Date of entry into force: January 20, 2021 last updated: November 25, 2022
Marrbery (“Marrbery”, “us” or “we”) is committed to your privacy and the protection of your personal data. We define personal data broadly as information that directly identifies an individual or makes him or her identifiable when combined with other information.This Recruitment Privacy Notice (the “Privacy Notice”) explains how we process and protect your personal data in connection with Marrbery’s recruitment processes and programs. In the event of a conflict between this Privacy Notice and applicable law, the following shall prevail
This privacy notice applies only to the personal data of applicants, potential candidates for employment or partnership, and those who participate in our recruitment programs and activities. This personal data is transmitted directly to Marrbery during the online application process and subsequent communications and/or through alternative channels (e.g., through professional recruitment firms). Marrbery may also collect and process your personal employment data when we conduct due diligence related to a potential corporate acquisition of your current employer (e.g., if you are a member of the target company’s senior management). This Privacy Notice does not apply to the personal data of our employees, partners, customers, suppliers or any other persons from whom Marrbery collects personal data for other purposes.
By providing us with your personal data, you confirm that:
You have read and understood this Privacy Notice and consent to the use of your personal data as described in this document.
Your personal data may be transferred to and processed around the world, including in countries that may not be considered to offer the same level of data protection as your home country, for the purposes and in the manner set out in this Privacy Notice.
You are under no obligation to provide us with any requested information, but your failure to do so may result in our inability to continue your candidacy for the job for which you have applied.
All of your statements are true and correct to the best of your knowledge and belief, and you have not knowingly omitted any related information of an adverse nature. Providing any inaccurate information may disqualify you from employment.
This Privacy Notice does not form part of any employment contract offered to candidates hired by Marrbery.
Personal data that we collect
The types of personal data we request from you and how we process them are determined by the requirements of the country in which the position you are applying for is located, not the country in which you reside. If you are applying in more than one location or if the position you are applying for is available in more than one country, the types of personal data we ask you for and how we process it are determined by the requirements of all countries in which the position is located.
We typically collect personal data directly from you when you apply for a position with us, such as your name, address, contact information, photos and videos, work and educational history, achievements, identification documents, and test scores. If you receive an offer from us, we may conduct a background check and, to the extent permitted by applicable law, we may also collect data related to criminal offenses and legal proceedings. We also collect similar personal data about you from third parties, such as professional recruitment firms, your references, previous employers, Marrbery employees with whom you have interviewed or who have recommended you for employment, and, to the extent permitted by applicable law, background check providers. We may also collect personal information about you online to the extent that you choose to make this information publicly available. For example, we may find your profile on professional social networking websites (such as LinkedIn) and contact you about relevant job opportunities.
Sensitive personal data is a subset of personal data that includes ethnicity, health, trade union membership, philosophical beliefs, sexual orientation and other categories as permitted by law. We may collect sensitive personal data about a candidate to the extent permitted by applicable law and to support our efforts to create an inclusive and diverse work environment. We may also collect sensitive personal data to the extent that a candidate chooses, without being asked, to voluntarily disclose it during the hiring process. In limited circumstances, and to the extent permitted by applicable law, we may also collect sensitive personal health and medical information, such as infection status, test results and immunization status, to fulfill our public health and safety obligations and to protect the Firm and its employees, clients and third parties.
Use of your personal data
We collect and use your personal data for legitimate human resources and business purposes, including
identifying and evaluating candidates for potential employment and for future positions that may become available maintaining recruitment and hiring records; ensuring compliance with legal requirements, including those related to public health and safety in the workplace; promoting our diversity and inclusion programs and practices; conducting background checks, including to the extent permitted by applicable law, and, if you receive an offer from us, criminal background checks; protecting our legal rights to the extent permitted or required by law; and protecting the workplace and communicating with healthcare professionals, law enforcement or other government agencies in the event of an emergency or public health event, such as when the health or safety of you or one or more persons may be at risk, including, to the extent permitted by applicable law, sharing information about infection status, test results and immunization status.
