FintechOS Recruitment Policy

[March 16th, 2022]

1. Objective

The objective of this Recruitment Policy is to explain how we collect, use, share and protect your personal data and how we enable your rights in connection with our online and offline recruitment activities.

Personal data means all information that relates to an identified individual or to an identifiable individual. For example, your name, address, contact information (such as phone number, email address), educational and employment background, CV and job qualifications.

This Policy applies to all applicants, candidates, and prospects (including those who may be unsuccessful in the application process) and third parties whose information you provide to us in connection with any application.

This document supports the following principles:

  • We are committed to process personal data honestly, ethically, with integrity, and always consistent with applicable law and our values.
  • We are transparent about the personal data we collect, use, share and store.
  • People applying for a role at FintechOS should easily understand how we collect and process their personal data and their rights with respect to this personal data.

Please read the following carefully to understand our use of your personal data.

Providing personal information on our or a third-party’s career sites is entirely voluntary, and you are under no obligation to supply any further information as part of our application processes. Please keep in mind that if you do not provide sufficient information, we may be unable to process your job application, consider your suitability for a specific role, comply with our legal obligations, or manage our business.

2. Who is collecting your personal data?

Each of the entities of the FintechOS Group is the data controller of your personal data that is collected and processed in connection with your job application with such entity:

Entity

Registered office

FINTECH OS S.R.L.

Bucharest, Oregon Park, 46D-46E-48, Pipera Road, Building C, 2nd Floor, District 2, Romania

FINTECHOS EASY SOLUTIONS S.R.L.

Craiova City, 30 Știrbei Vodă Blvd., Malmo Building, Office No. 704, 7th floor, Dolj County

FINTECHOS TECHNOLOGY UK LTD

Devonshire House 60 Goswell Road, London, England, EC1M 7AD

FINTECHOS EU B.V.

Nieuwezijds Voorburgwal 104, 1012 SG, Amsterdam, Netherlands

FINTECHOS LLC

8 The Green, STE R, Dover, Delaware, US, zip code 19901

We provide details of how to contact us in the “How to contact us” section of this Recruitment Policy.

3. Definitions

In this Recruitment Policy:

“we/us/our” or “FintechOS”

means any of the entities of the FintechOS Group as described above;

“third-party”

means someone who is not you or us or a part of FintechOS Group;

4. How will we collect personal data about you

We collect personal data about you:

  1. Directly from you, through your application form and/or during the hiring process (online or in-person);
  2. Recruitment agencies and services, from which we collect your CV information and contact data; and
  3. From other third parties, (which can include, for example, your name and contact details including your telephone number and email address) subject to the requirements of applicable law. These parties may include:
    • Publicly available information (such as LinkedIn and other job seeking sites where you have made your profile and job seeking interests publicly available.);
    • Former employers;
    • Named referees, from whom we may collect a formal reference; and
    • Other third parties, such as external workforce suppliers, background check agencies, police departments, (if and to the extent permitted by applicable law).

If you intend to provide us with details of a reference or any other third party as part of your CV/application form, it is your responsibility to obtain consent from that third party prior to providing the personal data to us.

Personal data

The types of personal data we may collect about you are, for example:

  1. Personal details, such as name, address, personal email address, telephone number, language(s) spoken, proof of identity and identification information, including your date of birth, gender, and national identification number or similar government-issued identification numbers, photograph;
  2. Recruitment details, such as, application form, CV, resumes, copies of right to work documentation, references and other information included in a CV or as part of the application process, previous employment background, education history, professional qualifications, other relevant skills, certification, information necessary to complete a background check;
  3. Documentation required under immigration laws: Citizenship, passport data, details of residency or work permit.

Special categories of personal data

As a general rule, we do not process personal data about racial or ethnic origin, political opinion, philosophical beliefs, religion, sexual orientation, genetic data, health, criminal records or union membership unless required by law or union agreement for data subjects in some countries.

In special cases however, where there is a legal basis, or legitimate security reasons, such data can be processed as allowed under applicable law in certain jurisdictions.

For example, for positions that play a strategic role within the organization and may impact company-wide decisions (such as directors, officers, high-level executives, accountants or other similar positions), we may carry out basic criminal record checks in order to perform security background checks to the extent permitted by the applicable law and only if where this is necessary to assess your suitability for the role you have applied.

Please note that we do not collect this information in all countries and will only collect this where we are entitled to do so in accordance with national legislation.

5. How we use information about you

We may process the personal data that we collect about you for the following purposes:

Purpose

Justification

To evaluate and take a decision about your application during the recruitment process.

To perform pre-employment screening.

Necessary step prior to entering into an employment contract with you (art. 6 b) GDPR).

Compliance with a legal obligation (art. 6 c) GDPR).

If pre-employment screening is performed:

  • consent (where specifically sought and obtained only, art. 6 a) GDPR)
  • compliance with a legal obligation (art. 6 c) GDPR)

To check if you are legally entitled to work in the EU.

Compliance with a legal obligation (art. 6 c) GDPR)

To communicate with you and respond to your requests or application.

