Privacy Policy

COMMSIGNIA RECRUITMENT PRIVACY POLICY


This Privacy Policy (hereinafter referred to as the „Policy”) was posted on and is effective as of 25 May 2018.

  1. DATA CONTROLLER AND DEFINITIONS
 
With the present Recruitment Privacy Policy (hereinafter: “Policy”), Commsignia Ltd. (hereinafter: “Company ” or “Commsignia ” or “We”) intends to ensure that it gathers, stores and handles data fairly, lawfully, transparently and with respect towards individual rights. This Policy applies to the recruitment procedure of Commsignia and its affiliates. This Policy gathers the Company’s guidelines and principles for collecting, storing, using, processing and disclosing partner’s personal data regarding your application procedure(s).
The processing and collection of personal data by the Company is in harmony with the directly applicable laws of the European Union and the provisions of the Hungarian laws in effect. In case of personal data processing, the Regulation (EU) 2016/679 of the European Parliament and of the Council (hereinafter: “GDPR ”; for relevant definitions please see Appendix No. 1) , the Act CXII of 2011 on the Right to Informational Self-determination and Freedom of Information (hereinafter: “Freedom of Information Act”), the Act XLVIII of 2008 on the Essential Conditions and Certain Limitations of Business Advertising Activity (hereinafter: “Business Advertising Act”), furthermore the recommendations and the data protection practice of the Hungarian National Authority for Data Protection and Freedom of Information (hereinafter: “NAIH “) and the recommendations of the Article 29 Data Protection Working Party (hereinafter: “WP29”) shall apply.
During the recruitment process we process your personal data provided by you during the application procedure, especially in your curriculum vitae and cover letter.  The Company will keep the received personal data confidential and takes all necessary steps to secure data processing. As Commsignia determines the purposes and means of the processing of any personal data collected or received from you, the Company is a data controller of any personal data described in this Policy. You are the data subject related to the personal data that the Company receives during the application procedure.  
Company name of the data controller: Commsignia Ltd.
Registered office: Széchenyi u. 14., 7252 Attala, Hungary
Court of registration: Court of Szekszard
Company registration number: 17-09-010377
Tax number: HU23874664
Email address:  info@commsignia.com
Website: www.commsignia.com
 
Site means https://www.commsignia.com and its subdomains.   User or “you” means a registered or not registered visitor of the Site.   User Activity means location and behavior data (language selection on the Site, products put in the User’s cart), onsite browsing history, and usage patterns (frequency/patterns of logging-in).

  1. SCOPE OF PROCESSED DATA, PURPOSE, LEGAL BASIS OF DATA PROCESSING, THE PERIOD FOR WHICH THE PERSONAL DATA IS STORED
   
  Categories of personal data concerned Purpose of data processing Legal basis of data processing Period for which the personal data is stored
a) Professional CV, letter of motivation. Assessing the proficiency, qualification, professional experience necessary to fulfill the position in question and evaluating the motivation of the applicant. The legitimate interest of the Data Controller in selecting the most suitable candidate in order to ensure its operation and your consent when sending your application. Period of conducting the selection procedure; an additional period of 12 months afterwards if the applicant consented to it, or until you withdraw your consent at jobs@commsignia.com, unless a longer retention period is required or permitted by law (such as tax, accounting or other legal requirements). When we have no longer or no legal basis to process your personal information, we will either delete or anonymize it.
b) Personal and contact data of the applicant provided in the course of application. Identification, keeping contact.
b) Data concerning proficiency, qualification and professional experience. Certifying the qualification necessary to fulfill the position in question
d) Data generated by the Data Controller about the applicant during the interviews concerning the evaluation of the candidates. Evaluation of the suitability of the applicant in the selection procedure.
e) Personal data generated during tests, Assessment Centre and other tasks testing skills necessary to fulfill the position before admission.   Determining suitability for the position.
  No automated individual decision-making or profiling is performed in the course of the data processing of the Data Controller concerning the applicants.  

  1. RECIPIENTS OF THE PERSONAL DATA
 
The visibility of Personal Data is restricted and will be accessible only by the relevant people at Commsignia who are taking​ care of your application. Except​ as expressly described below, we neither rent nor sell your information to other people or non-affiliated companies. We may share your information only when we have your permission.
The Company may request data process service for processing the personal data. During the service of data process, the data processor shall abide under the present Policy, relevant legislations in force, furthermore the provisions of the existing contracts of the Company.
In order to fulfil its purposes as a data controller COMMSIGNIA cooperates with the data processors listed below. COMMSIGNIA reserves the right to change the data processors at any time.
Name of the data processor Data processing activity carried out on behalf of COMMSIGNIA and list of the personal data the data processor has access to
Company name: Google LLC. Address: 1600 Amphitheatre Parkway, Mountain View, CA 94043 Website: www.google.com Contact: https://support.google.com/cloud/contact/dpo Google cloud service is used to store the processed personal data listed in 2.4.1.2.

