Privacy policies of the recruitment process

Mimovrste d.o.o., ID No.: 1589121000, a company with registered office at Cesta Ljubljanske brigade 21, 1000 Ljubljana, (hereinafter referred to as „we„) considers the protection of personal data to be an integral part of its obligations towards job applicants. 

In this document (further also as ‘Information Memorandum’) you will find information on what personal data we process as part of the recruitment process. You will find information on whether we process personal data on the basis of your consent or on the basis of another legal ground, the purposes for which we process the data, whether we transfer it to anyone and what rights you have in relation to the processing of your personal data. 

• What personal data do we process?

We process the following personal data:

1. identification data, which means, in particular, name, surname, title, date of birth, gender, or photograph;
2. contact data, which means personal data that enables us to contact you, in particular your contact address, telephone number and e-mail address;
3. job-related information, including information about your education, training, previous experience and references;
4. your suitability assessment data, which means the data we use to assess whether you are a suitable candidate for a particular role, in particular our assessment of your performance at interview or test results. 

• Why do we process personal data and what entitles us to do so?

As part of the recruitment process, we process personal data for different purposes and to different extents. In doing so, we process personal data for the preparation of the contract and, where applicable, on the basis of your consent. 

B.1 Processing without your consent – for the preparation of a contract

For the preparation of an employment contract, a work performance agreement or a work activity agreement, we process your identification, contact, work-related and suitability assessment data for the purpose of carrying out the selection procedure, including the screening of candidates. This is specifically so that we can invite you for interviews and communicate with you and so that we can assess your suitability for the vacancy and check your references from the documents provided. 

We keep personal data processed for the preparation of a contract or agreement for the duration of the recruitment process, unless you give us your consent to further storage in the applicant database.

B.2 Processing on the basis of your consent for the purposes of maintaining the applicant database

On the basis of your consent, we process your identification, contact and job-related data in order to include you in our database of candidates and to be able to contact you with other relevant job offers. We may also use the data from the applicant database for evaluation and analysis purposes to determine who is interested in working for us, what their qualifications are, etc. If you do not give us your consent, we will only process this data until the end of the recruitment process; if you give us your consent, we will only process this data for a maximum of 2 years after the end of the recruitment process. 

You may withdraw your consent at any time by following the procedure for exercising your rights described below in section „F. How can I exercise individual rights? „. Withdrawal of consent does not affect the lawfulness of processing prior to such withdrawal.

B.3 Processing on the basis of your consent for the purposes of intra-group transfers

On the basis of your consent, we transfer your identification, contact and job-related data to other companies of the Allegro Group for the purpose of maintaining the database of candidates and conducting the selection process, including the screening of candidates. For a more detailed definition of to whom we transfer data, please refer to section „C. Who processes your personal data and to whom do we transfer it? „. These companies may subsequently contact you with a relevant job offer for a period of 2 years if they assess you as a suitable candidate based on the data provided. The data transmitted from the database of candidates may also be used by these companies to evaluate and analyse who is interested in working for Allegro Group, what their qualifications are, etc. To Allegro Group belong the following entities: Allegro.eu SA., Allegro Sp. z o.o., Ceneo.pl Sp. z o.o., eBilet Polska Sp. z o.o., Allegro Finance Sp. z o.o., Allegro Pay Sp. z o.o., OpenNet.pl Sp. z o.o., Mall Group a.s., Allegro Retail a.s., Internet Mall Slovakia s.r.o., Internet Mall Hungary Kft., m-HU Internet Kft., MIMOVRSTE, spletna trgovina, d.o.o., Internet Mall d.o.o., WE|DO SK s.r.o., “SkyNet Custom Brokers” Sp. z o.o.

You may withdraw your consent at any time with respect to any individual company. You can withdraw your consent from us by following the procedure for exercising your rights described below in section „F. How can I exercise individual rights? „. Withdrawal of consent does not affect the lawfulness of processing prior to such withdrawal.

• Who processes your personal data and to whom do we transfer it? 

All of the above-mentioned personal data are processed by us as the controller. This means that we determine the above defined purposes for which we collect your personal data, determine the means of processing and are responsible for its proper execution.

As already mentioned, with your consent, we transfer your contact and identification data and data related to the performance of work for the recruitment process to Allegro Group so the entities within it may contact you with a relevant job offer.  

For the processing of personal data, we also use the services of other processors who process personal data on our instructions. Such processors include IT solution providers, advertising portals that collect CVs for us, such as LMC s.r.o. , ID No.: 264 41 381, and consultancy companies that help us assess whether you are a suitable candidate for us (e.g. assessment centers).

Furthermore, we are obliged to transfer the processed personal data to state administration authorities, courts, law enforcement authorities and supervisory authorities if they ask us to do so. 

