Privacy policy for recruitment using Teamtailor
The service for handling recruitments and simplifying the hiring process (the "Service") is powered by Teamtailor AB (Registration Number 556936-6668, Adress Östgötagatan 16, 116 21, Stockholm, Sweden) on behalf of Coolbet ("Controller" “we” “us” etc.). It is important that you, as an individual using the Service, feel safe with, and are informed about, how we handle your Personal Data in the recruitment process. Striving to maintain the highest possible standard regarding the protection of Personal Data we process and protect your Personal Data in accordance with this Privacy Policy (“Privacy Policy”) and Regulation (EU) 2016/679 of 27 April 2016 on the protection of natural persons with regard to the processing of personal data and on the free movement of such data (“GDPR”).
Please read the following carefully to understand our views and practices regarding your Personal Data and how we will treat it.
1. Who we are?
1.1. Coolbet is the controller of your Personal Data in accordance with current privacy legislation. Controller is the legal term used to signify the organization that controls what to do with any given Personal Data.
2. Who does this privacy policy apply to?
2.1. This policy applies to all job applicants and potential candidates for employment with Coolbet. It applies to all individuals who submit a CV, resume, or other information to Coolbet (either directly or through a recruitment agency) or who apply through any of our official recruitment mediums.
3. How may we process your Personal Data?
3.1. We are responsible for the processing of the Personal Data that you directly contribute to the Service, or for the Personal Data that we may indirectly in other ways collect with regards to the Service.
3.2. “Processing” refers to any action or set of actions we perform on your Personal Data, and according to the General Data Protection Regulation (GDPR) encompasses a broad range of operations, which could be performed manually or automatically and include collection, recording, organization, storage, alteration, retrieval, consultation, use, disclosure, erasure or destruction.
4. When and how do we collect your Personal Data?
4.1. We collect your Personal Data directly from you when you:
4.1.1. make an application through the Service or otherwise, adding personal data about yourself either personally or by using a third-party source such as Facebook or LinkedIn; and
4.1.2. use the Service to connect with our staff, adding your Personal Data either personally or by using a third-party source such as Facebook or LinkedIn.
4.1.3. provide Personal Data in the chat (provided through the website that uses the Service), via email, or other communications and such data are of relevance to the application procedure.
4.2. We may collect your Personal Data indirectly:
4.2.1. from third parties, such as Facebook, Linkedin and through other public sources; this is referred to as “Sourcing” and can be manually performed by our employees or automatically in the Service;
4.2.2. when our existing employee(s) make recommendations about you as a potential applicant and provide us your Personal Data for the recruitment purposes; in the cases where this is made, you are considered as the applicant of Services in the context of this Privacy Policy and you will be informed about the processing.
5. What Personal Data about you may be collected and processed?
5.1. Personal Data means any information about you we may collect and process through the recruitment process from which you could be identified, which includes, but is not limited to:
5.1.1. Data which you have provided to us in your candidate application form: your first name and last name, your place of residence (country, city), email address and phone number, data about the position being applied for, are you at least 21 years old, country (countries) citizenship/residence permit you own, your monthly salary expectation, when could you start working with us, how were you referred to us, what is the main reason you want to join us, link to your LinkedIn profile.
5.1.2. Additional data which you have provided to us in your application documents (curriculum vitae CV, cover letter and any additional documents), including, but not limited to: date of birth, photo, work experience and employment history, job titles, qualifications, suitability and competence, educational background, language skills and other skills, your contact details (such as postal address).
5.1.3. Data generated during the recruitment process, such as interview video, assignments, tests and notes, answers to questions asked through the recruiting, data related to personal and suitability assessments, and data related to the progress of the recruitment process and selection, information on whether your application can be used in other our recruitments.
5.1.4. Data obtained from social networks and other publicly accessible sources, including but not limited to LinkedIn and Facebook accounts.
5.1.5. Data provided to us by your referees (if applicable).
5.2. Please, bear in mind that:
5.2.1. if your identity has been removed from the data it will become anonymous data and that will not be your Personal Data;
5.2.2. we collect and process only your Personal Data that is relevant for the recruitment process and to the extent it is necessary;
5.2.3. your Personal Data that is processed with the purpose of aggregated analysis or market research is always made unidentifiable and it cannot be used to identify you, and thus such data are not considered as Personal Data.
5.3. Although we have no intention to collect and do not ask you to provide, in the course of Services (for instance, in your CV) you may disclose to us your sensitive Personal Data, revealing your 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 are considered as sensitive categories of personal data. Such sensitive Personal Data will be processed with extra care and security.
5.4. It is important that you provide us with up-to-date and accurate Personal Data in order to enable us to process your application. We may need to reject an application on the basis that insufficient, irrelevant, or false information has been provided to completely assess the application.