Commsignia uses Google Drive to store all its data, including your personal data. Its system ​has been designed to handle and keep all data safe and with high security. Data can be accessed only by authorized persons. In addition, Commsignia stores paper based personal data in locked storages within its office space. Any unauthorized collection, processing, or use of such data by employees of Commsignia is prohibited.
Commsignia only transfers personal data collected from the EU territory to a third-party having a registered seat outside the EU or the United States of America acting as a data processor without appropriate safeguards when it is necessary for the performance of the contract. Commsignia will make every effort to ensure that the personal data transferred is safe and secure and that the personal data is processed in a manner consistent with the GDPR.
If the applicant does not directly apply for a position at the Data Controller (that is, for example through a recruitment agency or through a temporary employment agency or a student labor association) then the Data Controller may collect certain data from these sources as well, and will handle these data in line with this Policy.

 
  1. COOKIES

4.1. COMMSIGNIA hereby informs you that if you download certain parts of the Site, small data files (“Cookies”) will be automatically sent by the web server to your electronic device. In certain cases, these data files may be considered as personal data under the applicable data protection laws. These data files are necessary for the proper operation of the Site , and are used to collect information on the User’s visits to the Site.
4.2. The User can accept or refuse Cookies on a case-by-case basis, or refuse all Cookies by adjusting his/her browser settings. To find out how to do this and learn more on Cookies, please visit: https://www.youronlinechoices.eu/ . If the User chooses to refuse all Cookies, access to some of the Site pages features will be limited.
Type of Cookie Purpose of Cookies Legal basis of data processing Cookie retention period
Google Analytics The Site   uses the Google Analytics tool to collect and analyze information on how the User uses the Site . We use the information to compile reports and improve the Site . The data is collected in an anonymous form, including the number of Users to the Site, where Users have come to the Site   from, and the pages they visited within the Site  . The collected data cannot be tracked back to the User. For further information on Google’s privacy policy, click here  . User’s consent. Google Analytics Cookies are created as soon as the User visits a website on which a valid Google Analytics tracking code is installed. The Cookies will be held in the User’s browser for a maximum period of 2 years from the above date. For further information, please click here .
Google AdWords (Google Remarketing) Third-party service providers, including Google, store previous visits made by a User to the Site ,and use this information to display COMMSIGNIA’s advertisements to the User on the websites of Google’s partners. When the User visits the Site , we send one or more Cookies provided by Google Inc. (1600 Amphitheatre Parkway, Mountain View, CA 94043, USA) to your computer, which uniquely identify your browser. Google’s remarketing Cookies are used in Google AdWords. The Cookies provided by Google remember the number and times of visits to the Site   as well as the sub-pages viewed by the User when browsing the Site. The recorded data is stored anonymously. The User can block Google’s remarketing Cookies on the opt-out page of Google’s Ads Settings  , and can also block third-party Cookies on the Network Advertising Initiative  opt-out page. User’s consent. The AdWords Cookies expire 90 days after the User visited the Site . For further information, please click here.
Session ID Session Cookies allow the User to be recognized within the Site. The most common example of this functionality is the shopping cart feature of the Site. When the User visits a page of a catalogue and selects some items, the session Cookie remembers the selection, so the shopping cart will contain the selected items when the User is ready to check out. User’s consent. The information is saved until the end of the current session. After that, the collected information will no longer be available.
Auto login These Cookies remember the User’s login information and automatically fill out the login form for the User when the User starts the login process next time. User’s consent. The Cookies will be held in the User’s browser for a maximum period of 6 months.
  1. DATA SECURITY

COMMSIGNIA observes all applicable regulations regarding the security of personal data, therefore both COMMSIGNIA and its authorized data processors implement appropriate technical and organizational measures to protect personal data, and establish adequate procedural rules to enforce the provisions of the GDPR and all relevant local laws concerning confidentiality and the security of data processing.

