Account Holder Privacy Notice
I. Protecting Your Privacy
We, the team at Talentbase, strongly value our own privacy – and therefore are committed to protect your personal data (i.e. information that identifies you) as though it is our own.
If you have any questions about how we protect your privacy, get in touch here: firstname.lastname@example.org
One of your rights under applicable law, particularly Regulation [EU] 2016/679, or as it is otherwise known, the GDPR – is that you must be informed when your personal data – also known as personal information – is processed (collected, used, stored) by any organisation. You also have the right to know the details and purpose of that processing.
This Privacy Notice describes our practices relating to the personal data of individuals who create an account on the Talentbase Recruitment Portal (the ‘Portal’). For any processing of personal data undertaken through the Portal and in the course of the provision of our services, the data controller — the company that’s responsible for your privacy — is Talent Base Limited its address at 85, St John Street, Valletta, VLT 1165, Malta.
We assure you that we will only use and disclose any personal data collected from you in accordance with the manner set out in this policy.
II. Information we collect
Most of the personal information which we may collect about you through this Portal is given to us only if you choose to give it to us.
Such personal information may be requested from you when you fill in a field (e.g. to create an account, sign up for our newsletter or fill in any other form with your questions and comments or any other form or application downloaded through or from our Portal). If you send us emails, then the personal data we process will depend on what you send us in the email.
The information we collect from you normally includes the following:
1. Name + Surname;
2. Contact Details;
a. Email address
b. Telephone Number;
3. Information from accounts you link to us;
4. Information about your device (phone or laptop) with which you used our Portal;
5. If you create an account/profile in order to apply for a vacancy other information will
be requested (see the section on Your Profile below)
Check out the next sections to understand how and why we use this information.
III. How & Why we use your information
We use your information in a number of different ways — what we do with it then depends on the information and the purpose for which we collected.
The tables below set this out in detail, showing what we do, and why we do it.
- Your name and contact details
|How we use your
Name + surname
+ contact details (email address)
|To send you service messages by text or e-mail, such as order updates.
|We’ve got to do this to perform our contract with you (e.g. to confirm payment) if you have a contract with us – or to respond to your queries.|
|To deliver our services to you (if you make an account with us)||We’ve got to do this to reply to your requests for information or to perform our contract with you.|
|To send you information by email, SMS, or post, about our new products and services||To keep you up to date. We only send this with your permission – and you can ask us to stop.|
|Fraud prevention and detection||To prevent and detect fraud against either you or us – unfortunate, but absolutely essential|
|Showing you adverts as your browse the web||So you can see our latest products and deals|
|Knowing what you, and other customers, like||To ensure we are giving you what you want, and to stay ahead of the competition|
2. Your contact history with us
What you’ve said to us — for example, over email or contact forms.
|How we use your contact history||Why?|
|Provide customer service and support||We’ve got to do this to perform our contract with you to your best satisfaction|
|Train our staff||For our team to remain up to scratch so that you get the best possible customer service.|
3. Information about your device (phone or laptop) with which you used our Portal
Information you give us when you browse our site or use our app, including your IP address and device type and, if you choose to share it with us, your location data, as well as how you use our Portal.
|How we use information about your phone or laptop, and how you use our Portal||Why?|
|Improve our Portal and set default options for you (such as language and currency)||To give you the best possible customer experience|
|Protect our Portal||To prevent and detect fraud against either you or us — and to meet our legal obligations about looking after your data|
4. Information from accounts you link to us
What we do if you link your Linkedin account to us
|How we use information from accounts you link to us||Why?|
|To enable you to log into our Portal simply and easily without having to create a specific account||To make it easier for you to use our Portal and purchase our products or services.|
5. Your responses to surveys, competitions and promotions
|How we use your responses to surveys, competitions and promotions||Why?|
|Run the survey, competition or promotion||We’ve got to do this to perform our contract with you once you participate.|
- You don’t have to give us any of this personal information but if you don’t, you may not be able to use our site or all of the services we offer on the site, and you are unlikely to receive an optimal customer experience.
