Uplift's Privacy Policy

This Privacy Policy ("Privacy Policy") has been prepared by UpliftPeople Consulting OÜ ("Uplift", "We", "Us" or "Our"), the Data Controller with its registered office at Harju maakond, Kesklinna linnaosa, 3. korrus, Viruväljak 2, Tallinn Estonia under Personal Data Protection Act and General Data Protection Regulation.

This Privacy Policy describes our policies and procedures on the collection, use and disclosure of your Personal Data when we perform our Services and tells you about your privacy rights. We consider your privacy to be of utmost importance and we will always hold and process your information in accordance with data protection laws.

1. Interpretation and Definitions

a. Interpretation

The words of which the initial letter is capitalized have meanings defined under the following conditions. The following definitions shall have the same meaning regardless of whether they appear in singular or in plural.

b. Definitions

For the purposes of this Privacy Policy:

Business refers to the Company as the legal entity that collect your personal information and determines the purposes and means of the processing, or on behalf of which such information is collected and that alone, or jointly with others, determines the purposes and means of the processing.

Candidate refers to any individual who applies for a job opening. This includes individuals who submit their CVs or other personal information through our website, LinkedIn, or other recruitment channels.

Candidate Pool refers to the collection of CVs and Personal Data of individuals who have given their explicit consent to be considered for future employment opportunities. Uplift People Consulting OÜ maintains this pool for a period of six months, after which candidates are contacted to renew their consent if they wish to remain in the pool.

Client refers to any employers or potential employers that engages Uplift People Consulting OÜ to provide recruitment and headhunting services.

Company refers to Uplift People Consulting OÜ.

Country refers to Estonia.

Data Controller , for the purposes of the Law, refers to the Company, Uplift People Consulting OÜ, as the legal person which alone or jointly with others determines the purposes and means of the processing of Personal Data.

Data Processor , for the purposes of the Law, a natural or legal person that processes Personal Data on behalf of a Data Controller as instructed by the Data Controller.

Data Subject , for the purposes of the Law, refers to an individual whose Personal Data is being collected, processed, or stored by a Data Controller or Data Processor.

Direct Recruitment refers to identifying and shortlisting of candidates for the purpose of matching them with an open role.

GDPR refers to EU General Data Protection Regulation.

Headhunting Service refers to the targeted and proactive search for highly qualified candidates, often for executive or specialized roles, typically involving a personalized approach to identify, engage, and attract individuals who may not be actively seeking new opportunities.

Law refers to Personal Data Protection Act, UK GDPR, EU General Data Protection Regulation, and any other applicable data protection legislation.

Personal Data is any information that relates to an identified or identifiable individual.

Online Job Portals refers to websites and online platforms, such as LinkedIn, that facilitate the posting of job vacancies and the collection of job applications.

Services refers to the Direct Recruitment and Headhunting services provided by Uplift.

Service Provider refers to third-party companies or individuals employed by the Company, to provide the services to the Company.

Supervisory Authority refers to Estonian Data Protection Inspectorate.

Websiterefers to www.uplift-people.com.

2. Collecting and Using Your Personal Data and Purposes of Processing

Mainly, we collect and use the Personal Data you provide to us. However, in certain circumstances, we may collect your Personal Data from third parties. Please find below details on our activities regarding the collection and processing of your Personal Data, as well as the processing purposes.

  1. Collecting Applications for Open Positions: When you apply for open positions on our Website or through Online Job Portals, such as LinkedIn, we collect your Personal Data, including but not limited to your name, date of birth, contact details, CV, and any other information you provide in your application. This information is processed for the purposes of evaluating your suitability for the relevant positions, conducting interviews, assessing your skills, and shortlisting.

    If you apply for a job opening through Online Job Portals, please note that the relevant platform may retain your Personal Data. We advise you to review the privacy policy of the relevant platform to understand how your Personal Data is handled.

    To assist with our recruitment process, we use Workable, an online application provided by Workable Software Limited. Workable processes personal information on our behalf as a data processor. Workable is only entitled to process your Personal Data in accordance with our instructions and is obligated to ensure that your data is handled securely and in compliance with applicable data protection laws.