  1. RIGHTS OF THE DATA SUBJECT


Right to be informed, Right of access and to rectification: You have the right to obtain confirmation whether or not we are processing personal data relating to you, have communicated to you such data so that you could verify its accuracy and the lawfulness of the processing and have the data corrected, amended or deleted where it is inaccurate or processed in violation of the GDPR.
Right of erasure: In certain circumstances, you may have a broader right to erasure of personal information that We hold about you – for example, if it is no longer necessary in relation to the purposes for which it was originally collected. Please note, however, that We may need to retain certain information to comply with our legal obligations.
Right to object to processing: You may have the right to request Commsignia to stop processing your personal data.
Right to restrict processing: You may have the right to request that we restrict processing of your personal information in certain circumstances (for example, where you believe that the personal information we hold about you is inaccurate or unlawfully held).
Right to Data Portability: In certain circumstances, you may have the right to be provided with your personal information in a structured, machine readable and commonly used format and to request that We transfer the personal information to another data controller without hindrance.

  1. RIGHTS AND ENFORCEMENT

7.1. Any personal information which you provide for COMMSIGNIA must be true, complete, and accurate in all respects. You agree to notify us of any change in your personal information via COMMSIGNIA’s email address specified in section 1 without delay.
7.2. The User may exercise the following rights in relation to COMMSIGNIA’s data processing activities: 7.3. You are entitled to request information on data related to you and processing carried out by COMMSIGNIA thereof, especially information as to what personal data relating to you is stored; the sources from which they were obtained; the purpose, grounds, and duration of processing; if your personal data is made available to others, the legal basis and the recipients; and any data protection incident in relation to your personal data by sending an email or mail to the email or postal address (registered office) specified in section 1. COMMSIGNIA shall provide written information on the processing of your personal data within 1 months after receipt of the request. You may also request the correction of your personal data.
7.4. You are also entitled to request a structured, commonly used and machine-readable formatted copy of your personal data that COMMSIGNIA is processing subject to conditions set out in Article 20 of the GDPR. You have the right to transmit your personal data to another controller or, where it is technically feasible, you can request COMMSIGNIA to transfer your personal data directly to another controller as specified in Article 20 of the GDPR.
7.5. If your personal data is inaccurate, you may request COMMSIGNIA to rectify such data, provided that the correct data is at COMMSIGNIA’s disposal.
7.6. Your personal data shall be deleted upon your request in accordance with applicable laws. Your request for data deletion may be submitted to COMMSIGNIA by using the email or postal address (registered office) specified in section 1. COMMSIGNIA shall delete all stored personal data in compliance with this Policy by obfuscating your personal data, by making it anonym in a permanent and non-reversible manner.
7.7. Please be informed that your data will not be deleted if the processing thereof is required by law or other exceptions apply under applicable law.
7.8. You have the right to obtain restriction of processing from COMMSIGNIA in the following cases: 7.8.1. you think that your processed personal data is not accurate, for a period enabling COMMSIGNIA to verify the accuracy of your personal data;
7.8.2. the processing is unlawful and you oppose the erasure of your personal data, you are entitled to request restriction of their use instead;
7.8.3. COMMSIGNIA no longer needs your personal data for the purposes of processing, but you require COMMSIGNIA to continue the processing for the establishment, exercise or defense of your legal claims;
7.8.4. you have objected to processing, for a period pending the verification whether the legitimate grounds of COMMSIGNIA override those of yours.
7.9. At any time, you have the right to object to processing your personal data subject to certain conditions under applicable laws, you may separately object against processing your personal data for direct marketing purposes, including Profiling, as set out herein. In this case, COMMSIGNIA will no longer process your personal data unless if COMMSIGNIA demonstrates compelling legitimate grounds for the processing which override your interests, rights and data protection related freedoms or if the processing is necessary for the establishment, exercise or defense of legal claims.
7.10. You may lodge a complaint about the processing of your personal data to the National Authority for Data Protection and Freedom of Information (Nemzeti Adatvédelmi és Információszabadság Hatóság – NAIH; address: H-1125 Budapest, Szilágyi Erzsébet fasor 22/C.; postal address: 1530 Budapest, Pf. 5; phone: +36-1-391-1400; facsimile: +36-1-391-1410; email: ugyfelszolgalat@naih.hu) or to the data protection authority of your home country or country of your residency.
7.11. Independently from lodging a complaint to NAIH, you may turn to court pursuant to the provisions set forth in the Privacy Act if your rights are infringed. Upon your decision, the procedure may be launched before the tribunal in whose jurisdiction you are domiciled or you have a temporary address. Prior to initiating a legal procedure, it may be useful to discuss the complaint with COMMSIGNIA.
7.12. Your detailed rights and remedies are set out in subsections 14–18 and 21–23 of the Privacy Act and in Articles 15-21 of the GDPR.

  1. CONTACTING COMMSIGNIA

We value your opinion. If you have any comments, questions, or wish to obtain more information on data processing at COMMSIGNIA, please send an email at jobs@commsignia.com or mail to the email or postal address specified in section 1. We will handle the submitted information confidentially. Our representative will contact you within a reasonable time.

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