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Privacy Statement

WHAT IS THE PURPOSE OF THIS DOCUMENT?

This privacy notice describes how we collect and use personal information about you during and after your working relationship with us, in accordance with the General Data Protection Regulation (GDPR) and other applicable national data protection legislation (collectively the "data protection law"). It applies to all employment candidates of Bolttech.


Austria		 Bolttech Device Protection (AUT) GmbH with registered
address 1 Kohlmarkt 8-10 1010, Vienna, Austria
Bolttech Digital Insurance Agency (EU) GmbH with registered
address: 1 Kohlmarkt 8-10 1010, Vienna, Austria
Ireland
 Bolttech Device Protection (Ireland) Limited with registered address Block C,
77 Sir John Rogersons Quay, Dublin 2, D02 VK60
Italy Bolttech Services (Italy) Srl with registered office Corso Monforte, 2 it-20122 Milano (MI)
Bolttech Device Protection (Italy) Srl with registered office Corso Monforte, 2 it-20122 Milano (MI) Italy
Luxembourg Bolttech Holdings (Europe) Sarl with registered address 2, rue Edward Steichen, 1st floor, lu-2540 Luxembourg
Bolttech Digital Brokerage (EU) Sarl with registered address 2, rue Edward Steichen, 1st floor, lu-2540 Luxembourg
Portugal Edirectinsure Portugal Unipessoal Lda with registered address Rua Gonçalo, Cristóvão, N 185, 5º 4049-012 Porto, Portugal
UK Bolttech Device Protection (UK) Limited with registered office New Broad Street House, 35 New Broad Street, London EC2M 1NH
Bolttech Holdings (Europe) Sarl – United Kingdom Branch with registered address New Broad Street House, 35 New Broad Street, London EC2M 1NH

The selected entity is the “data controller” (hereinafter the "data controller" or "we", "our").

This means that we are responsible for deciding how we hold and use personal information about you.

We are required under data protection legislation to notify you of the information contained in this privacy notice.

This privacy notice applies to you if you are one of our prospective employee (the "data subjects"). This notice does not form part of any contract of employment or other contract to provide services.

It is important that you read and retain this notice, together with any other privacy notice we may provide on specific occasions when we are collecting or processing personal information about you, so that you are aware of how and why we are using such information and what your rights are under the data protection law.

DATA PROTECTION PRINCIPLES

We will comply with data protection law. This says that the personal information we hold about you must be:

  1. Used lawfully, fairly and in a transparent way.
  2. Collected only for valid purposes that we have clearly explained to you and not used in any way that is incompatible
  3. with those purposes.
  4. Relevant to the purposes we have told you about and limited only to those purposes.
  5. Accurate and kept up to date.
  6. Kept only as long as necessary for the purposes we have told you about.
  7. Kept securely.

THE KIND OF INFORMATION WE HOLD ABOUT YOU

Personal data, or personal information, means any information about an individual from which that person can be directly or indirectly identified. In connection with your application, we will collect, use and store the following categories of personal data about you:

  • The data you have provided to us in your curriculum vitae (CV) and the personal data contained in your covering letter.
  • The data you have provided on our application form, including name, title, home/term address, telephone number, personal email address, date of birth, gender, employment history, qualifications, nationality, visa and working permit details, social media accounts, profession, professional memberships, educational achievements, diplomas, transcripts, languages, computer skills, national service completion (if applicable), identification number and any data you provide us during interviews at our premises.
  • Any personal data provided to us about you by your referees, if applicable.

HOW IS YOUR PERSONAL INFORMATION COLLECTED?

  • We collect personal information about prospective employees, workers and contactors through the application and recruitment process, either directly from candidates or sometimes from an employment agencies. We may sometimes collect additional information from third parties including former employers and the candidate named referees, from whom we collect the following categories of data: full name, periods of previous employment, performance during previous employment.
  • We may also collect data from publicly accessible sources, such as Linkedin, where we collect your full name, email, work history, and other data included on your profile.

THE LAWFUL BASES WE RELY ON WHEN PROCESSING PERSONAL DATA ABOUT YOU

We will collect and process your personal information in accordance with the applicable data protection law. Most commonly, we will use your personal information on the basis of the following lawful grounds of processing:

  1. Your consent.
  2. Where we need to perform the contract we have entered into with you.
  3. Where we need to comply with a legal obligation.
  4. Where it is necessary for legitimate interests pursued by us or a third party and your interests and fundamental rights do not override those interests.