6. What is the purpose and legal basis for the processing of your personal data?
6.1. Your Personal Data are collected and processed for the following purposes:
6.1.1. Managing and facilitating recruitment of employees to our business. The lawfulness of the processing of personal data is our legitimate interest to simplify and facilitate recruitment.
6.1.2. Respond to communications you send to us. The lawful basis for such processing of Personal Data is your consent.
6.1.3. Resolving possible legal disputes or claims arising out of the recruitment process.
6.1.4. For the purpose of future recruitment processes to consider you for future job roles which may come available at a later stage in case you have given your consent.
6.2. Where we process your Personal Data as set out above, we may do this directly or appoint members of our group or service providers (known as processors), who only process your Personal Data on our behalf for the purposes set out above.
6.3. We may use non-personal information (which is non-identifiable information that, when taken alone, cannot be used to identify or contact you). As such, we are not aware of the identity of the user from which the non-personal information was collected. We use such information for different purposes, such as the improvement of Services and performing web analytics. We may gather such information, either independently or through the help of our third-party service providers.
7. Your consent on collection and processing of Your Personal Data
7.1. You give your consent for the purposes set above to the collection, retention, transfer, and processing of Your Personal Data through the Service under terms of this Privacy Policy when you:
7.1.1. make an application through the Service, adding your Personal Data either personally or by using a third-party source as Facebook or LinkedIn, and we may use external sourcing-tools to add additional information; and
7.1.2. use the Service to connect to our Human Resources department, providing Personal Data about you either personally or by using a third-party source such as Facebook or LinkedIn; and
7.1.3. provide to us in the course of the recruitment process, including, but not limited to Personal Data disclosed during an interview while answering to questions asked through the recruiting when sending your Personal Data (for example, checks of criminal records) related to personal and suitability assessments.
7.2. You also give us consent to the collection and processing of publicly available your Personal Data and compiling it for recruitment purposes.
7.3. You have the right to withdraw your consent at any time when we are relying on consent to process your Personal Data by contacting us at email privacy@coolbet.com. This will not affect the lawfulness of any processing carried out before you withdraw your consent. However, if you withdraw your consent, you will not be able to apply for a specific job or otherwise use the Service.
8. How long your Personal Data will be retained?
8.1. To determine the appropriate retention period for Personal Data, we consider the amount, nature, and sensitivity of the Personal Data, the potential risk of harm from unauthorized use or disclosure of your Personal Data, the purposes for which we process your Personal Data (kindly refer to mentioned above) and whether we can achieve those purposes through other means, and the applicable legal and regulatory requirements. We store your Personal Data for up to 18 months after you have submitted an application through the Service.
8.2. To provide more information, when we choose the ideal candidate, before making the offer we will be doing the background check. After the background check is successful, we will continue with the offer. If you were selected for the position you applied for, but either you have not provided us with the criminal record check or the performed criminal record check showed that you have criminal records, then we will not be able to make you a job offer.
8.3. In order to comply with our legal obligations and for the due diligence process, to be able to ensure and demonstrate that our employees have not been convicted of any crimes, and are trustworthy and responsible, we will store your Personal Data related to the criminal record checks during the period of your employment if you were successfully selected and recruited for departments that can make decisions that affect carrying out gambling.
8.4. Your Personal Data related to criminal record checks will be deleted immediately following the completion of the selection process in case:
8.4.1. you were selected for the position you applied for, and the performed criminal record check showed that you have criminal records;
8.4.2. you were selected for the position you applied for, provided us with the criminal record check showing no criminal records, offered a job you applied for, but you have not accepted our job offer.
8.5. In case you were employed for the positions listed in clause 8.3. of this Privacy Policy, your Personal Data related to criminal record checks will be stored during the entire period of your employment and will be deleted immediately by us following the date of termination of employment.
8.6. We might keep your Personal Data for a longer period of time with your explicit consent, for example, for the purpose of future recruitment processes to consider you for future job roles which may come available at a later stage.
9. Your legal rights and what we may need from you
9.1. You have certain rights in relation to the use of your personal data. They are;
9.1.1. The right to request access to your Personal Data that is processed by us.
9.1.2. The right to request correction of inaccurate or incomplete Personal Data concerning you. Although we may need to verify the accuracy of the new data you provide to us.
9.1.3. The right to request the erasure of your Personal Data enables you to ask us to delete or remove your Personal Data where there is no good reason for us continuing to process it.
9.1.4. You also have the right to ask us to delete or remove your Personal Data where you have successfully exercised your right to object to processing, where we may have processed your Personal Data unlawfully, or where we are required to erase your Personal Data to comply with applicable law. Note, however, that we may not always be able to comply with your request of erasure for specific legal or regulatory reasons which will be notified to you, if applicable, at the time of your request.
9.1.5. The right to withdraw your consent to the processing at any time where we are relying on consent to process your Personal Data. This will not affect the lawfulness of any processing carried out before your withdrawal of consent. But keep in mind that if you withdraw consent you may not be able to apply for a specific job or otherwise use the Service.
