PRIVACY POLICY

In this privacy, the following definitions are used:
Data controller means a person who (either alone or jointly or in common with other persons) determines the purposes for which and the manner in which any personal data are, or are to be, processed.
Data processor, in relation to personal data, means any person (other than an employee of the data controller) who processes the data on behalf of the data controller.
“You”, “your” or “data subject” means:
- Visitors to our website
- Subscribers to any service we offer through our site
- Prospective or existing clients corresponding with us by phone, e-mail or otherwise
- Job applicants
Data controller, “we”, “us” and “our” means:
Venbest-Recruiting LLC and its data processors;
Personal data means any information relating to an identified or identifiable natural person (data subject). An identifiable natural person is one who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person. The definition incorporates, where applicable, the definitions provided in the General Data Protection Regulation (EU 2016/679).;
Sensitive personal data
The GDPR refers to sensitive personal data as “special categories of data”. Please see “Special categories of data”.
Special categories of personal data
Means personal data revealing racial or ethnic origin, political opinions, religious or philosophical beliefs, or trade union membership, and the processing of genetic data, biometric data for the purpose of uniquely identifying a natural person, data concerning health or data concerning a natural person\'s sex life or sexual orientation.

For the purpose of the General Data Protection Regulation the data controller is Venbest-Recruiting LLC with company registration number 35624382 and the registered address at Peremogy Avenue 90/1, Kyiv , 03062, Ukraine.
Contact email: hcet.srelliks%40ofni
Changes to this privacy policy
Any changes we may make to this privacy policy in the future will be posted on this page and, where appropriate, notified to you by e-mail or when you next visit or log onto the Website.

Personal Data you provide us voluntarily
We collect the information provided by you to operate effectively and provide you the best experiences with our Website, products and services. You provide some of this information voluntarily by filling in the contact forms on our web site, creating an account at our Website or by corresponding with us by phone, e-mail or otherwise. This includes information you provide if you subscribe to any promotion we offer through our site, send us a query or feedback, sign up for information on events, upload a document with your enquiry, participate in discussion boards or other social media functions on our site, promotion or survey, provide your postcode or location to help us to find our nearest branch to your location, or when you report a problem with our Website.
We collect information that is provided to us by jobs candidates (“Applicants”), when they apply to any of the open positions published at our Website via the relevant Position Application Form on our Website by sending us an e-mail or otherwise (see above): Your contact details and CV (“Applicants Information”) might include your:
First name, Surname, e-mail address and phone number, credentials: we collect passwords, password hints and similar security information used for your authentication and account access if you create an account at our Website, goods or services provided, your message/enquiry which might contain but not limited to: your company name, web site link, IT infrastructure description
Sensitive information and special category data
With your application you occasionally might provide us some sensitive information or special category data related to your disability status, racial or ethnic origin (please check the paragraph Definitions and interpretation). Submission of this type of information is strictly voluntary. By the nature of our business we do not process large scale special category data on a regular basis and will consider such input an occasional submission. We will obtain your consent to process special category data if you wish to share it with us on our later communication regarding your application. If this is not possible we will destroy such data and erase any copy in our possession.
Criminal offence data
By the nature of our business and the purposes of processing the data, the services hereunder are not intended for processing of criminal offence data (please check the paragraph Definitions and interpretation). If you provide any information or documents containing this type of data, you are hereby notified that any input of such information will be solely at your risk and responsibility, we will destroy such data if we receive it accidently.
Children
We do not provide any services to children below 16 and do not knowingly collect personal information from children below 16.
Information you provide about others
In providing personal data about other individuals (such as someone in whose name you are registering an account or subscribing to our marketing promotions), you represent that you have notified them of (i) the purposes for which information will be used (ii) the recipients of their personal data and (iii) how they can access and correct the information. You further represent that You have obtained all necessary consents from them.

We might get some information from our visitors by recording how they interact with our Website with the use of cookies, analytics tools or obtain data from third parties.
This technical information might have included:
Device and connectivity information such as IP (Internet Protocol) address, Browser type and version, Language settings, Browser plug-in types and versions.
This technical information will not be included:
Pages you viewed or searched for, Full uniform resource locators (URL), Methods used to browse away from the page, Clickstream to, through and from the site (including date and time), Length of visits to certain pages, Page interaction information (such as scrolling, clicks, and mouse-overs).
Log information, such as error reports, download errors, any problems users might experience using the web site.
We do not match information collected automatically through cookies and analytics tools with other personally identifiable information you may have provided to us when you create an account or submit a form through our Website.

A cookie is a small file, typically of letters and numbers, downloaded on to a device when the user accesses certain websites. Cookies allow a website to recognize a user’s device.

