This information notice is a global notice which describes broadly how we, EASTAR and our affiliated companies within the EASTAR Group (the "Company") collect information relating to Candidates through our online recruitment system on a website on our domain, the exact website link of which may change from time to time (the "Site") and through other means, as well as how we Process (as that term is defined below) and potentially use such information. The Company acknowledges that the laws of certain jurisdictions may restrict, limit, or prevent, either in whole or in part, the Company from collecting, Processing, or using such information in the manner described below. Accordingly, in the event that any portion of this policy conflicts with applicable federal, state, local, or other law(s), such law(s) shall supersede and govern. Similarly, the Company will not collect, Process, or use any such information in a manner that violates any applicable federal, state, local, or other law(s). By way of example only, while the below notice states that the term "Personal Data" may include "salary information", the Company will not collect, Process, request, or inquire about a job applicant’s salary information or history where applicable federal, state, local, or other law(s) bars the Company from doing so. In addition, any information that we collect via the Site and through other means, or Process or use, shall be in compliance with local laws.
The purpose of this information notice is to make you aware of how the Company will Process Personal Data that we obtain about Candidates through the Site and other means. Please refer to Annex 1 for details of the data controller of the Personal Data if you are based within the European Economic Area.
"Candidate" means any individual who makes an application (directly or indirectly via a representative) to join the Company through the Site.
"Processing" includes the collection, storage, retrieval, alteration, disclosure or destruction of personal data.
"Personal data" means information in any format relating to an identified or identifiable individual, which can include (but is not limited to) personal identifiers (for example: name, address, photographs, email address, credit card number, employment details, salary information, etc.).
This notice may be amended from time to time and does not form part of a Candidate’s contract of employment, if successful with their application to join the Company.
1. Why the Company Processes Personal Data
The Company Processes the Personal Data of Candidates, as necessary to evaluate an Candidate’s application for employment and for our legitimate business interests relating to processing and considering a Candidate’s application to join the Company.
The Company may also Process personal data, including Special Categories of personal data as described below, where necessary to do so for compliance with any legislative duty, as required in relation to legal proceedings or law enforcement or government investigations or where proportionate to a Candidate’s job function, e.g. the results of background risk screening and the results of credit reference checks for Candidates applying for risk-exposed financial roles (see Notice of Background Check and Authorisation/Acknowledgement for further information).
2. The Personal Data Collected by the Company
The categories of Personal Data collected by the Company through the Site and via other means include but are not limited to the following:
Contact information (including name, address, work-related and home email addresses, telephone number)
Personal details (including gender and date of birth)
Employment and education information (including previous employment history and positions held, qualifications, attendance at educational establishments and training received).
The Company may also collect further categories of Personal Data that a Candidate provides in any cover letters or work samples, uploaded on the Site.
3. The Special Categories of Personal Data Collected by the Company
Not all countries' laws treat this type of data in the same way, but typically "Special Categories" of personal data include, for example, data relating to racial or ethnic origin, political opinions, religious or philosophical beliefs, trade-union membership, biometric data, health, sex life, sexual orientation or data relating to offences, criminal convictions or security measures, or any other data identified as such under applicable local laws.
The Company only collects Special Categories of personal data when permitted by law and only after establishing appropriate safeguards. Processing of the following Special Categories will only be carried out by the Company where permitted by law and in the following circumstances:
Criminal convictions - only where information relating to a Candidate's past criminal convictions would be directly relevant to determining his or her fitness and suitability for a particular position, where relevant to potential or on-going litigation or legal proceedings that could impact the Candidate's future employment relationship with the Company or where necessary to satisfy the Company's obligations arising under health and safety or other applicable laws. Where the Company intends to obtain information relating to a Candidate's commission of past criminal offences, the Candidate shall be notified beforehand;
Trade union membership - within the limits provided for by law or by any collective bargaining agreement;
Racial or ethnic origin and religious or philosophical beliefs - in accordance with local laws, such as anti-discrimination laws, where required for tax purposes or for equal opportunities monitoring purposes; and/or
Health information - to comply with occupational health and safety laws and or regulations or when necessary to manage and administer leave or absences, or to make or consider making reasonable adjustments.
