CANDIDATE PRIVACY POLICY
Last updated 18 November 2022
In order for us to consider and process your job application, and to manage and facilitate our hiring procedures (the "Recruitment"), we need to process your personal data. We care about protecting your personal integrity, which is why we strive to be as transparent as possible in this recruitment privacy policy (the "Privacy Policy") about how and why we collect, use and retain your personal data. We also inform you about your rights and how you can exercise them.
Please do not submit any sensitive or personal data in excess of what is necessary to apply for a job or to connect with us. For example, please refrain from submitting any personal data relating to your ID number, racial or ethnic origin, sexual orientation, religious or philosophical beliefs, health, or trade union membership.
If you have been added as a reference in a candidate's job application, please refer specifically to the relevant column in Section 3 (Purpose of Processing and Legal Grounds), but please note that this entire Privacy Policy, in relevant parts, also applies to you.
We recommend that you visit this Privacy Policy from time to time to check for any updates. If we make any amendment to this Privacy Policy, we will add a "Last updated" date above.
1. Who is responsible for my personal data?
Ringtail Interactive AB, with registration number 556989-5906, and with registered address at Box 334, 184 24 Åkersberga, Sweden ("Ringtail", "we", "us" or "our") is the data controller for the processing activities described in this Privacy Policy.
We understand that some legal data protection terms can be tricky to understand. For example, when we refer to "personal data", we mean any information that directly or indirectly relates to you (or another identifiable person); this could be a name, a telephone number, an email address etc. Another example is the term "processing", which we use to make reference to what we (or others) may do with your personal data; such as the collection, use, structuring, storing, erasure etc. of your personal data.
2. What personal data do we collect?
We will collect personal data about you in connection with the Recruitment. We will collect personal data either from you, a third party, or through public sources (such as LinkedIn), typically in one of the following scenarios:
- If you apply for a job or connect with us via our Website (as defined below), we will collect personal data directly from you ("Self-application").
- If we receive your job application from an external recruiting agency or individual recruiter, we will collect your personal data from such recruiter ("Sourced Application").
- If a current employee of Ringtail adds you as a candidate in the Recruitment, we will collect your personal data from such employee ("Referred Application").
- If you have been added as a reference by a candidate in the Recruitment, we will collect your personal data from such candidate.
We collect most of the personal data via our recruitment site available at https://jobs.ringtailinteractive.com/ (the "Website"). We will certainly inform you if someone other than yourself has submitted your personal data to us. You can read about the different categories of personal data that we collect from you in the table below. We have listed some examples of personal data in each category for your convenience.
Categories of personal data and examples of personal data
Name and contact information: Name, telephone number, email address, and company name (as applicable).
Employment authorization: Work permit status in Sweden, EU-citizenship and any documents proving the right to work in Sweden (if necessary).
LinkedIn or Facebook profile data: Name, email address and profile picture (if included in the Recruitment).
Information in CV and cover letter: IEducation, work experience, title, and other skills, and any other information that you choose to include.
Application data: Any other information included in your candidate profile or a pitch, either in a free text field format or by attachment of additional documents (such as salary expectations, relevant certificates, testimonials, test results).
Evaluation data: Data related to our evaluation of our candidates, such as interview notes.
Communication: Correspondence between us and you related to the Recruitment.
3. Purpose of Processing and Legal Grounds
We will process your personal data for different purposes, on different legal grounds, and for different storage periods, depending on the processing activity we undertake, in accordance with the General Data Protection Regulation (EU) 2016/679 (the "GDPR"). Please read the below table to understand why we process your personal data. We may process your personal data for additional purposes, such as to comply with a public authority's legal request, which we have describe further below in Section 5 (Who do we share your personal data with?).
Purpose / Category of personal data / Legal ground
3.1
Purpose: To receive, log and send confirmation of receipt of your Self-application.
Categories of personal data:
- Name and contact information
- Employment authorization
- LinkedIn or Facebook profile data
- Information in CV and cover letter
- Application data
Legal ground: Necessary pre-contractual steps (Article 6.1(b) GDPR). The processing is necessary to take steps on your request prior to entering into an employment contract.
3.2
Purpose: To connect with you if you use the "Connect" function on our Website. The purpose of connecting is to (a) better match you with a role, (b) allow you to add references, (c) pitch yourself with your own words, (d) subscribe to jobs; and (e) allow you to easily exercise your data privacy rights.
Categories of personal data:
- Name and contact information
- LinkedIn or Facebook profile data
- Information in CV and cover letter
- Application data
Legal ground: Our legitimate interest (Article 6.1(f) GDPR). The processing is necessary to fulfil our legitimate business interest in finding suitable candidates for Ringtail, which we have determined overweighs your interest not to have your personal data processed for this purpose.