We might use the following cookie types to recognize you when you visit our site or use our Services, remember your preferences and give you a personalized experience:

Session cookies

A session cookie exists only in temporary memory while the user navigates the website. Web browsers normally delete session cookies when the user closes the browser.

Persistent cookies

Persistent cookie expires at a specific date or after a specific length of time. This means that, for the cookie's entire lifespan (which can be as long or as short as its creators want), its information will be transmitted to the server every time the user visits the website that it belongs to.

Third-party cookies

A third-party cookie belongs to a domain different from the one shown in the address bar. This sort of cookie typically appears when web pages feature content from external websites. We may use them for website analytics and advertising purposes.

Strictly necessary cookies

These cookies enable websites to remember choices their users make, for example, user name, language or text size. These cookies are known as functionality cookies and help to improve user experience of a website by providing a more personalized service.

Targeting cookies

These are cookies that are used to deliver content that best suits you and your interests. It can be used for targeted advertising, limiting ad serving or measuring the effectiveness of a promotional campaign.

Usually browsers accept cookies automatically, however you can control and/or delete cookies as you wish.

You can delete all cookies that are already on your computer and you can set most browsers to prevent them from being placed.

Most browsers allow you to:

- See what cookies you\'ve got and delete them on an individual basis

- Block third party cookie

- Block cookies from particular sites

- Block all cookies from being set

- Delete all cookies when you close your browser

Do not track is a function that allows visitors to opt out from being tracked by websites for any purpose including the use of analytics services, advertising networks and social platforms. Do not track options are available in a number of browsers including:
- Google: https://support.google.com/chrome/answer/95647?hl=en-GB
- Internet Explorer: https://support.microsoft.com/en-us/help/260971/description-of-cookies
- Mozilla Firefox: https://support.mozilla.org/en-US/kb/cookies-information-websites-store-on-your-computer
- Safari (Desktop): https://support.apple.com/kb/PH5042?locale=en_US
- Safari (Mobile): https://support.apple.com/en-us/HT201265
- Android Browser: https://support.google.com/chrome/answer/95647?co=GENIE.Platform%3DAndroid
- Opera: https://www.opera.com/help
- Opera Mobile: https://www.opera.com/help/mobile/android#privacy
For other browsers, please consult the documentation that your browser manufacturer provides.

Google Analytics cookies
Google Analytics collects information anonymously. It reports website trends without identifying individual visitors. You can opt out of Google Analytics without affecting how you visit this site. For more information on Google Analytics, please visit it's website: https://support.google.com/analytics/answer/6004245
Web beacons
Web beacons consist of a small string of software code that represents a graphic image request on a page or email. There may or may not be a visible graphic image associated with the web beacon and often the image is designed to blend into the background of a page or email. Web beacons can be used for many purposes - including website traffic reporting, unique visitor counts, advertising auditing and reporting, and personalization.
We might use the following tracking pixels:
- Meta
- Google
- Microsoft
- SendPulse
- Weblium
 - Calendly
You can opt out of interest-based targeting provided by participating ad servers through the Digital Advertising Alliance (http://youradchoices.com). In addition, on your iPhone, iPad or Android, you can change your device settings to control whether you see online interest-based ads.

Our Website might include certain Social Media features and widgets, such as the following: Facebook like, Facebook share, Twitter tweet, Instagram follow, Youtube, Linkedin, Pinterest, Telegram, buttons or other interactive mini-programs (“Social Media Features”).
These Social Media Features may collect information such as your IP address or which page you are visiting on our Website, and may set a cookie to enable them to function properly. Social Media Features are either hosted by a third party or hosted directly on our Website. Please be aware that if you choose to interact or share any Personal Information via such widgets, you are in fact providing it to these third parties and not to us. Your interactions with these third parties are managed by these Social Media policies and not ours. For example, you will not be able to use the “Facebook Like” button if you are not logged in to your Facebook account. Once you use the button this will be associated with your Facebook history, but we will not process this information.