- We also anonymise and aggregate personal information (so that it does not identify you) and use it for purposes including testing our IT systems, research, data analysis, improving our site and app, and developing new products and services. We also share this anonymised information with third parties – but don’t worry, they cannot identify you.
The Legal Basis for Processing
For some of the uses of your personal data (as described above) there is a legal basis under applicable data protection laws for us to use such personal data without having obtained your consent.
This includes, for example, where it is necessary for us to use the information to perform a contract with you or take steps at your request prior to entering into a contract with you, such as to process your order, provide customer-care and support services to you.
It also includes circumstances (such as we have described below) where we have a legitimate interest to use your data, provided that proper care is taken in relation to your rights and interests:
(i) to ensure that you know about any changes to the Portal or the terms of this Privacy Notice.
(ii) to ensure that we organise our databases efficiently and understand how our clients may make purchases;
(iii) to carry out research and analysis of your data (including purchase information) as this helps us understand our clients better, who they are and how they interact with us;
(iv) to improve and ensure the security of the Portal (for example, for statistical, testing and analytical purposes, troubleshooting).
• We will hold on to your information for no longer than is necessary keeping in mind the purpose/s (or compatible purposes) for which we first collected the data.
• We may also keep hold of some of your information if it becomes necessary or required to meet legal or regulatory requirements, resolve disputes, prevent fraud and abuse, or enforce our terms and conditions.
• As a guide:
– we will keep personal data while your account with us is active (if you have an account) or until such time as you ask us to stop communications with you, unless we need to keep the data for longer;
– we may keep certain categories of personal data for longer in order to meet any legal or regulatory requirements, or to resolve a legal dispute;
– and, we may keep different types of personal data for different lengths of time if required by law (for instance, we may need to keep certain personal data relating to purchases for about 10 years in order to comply with tax/VAT reporting requirements);
• You may obtain more information as to the retention periods or the criteria used by us to determine the retention periods by contacting us here email@example.com
IV. Children Under 18
If you are aged 18 or under, please get your parent/guardian’s permission before you provide any personal information to us.
We will need to process personal data relating to parents or guardians in that case – and we may also need to request for verification documentation to ensure that consent is given or authorised by the holder of parental responsibility.
V. Sharing your information
We do not, and will not, sell any of your personal data to any third party – including your name, address, email address or credit card information. It is not our business to do so – and we want to earn your trust and confidence.
• However, we share your data with the following categories of companies as an essential part of being able to provide our services to you, as set out in this statement:
i. Companies that are involved in the process of getting our services from us to you, such as payment service providers, and hosting providers amongst others.
ii. Professional service providers, such as advertising partners and website hosts who service us in turn to operate our business.
iii. Credit reference agencies, law enforcement and fraud prevention agencies, so we can help tackle fraud.
iv. Other companies that you may approve, such as social media sites (if you choose to link your accounts to us) or payment service providers.
• In most circumstances we will not disclose personal data without consent. However there may be occasions where we might have to – e.g. with a court order, to comply with legal requirements and satisfy a legal request, for the proper administration of justice, to protect your vital interests, to fulfil your requests, to safeguard the integrity of the relevant websites operated by us or by such related entities or subsidiaries, or in the event of a corporate sale, merger, reorganisation, dissolution or similar event involving us and/or our subsidiaries and related entities.
• When we do share data, we do so on an understanding with the other entities that the data is to be used only for the purposes for which we originally intended – again, we don’t want you to have any surprises.
• We may also provide third parties with aggregated but anonymised information and analytics about our customers and, before we do so, we will make sure that it does not identify you. Anonymous information means it is anonymous.
• If we ever have to share data with entities that are outside of the EEA, we will be sure to do so in a manner that complies with the requirements established by the GDPR.
