DEVEXPERTS RECRUITING PRIVACY POLICY

A. COLLECTION AND USE OF YOUR INFORMATION

If you wish to apply for any vacancy at Devexperts or at dxFeed, We may collect Your Personal Data specified below from three sources: 1) You personally; 2) Your referees that may be mentioned by You; 3) public Internet job resource media.

We shall collect and process any Personal Data provided by You to Us for the purposes enlisted below:

• Enabling recruitment and hiring process (incl. conducting tests and interviews, keeping records of Your recruitment process), notifying You of the stages of Your recruitment purposes;
• Responding to Your demands, requests and inquiries;
• Notifying You about sufficient changes to this Policy;
• Complying with legal and/or regulatory requirements and cooperating with regulators and law enforcement bodies;
• Protecting Our rights, Your rights, and the rights of others, and meeting Our own high standards of business practice.

If You agree to be a member of Our SmartRecruiters Community (“Community”), We may use Your Personal Data for additional purposes.

B. HOW WE PROTECT YOUR PERSONAL DATA

We shall:

• process the Personal Data in accordance with Data Protection Laws only for the purposes specified above or as otherwise instructed in writing by You, and inform You if any instruction contradicts any legal requirements to which We are subject;
• keep all Personal Data confidential;
• ensure that access to Personal Data shall only be provided to those of Our employees, or service providers who need access to such data for to process Your Personal Data for the purposes stated above;
• take adequate technical, organizational and physical security measures to safeguard Personal Data against unauthorized access, destruction, disclosure, transfer, or other improper use;

• provide You at Your written request with reasonable access to the Personal Data about You that We hold for You to be able to review and update Your Personal Data;
• promptly notify You of any accidental or unauthorized access, destruction, disclosure, transfer or other improper use of Your Personal Data, after We become aware of any such access, destruction, disclosure, transfer or other improper use;
• provide You at Your written request with all information necessary to demonstrate that We are in compliance with this clause B;
• audit the adequacy of Our security measures used to process Personal Data;
• upon expiration of 2 (two) years period since input of Your Personal Data and/or upon Your written request of revocation of Your consent delete, anonymize and/or, at Your election, return the Personal Data to You, unless it is technically impossible or We are legally obliged to keep Your Personal Data; in this case We delete Your Personal Data when this legal obligation is fulfilled.

C. HOW WE SHARE YOUR INFORMATION

From time to time, to the extent permitted by applicable law, We may share Your information with third party service providers (e.g. credit card processors, data hosters) and authorities in the following circumstances:

• Our Affiliates. Due to being global company, Devexperts has foreign offices that may be involved in Your hiring process. We share Your Personal Data with them to make recruitment efficient for both sides. You shall always be informed and special consent will be asked for in case of cross-border transfer outside of EU in accordance to section D. Consents and G. International Transfers below.
• Third party service providers. We may share Your information with third parties who perform functions on Our behalf (e.g., hosting or operating our services, managing recruitment process). We do not authorize these third party service providers to use Your information for purposes other than for which it has been provided, and do not authorize these third parties to disclose that information to unauthorized parties. We require these third parties to maintain appropriate security to protect Your information from unauthorized access or processing.
• Authorities. We may disclose Your Personal Data to regulatory authorities, courts, and government agencies, where We believe that doing so would be in accordance with or permitted or required by any applicable law, regulation or legal process, to defend the interests, rights, and/or property of Us or others, or to respond to emergencies.

We shall transfer Your Personal Data to entities stated above in the section C and shall ensure that any such transfers of Personal Data to third parties will be subject to contractual requirements to safeguard Personal Data equivalent to those set out in Clause B, and We shall remain liable to You for any breaches caused by third parties upon such transfer. However, third party service providers have separate and independent privacy policies. We therefore have no responsibility or liability for their activities after We have done Our best to provide safety for Your Personal Data processing.

If Devexperts is involved in a merger, acquisition or asset sale, Devexperts will continue to ensure the confidentiality of the Information and give affected users notice before the Information becomes subject to a different privacy policy.

D. CONSENTS

By continuing using Our Site You give Your consent to the (“Site privacy police”) and to Our processing of Your Personal Data collected through the Site.