Trusted partners (data processors) who work on our behalf under confidentiality agreements and might store, maintain or process your data:
We have partnered with a number of authorized service providers (data processors), whose services and solutions complement, facilitate and enhance our own under written confidentiality agreements that guarantees that the requirements of the GDPR will be met and the rights of data subjects are protected. Data processors only act on behalf of our documented instructions. They have direct responsibilities under the GDPR and may be subject to fines or other sanctions if they don’t comply.
These might include:
Hosting providers, information technology service providers, data and cyber security services, web analytics, e-mail distribution and monitoring services, marketing services, content delivery networks (CDNs), our legal and financial advisors, accountants, insurance brokers and companies, delivery services.
Such data processors may receive or otherwise have access to your identifiable or non-identifiable personal data, in its entirety or in part – depending on each of their particular roles and purposes in facilitating and enhancing our Services and business, and may only use it for such purposes. Under no circumstances may data processors will use the data for their own purposes.
Your personal data might be maintained, stored and processed at a destination outside the European Economic Area under our written instructions and regardless of any lesser legal requirements which may apply in their jurisdiction in:
Ukraine, United States of America
Once this contract is concluded, data processor will return data to us or transmit to another processor appointed by us, and erase any copy in its possession. However, the processor may keep the data locked to address possible administrative or jurisdictional responsibilities.

We will hold your personal data during the business relationship between you and us, whether you are a user of our website, a client or candidate. If you are an applicant, we will hold your personal data during the application process. We may retain submitted Applicants Information even after the applied position is no longer available. This is done so we could re-consider Applicants for other positions and opportunities.

If you are our client or a successful applicant, we still might hold your information for as long as is necessary to comply with our statutory and contractual obligations and in accordance with our legitimate interests as data controller (Please see paragraph “Lawful basis and the purposes of the processing (Uses made of your personal information)”). We will use reasonable endeavours to ensure your data is maintained and up-to-date. As a data subject you have rights related to maintenance, storage and processing of your personal data. Please see paragraph “Your rights”. Unless otherwise specified, where you have indicated to us that you are happy for us to send you the information about goods and services we offer and we feel may interest you or similar to those that you have already purchased or enquired about do so, we assume you are happy for us to keep your collected personal data. We may retain your Personal Information (contact details) for as long as your User Account is active or as otherwise needed to provide you with information our Services.

As the data subject you have rights related to processing of your personal data and the option of withdrawing your consent to receive promotions at any time. Please see paragraph “Your rights”.

We process all personal data lawfully, fairly and in a transparent manner. We use the data we collect for the following basic purposes, described in more detail below:

1. To take steps at the request of the data subject prior to entering into a business relationship (oral or written contract):

1.1 By contacting us by means specified in paragraph “Personal Data you provide us voluntarily”, we assume that processing is necessary for the performance of a business relationship (oral or written contract) or in order to take steps prior to entering into a business relationship (oral or written contract), and therefore the lawful basis is Contract and our Legitimate interests.

1.2 We will use the provided information to operate effectively and do our best to respond to your enquiry. Once you enter into a business relationship (oral or written contract) with us we will invoice our services and offer you post-sales service and loyalty if required.

1.3 If you are a candidate, we will use your data to submit your CV for general applications, to apply for specific jobs, to find a position that is most suitable for you, to match your details with existing job vacancies and to send your personal information under your explicit consent to our clients in order to apply for jobs;

2. Special category data.

2.1 You might provide special category data with your application. Submission of this type of information is strictly voluntary. By submitting special category data you agree to its processing and disclosure to our clients. The lawful basis is consent and the condition for processing is Consent.

3. If you are a client, we will hold your data to fulfil our contract and legal obligations.

3.1 We might hold your information for as long as is necessary to comply with our legal obligations and in accordance with our legitimate interests as a data controller after the contractual relationship between you and us elapses. The lawful basis for such retention is legal obligation. As the data subject you have rights related to maintenance, storage and processing of your personal data. Please see paragraph “Your rights”.

4. To send you communications, including promotional communications and advertising with your explicit consent or allow you to participate in interactive features of our service, when you choose to do so. The lawful basis for such processing is Consent.

4.1 If you wish not to receive such promotional e-mails, you may withdraw your consent at any time by contacting us as described in paragraph “Your rights” or follow the “unsubscribe” or instructions contained in the promotional communications you receive.

5. Website improvement.

We might use your automatically collected data such as IP address and browser data for our Website improvement, such as:

5.1 To administer our site and for internal operations, including data security, troubleshooting, testing, statistical and survey purposes;

5.2 To ensure that content from our site is presented in the most effective manner for you and for your device. The lawful basis for such processing is Legitimate interests.

We do not rent, sell, or share personal information about you with other people or non-affiliated companies without your consent except to provide products or services you've requested, when we have your permission, or under the following circumstances:

1. We provide the information to trusted partners who provide us services under confidentiality agreements, specified in Paragraph “Trusted partners (data processors) who work on our behalf under confidentiality agreements and might store, maintain or process your data. These companies do not have any independent right to share this information.

2. If you are a job candidate, we will send your personal information under your explicit consent to our clients in order to apply for jobs. We will provide you the full details of our client and obtain your informed consent to disclose your personal data prior to disclosing it.