PURPOSES OF PROCESSING YOUR PERSONAL INFORMATION

We will use the personal data we collect about you to:

  • Assess your skills, qualifications, and suitability for the role.
  • Ascertaining your fitness to work.
  • Carry out background and reference checks, where applicable.
  • Communicate with you about the recruitment process.
  • Keep records related to our hiring processes.
  • Comply with legal or regulatory requirements.
  • Checking you are legally entitled to work in the country in which you would be contracted to work in
  • It is in our legitimate interests to decide whether to appoint you to the role since it would be beneficial to our business to appoint a suitable candidate to that role.
  • We also need to process your personal data to decide whether to enter into a contract with you and to determine the terms on which you would work for us;.
  • Conducting data analytics studies to review and better understand employee retention and attrition rates.
  • Equal opportunities monitoring.

Having received your CV and covering letter and the results from any tests you took; we will then process that data to decide whether you meet the basic requirements to be shortlisted for the role. If you do, we will decide whether your application is suitable to invite you for an interview. If we decide to call you for an interview, we will use the data you provide to us at the interview to decide whether to offer you the role. If we decide to offer you the role, we may then take up references and/or any other check before confirming your appointment.

HOW WE USE PARTICULARLY SENSITIVE PERSONAL DATA

We will use your sensitive personal data only in so far as we are permitted by Law to do so: We will use data about your disability status to consider whether we need to provide appropriate adjustments during the recruitment process, for example whether adjustments need to be made during a test or interview. We will use data about your nationality or ethnicity, to assess whether a work permit and a visa will be necessary for the role.

If you fail to provide personal information:

Please note that there will be cases where, if you fail to provide certain information when requested, which is necessary for us to consider your application (such as evidence of qualifications or work history), we may not be able to process your application further. For example, if we require references for this role and you fail to provide us with relevant details, we will not be able to take your application further.

Change of purpose: We will only use your personal information for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is not incompatible with the original purpose. If we need to use your personal information for an unrelated purpose which is not compatible with the purposes for which your personal information was originally collected, we will notify you and we will explain the legal basis which allows us to do so.

INFORMATION ABOUT CRIMINAL CONVICTIONS

Where appropriate and permitted under local laws, we will collect information about criminal convictions as part of the recruitment process. We will use information about criminal convictions to ensure that we comply with all applicable legislation, including but not limited to legislation that regulates the insurance sector.

AUTOMATED DECISION-MAKING

You will not be subject to automated decisions that will have a significant impact and or binding effects on you based solely on automated decision-making, unless we have one of the above lawful bases for doing so and we have notified you, including the provision of meaningful information about the logic involved, as well as the significance and the envisaged consequences of such processing.

We do not envisage that any decisions will be taken about you using automated means, however we will notify you in writing if this position changes.

DATA SHARING

We will only share your personal data with the following third parties for the purposes of processing referred above where required by law, where it is necessary to administer the relationship with you or where we have another legitimate interest in doing so.

All our third-party service providers and other entities in the group are required to take appropriate security measures to protect your personal data in line with our policies.

We do not allow our third-party service providers to use your personal data for their own purposes. We only permit them to process your personal data for specified purposes and in accordance with our instructions.

The following activities may be carried out by third-party service providers: (i) IT services, notably hosting of information in cloud based instances; (ii) employment agencies; (iii) executive search firms (iv) information verifiers, (v) credit bureaus.

We may share your personal information with other third parties, for example in the context of the possible sale or restructuring of the business. In this situation we will, so far as possible, share anonymised data with the other parties before the transaction completes. Once the transaction is completed, we will share your personal data with the other parties if and to the extent required under the terms of the transaction.

We may also need to share your personal information with a regulator or to otherwise comply with the law. This may include making returns to tax authorities, disclosures to stock exchange regulators (including a Regulatory News Service) and disclosures to shareholders such as directors’ remuneration reporting requirements.

TRANSFERRING INFORMATION OUTSIDE THE EUROPEAN UNION

Some Bolttech offices are located outside of the European Union and we may use third party service providers that are also located abroad.

At the date of this privacy notice these countries are Hong Kong, Singapore, United States of America (and United Kingdom).

In case these countries are not deemed to provide an adequate level of protection for your personal information. we will put in place appropriate measures to ensure that your personal information is treated by those third parties in a way that is consistent with and which respects the applicable data protection law.

