be carried out for this particular purpose of running the said recruitment processes and in view of sending Newsletters, if you are to state your agreement to this end.

Also, if you are to contact us by using our contact details, for any other purposes than that of recruitment, we shall process your Personal Data exclusively for the purpose you mention to us (e.g.: only for the purpose of replying to the message we receive from you).

Any such data on you may also be processed on a subsequent basis following the relevant storage period, for statistics purposes, yet at any and all times in such a form that shall not trigger your identification.

Legal grounds for processing

Signium – Stein & Partner wishes to keep close contact with you only if and as long as you wish the same.

As a consequence, the act of processing such Personal Data has its legal grounds in your very own agreement to this end (art. 6 paragraph 1 letter (a) of GDPR), as stated by the decision you have made to send us your Personal Data or as expressed under the form of your express statement of will within the meaning of agreeing to receive Newsletters.

If you are part of a recruitment process, the processing will take place in order to carry out the steps necessary to conclude a contract (art. 6 paragraph 1 letter (b) sentence II of the GDPR).

Should make your CV or your professional expertise public on various recruitment dedicated websites, we shall duly assume you are open to be contacted for a new job and we shall thus justify a legal interest (art. 6 paragraph 1 letter (f) of GDPR) in taking over your data from that website in view of contacting you or present your profile to our clients who might be interested on your professional background.

In case you refused to enter into a recruitment process, we use, as well, our legitimate interest, in keeping some minimum information about you, like, your name, your current company and position, in order to avoid contacting you again for that position or for any further positions (if you specifically asked us to do so) and to inform our client for which you have been contacted, that you refused the position.

Personal Data Addressees

(i) If you have sent us your CV by using “apply now” or “send cv” or even “contact” section, your Personal Data shall be received, by secured means, by us, shall be included in our database and we might disclose them, under confidentiality obligations, to our clients which might be interested of your professional background for the open position with which the client has contractually entrusted us

(ii) If you have applied for a specific position and sent us your personal data in relation to that position, using the section “open positions”, we might disclose your personal data, under confidentiality obligations, to the client for which the recruitment process is conducted in terms of the job position you have applied for. The Personal Data you provide under this section are not to be used by Signium – Stein & Partner in connection with any other positions of the same client or of any other such clients, but to the extent you shall check, at this particular section level, the option “I consent to be included in Signium – Stein & Partner’s active database until I withdraw my consent, and to be contacted by Signium – Stein & Partner for future positions that could be of interest to me.” In such situations, we will be able to contact you for the period of time you are registered in our database, and upon the opening of any position which may be of interest to you and to share your personal data, under confidentiality obligations, with our clients which might be interested of your professional background for open positions at them.

In both the above cases:

-to the extent that you are not interested in entering in a recruitment process for a particular position for which we have contacted you, we may disclose to our clients, based on our legitimate interest in proving that we have contacted you, only your name, the company you are currently employed on and the position you hold, the client undertaking not to use your data in any other way.

-your personal data might be disclosed to the providers of services that are adjacent to the relevant recruitment process (for instance for the purpose of taking any personality tests, if requested by the client in terms of the position regarding which the recruitment process is carried out and that you have applied for).

Should you choose so, we shall also send you newsletters.

Should you send us your CV by email or at our head office address, we kindly ask you to consider the matters stipulated under paragraphs (i) and (ii) above mentioned, lest the sending of information reports for which we ask for your express agreement to this end.
Should you choose so by ticking Newsletter section, we might share your contact details with service providers in the field of automatic messaging.

We hereby add the fact that some of our clients are companies from other EU countries, or even from non – EU states, or they are subsidiaries of any such companies, involved in the recruitment process and to which we shall send your Personal Data for the purpose of running the relevant recruitment process. In the latter case, we shall ensure that prior to sending your Personal Data, one shall have signed the standard contract clauses regarding the securing of such Personal Data. We will will inform you about the client’s state of origin before transmitting your data to him and we will obtain your prior consent in this regard (art. 49 paragraph 1 letter b) of the GDPR).

In all cases, our client with whom we are sharing your personal data shall be held by confidentiality obligations and will not have the right to disclose your personal data to other third parties, but only to use them for internal analysis purposes in relation to a recruitment process.

Personal Data may be incidentally accessed by Signium – Stein & Partner IT service providers (website hosting, information systems maintenance), as well as by other service providers, such as legal advisors (upon the occurrence of any litigations), auditors or other collaborators directly involved in the recruitment projects. However, in any and all events the latter shall have only temporary and / or restricted access to your Personal Data that they may incidentally access and only for that period of time that may be required for the said services to be performed. All of our service providers shall comply with the confidentiality obligations.

