***Please note that you should review 2 policies-one for Teamtailor and one for Axel Arigato.

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Privacy policy for recruitment using Teamtailor

The service for handling recruitments and simplifying the hiring process (the "Service") is powered by Teamtailor on behalf of Axel Arigato ("Controller" “we” “us” etc.). It is important that the persons using the Service ("Users”) feel safe with, and are informed about, how we handle User's personal data in the recruitment process. We strive to maintain the highest possible standard regarding the protection of personal data. We process, manage, use, and protect User's Personal Data in accordance with this Privacy Policy ("Privacy Policy").

1. General

We are the controller in accordance with current privacy legislations. The Users’ personal data is processed with the purpose of managing and facilitating recruitment of employees to our business.

2. Collection of personal data

We are responsible for the processing of the personal data that the Users contributes to the Service, or for the personal data that we in other ways collects with regards to the Service.

When and how we collect personal data
We collect personal data about Users from Users when Users;

• make an application through the Service or otherwise, adding personal data about themselves either personally or by using a third-party source such as Facebook or LinkedIn; and
• use the Service to connect with our staff, adding personal data about themselves either personally or by using a third-party source such as Facebook or LinkedIn.
• provides identifiable data in the chat (provided through the website that uses the Service) and such data is of relevance to the application procedure;

We collect data from third parties, such as Facebook, LinkedIn and through other public sources. This is referred to as “Sourcing” and be manually performed by our employees or automatically in the Service.

In some cases, existing employees can make recommendations about potential applicants. Such employees will add personal data about such potential applicants. In the cases where this is made, the potential applicant is considered a User in the context of this Privacy Policy and will be informed about the processing.

The types of personal data collected and processed
The categories of personal data that can be collected through the Service can be used to identify natural persons from names, e-mails, pictures and videos, information from Facebook and LinkedIn-accounts, answers to questions asked through the recruiting, titles, education and other information that the User or others have provided through the Service. Only data that is relevant for the recruitment process is collected and processed.

Purpose and lawfulness of processing
The purpose of the collecting and processing of personal data is to manage recruiting. The lawfulness of the processing of personal data is our legitimate interest to simplify and facilitate recruitment.

Personal data that is processed with the purpose of aggregated analysis or market research is always made unidentifiable. Such personal data cannot be used to identify a certain User. Thus, such data is not considered personal data.

The consent of the data subject
The User consents to the processing of its personal data with the purpose of Controller’s handling recruiting. The User consents that personal data is collected through the Service, when Users;

• make an application through the Service, adding personal data about themselves either personally or by using a third-party source as Facebook or LinkedIn, and that Controller may use external sourcing-tools to add additional information; and
• when they use the Service to connect to Controller’s recruitment department, adding personal data about themselves either personally or by using a third-party source such as Facebook or LinkedIn.

The User also consents to the Controller collecting publically available information about the User and compiles them for use in recruitment purposes.

The User consents to the personal data being collected in accordance with the above a) and b) will be processed according to the below sections Storage and transfer and How long the personal data will be processed.

The User has the right to withdraw his or her consent at any time, by contacting Controller using the contact details listed under 9. Using this right may however, mean that the User can not apply for a specific job or otherwise use the Service.

Storage and transfers
The personal data collected through the Service is stored and processed inside the EU/EEA, or such third country that is considered by the European Commission to have an adequate level of protection, or processed by such suppliers that have entered into such binding agreements that fully complies with the lawfulness of third country transfers or to other supplies where adequate safeguards are in place to protect the rights of the data subjects whose data is transferred. To obtain documentation regarding such adequate safeguards, contact us using the Contact details listed in 9.

How long the personal data will be processed
If a User does not object, in writing, to the processing of their personal data, the personal data will be stored and processed by us as long as we deem it necessary with regards to the purposes stated above. Note that an applicant (User) may be interesting for future recruitment and for this purpose we may store Users’ Personal Data until they are no longer of value as potential recruitments. If you as a User wish not to have your Personal Data processed for this purpose (future recruitment) please contact us using the contact details in paragraph 9.