Please be aware that the entities from Allegro Group use each other’s services and act on each other’s instructions as far as the consultation and support relating to the recruitment process are concerned.

• From what sources do we obtain personal data?

Most personal data is collected directly from you by providing it to us as part of the recruitment process, whether in an oral interview, CV or other documentation. 

In addition, to a limited extent, we collect and further process personal data obtained from the persons listed as contacts in your references and from professional social networks such as LinkedIn. 

• What rights do you have when processing personal data?

Just as we have rights and obligations when processing your personal data, you also have certain rights when processing your personal data. These rights include:

• Right of access

Simply put, you have a right to know:

• what data we process about you,
• for what purpose, 
• for how long, 
• where we obtain your personal data, 
• to whom we pass them on, 
• who processes them outside of us and 
• what other rights you have in relation to the processing of your personal data. 

You have learned all this in this Information Memorandum. However, if you are unsure which personal data we process about you, you can ask us to confirm whether or not personal data relating to you is processed by us and, if so, you have the right to access that personal data. As part of your right of access, you may ask us for a copy of the personal data we are processing, and we will provide you with the first copy free of charge and subsequent copies on payment of a fee. 

• Right to rectification

To err is human. If you discover that the personal data we process about you is inaccurate or incomplete, you have the right to have it corrected or completed without undue delay. 

• Right to erasure

In some cases, you have the right to have us delete your personal data. We will delete your personal data without undue delay if one of the following reasons is met: 

• we no longer need your personal data for the purposes for which we processed it, 
• you withdraw your consent to the processing of your personal data, where the data is data for which your consent is necessary and we have no other reason why we need to continue to process it (for example, to defend our legal interests),
• you exercise your right to object to processing (see section E.6 Right to object to processing below) in respect of personal data that we process on the basis of our legitimate interests and we find that we no longer have such legitimate interests to justify such processing; or 
• you believe that the processing of personal data by us has ceased to comply with generally binding regulations.

But please bear in mind that even if it is one of these reasons, it does not mean that this right is unlimited. It does not apply if the processing of your personal data is still necessary for:

• to fulfill our legal obligation, 
• for archival, scientific or historical research or statistical purposes, or
• establish, exercise or defend our legal rights.

• Right to restriction of processing

In some cases, in addition to the right to erasure, you can exercise the right to limited processing of personal data. This right allows you in certain cases to request that your personal data be marked and not subject to any further processing operations, but not forever (as in the case of the right to erasure), but for a limited period of time. These cases where we have to restrict the processing of your personal data are situations where:

• you dispute the accuracy of the personal data before we agree what data is correct,
• we process your personal data without a sufficient legal basis (e.g. beyond what we need to process), but you would prefer only to restrict such data before deleting it (e.g. if you expect to provide us with such data in the future anyway), 
• we no longer need your personal data for the above processing purposes but you require it for the establishment, exercise or defence of legal claims, or 
• object to the processing. The right to object is described in more detail below in section E.6 Right to object to processing). We are obliged to restrict the processing of your personal data during the period of time that we are investigating whether your objection is justified.

• Right to portability

You have the right to obtain from us all your personal data that you yourself have provided to us and that we process on the basis of your consent (see section „B.3 Processing on the basis of your consent“ above) and on the basis of the performance or conclusion of a contract. We will provide you with your personal data in a structured, commonly used and machine-readable format. In order to be able to easily transfer the data upon your request, it may only be data that we process automatically in our electronic databases. Therefore, we cannot always and under all circumstances transfer to you in this form all the data that you have filled in our forms (for example, your handwritten signature).  

• Right to object to processing

You have the right to object to the processing of your personal data based on our legitimate interest. In such a case, we will not process your personal data further for that purpose unless we have compelling legitimate grounds for continuing such processing. 

• Right to lodge a complaint

Exercising your rights in the above manner is without prejudice to your further right to lodge a complaint with the Office for Personal Data Protection. You can exercise this right if you believe that we are processing your personal data unlawfully or in violation of generally binding legal regulations. You can file a complaint against our processing of personal data with the Information Commissioner of the Republic of Slovenia (Informacijski pooblaščenec), which is located at Dunajska cesta 22, SI-1000 Ljubljana.

• How can I exercise individual rights?

In all matters related to the processing of your personal data, whether it is a question of exercising a right, filing a complaint or anything else, you can contact us via the company’s data box, in paper form to the address of the company’s registered office or at the e-mail address dpo@mallgroup.com. We will process your request without undue delay, but within one month at most. In exceptional cases, in particular due to the complexity of your request, we are entitled to extend this period by a further two months. We will, of course, inform you of any such extension and the reasons for it. 

• Data Protection Officer 

Our Data Protection Officer is at your disposal in all matters relating to the processing of your personal data. You can contact our Data Protection Officer by email at dpo@mallgroup.com.