If You wish to apply for a job in Devexperts or in dxFeed, We will process Your Personal Data based on Our legitimate interest as an employer to find the best suitable candidate for the vacancy. In case of cross-border transfer of Your Personal Data to Our foreign Affiliates, We will ask for a special consent from You. Moreover, We are initially asking for Your consent to process Your Personal Data for an extended amount of time (2 (two) years) to be able to contact you and process Your Personal Data if the recruitment process takes some time or the employment conditions/vacancies have some amendments. Unfortunately, We have to warn You that if You withhold Your consent for either cross-border transfer or 2 (two) years retention period, though We will do Our best to proceed with Your hiring process in accordance to Your wishes, We may have to refuse You due to our internal recruitment processes.

E. YOUR RIGHTS REGARDING YOUR PERSONAL DATA

Subject to local law, You may have certain rights regarding Your Personal Data. These may include, depending on the circumstances, the following rights to: access Your personal information; rectify the personal information We hold about You; erase Your personal information; restrict Our use of Your Personal Data; object to Our use of Your Personal Data; receive Your Personal Data in a usable electronic format and transmit it to a third party (also known as the right of data portability); lodge a complaint with Your local data protection authority; and withdraw any consent You have given to the use of Your Personal Data. If You would like to discuss or exercise the rights You may have, feel free to contact Us via email at privacy@devexperts.com.

Here You may find the list of Your rights if Your Personal Data is processed subject to the GDPR:

• Right to access, rectification, erasure and restriction of processing;
• Right to restrict processing;
• Right to object to processing;
• Right to data portability;
• Right to lodge a complaint.

In case You wish to opt out from certain disclosure of any of Your Personal Data to a third party or choose to limit purposes for which Your personal information is collected or used by Us, You may do so by contacting us via email at privacy@devexperts.com. However, We feel obliged to warn You that Your setting of certain limitations of Your Personal Data processing by Us may cause Our inability to follow the recruitment process and respond to Your inquirues in its fullest scope.

F. YOUR OBLIGATIONS REGARDING YOUR PERSONAL DATA

In relation to all Personal Data provided to Us, You shall ensure that You shall not, by any act or omission, put Us, third party service providers in breach of any of the Data Protection Laws.

G. INTERNATIONAL TRANSFERS

We are an international company, Our Recruiting Team members as well as vacancies may be located outside of the EU. In order to proceed with recruitment process, We may send and store your Personal Data outside of the country where You reside or are located, including to countries that may not or do not provide the same level of protection for Your Personal Data. We are committed to protecting the privacy and confidentiality of Personal Data when it is transferred so, in spite of the data protection adequacy level of such countries, We shall only transfer Personal Data to such third party that: (i) has provided satisfactory assurances to Us that it will protect the Personal Data in accordance with this Policy and the applicable data protection legislation; and (ii) has a legal or contractual right to require such transfer.

H. TRANSFERS OUTSIDE EEA

If you reside or are located within the EEA and Your Personal Data are to be transferred to a country that is not considered “adequate” for privacy by the EU Commission, We shall take appropriate steps to provide the same level of protection for the processing carried out in any such countries as You would have within the EEA to the extent feasible under applicable law and We shall additionally conclude the following agreements with the data receiving organization in such countries: the Standard Contractual Clauses for Controller-to-Controller Transfers approved by EC Commission Decision of 27 December 2004 (the “C-to-C Transfer Clauses“) or the Standard Contractual Clauses for the Transfer of Personal Data to Processors Established in Third Countries approved by EC Commission Decision of 5 February 2010 (the “C-to-P Transfer Clauses“) depending on the nature of the Processing. By submitting Your Personal Data, You agree to this transfer, collection, systematization, checking, rectification, updating, usage, storing and processing.

You can find the terms of the C-to-C Transfer Clauses and C-to-P Transfer Clauses at the following link https://ec.europa.eu/info/law/law-topic/data-protection/data-transfers-outside-eu/model-contracts-transfer-personal-data-third-countries_en.

I. DEFINITIONS

For the purposes of this Policy:

1. The terms “Controller” “Processor”, “Process(ing)”, and “Personal Data” each have the meaning given to such terms in the GDPR.
2. If you apply for any vacancy at Devexperts or at dxFeed, We will process the Personal Data provided to Us by You or Your referees (if applicable). In connection with Your application, we will collect, use and store certain 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 (if any).
   • The Data You have provided through our providers.
   • Any Personal Data provided to Us about You by Your referees such as Your work experience, personal qualities and competencies (if applicable).
3. The term “Data Protection Laws” means applicable legislation and regulations relating to the protection of Personal Data, (including the GDPR).
4. The term “Data Subject” shall mean an individual whose Personal Data is at issue.
5. The term “GDPR” shall mean European Union Regulation 2016/679 and includes any relevant implementing measure in each relevant European state, or any successor legislation thereto.