VI. Marketing Messages
We would normally communicate to you about products or services in which you have shown interest – we understand that you would be interested in receiving this information as it is of use with the product or service. But rest assured, you can ask us to stop.
Also, if you have said we can (i.e. you gave us your clear confirmation), we will send you marketing messages by email, to keep you aware of what we’re up to and to help you see and find our products.
How to stop marketing messages from us
You can stop receiving marketing messages from us at any time by clicking on the ‘unsubscribe’ link in any email we send you or by changing the settings tied marketing messages and/or newsletters in your Profile.
VII. Seeing our adverts online
We engage in online advertising, also to keep you aware of what we’re up to and to help you see and find our products using targeted ads which may appear when you are on other websites and apps that offer such digital marketing services.
We use a range of advertising technologies like ad tags, cookies, mobile identifiers, and pixels as well as specific services offered by some sites and social networks, such as Facebook’s Custom Audience service.
The banners and ads you see will be based on information we hold about you, or your previous use of our Portal (for example, your search history, and the content you read) or on banners or ads you have previously clicked on.
VIII. Your Profile
You have created an account on the Portal, allowing you to create a curriculum vitae and submit your information for any vacancies we may be posting on the Portal on behalf of our business clients.
We are the data controller for the information you provide during the process unless otherwise stated. If you have any queries about the process or how we handle your information please contact us at firstname.lastname@example.org
• What will we do with the information you provide to us?
All of the information you provide during the process will only be used for the purpose of progressing your application to interested business clients, or to fulfil legal or regulatory requirements if necessary.
We will not share any of the information you provide through your Profile with any third parties for marketing purposes or store any of your information outside of the European Economic Area. The information you provide will be held securely by us and/or our data processors whether the information is in electronic or physical format.
We will use the contact details you provide to us to contact you to progress your application to interested business clients.
We will use the other information you provide to assess your suitability for the role you have applied for.
• What information do we ask for, and why?
We do not collect more information than we need to fulfil our stated purposes and will not retain it for longer than is necessary. The information we ask for is used to assess your suitability for employment.
You don’t have to provide what we ask for but it might affect your application if you don’t.
o Creation of Account
We ask you for your personal details including name, date of birth, email, address, phone number, skills, language, hobbies and contact details. We will also ask you about your previous experience, education, referees and other relevant information for your account and detailed curriculum vitae to be created. Our Talentbase team will have access to all of this information.
Pseudonymised (i.e. personal data is treated in a way which does not allow third parties outside of Talentbase to identify you) information about you will be shared with our business clients. Where our business clients have expressed interest in you, the recruitment specialists in the Talentbase team will shortlist your application for interview.
• Retention Periods
We will continue to retain your personal data in order to continue to provide you access to new recruitment opportunities. In order to ensure that your data is up to date, you will be prompted on a yearly basis to update your profile with any developments and changes which may affect your curriculum vitae. Should you deactivate your account, or if you do not update your profile for an uninterrupted period of five (5) years, your account will be terminated and your personal data will be deleted permanently. If you have any other questions on our practices vis-à-vis the retention of your data, please contact us on email@example.com
IX. Your rights
You enjoy several rights relating to your personal information:
(i) The right to be informed about how your personal information is being used;
(ii) The right to access the personal information we hold about you;
You can access the personal data we hold on you by contacting us firstname.lastname@example.org or +356 2124 1817.
To process your request, we will ask you to send us proof of identity so that we can be sure we are releasing your personal data to the right person.
We will carry out our best efforts to process your request within one month or, if the request is particularly complex, two months. We can provide you with a copy of your personal data in electronic format or hard copy.
If we consider the frequency of your requests as being unreasonable, we may refuse to comply with your request. In those circumstances, if you disagree, you can complain to the data protection authority – in Malta, the Information and Data Protection Commissioner.
(iii) The right to request the correction of inaccurate personal information we hold about you;
We appreciate feedback from you to ensure our records are accurate and up-to-date.