  2. Blind Positions: For most of our processes, we keep the Client's information confidential. Therefore, the positions you apply for are blind positions. If we determine that you are suitable for a position, we will first inform you about the Client and obtain your explicit consent before transferring your Personal Data to the Client.
  3. Interviews: When you are selected for an interview, we may collect additional Personal Data from you, including but not limited to interview notes, assessments, and feedback from interviewers. This information is processed to further evaluate your suitability for the relevant positions, to understand your skills and competencies in more detail.
  4. Assessment and Selection Process: When As part of our evaluation and assessment process, we may collect data related to your performance during various stages of our recruitment process. This includes but is not limited to language assessments, and any other evaluations we made. This information helps us to identify the most suitable candidates for our job openings and to ensure a fair and thorough selection process.

    We may use Workable’s technology to select appropriate candidates for us to consider based on criteria expressly identified by us, or typical in relation to the role for which you have applied. The process of finding suitable candidates is automatic, however, any decision as to who we will engage to fill the job opening will be made by our staff.

  5. Cross-border Data Transfers: Some of our Clients may be located outside the GDPR area. In such cases, we will inform you and obtain your explicit consent under GDPR Article 49(1)(a). You will be informed of the possible risks of such transfers due to the absence of an adequacy decision and appropriate safeguards.
  6. Candidate Pool: To enhance your opportunities for future employment, we maintain a Candidate Pool. This pool allows us to keep track of promising candidates and consider them for upcoming positions that match their qualifications.

    With your explicit consent, we may retain your CV and Personal Data in our Candidate Pool for a period of six months. We will contact you to renew your consent at the end of this term if you wish to remain in the candidate pool. This allows us to consider you for future opportunities that may arise.

  7. Headhunting: As part of our headhunting services, we identify and approach potential candidates who may be suitable for our Client's vacancies. This involves collecting publicly available information from LinkedIn and other open sources. When we identify a potential candidate, we may collect additional Personal Data from publicly accessible sources. This data is used to evaluate the candidate's suitability for the role and to reach out to them regarding the opportunity. The aim is to find and attract highly qualified candidates for specific job openings on behalf of our clients.
  8. When You Get in Touch with Us: If you contact us for any reason, we will process your Personal Data to handle and respond to your inquiries, provide support, and improve our services. This includes any Personal Data you provide when you communicate with us through email, phone, or other channels.
  9. Open Position Bulletins: With your explicit consent, we may send you bulletins featuring open positions that match your profile and career interests. You have the right to withdraw your consent and opt-out at any time, and we provide an easy way to unsubscribe from these emails in each bulletin we send.

3. Lawful Basis for Processing Your Personal Data

Under the GDPR and Personal Data Protection Act, the lawful bases we rely on for the processing of your Personal Data include:

Legitimate Interest: We may process your Personal Data based on our legitimate interests. These interests include, without limitation, our interest in assisting job applicants in finding new employment opportunities. We ensure that our legitimate interests do not override your fundamental rights and freedoms.

Contract: We may process Personal Data to fulfill our contractual obligations to you. This includes processing your data to provide services as per our agreement with you, such as facilitating job placements.

Consent:In transferring your Personal Data to our Clients for blind positions, storing your Personal Data in our Candidate Pool and sending you Open Position Bulletins, we rely on your consent to process your Personal Data. This will be explicitly stated, and we will request your specific, informed consent for these activities. You have the right to withdraw your consent at any time. Besides, when our Clients located outside the GDPR area, we will inform you and obtain your explicit consent under GDPR Article 49(1)(a).

Legal Obligation:We may process your Personal Data to comply with legal or regulatory obligations..

4. Sharing Your Personal Data

We value your privacy and are committed to protecting your Personal Data. We only share your information in specific situations and with entities that adhere to our stringent data protection standards. Below, we outline the circumstances under which we may share your Personal Data and the measures we take to ensure its security.