3.3
Purpose: To receive, log and send information about our collection and processing of a Sourced Application or Referred Application. Please note that our employees or a recruiter may include a link to your LinkedIn, provide certain Application Data, and/or your CV/cover letter.
Categories of personal data:
- Name and contact information
- LinkedIn profile data
- Information in CV and cover letter
- Application data
Legal ground: Our legitimate interest (Article 6.1(f) GDPR). The processing is necessary to fulfil our legitimate business interest in finding suitable candidates for Ringtail, which we have determined overweighs your interest not to have your personal data processed for this purpose.
3.4
Purpose: To schedule and conduct interviews with you, to evaluate you during the Recruitment, and to manage the Recruitment in all other aspects, such as communicating with you.
Categories of personal data:
- Name and contact information
- LinkedIn or Facebook profile data
- Information in CV and cover letter
- Application data
- Evaluation data
- Communication
Legal ground: Our legitimate interest (Article 6.1(f) GDPR). The processing is necessary to fulfil our legitimate business interest in finding suitable candidates for Ringtail, which we have determined overweighs your interest not to have your personal data processed for this purpose.
3.5
Purpose: If you have been added as a reference by a candidate, we may reach out to you to obtain your recommendation. We may also contact you again for more detailed information to evaluate the candidate.
Categories of personal data:
- Name and contact information
- Information in CV and cover letter
Legal ground: Our legitimate interest (Article 6.1(f) GDPR). The processing is necessary to fulfil our legitimate business interest in finding suitable candidates for Ringtail, which we have determined overweighs your interest not to have your personal data processed for this purpose.
3.6
Purpose: To make sure you have the right to work in Sweden, and, if required, initiate your work permit application.
Categories of personal data:
- Name and contact information
- Employment authorization
- Information in CV and cover letter
Legal ground: Compliance with legal obligation (Article 6.1(c) GDPR). The processing is necessary to comply with our legal obligation to ensure that you have authorization to work in Sweden.
3.7
Purpose: To contact you about future job opportunities.
Categories of personal data:
- Name and contact information
- Employment authorization
- LinkedIn or Facebook profile data
- Information in CV and cover letter
- Application data
Legal ground: Your explicit consent (Article 6.1(a) GDPR). The processing is necessary to contact you about future job opportunities that you have requested
4. How to withdraw consent
You have the right to withdraw your consent at any time if our processing of your personal data is solely based on your explicit consent (such as when you have subscribed for future job opportunities). Please note that if you withdraw your consent, this will not affect the legality of the processing that we have undertaken prior to you withdrawing your consent. If you have "connected" with us via our Website, you can easily manage your consent settings on your page under "job subscriptions" by turning off notifications and unchecking the consent box at the bottom. You can also contact us using the contact information below in Section 12 (How to contact us).
5. Who do we share your personal data with?
We care about your privacy, which is why we will only share your personal data with third parties that are capable of providing sufficient guarantees for the protection of your personal data. We will not share your personal data to the extent it is not necessary for a specific purpose. We have listed the categories of third parties with whom we may share your personal data below.
Public authorities
We may need to share your personal data with a public authority for the purpose of complying with applicable law. The legal ground is to comply with a legal obligation.
Mergers and acquisitions
We may need to share your personal data with potential investors and/or buyers (including their hired experts) for the purpose of raising capital or selling Ringtail (or all or parts of the Ringtail's assets), or if we are otherwise subject to a merger with another company. The legal ground is our legitimate interest to complete such transactions, which we have determined overweighs your interest not to have your personal data processed for this particular purpose.
Suppliers, contractors and subcontractors
In order to manage the Recruitment, we will share your personal data with certain carefully selected suppliers and contractors. Such suppliers and contractors could be consultants or providers of legal, technical, HR and IT support/functionalities, analytical service companies, storage and IT infrastructure providers (such as cloud storage and online recruitment tool providers), and other similar companies relevant for the Recruitment. They will only process your personal data based on our instructions to them, and we will always ensure that the necessary agreements (for example a so called data processing agreement) are in place to protect your personal data at all times.
For all processing activities where the legal ground is not your consent, the legal ground for sharing your personal data with suppliers and contractors is our legitimate interest in conducting our business by accessing these services and functionalities, which we have determined overweighs your interest not to have your personal data processed for this purpose.
For processing activities where the legal ground is your explicit consent to receive communication about future job opportunities, the legal ground for sharing your personal data is your explicit consent. We will share your personal data with Teamtailor AB.
6. Where do we process your personal data?
Some of the suppliers and contractors we work with may be established in a country outside of the European Union (EU) and the European Economic Area (EEA) and, if that is the case, we will always ensure that a proper transfer mechanism is relied on so that your personal data is safeguarded at all times, as if they were processed within the EU/EEA, which could include one of the following measures:
- We will transfer your personal data only to countries that, according to the European Commission, provide an adequate level of protection. This means that those countries offer a similar level of protection as provided under the data protection legislation in the EU.
