PRIVACY STATEMENT

GLOBE TECHNICAL SERVICES LTD – PRIVACY STATEMENT

Effective Date: [24 September 2019]

  1. ABOUT GLOBETECH
  2. THE PURPOSE OF THIS PRIVACY STATEMENT
  3. WHO THIS PRIVACY STATEMENT APPLIES TO
  4. CATEGORIES OF PERSONAL DATA
  5. OUR LEGAL BASIS
  6. OUR PROCESSING ACTIVITIES
  7. SOURCES OF PERSONAL DATA
  8. DISCLOSURE OF PERSONAL DATA
  9. SECURITY MEASURES
  10. TRANSFERS OUTSIDE THE EEA
  11. COOKIES
  12. THIRD PARTY WEBSITES
  13. RETENTION
  14. YOUR RIGHTS UNDER THE GDPR
  15. AMENDMENTS TO THIS PRIVACY STATEMENT
  16. OUR CONTACT INFORMATION
  17. SUPERVISORY AUTHORITY

1. ABOUT GLOBETECH

Terms used to refer to the Company include “we”, “us” and “our” and “GlobeTech ”

Company: Globe Technical Services Ltd.
Address: 1st Floor, Unit I, Building 6900, Cork Airport Business Park, Cork, T12 CFR6, Ireland.
Website: www.globetech.eu
Email: info@globetech.eu
Phone: +353 (0) 21 483 9380

GlobeTech is a global IT managed service solutions provider and software development company. We have offices in Ireland, Central Europe, the USA, and Asia and in excess of 400 staff.

Our multinational managed service teams work across Localisation QA, Translation, Natural Language Processing, Linguistical Data Analysis & IOT Data Analysis.

Our software development service teams have developed solutions for a range of clients, from local city & county councils, and the Irish police force, to top international events such as the London Olympic Games and the Superbowl. GlobeTech has also developed transport on-demand solutions for the non-emergency medical vehicles sector in the US.

In order to provide our services, we need to process Personal Data. We are committed to protecting the rights and privacy of individuals in accordance with data protection legislation including the General Data Protection Regulation in Europe (the “GDPR”).

This Privacy Statement applies to all of the following companies in the group: “GlobeTech”, “GlobeConnex SARL”, “GlobeConnex UK Limited”, “GlobeConnex” and “GlobeConenx s.l”.

2. THE PURPOSE OF THIS PRIVACY STATEMENT

This Privacy Statement describes our approach to data privacy and sets out the basis on which any Personal Data we collect from you, or that you provide to us, will be used by us where we are controllers of that personal data for the purposes of the GDPR. Please read this Privacy Statement carefully to understand our views and practices regarding the Personal Data we collect and how we will treat it.

Your privacy is important to us and we are committed to protecting and safeguarding your rights.

3. WHO THIS PRIVACY STATEMENT APPLIES TO

This Privacy Statement provides specific information relating to the following individuals whose Personal Data we process:
(i) prospective employees/those applying for jobs at the Company “Candidates”;
(ii) business contacts details including those of our customers, suppliers, partners, shareholders and business prospects “Business Contacts”; and
(iii) users/visitors of our Website “Website Users”.

Personal Data of employees of the Company is dealt with in a separate internal privacy notice.

4. CATEGORIES OF PERSONAL DATA

We process the following categories of Personal Data:

Identification Data
This includes name, date of birth, driver’s license and passport information

Contact Data
This includes email address, phone number, postal address, other communication access details (e.g. Skype)..

Correspondence Data
If you interact with us, we will record details of those interactions. For example, we will process details of phone calls, email correspondence and hard copy correspondence.

Marketing Data
This includes your preferences in receiving marketing from us and your communication preferences.

Recruitment Data
If we interact with you for the purposes of any job with the Company, we will collect recruitment related data such as identity data, CV data, and job application data as part of the recruitment process.

When processing CV data, we may process certain Personal Data including the following: date of birth, employment history, skills/ experience, languages, educational history, qualifications, membership of professional associations, contact details of employer references/character references, licenses held, interests and hobbies, languages, locations, nationality, passport, eligibility to work in certain jurisdictions, salary expectations.

As part of processing Recruitment Data, we process interview/screening answers and notes and usernames and passwords for access to our recruitment portal.

Recruitment and Special Category Data
If we interact with you for the purposes of a job with the Company, we may collect Recruitment Data that is of a special category per the GDPR definition: this can include diversity data such as gender, religion, racial or ethnic origin, sexual orientation, trade union membership or data relating to health. We will only source this data with the explicit consent of Candidates.

Web Data
When you interact with us online we will automatically collect data about your use of our services, including data on the type of device you’re using, its IP address, operating system, referral source, length of visit, page views and website navigation paths, as well as information about the timing, frequency and pattern of your service use. This information is collected at an aggregate level and your identity data is not stored as part of this technical data.