3. If you are a client, we will share your business details with the job applicants.

We may disclose your information to third parties when we reasonably believe we are obligated to do so by law, and in order to investigate, prevent, or take action regarding suspected or actual prohibited activities, including but not limited to, fraud and situations involving potential threats to the physical safety of any person.

4. In the event we are acquired by or merged with a third party entity or undergo another change of control, we reserve the right to transfer information, including any PII and non-PII, to a successor entity. In this event, we will notify you by electronic means and obtain your consent before information about you is transferred and becomes subject to a different privacy policy.

Application information

We also collect information that is provided to us by jobs candidates (“Applicants”), when they apply to any of the open positions published at our Website via the relevant Position Application Form on our Website by sending us an e-mail or otherwise (see paragraph Personal Data you provide us voluntarily).

Your contact details and CV (“Applicants Information”) might include your:

Your first name, Surname, residential address, email address, telephone number, employment and educational history, language proficiencies and other work-related skills, date of birth, gender, national insurance number, citizenship and work authorization status, references as well as their contact information, resume or any document you may choose to upload to our website as part of your application, qualifications for employment, work and salary expectations.

Sensitive information and special category data

With your application you might provide us some sensitive information or special category data related to your Disability status, racial or ethnic origin (please check the paragraph Definitions and interpretation). Submission of this type of information is strictly voluntary. We will obtain your consent to process special category data if you wish to share it with us on our later communication regarding your application. If this is not possible we will destroy such data and erase any copy in our possession.

Criminal offence data

By the nature of our business and the purposes of processing the data, the services hereunder are not intended for processing of criminal offence data (please check the paragraph Definitions and interpretation). If you provide any information or documents containing this type of data, you are hereby notified that any input of such information will be solely at your risk and responsibility, we will destroy such data if we receive it accidently.

Purposes of the processing

By registering as a job candidate (“Applicant”) to any of the open positions published at our Website You explicitly confirm that you are interested in an employment with a help of Venbest-Recruiting LLC and contact us as a step to enter in a contract with us. You therefore voluntarily provide Your personal data to be used for recruiting purposes, in particular for filling and matching your profile with any and all open positions in portfolio of Venbest-Recruiting LLC, including beyond those for which you specifically applied.

Retention period

We may retain submitted Applicants Information even after the applied position has been filled or closed. This is done so we could re-consider Applicants for other positions and opportunities; so we could use their Applicants Information as reference for future applications submitted by them; and in case the Applicant is hired, for additional employment and business purposes related to his/her work. As a data subject you have rights related to maintenance, storage and processing of your personal data. Please see paragraph 'Your rights'.

International transfers

You can find detailed information related to data location in paragraphs 'Where Do We Store Your Information?' and 'Trusted partners (data processors) who work on our behalf under confidentiality agreements and might store, maintain or process your data'.

Law Enforcement, Legal Requests and Duties

We may disclose or otherwise allow others access to your Personal Information pursuant to a legal request, such as a subpoena, legal proceedings, search warrant or court order, or in compliance with applicable laws, if we have a good faith belief that the law requires us to do so, with or without notice to you. Your details may also be disclosed to the police and law enforcement agencies for the purpose of fraud detection, crime prevention and national security.

You have the following rights in accordance with the General Data Protection Regulation:

1. THE RIGHT TO BE INFORMED. In this privacy statement we supply you detailed information related to your personal data storage, maintenance and processing.

2. THE RIGHT TO ACCESS INFORMATION HELD ABOUT YOU.

3. THE RIGHT TO RECTIFY YOUR PERSONAL DATA if it is inaccurate, incomplete or out-of-date.

4. THE RIGHT TO ERASURE (DELETE OR REMOVE) YOUR PERSONAL DATA.

5. THE RIGHT TO RESTRICT (BLOCK) PROCESSING. When processing is restricted, we will store your personal data, but not further process it.

6. THE RIGHT TO DATA PORTABILITY is your right to receive the personal data which you have given to us, in a structured, commonly used and machine-readable format and the right to transmit that data to another controller from the current controller applicable if: The processing is based on consent or on a contract, and the processing is carried out by automated means.

7. RIGHTS RELATED TO AUTOMATED DECISION MAKING INCLUDING PROFILING.

8. THE RIGHT TO WITHDRAW YOUR CONSENT OR OBJECT TO DIRECT MARKETING AND OTHER TYPES OF PROCESSING IF APPLICABLE.

You can exercise your rights by contacting us at hcet.srelliks%40ofni

THE RIGHT TO LODGE A COMPLAINT WITH A SUPERVISORY AUTHORITY

You have The right to lodge a complaint with a supervisory authority if you have a concern about our information rights practices.