Necessary step prior to entering into an employment contract with you (art. 6 b) GDPR).

To comply with legal obligations, internal policies and audit

Necessary step prior to entering into an employment contract with you (art. 6 b) GDPR).

Compliance with a legal obligation (art. 6 c) GDPR).

To ensure the security of the company’s ownership over information and equipment.

Legitimate interests (to ensure security of the company’s equipment and the information stored on such devices.); (art. 6 f) GDPR)

To meet our general legal obligations as an employer – such as Compliance with government inspections and other requests from government or other public authorities.

Compliance with a legal obligation (art. 6 c) GDPR).

Legitimate interest (to ensure compliance with internal storing rules and support in case of need to defend / support specific claims as well as specific legal requirements); (art. 6 f) GDPR).

To defend any legal interest / rights / claims before official competent bodies.

Compliance with a legal obligation (art. 6 c) GDPR).

Legitimate interest (to obtain the satisfaction of our interest / rights / claims deriving from or in connection with the recruitment process with you or to defend ourselves where you would initiate legal proceedings against us). (art. 6 f) GDPR).

6. Who we share information about you with

We may share personal data about you with:

  1. Companies within the FintechOS Group;
  2. Companies or consultants who are engaged to perform services for, to, or on behalf of a company in the FintechOS Group, including for example, security, IT and software services and technical support suppliers, back-office, archiving services suppliers, insurance / leasing services suppliers, labour medicine services supplier, health safety services supplier, training and evaluation agencies, accommodation and transportation services providers / tourism agencies, marketing agencies, leasing companies, insurance companies, payroll services providers, providers of lunch / gift vouchers, accountants, mail / courier services providers, medical services providers), photo / video service providers, couriers;
  3. Law enforcement agencies, government bodies, regulatory organisations, courts or other public authorities if we have to, or are authorised to by law;
  4. A third party or body where such disclosure is required to satisfy any applicable law, or other legal, contractual or regulatory requirement;
  5. In conjunction with any merger, sale or acquisition of a company in the FintechOS Group.

7. Where we process information about you

In doing the above, we may need to transfer personal information about you to other companies in the FintechOS Group or third parties located (or whose servers may be located) in countries outside of where you are engaged, including countries outside of the European Economic Area (EEA). If we send personal information about you to a country that is not in the EEA, we will make sure that there is a legal basis for such transfer and that your personal information is adequately protected as required by applicable law, for example, by using standard agreements approved by relevant authorities and by requiring the use of other appropriate technical and organizational measures to protect your personal information.

Please contact the Privacy Officer if you would like to find out more about the way we comply with our legal obligations in relation to international data transfers.

8. How long we keep information about you

We’ll store your information for as long as we have to by law. If there is no legal requirement, we’ll only store it for as long as we need to. Generally, this means that we will retain your information for as long as you are engaged by FintechOS, and after you leave, we retain some of that information for long as is necessary to fulfil any legal or regulatory requirements and the purposes for which it was collected as prescribed by the law. For example, when your engagement with FintechOS ends, we will keep your information for the duration necessary to exercise rights deriving from employment relation or for the period imposed by the statute of limitation for tax liability establishment.

9. Your rights

Depending on and subject to applicable laws, you have certain rights regarding the personal data that we hold about you. These rights may include the following:

  1. Right to correct or update information: you have the right to have the information we hold about you corrected if it is not accurate.
  2. Right to access: you have the right to be provided with access to data held about you by us and type of processing (purpose, categories of personal data processed, recipients / third parties having access to your data), retention period, your specific rights. You may also ask a free-of-charge copy of your personal data we process
  3. Right to object: you have the right to object to the processing of your personal information where we rely on our legitimate ground to do so. Your objection will be balanced against our specific legitimate ground for processing.
  4. Right to deletion: in certain circumstances you have the right to request that we erase the personal information we hold about you.
  5. Right to restrict use of your information: if you feel the personal information we hold about you is inaccurate or believe we shouldn’t be processing your personal information, you may have the right to ask us to restrict processing that information.
  6. Withdrawal of consent: you may withdraw any consent to processing and prevent further processing if there is no other ground than consent under which FintechOS can process your personal data.
  7. Right to data portability: in certain circumstances you will have the right to take the personal information you have provided to us with you. You can raise a request for data portability by contacting askhr@fintechos.com.
  8. Right to lodge a complaint with the competent data protection supervisory authority (such as, in Europe, in the EU Member State of your usual residence) about the way we handle or process your personal data.

These rights can be exercised by contacting us at askhr@fintechos.com. If we don’t take action based on any of the above requests, we will inform you of our reasons for this.

10. Revisions to this Recruitment Policy

We may update this policy from time to time to comply with legal requirements or to meet our changing business needs, so we encourage you to check it regularly. The most up-to-date version of the Recruitment Policy can be found on our website.

11. How to contact us

If you have any further questions about this Recruitment Policy or how we process your information, please contact us by sending an email to askhr@fintechos.com.