Release Date: 13.07.2023
This privacy notice (hereinafter “notice”) explains how Jobbatical OÜ (hereinafter “we” or “us”) processes personal data of employees or future employees of our business clients (hereinafter “talents”) and their family members in relation to our services.
Our services include immigration services (such as registration of employment, assistance on applying the residence permit or visa, applying for personal identification number, registration of a place of residence, registration of tax residency and overview of labour taxes) and settle-in services (such as search for accommodation, family doctor, assistance on opening bank account, entering into phone service provider agreement etc.) that we provide for the relocation of talents and their family members from one employment place to another (hereinafter “relocation services”).
This notice also describes how we process personal data of visitors of our website www.jobbatical.com (hereinafter “website”), representatives of our potential and current business clients, and other individuals who contact us through the contact form on the website, by email or other means of communication (hereinafter “you” or the “data subject”).
This notice describes the processing of personal data by us as a data controller. This means that we individually or along with others determine the purposes and means of the processing of personal data.
1. DATA CONTROLLER
Name: Jobbatical OÜ.
Registry code: 12671900.
Address: Niine 11, 10414 Tallinn, Estonia.
Contact details of data protection officer: firstname.lastname@example.org.
2. PERSONAL DATA WE PROCESS
“Identification data” – this includes your first and last name. This data is collected directly from you, or from the representative of the company you work for. We may also collect this information from public registers, such as business register, for the purposes of concluding a service contract with the company you represent.
“Contact data” – this includes your email address and phone number. This data is collected directly from you, or from the representative of the company you work for. We may also collect this information from public registers, such as business register, for the purposes of concluding a service contract with the company you represent.
“Talent data” – this includes the talent’s first name, last name, date of birth, personal ID code, nationality, passport data, photo, place of residence, e-mail address, phone number, country of destination, name and other details of the employer, place of work, occupation, education, criminal background, marital status, data concerning family members and other data that is relevant and is requested by relevant authorities, institutions and other involved persons during the provision of requested relocation services or that is necessary to provide our platform services (e.g., your account credentials). The personal data is collected from our business client (i.e., talent’s current or future employer) upon creation of a talent user account and/or directly from the talent.
“Talent family member data” – this includes the first name and last name of the talent’s family member, as well as his or her date of birth, personal ID code, nationality, passport data, photo, place of residence, e-mail address, phone number, country of destination, name and other details of the employer, place of work, occupation, education, marital status, and other data that is relevant and is requested by relevant authorities, institutions and other involved persons during the provision of requested relocation services. The personal data is collected mainly from the talent but can also be collected directly from the talent’s family member or from our business client (i.e., the talent’s current employer or future employer).
“Company data” – this includes the name of the company you represent, and other details, such as registry code and address (where relevant). This data is collected directly from you or from the representative of the company you work for. We may also collect this information from public registers, such as business register, for the purposes of concluding a service contract with the company you represent.
“Communication data” – this includes personal data contained in the correspondence you have with us. This data is collected when you contact us or when we contact you.
“Contract data” – this includes the date and the number of a contract (where relevant), as well as the written contract document. This data is generated upon conclusion of the contract or during its performance.
“Website visit data” – this includes personal data which is collected and further processed upon visiting and using our website. Depending on the particular cookie we use, the types of personal data may include different online identifiers, such as IP address, device fingerprints, client identifier or session ID. Please see more information regarding cookies and other tracking technologies in section 7 of this notice.
3. THE PURPOSES AND THE LEGAL GROUNDS FOR THE PROCESSING OF PERSONAL DATA
We process your personal data necessary for the performance of a contract to which you are the party or to take steps at the request of the data subject prior to entering into a contract for the purposes described below.
3.3 Legal obligation
We process your personal data on this legal ground if the legal obligation for processing arises from the law.
3.4 Legitimate interests
We process your personal data based on our legitimate interests for purposes described below. You have the right to ask clarifications regarding the processing based on the legitimate interests. You also have the right to send the objection, if you find that processing of your personal data for the purposes provided below prejudice your rights. Please see section 1 of this notice for our contact details.
4. CATEGORIES OF RECIPIENTS OF PERSONAL DATA AND TRANSFER OF PERSONAL DATA TO THIRD COUNTRIES
In some cases, we may transfer your personal data to certain recipients who are categorized as follows:
4.1 Partners who provide the services to us, and who process the personal data on our behalf (data processors), e.g.:
(a) providers of various ICT services (including providers of website hosting services and other providers of cloud services);
(b) various contractors (IT development, support, accounting, partners providing relocation services).