3. Users’ rights

Users have the right to request information about the personal data that is processed by us, by notifying in writing, us using the contact details below under paragraph 9 below. Users have the right to one (1) copy of the processed personal data which belongs to them without any charge. For further demanded copies, Controller has a right to charge a reasonable fee on the basis of the administrative costs for such demand.

Users have the right to, if necessary, rectification of inaccurate personal data concerning that User, via a written request, using the contact details in paragraph 9 below.

The User has the right to demand deletion or restriction of processing, and the right to object to processing based on legitimate interest under certain circumstances.

The User has the right to revoke any consent to processing that has been given by the User to Controller. Using this right may however, mean that the User can not apply for a specific job or otherwise use the Service.

The User has under certain circumstances a right to data portability, which means a right to get the personal data and transfer these to another controller as long as this does not negatively affect the rights and freedoms of others.

User has the right to lodge a complaint to the supervisory authority regarding the processing of personal data relating to him or her, if the User considers that the processing of personal data infringes the legal framework of privacy law.

4. Security

We prioritize the personal integrity and therefore works actively so that the personal data of the Users are processed with utmost care. We take the measures that can be reasonably expected to the make sure that the personal data of Users and others are processed safely and in accordance to this Privacy Policy and the GDPR-regulation.

However, transfers of information over the internet and mobile networks can never occur without any risk, so all transfers are made on the own risk of the person transferring the data. It is important that Users also take responsibility to ensure that their data is protected. It is the responsibility of the User that their login information is kept secret.

5. Transfer of personal data to third party

We will not sell or otherwise transfer Users’ personal data to third parties.

We may transfer Users’ Personal Data to;

• our contractors and sub-contractors, acting as our Processors and Sub-Processors in accordance with our instructions, for the provision of the Service;
• authorities or legal advisors in case criminal or improper behaviour is suspected; and
• authorities, legal advisors or other actors, if required by us according to law or authority’s injunction.

We will only transfer Users’ personal data to third parties that we have confidence in. We carefully choose partners to ensure that the User’s personal data is processed in accordance to current privacy legislations. We cooperate with the following categories of processors of personal data; Teamtailor, who supplies the Service, server and hosting companies, e-mail reference companies, video processing companies, information-sourcing companies, analytical service companies and other companies with regards to suppling the Service.

6. Aggregated data (non-identifiable personal data)

We may share aggregated data to third parties. The aggregated data has in such instances been compiled from information that has been collected through the Service and can, for example, consist of statistics of internet traffic or the geological location for the use of the Service. The aggregated data does not contain any information that can be used to identify individual persons and is thus not personal data.

7. Cookies

When Users use the Service, information about the usage may be stored as cookies. Cookies are passive text files that are stored in the internet browser on the User’s device, such as computer, mobile phone or tablet, when using the Service. We use cookies to improve the User’s usage of the Service and to gather information about, for example, statistics about the usage of the Service. This is done to secure, maintain and improve the Service. The information that is collected through the cookies can in some instances be personal data and is, in such instances, regulated by our Cookie Policy.

Users can at any time disable the use of cookies by changing the local settings in their devices. Disabling of cookies can affect the experience of the Service, for example disabling some functions in the Service.

8. Changes

We have the right to, at any time, make changes or additions to the Privacy Policy. The latest version of the Privacy Policy will always be available through the Service. A new version is considered communicated to the Users when the User has either received an email informing the User of the new version (using the e-mail stated by the User in connection to the use of the Service) or when the User is otherwise informed of the new Privacy Policy.

9. Contact

For questions, further information about our handling of personal data or for contact with us in other matters, please use the below stated contact details; Axel Arigato : peopleandculture@axelarigato.com

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AXEL ARIGATO APPLICANT PRIVACY NOTICE

Axel Arigato, (“Axel Arigato”, “we”, “us”, “our”) is committed to protecting and respecting your privacy. This Privacy Notice sets out why and how we collect, use, and hold your personal data when you apply to work with us, as well as your rights in respect of your personal data.