Financial Data
Financial Data includes payment related information or bank account details and financial data received as part of the services that we provide.

5. OUR LEGAL BASIS FOR PROCESSING PERSONAL DATA

We process all Personal Data lawfully and in accordance with the requirements of the law. The GDPR sets out the grounds where processing of Personal Data can be undertaken.

We set out here the legal basis we use to process Personal Data:

Contract
We will process Personal Data where necessary to perform our obligations relating to or in accordance with any contract that we may have with you or to take steps at your request prior to entering into that contract (e.g. our client services agreement);

Consent
If you consent to the processing of your Personal Data, then we may process your Personal Data on this ground. For example, a Candidate may give us their consent to process their Personal Data when they apply to a position advertised on our website.

Where we are unable to collect consent for a particular processing activity, we will only process the Personal Data if we have another lawful basis for doing so.

Legitimate Interest
At times we will need to process your Personal Data to pursue our legitimate business interests, for example for administrative purposes, to collect debts owing to us, to provide information to you, to operate, evaluate, maintain, develop and improve our websites and services or to maintain their security and protect intellectual property rights.

We will not process your Personal Data on a legitimate interest basis where the impact of the processing on your interests or fundamental rights and freedoms outweigh our legitimate interests.

You may object to any processing we undertake on this basis. If you do not want us to process your Personal Data on the basis of our legitimate interests, contact us at info@globetech.eu and we will review our processing activities.

Legal Obligation
If we have a legal obligation to process personal data, such as the payment of taxes, we will process personal data on this legal ground.

6. OUR PROCESSING ACTIVITIES

We use your Personal Data to provide you with our services and to assist us in the operation of our company. Under data protection law, we must ensure that the purpose of processing is clear.

We have set out below the general purpose of processing, the categories of Personal Data processed and the related lawful basis for processing.

7. SOURCES OF PERSONAL DATA

CANDIDATE PERSONAL DATA

We will only ever source data that is necessary to provide services to you and in a way that would be generally expected.

We receive Personal Data relating to Candidates from a variety of sources. The primary source is from Candidates directly. Through our Career page contact forms, you have an opportunity to send us your Personal Data relating to job application or prospective vacancies. In submitting your Personal Data through contact forms on our website, we collect information that identifies you as an individual. This information includes Recruitment Data as described above.

We collect Personal Data from you in the context of seeking a role within GlobeTech, or on a GlobeTech project with a third-party client. This involves receiving your Personal Data, highlighting your skills and competencies, contacting you, emailing you with projects that may be of interest to you and sharing your Personal Data with those GlobeTech clients in relation to a project placement, where appropriate. When you submit your Personal Data through the Contact Forms you are agreeing to GlobeTech sharing your data with third party clients for the purposes of securing a role within GlobeTech or working on a GlobeTech project with a third party. We collect Personal Data about you from the application forms and questionnaires you may be asked to complete; we also gather Personal Data from records of our correspondence, phone calls and emails.

Examples of the sources of Personal Data of Candidates are as follows:

A third party may provide your Personal Data to us, when we:

BUSINESS CONTACT PERSONAL DATA

We collect Business Contact Personal Data from our business contacts including – customers, suppliers, partners, shareholders and business prospects.

We source Business Contact Personal Data in order to serve the business relationship. We will only ever source Personal Data that is necessary and in a way that would be generally expected.

We receive Personal Data about Business Contacts from a variety of sources, as follows:

WEB USERS PERSONAL DATA

We collect Website User information from all visitors to our web site www.globetech.eu in order to improve our services and develop the Website.

We receive Personal Data about Website Users who access our advertisements or our Website regardless of whether they interact or register with the Website.

For more details please refer to our Cookie Statement.

8. DISCLOSURE OF PERSONAL DATA

We will need to share your information in certain circumstances. We will always ensure that we comply with the law when we transfer your Personal Data. We will also ensure that any processor or sub-processor takes appropriate technical and organisational measures when processing Personal Data on our behalf.

In certain circumstances, we may disclose Personal Data to third parties as follows:

More specifically we may share:

When we engage another organisation to perform services for us, we may provide them with information including Personal Data, in connection with the performance of those functions. We do not allow third parties to use Personal Data except for the purpose of providing these services.

9. SECURITY MEASURES

We will take all steps reasonably necessary to ensure that all Personal Data is treated securely in accordance with this Privacy Statement and the relevant law, including the GDPR.

In particular, we have put in place appropriate technical and organisational procedures to safeguard and secure the information we process.
We monitor for and do everything we can to prevent security breaches of the Personal Data that we process.

Once we have received your information, we will use strict procedures and security features for the purpose of preventing unauthorised access and ensuring that only those who need to have access to your Personal Data can access it.

We also use secure connections to protect Personal Data during its transmission. Where you have been given (or where you have chosen) a password which enables you to access services, you are responsible for keeping this password confidential. Please do not share your password with anyone.