If you think that the information we hold about you is inaccurate or incomplete please ask us to correct it by contacting us here email@example.com
(iv) The right to request that we delete your data, or stop processing it or collecting it;
You can ask us to delete your personal data; however, this is not an absolute right.
In spite of a request for erasure, we may be justified to keep personal data which we need to keep, e.g. (i) to comply with a legal obligation (for instance, we are required by personal data for VAT reporting purposes); and (ii) in relation to the exercise or defence of any legal claims.
When you ask us to delete your personal data, we assume that you do not want to hear from us again. To ensure that we do not send you any special offers in the future (for example, if we purchased your details from a third party list), we will retain just enough of your personal data solely for suppression purposes.
Other than as described above, we will always comply with your request and do so promptly. We would carry out our best efforts to notify any third parties with whom we have shared your personal data about your request so that they could also comply.
(v) The right to stop direct marketing messages;
(vi) The right to object to certain processing based on legitimate interest;
You have a right to object to our use of your personal information including where we use it for our legitimate interests or where we use your personal information to carry out profiling using automated means.
(vii) The right to request human intervention if automated processing without human intervention is used to make decisions having legal or similar effects on you;
(viii) The right to withdraw consent for other consent-based processing at any time;
(ix) The right to request that we transfer or port elements of your data either to you or another service provider;
You have the right to move, copy or transfer your personal data from one organisation to another. If you do wish to transfer your personal data we would be happy to help.
If you ask for a data transfer, we will give you a copy of your personal data in a structured, commonly used and machine-readable form (e.g. a CSV file format). We can provide the personal data to you directly or, if you request, to another organisation.
Please note that we are not required to adopt processing systems that are compatible with another organisation, so it may be that the recipient organisation cannot automatically use the personal data we provide.
When making a transfer request, it would be helpful if you can identify exactly what personal data you wish us to transfer.
(x) The right to complain to your data protection regulator — in Malta – the Information and Data Protection Commissioner (IDPC)
If you want to exercise your rights, have a complaint, or just have questions, please contact us here firstname.lastname@example.org
Please appreciate that the rights must be exercised within some limitation – for example, if you ask us for information we can only give you what relates to you and not what relates to other persons. When we receive requests, we may also request that you identify yourself and provide documentation or information for verification (we would not want to disclose information to the wrong person). Unreasonable requests may be subjected to a reasonable fee or refusal to respond.
X. Security of your Personal Data
Security of your personal data is very important to us.
Where it’s appropriate, our Portal uses HTTPS to help keep information about you secure. However, no data transmission over the internet can be guaranteed to be totally secure.
You have completed a registration process to use the Account part of the Portal. This may include the creation of a username, password and/or other identification information. Any such details should be kept confidential by you and should not be disclosed to or shared with anyone.
Where you do disclose any of these details, you are solely responsible for all activities undertaken where they are used.
Whenever you create a password, then to protect your account you should choose a strong password, meaning it should be lengthy and include a mixture of letters and numbers with mix of CAPS.
We do our best to keep the information you disclose to us secure. However, we can’t guarantee or warrant the security of any information which you send to us.
Security measures which have implemented to secure information transmitted over our Portal or stored on our systems include the following:
1. Use of secure servers;2. Use of firewalls;3. Use of encryption;
4. Physical access controls at data centres;
5. Information access controls;
6. Use of back-up systems;
Please understand, however, that no system is perfect or can guarantee that unauthorised access or theft will not occur.
XI. Changes to how we protect your privacy
XII. Links to Other Websites
This privacy notice does not cover the links within this site linking to other websites which are not controlled by us. We are not responsible for the collection or use of your personal information from these third-party websites.
Therefore, we encourage you to read the privacy statements on the other websites you visit.
XIII. How to contact us
We are always happy to hear from you, whether to make a suggestion but especially if you feel we can do better.
Talent Base ltd
85, St John Street, Valletta VLT 1165, Malta
We have appointed a Data Protection Officer who may be contacted here: email@example.com