Clients: We share your Personal Data only with specific Clients. For blind positions, we obtain your prior explicit consent before transferring your Personal Data. Our Clients have access to your Personal Data only on a need-to-know basis, meaning they process only the Personal Data that is related to their specific tasks.

Providers: Service We may share your Personal Data with our trusted Service Providers who assist us in delivering our Services. Any data shared with these providers will be limited and proportionate to the specific service they are rendering on our behalf. We also ensure that these Service Providers commit to stringent data protection standards and follow secure data transfer protocols to safeguard your information.

Legal and Governmental Requests:We may disclose your Personal Data to courts, government agencies, or other judicial and governmental bodies when required by law or in response to their official requests. This disclosure is made to comply with legal obligations and protect the rights, safety, and integrity of our Company.

5. How Long We Keep Your Personal Data

We are committed to retaining your Personal Data only for as long as necessary to fulfill the purposes for which it was collected, or as required by applicable laws and regulations.

Data and documentation collected during the application process will be deleted after the evaluation process is complete unless you provide explicit consent for us to store your data in our Candidate Pool.

If you give explicit consent, we will retain your CV and personal data in our Candidate Pool for a period of six months. At the end of this term, we will contact you to renew your consent if you wish to remain in the Candidate Pool. If you do not renew your consent, your Personal Data will be deleted.

We regularly review the Personal Data we hold and ensure its secure deletion when it is no longer needed for the purposes for which it was collected.

6. Ensuring the Security of Your Personal Data

We have taken appropriate technical and organizational security measures to protect your Personal Data against accidental or unlawful destruction, loss, or alteration and against the unauthorized disclosure, abuse, or other processing in violation of Law.

This includes identity and access management; preventing unauthorized viewing of personal data; deliberately set password requirements; structurally safe network design and other relevant continuously updated security measures.

7. Your Rights Regarding Personal Data

We are committed to safeguarding the privacy of your Personal Data and ensuring you can exercise your rights effectively. According to the GDPR and Personal Data Protection Act, you have the following rights:

Access Your Personal Data: You have the right to access, update, or request the deletion of your Personal Data held by Us. In most cases, you can manage this directly within your Account settings. If you need assistance, please reach out to Us, and We will gladly provide you with a copy of the Personal Data we have on record.

Correct Inaccurate Information: If We hold incomplete or inaccurate information about you, you have the right to request corrections to ensure your data is accurate and up-to-date.

Object to Data Processing: You can object to the processing of your Personal Data when We rely on a legitimate interest as the legal basis for processing. If your particular situation warrants it, you may also object to the use of your data for direct marketing purposes.

Request Data Erasure: If there is no valid reason for us to continue processing your Personal Data, you have the right to request the deletion or removal of your data.

Data Portability: Upon request, we will provide you or a third party you designate with a structured, commonly used, machine-readable format of your Personal Data. This right applies primarily to automated information you initially consented to or information used to fulfill a contract.

Withdraw Consent: You can withdraw your consent to the use of your Personal Data at any time.

We are committed to upholding your rights and ensuring your data privacy. If you have any questions or wish to exercise any of these rights, please contact us, and we will assist you promptly.

8. Exercising Your Data Protection Rights

Should you wish to exercise your rights under the Law, including those related to access, rectification, deletion, and objection, please reach out to Us by using the Data Subject Request Form attached to this Policy. To ensure the security of your data, We may ask you to confirm your identity before addressing your requests. Rest assured; We will make every effort to respond promptly to your inquiries.

We value your privacy and aim to address your concerns as swiftly as possible. Please note that in accordance with Law, we will respond to your requests within 30 days at the latest.

If you are located within the European Economic Area (EEA) and have further questions or concerns, you also have the right to contact your local data protection authority for additional information or assistance.

9. Changes to this Privacy Policy

We may update Our Privacy Policy from time to time. We will notify you of any changes by posting the new Privacy Policy on this page.

You are advised to review this Privacy Policy periodically for any changes. Changes to this Privacy Policy are effective when they are posted on this page.

10. Contact Us

If you have any questions about this Privacy Policy, you can contact us:

By email: privacy@uplift-people.com

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