Specific legal requirements may apply. These vary by jurisdiction. In some jurisdictions, explicit consent may be required and will be sought from you, as appropriate.
4. How the Company Protects Personal Data
The Company will take all steps reasonably necessary to ensure that there are appropriate security measures in place to safeguard Personal Data. In determining the appropriate security the Company takes into account technological developments and assesses the measures in place against the risk of harm that may result from a security breach. The security measures implemented by the Company are appropriate to protect against the risks presented by the Processing and are put in place to prevent unauthorised or unlawful disclosure as well as to protect against accidental loss, destruction or damage to Personal Data.
The Company uses a range of IT security tools on its network in order to protect the information held, including monitoring the sending of data and documents to recipients outside the network, in order to detect unauthorised sharing or transmission of Personal Data or Company confidential material. Alerts are generated automatically based on system triggers. The Company takes reasonable measures to preserve the confidentiality in Candidate communications.
5. With Whom the Company Shares Personal Data
The Personal Data obtained through the Site and via other means may be shared across the Company, where necessary for legitimate business purposes relating to the recruitment of the Candidate or to comply with applicable legal requirements.
The Company may also share Personal Data with third party service providers (e.g. translation services and background check providers) that it has retained to perform services on its behalf or for legal/regulatory purposes. Where Personal Data are disclosed to third parties, appropriate safeguards shall be implemented to ensure that the data will be Processed legitimately and protected appropriately.
The Company reserves the right to transfer any Personal Data in the event that the Company sells or transfers all or a portion of its business or assets, without offering you the opportunity to opt out of such transfer (except where required by local law). In the event of such a sale or transfer, the Company will use reasonable efforts to direct the transferee to use Personal Data in a manner that is consistent with this notice.
6. International Transfers of Personal Data
The Company may, from time to time and subject to the appropriate safeguards, need to transfer Personal Data to other EASTAR companies or to relevant third parties internationally, for the purposes of recruitment.
If you are located in the European Economic Area ("EEA") or Switzerland: the personal data that the Company Processes about Candidates may be transferred to, and stored at, a destination outside the EEA and Switzerland. It may also be Processed by Company staff operating outside the EEA and Switzerland, or at another EASTAR company, or data processor(s) engaged by the Company. Some of these destinations do not offer the same statutory protection for Personal Data as exists within the EEA and Switzerland. Such transfers will be for the same limited purposes, and under similar security conditions, as those applicable to the Processing of the Personal Data of Candidates in the applicable country. The transfers are made subject to appropriate Legal safeguards, such as use of the EU Commission approved Standard Contractual Clauses.
If you are located in Germany: We may transfer your personal data outside the EEA and Switzerland, pursuant to an International Data Transfer Agreement.
7. Marketing
If you have applied for a position with the Company, we may send you marketing communications if your application was unsuccessful, for example to inform you of recruitment events or to make you aware of any future employment opportunities that you may be interested in. You can opt out of receiving these marketing emails by following the instructions contained in any such message or by contacting us at any time.
8. Your Rights
If you wish to exercise your rights under applicable local laws with regards the processing of your Personal Data via the Site and other means, you must do so in writing and direct the request to your local HR contact. We may ask you for additional information to confirm your identity and for security purposes, before disclosing information requested to you.
If you are located in the European Economic Area ("EEA") :You may have the right to request access to your Personal Data, to have it rectified or erased, to object to its processing or to have access to it restricted. You may also have the right to receive a copy of your Personal Data in a machine-readable format, the right to not to be subject to any decision that significantly affects you being taken solely by automated processing, including profiling.
9. Retention of Personal Data
We retain Personal Data for the duration of the Candidate’s application period to join the Company. In the event that the Candidate does not join the Company, we will retain their Personal Data for as long as is necessary for the purposes of our legitimate business interests as listed above, and in accordance with applicable laws and with our retention policies and procedures, after which time such data will be deleted or put beyond use.
10. Questions about your Personal Data
If you have any questions about the Processing of Personal Data via this Site, please contact our HR by email at Felix@eastarboardgame.com. The processes described in this notice supplement any other remedies and dispute resolution processes which may be provided by the Company and/or which may be available under applicable local laws, including your right to lodge a complaint with a supervisory authority in your country.