4.2 Independent controllers of personal data:
(a) local or government authorities and institutions who are involved in relocation process (e.g., immigration authorities, etc.);
(b) our business clients who are or will be the employers of the talent, or who also need to process talent family member data for their own purposes;
(c) providers of employer of record (EOR) or similar services who we cooperate with together with our business clients;
(d) banks and other financial institutions, our attorneys, auditors, etc.
4.3 Public authorities and supervisory bodies, e.g., court, law enforcement authorities, Data Protection Inspectorate. We transfer your personal data to public authorities and supervisory bodies only if the law requires it.
Unless necessary for the provision of services, we do not transfer your personal data outside of the European Union (EU) or the European Economic Area (EEA), nor to such third country or international organization, the level of data protection of which the European Commission has not considered adequate. If your personal data is transferred outside of the EU or EEA, such transfer of personal data will take place only upon appropriate legal basis, and we will take appropriate protective measures. Data transfers to such third countries are mainly based on Standard Contractual Clauses adopted by the European Commission.
You have the right to get additional information about the transfer of your personal data by sending us the relevant request using the contact details described in section 1 of this notice.
5. RETENTION OF PERSONAL DATA
We retain your personal data for the period necessary for the achievement of purposes stated in this notice or until the law requires it.
For example, we will retain accounting source documents for seven years as of the end of the financial year during which the source document was recorded in the accounts.
Specific terms of retention can be exercised by accessing your personal data. Please see the explanation in the section “Your rights regarding the personal data”.
6. YOUR RIGHTS REGARDING THE PERSONAL DATA
Right of access to your data: you have the right to know, whether personal data concerning you are being processed or not, what is the purpose of processing and what are the categories of personal data. Besides, to whom the personal data is disclosed (especially the recipients in third countries), for how long the personal data is retained and what are your rights concerning rectification, erasure and restriction of the processing.
Right of rectification: you have the right to demand rectification of the personal data concerning you if the data are inaccurate or incomplete.
Right of erasure: in some cases, you have the right to demand erasure of the personal data concerning you, for example in case when you withdraw your consent and there are no other legal grounds for the processing of the personal data.
Right to restrict the processing: in some cases, you have the right to restrict processing of the personal data concerning you for a certain time (e.g., if you have objected the processing of personal data).
Right to object: you have the right to object the processing of personal data, which is processed based on the legitimate interest, including profiling. Upon objection, we will no longer process the personal data unless we demonstrate compelling legitimate grounds for the processing which override your interests, rights and freedoms.
Right to data portability: if processing of your personal data is based on your consent or the contract with us and the data processing is carried out by automated means, then you have the right to receive the personal data concerning you, which you have provided to us, in a structured, commonly used and machine-readable format. Also, you have the right to claim to transmit those personal data to another service provider if it is technically possible.
Right to turn to us, supervisory authority, or a court: if you want to exercise the above-mentioned rights, please send us and email using the contact details described in section 1 of this notice. If you find that your rights have been breached, you have the right to turn to the Data Protection Inspectorate (Andmekaitse Inspektsioon) and/or court. The contact details of the Data Protection Inspectorate are available at www.aki.ee.
7. COOKIES AND OTHER WEB TECHNOLOGIES
We use all the cookies and other web technologies, except the strictly necessary cookies, with your prior consent. You always have the right to withdraw the consent by changing your preferences via our website. In case the strictly necessary cookies process your personal data, we rely on legitimate interests in processing of such data (see section 3.3 above that explains our legitimate interests).
We use first-party cookies (such cookies are created and stored directly by us), but also third-party cookies (i.e., the cookies that are created and stored by third-party service providers, such as Google).
We may use both session cookies and persistent cookies. Session cookies or non-persistent cookies are cookies that exist only temporarily while you browse our website. Your web browser should delete these cookies when you close your browser. However, persistent cookies use expire on a specific date or after a period of time specified by the third party or us.
For your convenience, we have categorized the cookies we use on our website by their purposes as follows:
Strictly necessary : These cookies are used to enable the basic functionality of the website, which means that without these cookies our website would not function as it should. Due to the nature of such cookies, and in accordance with applicable law, we ae entitled to use them without your prior consent. However, if these cookies process personal data, we rely on our legitimate interests upon processing of such data.
Marketing: These cookies are used to deliver advertising that is more relevant to you and your interests. Marketing cookies are used only based on your prior consent.
Analytics: These cookies are used to understand how this website performs, how visitors interact with the site, and whether there may be technical issues. Analytics cookies are used only based on your prior consent.
Hereunder we have listed all the cookies used on our website:
8. AMENDMENT OF THIS NOTICE
We have the right to amend this notice unilaterally. The amended version of the notice will be published on our website.