We require such third parties to enter into data processing agreements containing provisions, such as standard contractual clauses, that ensure that your personal information will receive equivalent protection in the hands of those third parties to the protection given by the applicable data protection law.

You may request a copy of these agreement from the Data Controller at any time.

DATA SECURITY

We have put in place appropriate security measures to prevent your personal information from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your personal information to those employees, agents, contractors and other third parties who have a business need to know and have been expressly authorized to the processing of personal data. They will only process your personal information on our instructions and they are subject to a duty of confidentiality.

We have put in place procedures to deal with any suspected data security breach and will notify you and any applicable regulator of a suspected breach where we are legally required to do so.

DATA RETENTION

How long will you use my information for?

We will only retain your personal information for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements. To determine the appropriate retention period for personal data, we consider the amount, nature, and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal requirements.

In some circumstances we may anonymise your personal information so that it can no longer be associated with you, in which case such information is no longer personal data and we may use it without further notice to you.

RIGHTS OF ACCESS, CORRECTION, ERASURE, AND RESTRICTION

Your rights in connection with personal information

Under certain circumstances, by law you have the right to:

  • Request access to your personal information (commonly known as a “data subject access request”). This enables you to receive a copy of the personal information we hold about you and to check that we are lawfully processing it.
  • Request correction of the personal information that we hold about you. This enables you to have any inaccurate information we hold about you corrected and incomplete information completed, including by means of providing a supplementary statement.
  • Request erasure of your personal information. This enables you to ask us to delete or remove personal information where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal information where you have exercised your right to object to processing (see below).
  • Object to processing of your personal information where we are relying on a legitimate interest (or those of a third party), including profiling based on such legitimate interest, and there is something about your particular situation which makes you want to object to processing on this ground. We will no longer process the personal data unless we demonstrate compelling legitimate grounds to continue to processing the data. You also have the right to object where we are processing your personal information for direct marketing purposes, including profiling related to such direct marketing and we will stop processing your personal data.
  • Request, under certain circumstances, the restriction of processing of your personal information. This enables you to ask us to suspend the processing of personal information about you, for example if you want us to establish its accuracy or the reason for processing it.
  • Request, under certain circumstances, the transfer of your personal information to another party (data portability).
  • Not to be subject to to a decision based solely on automated processing, including profiling, which produces legal effects concerning him or her or similarly significantly affects him or her, except where such processing is permitted by the applicable data protection law.

If you want to review, verify, correct or request erasure of your personal information, object to the processing of your personal data, or request that we transfer a copy of your personal information to another party, exercise any other privacy right and request the list of third parties to whom we may communicate your personal, please contact the data privacy manager at the contact details below.

Please consider that in circumstances provided by the law, the exercise of your privacy rights may be limited, delayed or excluded. You will have the possibility to ask the relevant Supervisory Authority to verify that such limitation, delay and exclusion are based on legitimate grounds.

You also have the right to lodge a complaint before the competent Supervisory Authority, namely:

No fee usually required: You will not have to pay a fee to access your personal information (or to exercise any of the other rights). However, we may charge a reasonable fee if your request for access is clearly unfounded or excessive. Alternatively, we may refuse to comply with the request in such circumstances.

What we may need from you: We may need to request specific information from you to help us confirm your identity and ensure your right to access the information (or to exercise any of your other rights). This is another appropriate security measure to ensure that personal information is not disclosed to any person who has no right to receive it.

Your duty to inform us of changes: It is important that the personal information we hold about you is accurate and current.

RIGHT TO WITHDRAW CONSENT

Any time you have provided your consent to the collection, processing and transfer of your personal information for a specific purpose, you have the right to withdraw your consent for that specific processing at any time. The withdrawal of consent shall not affect the lawfulness of processing based on consent before its withdrawal. To withdraw your consent, please contact privacy@bolttech.eu. Once we have received notification that you have withdrawn your consent, we will no longer process your information for the purpose or purposes you originally agreed to, unless we have another legitimate basis for doing so in law.

DATA PRIVACY CONTACT

If you have any questions about this privacy notice or how we handle your personal information, please contact at privacy@bolttech.eu.

CHANGES TO THIS PRIVACY NOTICE

We reserve the right to update this privacy notice at any time, and we will provide you with the updated version of the privacy notice if there are any material changes applicable to you. We may also notify you in other ways from time to time about the processing of your personal information.