WHO THIS PRIVACY NOTICE IS FOR

This Privacy Notice applies to anyone who applies for a role within Axel Arigato. It is intended to apply to applicants for paid and unpaid roles, including as employees, temporary workers, and in connection with work experience placements.

If you have any questions, or feel you need any part of this Notice explained, please do not hesitate to reach out to us. If you have any questions or comments on your privacy and our processing of your personal data, you will find our contact details in the end of this Notice.

Please note, this Privacy Notice does not form part of any offer of employment or engagement with Axel Arigato.

WHO WE ARE

For the purposes of the GDPR (General Data Protection Regulation), the controller of your personal data is one of the following companies within the Axel Arigato group.
Denmark: Axel Arigato APS, 39771209
France: Axel Arigato Paris SAS, 893 422 261 (SIREN) / 89 342 226 100 014 (SIRET).
Germany: Axel Arigato GmbH, HRB 269862.
Portugal: Arigato Portugal Unipessoal Lda, 516 889 001
Sweden: Axel Arigato AB 556953–0438.

 

Personal data that we process.

We need to collect and process your personal data in order to consider your application and determine whether to offer you a position. In order to do so, we process the following types of personal data:

• Basic identifiers such as your title, name, date of birth, national insurance number.
• Contact details such as your address, telephone numbers, and email address.
• Details of your qualifications, skills, experience, and employment history.
• Information about your level of renumeration, including benefit entitlements, in your current or past roles.
• Information about your eligibility to work in the UK (United Kingdom).
• Information generated as part of the recruitment process, including psychometric test scores, interview notes and email communications between us.
• CCTV footage of you when you attend our premises for an interview (CCTV cameras are situated at the building entrances only).

SPECIAL CATEGORIES OF PERSONAL DATA

Certain categories of personal data are regarded by data protection law as more sensitive than others. Known as ‘special category personal data,’ this relates to information about your health, racial or ethnic origin, details of sexual life, sexual orientation, religious beliefs, political opinions, trade union membership, or any genetic or biometric data that is used to identify you. This information, and any information about criminal offences or convictions, warrants a higher level of protection under data protection law.

Routinely we collect the following types of special category personal data as part of the recruitment process:

• Information about health (for example, if you have a disability and we need to make reasonable adjustments for you as part of the recruitment process).

We do not collect information about criminal offences and convictions.

HOW WE OBTAIN YOUR PERSONAL DATA

We collect your personal data from the following sources:

• directly from you, for example within your CV and application forms that you complete;
• from recruitment agencies;

• Alva Labs (our provider for psychometric testing, used in connection with the recruitment process for certain roles);
• from your former employer or educational establishment (in connection with obtaining references);
• social media, e.g. LinkedIn.

Please note, when we collect personal data on our forms, we will make it clear whether you are required by law, or under a contract, to provide your personal data, and what will happen if you do not provide that data.

Where we need to collect personal data by law or in order to perform the contract, we have with you and you fail to provide that data when requested, we may not be able to meet our legal obligations or perform the contract we have or are trying to enter with you. This may, for example, result in the termination of an offer of employment or engagement.

HOW AND WHY, WE PROCESS YOUR PERSONAL DATA

We process your personal data for a range of purposes related to your working relationship with us, the efficient running of Axel Arigato and compliance with our legal obligations. Specifically, we process your personal data to:

• Communicate with you in relation to the recruitment process and progress your application;
• Make decisions about your recruitment, including in connection with assessing your suitability for the role you are applying for;
• Screening applicants for certain roles through use of psychometric testing;
• In connection with pay and benefit discussions with you to help determine whether we will make an offer to you;
• Carry out checks for eligibility to work in the UK laws;
• Verify your identity, experience, or qualifications;
• CCTV footage for you is processed for security reasons, for the protection of our property and for health and safety reasons.