9.1.6. Under certain circumstances, a right to data portability, which means a right to get your Personal Data and transfer it to another controller as long as this does not negatively affect the rights and freedoms of others.
9.1.7. The right to lodge a complaint to the supervisory authority regarding the processing of your Personal Data, if you consider that such processing of Personal Data infringes the legal framework of privacy and data protection laws.
10. Security
10.1. We prioritize personal integrity and therefore work actively so that your Personal Data are processed with utmost care. We take the measures that can be reasonably expected to make sure that your Personal Data are processed safely and in accordance with this Privacy Policy and the GDPR.
10.2. We are committed to safeguarding the Personal Data you provide to us. We take appropriate levels of security to protect your Personal Data from accidental or unlawful access, use, disclosure, alteration, loss, or destruction. We also take steps to ensure ongoing confidentiality, integrity, availability and resilience of our networks and systems.
10.3. However, transfers of data 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 you also take responsibility to ensure that your Personal Data are protected and kept in secret. Although we will do our best to protect your Personal Data, we cannot guarantee the security of any Personal Data that you disclose online. You accept the inherent security implications of using the internet and will not hold us responsible for any breach of security unless we have failed in our obligations under data protection legislation. For your own privacy protection, we encourage you not to include sensitive Personal Data (such as credit/debit card numbers) in any emails you may send to us.
11. Who may we share your Personal Data with?
11.1. We do not trade, share, transfer, or disclose any of your Personal Data, except as is otherwise provided in this Privacy Policy or as otherwise required by and in accordance with applicable law.
11.2. We may share your Personal Data for the purposes set out earlier with the following parties:
11.2.1. Staff of our Human Resource department involved with respect to a particular job role you have applied for;
11.2.2. our parent or subsidiary companies;
11.2.3. any potential acquirer, successor, or assignee as part of any proposed merger, acquisition, sale of assets, or similar transaction in which information is required to be transferred to one or more third parties as part of such transaction.
11.2.4. our contractors and sub-contractors, acting as our Processors and Sub-Processors in accordance with our instructions, for the provision of the Service;
11.2.5. authorities or legal advisors in case criminal or improper behavior is suspected, or in case of any dispute or claim; and
11.2.6. authorities, legal advisors or other actors, if required by us according to law or authority’s injunction.
11.3. We will only transfer your Personal Data to third parties that we have confidence in. We carefully choose partners to ensure that your Personal Data is processed in accordance with current privacy legislation. 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 supplying the Service.
12. Aggregated data (non-identifiable personal data)
12.1. Aggregated data may be derived from your Personal Data but is not considered as Personal Data as this data does not directly or indirectly reveal your identity. 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. We may collect, use and share aggregated data for any purpose (such as statistical or demographic).
13. Transfers of your Personal Data
13.1. Since we operate globally, it may be necessary to transfer your Personal Data to countries outside the European Economic Area (EEA). We shall only transfer your Personal Data outside the EEA in the event that the respective countries to which such data are to be transferred provide an adequate level of protection for your Personal Data. Determining whether an adequate level of protection of your Personal Data is provided is based on the existence of one of the following:
13.1.1. The European Commission has determined that the respective third country, territory or a specified sector within that third country ensures an adequate level of protection for data transfers.
13.1.2. The service provider or partner to whom your Personal Data is to be transferred provides appropriate safeguards, data subject rights and adequate legal remedies for data subjects are available. Such appropriate safeguards can be provided in various ways including the use of standard contractual clauses approved by the European Commission. For more information kindly click here.
13.1.3. We require all third parties to respect the security of your Personal Data and to treat it in accordance with the law. We do not allow our third-party service providers to use your Personal Data for their own purposes and only permit them to process your Personal Data for specified purposes and in accordance with our instructions.
14. Cookies
14.1. When you 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 your device, such as a computer, mobile phone, or tablet, when you are using the Service. We use cookies to secure, maintain and improve the Service and yours’ usage experience, and to gather information regarding the usage of 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.
14.2. You can at any time disable the use of cookies by changing the local settings in your devices. Disabling cookies can affect your experience of the Service, for example disabling some functions in the Service.
15. Do we change the current Privacy Policy?
15.1. We have the right to, at any time, make changes or additions to the Privacy Policy for recruitment using Teamtailor. The latest version of the Privacy Policy will always be available through the Service. You will be considered as notified of the changes when you have either received an email informing you about the new version (using the e-mail you have provided in the course of the Service) or when you are otherwise informed of the new version of Privacy Policy.
16. How can you contact us?
16.1. If you have a concern or any questions about our handling of your Personal Data, please contact our appointed Data Protection Officer (DPO) to try to resolve your query using the email privacy@coolbet.com.
Version 2.0
August 2023