If you think that there has been any loss or unauthorised access to Personal Data of any individual, please let us know immediately.

10. TRANSFERS OUTSIDE THE EEA

We will only transfer Personal Data outside the EEA if necessary and with appropriate safeguards in place.

As a global organisation we use and share Personal Data both inside and outside the EEA. We ensure that any transfer of Personal Data outside the EEA is undertaken using legally compliant transfer mechanisms and in accordance with the GDPR.

When we transfer Personal Data outside of the EEA, we generally rely on the Standard Contractual Clauses under Article 46.2 of the GDPR adopted by the EU Commission or the Privacy Shield in the case of transfers to the USA. However, we may also rely on some of the other legally compliant transfer mechanisms.

11. COOKIES

Cookies are small text files placed on your computer or mobile device by websites that you visit, and they help us improve the products and services that we offer you. They are used in order to make websites work, or work more efficiently, as well as to provide information to the owners of the site. Cookies may allow a website to remember your activity over a period of time. Cookies are optional and you do not have to accept them.

Further information on the cookies we use on https://www.globetech.eu and the purpose behind their respective uses are set out in our Cookie Statement.

12. THIRD PARTY WEBSITES

Our Website may contain links to and from third party websites. If you follow a link to any of these websites, please note that these websites have their own privacy settings, and these are not endorsed by us. We do not accept any responsibility or liability for these third-party websites. Please undertake the appropriate due diligence before submitting any Personal Data to these websites.

13. RETENTION

We only keep your Personal Data as long as it is necessary for the purposes of processing it or to comply with legal or regulatory requirements.

In some circumstances it is not possible for us to specify in advance the period for which we will retain your Personal Data. In such cases we will determine the appropriate retention period based on balancing your rights against our legitimate business interests. We may also retain certain Personal Data beyond the periods specified herein in some circumstances such as where required for the purposes of legal claims.

Our retention policy is as follows:

In certain cases, we may retain Personal Data for longer than specified here if required under relevant laws.

14. RIGHTS UNDER THE GDPR

You have various rights relating to how your Personal Data is used.

You can ask for access to the information we hold on you

You have the right to ask for all the information we have about you. When we receive a request from you in writing, we must give you access to everything we’ve recorded about you as well as details of the processing, the categories of Personal Data concerned and the recipients of the Personal Data.

We will provide the first copy of your Personal Data free of charge, but we may charge you a reasonable fee for any additional copies.

We cannot give you access to a copy of your Personal Data in some limited cases including where this might adversely affect the rights and freedoms of others.

You can ask to change information you think is inaccurate

You should let us know if you disagree with something included in your Personal Data.

We may not always be able to change or remove that information, but we’ll correct factual inaccuracies and may include your comments in the record to show that you disagree with it.

You can ask to delete information (right to be forgotten)
In some circumstances you can ask for your Personal Data to be deleted, for example, where:

Where your Personal Data has been shared with others, we will do what we can to make sure those using your Personal Data comply with your request for erasure.

Please note that we can’t delete your information where:

You can ask us to limit what we use your Personal Data for
You have the right to ask us to restrict what we use your Personal Data for where:

When Personal Data is restricted it can’t be used other than to securely store the Personal Data and with your consent to handle legal claims and protect others, or where it’s for important public interests.

You can ask to have your Personal Data moved to another provider (data portability)
You have the right to ask for your Personal Data to be given back to you or another service provider of your choice in a commonly used format. This is called data portability.

This right only applies if we’re using your Personal Data with consent and if decisions were made by a computer and not a human being. It does not apply where it would adversely affect the rights and freedoms of others.

You can make a complaint
You have the right to lodge a complaint with the local supervisory authority for data protection in the EU member state where you usually reside, where you work or where you think an infringement of data protection law took place.

15. AMENDMENTS TO THIS PRIVACY STATEMENT

We will post any changes on the Website and when doing so will change the effective date at the top of this Privacy Statement. Please make sure to check the date when you use our services to see if there have been any changes since you last used those services. If you are not happy with any changes that we have made you should cease using our services.

In some cases, we may provide you with additional notice of changes to this Privacy Statement, such as via email. We will always provide you with any notice in advance of the changes taking effect where we consider the changes to be material.

16. OUR CONTACT INFORMATION

Please contact us if you have any questions about this Privacy Statement or Personal Data we hold about you:
Email: info@globetech.eu
Address: The Compliance Officer, Globe Technical Services Ltd.,
1st Floor, Unit I, Building 6900, Cork Airport Business Park, Cork, T12 CFR6, Ireland
Telephone: +353 (0) 21 483 9380

17. SUPERVISORY AUTHORITY

If you have any concerns or questions about the processing of your Personal Data, the Supervisory Authority in Ireland may be contacted as follows:

Email: info@dataprotection.ie
Address: Canal House, Station Road, Portarlington, R32 AP23, County Laois
Tel Lo-Call: 1890 252 231

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