Depending on the circumstances, we rely on the following lawful bases to process your personal data (under Article 6 GDPR):

• Our processing of your personal data is necessary for the performance of a legal obligation to which we are subject, for example, checks for eligibility to work in the UK as required by immigration laws.
• Rarely, our processing of your personal data is necessary to protect your or another person’s vital interests (for example, to provide your details to a medical professional in a medical emergency when you are attending our premises for an interview).
• If you are unsuccessful in your application, we may retain copies of your CV and application for up to 24 months in case a similar position becomes available that you may be suitable for with your consent. You have the right to withdraw your consent at any time. To withdraw your consent, please contact peopleandculture@axelarigato.com
• Our processing of your personal data is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests. In particular, Axel Arigato relies on the following legitimate interests:

• To communicate with you in relation to the recruitment process, including providing you with feedback following an interview.

• To consider your suitability for the job you are applying for.
• For reasonable business purposes such as obtaining insurance or seeking professional advice from a third-party professional.
• To protect you and our property through use of CCTV monitoring of our premises.
• Carrying out equality and diversity monitoring.

Additional conditions for the processing of special category data and criminal convictions and offences data

We will only process this type of personal data where, in addition to an appropriate lawful basis (above), our processing complies with Article 9 or Article 10 (as appropriate) of the UK GDPR and, where relevant, it meets a condition in Section 10 and Schedule 1 of the Data Protection Act 2018. This will be the case where:

• Our processing is necessary for performing obligations or exercising rights conferred on us or on you by law in connection with your employment or social security and social protection (for example, we need to collect information about health to ensure we can comply with requirements to make reasonable adjustments).
• Our processing is necessary for the establishment, exercise, or defence of legal claims or in connection with any legal proceedings or obtaining legal advice (for example, providing information to an employment tribunal if a claim has been made).
• In the case of personal data relating to racial or ethnic origin, religious beliefs, health and sexual orientation, our processing is necessary to ensure meaningful equal opportunity monitoring and reporting.
• Our processing is necessary to protect the vital interests of an individual who is physically or legally incapable of giving consent (for example, providing your details to a medical professional in a medical emergency).

WHO WE SHARE YOUR PERSONAL DATA WITH

Your personal data will be seen by members of our recruitment team, including members of our People and Culture team, hiring managers and other prospective colleagues. Your personal data will only be shared with employees of Axel Arigato where this is necessary to make a decision about your application.

From time to time, we will share your personal data with other third parties. This may include:

• Your former employers or education providers, for example when carrying out reference checks;
• Recruitment and other agencies, if you apply or are put forward for a roll through a recruiter;
• For roles where we use psychometric testing as part of our recruitment process, your personal data will be shared with our provider Alva Labs;
• Depending on the role you are applying for, we may share your personal data with other companies within the Axel Arigato group, including:

• Denmark: Axel Arigato Aps
• France: Axel Arigato Paris SAS

• Germany: Axel Arigato GmbH
• Arigato Portugal, Unipessoal LDA
• Sweden: Axel Arigato AB
• United Kingdom: Axel Arigato Limited
• USA (United States): Axel Arigato LLC

 

HOW LONG WE RETAIN YOUR PERSONAL DATA

We will only retain your personal data for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements. When you apply for a role within Axel Arigato, we compile electronic records relating to your application, which we add to as you progress through the application process.

If you are successful in your application, most of this information will be transferred to your personnel file, which will generally be kept for 6 years (UK) following the end of your employment / engagement with us.

If you are unsuccessful in your application, we will retain this for an extended period of 24 months for the purpose of contacting you if any similar roles become available from time to time.

If you would like further information about how long, we retain your personal data for please see our Privacy Notice. A copy of which may be obtained from legal@axelarigato.com

WHERE WE PROCESS YOUR PERSONAL DATA

Most of your personal data is processed in your local country, however sometimes we need to share your personal data with other organisations operating outside your local country.

We share certain systems with our Swedish company Axel Arigato AB, and your personal data may be processed in Sweden. In addition, we may also transfer your personal data to other suppliers based in the European Economic Area (EEA), and the United States of America.