We also mention that your personal data could be kept in the databases of our suppliers in the USA with whom our Company has concluded Standard Contractual Clauses, according to those requested by the European Commission, since the USA is a state considered not to confer a level adequate protection of personal data.

Signium – Stein & Partner may also provide such Personal Data to the Supervisory Authority, to any courts of law, in the event of litigations, or to any other government authorities with control tasks, upon the latter’s request, anytime a legal disposition requires the company to make any such disclosure, or for the purpose of defending our company’s legal rights and interests.

Storage length

Personal Data shall only be used until the due completion of the recruitment process, and if you have chosen for their integration into our company database, as per any of the above-described methods, we shall process it until you revoke your consent as to such processing or until you will oppose to the processing.

If such Personal Data are required for any financial – accounting purposes, the same shall be stored to this end for the due period required under the legal dispositions in force (5 years as of the conclusion of the financial year, when the last processing took place).

If such Personal Data are required for the purpose of defending any of our rights before any courts of law, the same shall be duly stored for the period of the prescription term of the right to take action, or during the period of any such litigation running before the relevant courts of law.

Upon the occurrence of any of the previously described events, we shall delete such Personal Data from our database and we will take any and all reasonable measures so as to ask our clients to whom we have disclosed such Personal Data to do the same and erase such Personal Data from their own database.

Your rights in your capacity as Targeted Individuals

Since we process Personal Data that belong to you, in your relation with Signium – Stein & Partner, you benefit from several rights that are conferred to you by virtue of the data protection law. Such rights are as follows:

To ask the company for access to your Personal Data (by virtue of art. 15 of GDPR) which means the right to get a confirmation on the Company’s part, that it processes the Personal Data that belongs to you, as well as due information on the following: the purpose of such processing, the categories of data processed, data addressees, the relevant storage period for such data, the existence of the right to ask us for a due rectification or deletion of such personal data, any restriction on processing or on the right to oppose, the right to file any complaint before the supervisory authority, if there is any automated decisional process, namely if one makes decisions only as a result of an automatic process of personal data, if such data are transferred to third party countries and what securities are duly enforced by our company so as to ensure the transferred data security;
To ask Signium – Stein & Partner representatives to rectify, with no unreasonable delay whatsoever, any such Personal Data that no longer match the current status, by virtue of art. 16 of GDPR; Signium – Stein & Partner shall run periodical database update actions, in which event you may get a series of requests to this end. However, we kindly ask you to immediately contact us if any of your Personal Data that you have supplied have undergone any amendment so that we can carry out all the necessary updates.
To revoke your consent that you have given us in terms of processing your Personal Data, with the due notice that such consent revocation shall have no impact whatsoever on the legal character of the processing activity conducted by virtue of consent, prior to the latter’s revocation or in any other events stipulated under art. 17 of GDPR
To ask for the deletion of your Personal Data;
To ask us to restrict the relevant processing until the due rectification of your Personal Data or, if you may oppose such processing, until the settlement of the relevant request OR in any other events stipulated under art. 18 of GDPR;
To oppose the processing of your Personal Data, by virtue of art. 21 of GDPR;
To file a complaint to any supervisory authority in terms of personal data processing, or before any courts of law;
If and provided that one meets the legal conditions in force, you may also have the right to your data portability.

We hereby add that given the nature of the services we provide, wihin Signium – Stein & Partner, candidates are selected, in the first stage, upon consideration of the professional criteria stipulated by clients in terms of the occupation of the positions available within their companies, versus the professional information supplied by the very relevant candidates. Such selection is never accomplished by any automatic means, but only following one thorough analysis conducted by our recruitment staff, who is professionally trained to this end.

As a consequence, any such automatic decisional processes is ruled out. Any evaluation of your professional background and of the compatibility of your own professional profile with any given position shall be accomplished by our qualified personnel.

Security measures

It is our wish that the information you provide us with to stay with us. Therefore, we shall enforce any and all technical and organizational measures, as required in view of ensuring the latter’s security against any accidental destruction, loss, or any unauthorized disclosure. Our staff is well trained in terms of how they shall deal with any of the information received from you, our clients and providers also undertake the relevant confidentiality obligations, and our information systems are well protected so as to prevent any security incidents, to the extent the technology existing nowadays enables such thing to be achieved.

As related to our website, there are security measures in force for the servers hosting our website, which include the anti-virus, firewall, regular security checkups and security scanning, vulnerability checking and testing, intrusion testing systems.

Where should you address?

For any questions you may have regarding the aforementioned, as well as in view of exercising any of your rights, you may address a written application to our data protection responsible individual, at the following email address office@steinandpartner.com or at our Company’s head office address mentioned at the beginning of the present information note.