We may also use your personal data for Marrbery analytical purposes, including in aggregated/pseudonymized form, to improve our recruitment and hiring process and enhance our ability to attract successful candidates.
Legal basis for processing your personal data
Our processing of your personal data is based on the purposes mentioned above:
In particular, in connection with our legitimate business interests in assessing your application, to manage our relationship with you, to ensure that we recruit suitable employees and to evaluate and maintain the effectiveness of our recruitment process generally; and in the conduct of our business and the protection of the Firm and its employees, clients and third parties. In particular, about our performance of contractual and pre-contractual activities related to our potential employment relationship with you;
In particular, about our compliance with applicable laws regarding personal data necessary to fulfill our legal and regulatory obligations, in particular with regard to public health and safety in the workplace;
In part, with your consent, if we offer you the opportunity to participate in our additional recruitment programs or if we collect sensitive personal data for legally permitted purposes other than to comply with our legal obligations in relation to public health and safety in the workplace.
Background Screening
If you receive an offer from us, we may conduct a background check on you or have a third party do so on our behalf. Background checks will only be conducted where permitted by the law applicable to the location of the position and to the extent necessary and proportionate to the role you are offered. Background checks will include criminal records only to the extent permitted by law. Our legal basis for conducting background checks is to perform pre-contractual activities related to the establishment of our employment relationship. If a background check is required, you may be contacted by a third-party background check provider to request permission to disclose your information, at which time you will be provided with additional information about the process and what personal data it may include.
Data recipients and international data transfers
Your personal data may be accessed by recruiters and interviewers working in the country where the position you are applying for is located, as well as recruiters and interviewers working in different countries within the Marrbery global organization. Individuals performing administrative functions and Marrbery’s IT staff may also have limited access to your personal data to the extent necessary to perform their jobs. In some countries, you may have fewer rights under local law than in your country of residence, but we have implemented legal mechanisms designed to ensure that your personal data is adequately protected when it is processed by Marrbery subsidiaries and affiliates within the Marrbery global organization and by Marrbery service providers. This includes the transfer of your personal data to countries other than the country in which you reside.We use third-party service providers to provide our recruitment software system. We also share your personal data with other third-party service providers who may assist us in identifying and recruiting talent, administering and evaluating pre-employment screening and testing, and improving our hiring practices.Except as necessary to fulfill Marrbery purposes described in this Privacy Notice, we do not disclose your personal data to third parties. We also prohibit our service providers from using your personal data for purposes other than Marrbery. We do not share or sell your personal data with third parties.We maintain processes designed to ensure that any processing of personal data by third-party service providers is consistent with this Privacy Notice and protects the confidentiality, availability and integrity of your personal data in accordance with applicable law. Where required by law, we implement additional legal mechanisms designed to help ensure that your personal data is adequately protected during a transfer to another country. If you would like to receive additional information about these legal mechanisms, which may include the EU-Ukraine Standard Contractual Clauses, please contact us at the address provided at the end of this Privacy Notice.In addition, we may disclose or transfer your personal data in the event of a reorganization, merger, sale, joint venture, assignment or other transfer or disposition of all or any part of our business.
Automated sorting of applications
In some jurisdictions, we may use data analytics and algorithms to help us review the large number of candidates and application data we receive. These algorithms help us prioritize our application review process and sort candidates based on job characteristics that predict the strengths and abilities needed to fulfill the role. The algorithms are designed to analyze the candidate’s application data and compare it to our historical data on previously successful and unsuccessful candidates.The automated results are always considered in tandem with human judgment, not instead of it. We evaluate each individual candidate on their own merits.Some roles may require certain prerequisites or skills (e.g., fluency in a particular language, certain professional qualifications or certifications, or a number of years of experience in a similar position). Applications that do not meet these requirements will be automatically rejected.