- We will enter into standard contractual clauses adopted by the European Commission with the recipient of your personal data. This means that the recipient is required to comply with the same level of protection as provided under the data protection legislation in the EU.
In addition to one of the above measures, we will always seek to take any additional security measures that we deem appropriate and necessary to safeguard your personal data.
7. Cookies
We use cookies and other similar technologies on our website. Cookies are small passive text files that are placed and stored on your web browser or device when you visit our Website. We use cookies to improve your usage of our Website and to gather information about, for example, statistics about the use of our Website in connection with the Recruitment. This is done to secure, maintain and improve the Recruitment. For more information about the cookies that we use, please read our Cookie Policy.
8. For how long do we store your personal data?
We will keep your personal data for as long as it is necessary in order for us to fulfil the purpose for which we collected your personal data. We generally retain your personal data for 24 months from the date we make a decision in the Recruitment. We may, however, retain certain personal data for a longer period if we are required to do so pursuant to applicable law or a binding decision by a public authority or court of law, or to defend Ringtail against legal claims. If that is the case, we will retain it for the period required under law, such decision or in relation to such legal claim. We may also retain your personal data for a longer period if you enter into an employment agreement with us, in which case we will provide you with additional information about how we will process your personal data. If you have been added to the Recruitment as a reference, we will not store your personal data if you choose not to participate.
9. How do we protect your personal data?
We take the protection of your personal data seriously. We have reasonable and appropriate technical and organisational measures in place in our business to ensure that your personal data is safeguarded and protected against loss, destruction, misuse, and unauthorised access and disclosure.
Our employees work under strict confidentiality and follow clear instructions on how to manage your personal data in accordance with applicable data protection laws and our own policies. We only grant employees access to your personal data when it is necessary in order for them to perform their duties or to fulfil the purposes laid down in this Privacy Policy.
Because transfers of information over the internet and mobile networks can never completely be exclusive of risk, you transfer any personal data to us on your own risk. However, please note that we actively evaluate the security measures we have in place to ensure that they are robust and up to date. It is also important that you keep your login information secret and not share it with anyone.
10. Your rights and how you can exercise them
You have rights with regard to your personal data. Please read the following sections to understand them, as well as how you can exercise them. You can also read more about your rights on the Swedish Authority for Privacy Protection's website. Please note that your rights are not unconditional; therefore, an attempt to invoke any of the rights might not result in an action.
Right to information: You have the right to be informed about how we process your personal data. We respect this right by being transparent with you in this Privacy Policy.
Right of access: You have the right to obtain a confirmation from us as to whether or not we process your personal data. If we do process your personal data, you also have the right to obtain access to the personal data by requesting a copy showing which data we have about you, and how we use it. Please note that we may ask for additional information in order to identify you to ensure that personal data is disclosed to the correct individual.
Right to rectification: You have the right to, request that we correct inaccurate information about you, as well as to complete any incomplete information.
Right of erasure: You sometimes have the right to request the erasure of personal data that concerns you. We are required to erase the personal data in question, for example if the personal data is no longer necessary in relation to the purposes for which the personal data was initially collected. Please note that we are not obliged to delete your personal data if it is necessary to retain it to comply with legal obligations, or for the establishment, exercise or defence of legal claims.
Right to restriction of processing: You have the right to request that we restrict our processing of your personal if you for example believe that the information we have about you are inaccurate, our processing is unlawful, or we no longer need the information for the purposes they were collected.
Right to object: You have the right to object to our processing of your personal data if our processing is based on a legitimate interest.
Right to data portability: You have the right to request a copy of the personal data in a machine-readable format that concerns you and which we process to perform a contract or based on your consent. You can then have such personal data transmitted to a different data controller.
Right to withdraw your consent: You have the right to withdraw your consent. Please refer to Section 4 (How to withdraw consent) for more information.
Right to lodge a complaint: If you have any complaints about the way in which we process your personal data, you are always welcome to reach out to us. You also have the right to lodge a complaint to a supervisory authority (such as the Swedish Authority for Privacy Protection) here.
11. Amendments to this Privacy Policy
We reserve the right to introduce updates and make amendments to this Privacy Policy from time to time. This is necessary to ensure that we always provide you with correct and up to date information about how we process your personal data. We may, for example, be required to make changes to the way in which we process your personal data pursuant to applicable law or a decision issued by a public authority or court of law. The latest version of this Privacy Policy will always be available on our Website.
12. How to contact us
If you have any questions about the way in which we process your personal data, or about this Privacy Policy, please contact us using the following contact information:
privacy@ringtailinteractive.com
Ringtail Interactive AB
Box 334, 184 24 Åkersberga
Sweden