Whenever we transfer your personal data outside of your local country, we meet the GDPR requirements by ensuring that any personal data transferred outside your country continues to be protected as if it were being held in your country. For example, we will only transfer it to a country that is officially considered to provide adequate protection for personal data (this includes the UK and other countries within the EEA) or take additional steps to protect it by using one of the safeguarding measures available under data protection law.

In addition, we take additional safeguards when needed, such as encryption (TLS) and pseudonymisation.

For further information about the safeguards, we put in place when transferring your personal data outside your country please contact peopleandculture@axelarigato.com

YOUR RIGHTS IN RELATION TO OUR PROCESSING OF YOUR PERSONAL DATA

Data protection law provides you with the following legal rights over your personal data:

• The right of access: You can ask us for a copy of the personal data we hold (this is often called a “subject access request”). This right always applies. There are some exceptions which means you may not always be entitled to a copy of all your personal data that we hold.

• The right to rectification: You can ask us to correct any information we have about you if you think it is wrong or to complete information if you think it is incomplete.
• The right of erasure: You can ask us to delete or destroy information about you in some circumstances, for example if our use of your personal data is illegal or if we no longer need it.
• The right to restrict our use of your information: You can ask us to limit what we are doing with your information in some circumstances, for example you can ask us to stop using your information if you think it is inaccurate while we are its accuracy.
• The right to object: You can object to what we are doing with your information in some circumstances. For example, if we are relying on “legitimate interests” to process your personal data or if you do not want your personal data to be used for direct marketing purposes (e.g., sending you marketing emails).
• The right to withdraw consent: You always have the right to withdraw your consent to the processing of your personal data if we are processing it on the basis of your consent.
• The right to data portability: You can ask us to transfer your information to another organisation in a format that makes it easy for them to use. This right only applies to personal data held on a computer, that we have received directly from you and where we are processing it on the basis of your consent or for a contract, we have with you.
• Rights in relation to automated decision-making: If we make a decision about you based on solely automated means (for example, if we decide not to progress your application to work with us based solely on the results of psychometric testing), you have the right to ask for the decision to be reviewed by someone who is qualified and authorised to change that decision if appropriate.

Automated decision-making

Automated decision-making is when a computer or similar electronic system uses personal information to make decisions about people without human involvement. Profiling takes place when various aspects of a person (such as their behaviors, interests, or personality) are analyzed to make predictions or decisions about them.

For certain roles, we use your personal data in automated decision-making as part of our recruitment processes. For example, candidates for certain roles are invited to participate in psychometric testing before being invited to attend an interview. If you do not reach the required score, this will mean that we are unable to proceed with shortlisting you for an interview or continue processing your application.

Where we carry out automated decision-making, we have put in place safeguards to ensure that your rights are protected. For example, we carry out regular reviews of our provider to ensure the programs used are not biased and procedures to prevent errors and discrimination.

The right to lodge a complaint

We take our obligations under data protection law very seriously and are committed to respecting your privacy. If you are not happy with the way in which we are processing your personal data, in the first instance please contact legal@axelarigato.com (contact details below).

If we are unable to resolve your issue, you can also complain to the Data Protection Authority in your country:

Denmark: English (datatilsynet.dk)
France: https://www.cnil.fr/
Germany: https://www.bfdi.bund.de/ ;
Portugal: CNPD
Sweden: Integritetsskyddsmyndigheten | IMY
UK: https://ico.or.uk/make-a-complaint/.

CONTACT

If you have any questions about our processing of personal data or wish to enforce your rights, please contact:

Name: Marie Fall

Phone number: + 46 763 18 23 71

E-mail address: legal@axelarigato.com

CHANGES TO THIS NOTICE

We may amend this privacy notice at any time to reflect any changes in the way in which we process your personal data. If you are in the process of applying when any changes or updates are made to this notice, we will bring this to your attention as soon as possible.

If you have previously applied for a role with Axel Arigato and are submitting a new application, we recommend checking the privacy notice for any changes before submitting your application.