Data storage
If you accept an offer of employment with us, all relevant personal data collected during the pre-employment process will become part of your personnel record and will be stored in accordance with country-specific requirements and the privacy notice applicable to Marrbery employees that will be provided during the hiring process.If we do not hire you, we may, however, continue to retain and use your personal data for a period of time (which may vary by country) for system administration purposes, to consider you for potential future roles and to conduct research. After that, we retain a minimal amount of your personal data to record your recruitment activity with us.To the extent that we collect personal data, including sensitive personal data, for the specific purpose of complying with our legal obligations in relation to public health or workplace safety, we will retain that data for the duration of those legal obligations. Thereafter, we retain the minimum amount of your personal data to ensure that we comply with these obligations.We may want to stay in touch with you and consider your employment opportunities in the future. In this case, we will ask for your consent to be included in one of our recruitment programs, which provides you with the opportunity to learn about and stay in touch with Marrbery before or after you formally apply for a job. Participation in these recruitment programs is completely optional. We retain your personal data for a period of time.
Security
We use generally accepted technical and operational security standards to protect your personal data. Only authorized Marrbery personnel and our third-party service providers are permitted to access personal information, and these employees and third-party service providers are required to treat this information as confidential. Despite these safeguards, we cannot guarantee that unauthorized persons will not gain access to your personal information.
Your rights
We take reasonable steps to ensure that your personal data is accurate, complete and relevant for the purposes for which it is collected and used. We have also implemented measures designed to help ensure that our processing of your personal data complies with this Privacy Notice and applicable law.Under applicable law, you may have one or more of the following rights: the right to request information about the personal data we hold about you, including how we use that information and with whom we share it;the right to request a copy of your personal data that we hold;the right to change or correct your personal data if any information about you is incorrect or outdated;the right to portability of your personal data;the right to request erasure of your personal data;the right to request that we cease processing your personal data or restrict the processing of your personal data;the right to withdraw your consent to the processing of your personal data to the extent that our processing is based on your consent as a lawful basis for processing. This right may not apply if there is another legal basis for continuing to process or we need to retain certain personal data as required or permitted by applicable law; and/orThe right to provide us with instructions regarding the processing of your personal data in the event of your death.In addition, where permitted by applicable law, you may have the right to lodge a complaint with a competent data protection authority.If you would like to request access, review, rectification, erasure or portability of the personal data we have collected about you, to assert your rights regarding your personal data or to discuss how we process your personal data, please complete this form. If you are unable to access this form for any reason, you may contact us using the information provided at the end of this Privacy Notice.To protect your privacy and security, we will take reasonable steps to verify your identity before granting you access to your personal data. We will use reasonable efforts to promptly investigate, fulfill or otherwise respond to your requests as may be required by applicable law. Depending on the circumstances and the request, we may be denied access to personal data or otherwise not fully comply with your request; for example, when providing your information may reveal the identity of someone else. We reserve the right to charge an appropriate fee for fulfilling your request, if permitted by applicable law, and/or to reject your requests if, in the Firm’s sole discretion, they may be unfounded, excessive or otherwise inappropriate under applicable law.
Social media tools
Our application process allows you to provide us with relevant personal data from information you have on third-party websites (such as LinkedIn, Google Drive and Dropbox). If you choose to include your personal data from third-party websites, it will be used in accordance with this Privacy Notice.
Cookies and other tracking technologies
We may use our own and third-party cookies, web beacons, pixels, clear GIFs and other similar technologies (collectively, “Cookies and other tracking technologies”) to identify you and your interests, remember your preferences and track your use of our websites. We also use cookies and other tracking technologies to control access to certain content on our websites, to secure the websites and to process any inquiries you make to us.Some of our online recruitment activities are hosted by third parties. When you access sites operated by these third parties, they may, subject to our Cookie Policy, place their own cookies or other tracking technologies on your device. You can learn more about our use of cookies and other tracking technologies by reading our Privacy Policy and Cookie Policy
Contact us
If you have any questions about this Privacy Notice or if you would like to contact any of our Data Protection Officers or the Data Protection Team, please contact us at: privacy@marrbery.com
Marrbery Legal Department
Ukraine
Dnipro, 49008
Marrbery reserves the right to make changes to this Privacy Notice. We will post any changes to our Privacy Notice on this page. Please check this page regularly to stay informed.
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