This page and its sub-pages tell you everything you need to know about how Fairsystems LTD and/or its affiliates, subsidiaries, and newly acquired companies (“fairsystems”; “we”) protect the personal data we process and control relating to you (“your personal data”; “your data”) and which rights you have in relation to the processing of your personal data.
Below, we first give a general description of how fairsystems protects your personal data. Further below, we also include specific information on the following:
1. How does fairsystems protect your personal data?
fairsystems attaches great importance to your right to privacy and the protection of your personal data. We want you to feel secure that when you deal with fairsystems, your personal data are in good hands.
fairsystems protects your personal data in accordance with applicable laws and our data privacy policies. In addition, fairsystems maintains the appropriate technical and organizational measures to protect your personal data against unauthorized or unlawful processing and/or against accidental loss, alteration, disclosure or access, or accidental or unlawful destruction of or damage thereto.
The following sections provide further details as to how fairsystems processes your personal data:
- Which categories of personal data do we collect and how do we process such personal data?
- For which purposes and on which legal basis do we use your personal data?
- Will we share your personal data with third parties?
- What about sensitive data?
- What about data security?
- Where will your personal data be processed?
- How long will your personal data be retained by us?
- Which rights do you have with respect to the processing of your personal data?
Which categories of personal data do we collect and how do we process such personal data?
Below is also a chart describing the categories of personal data we collect:
|Additional personal details, contact details, and identifiers.||In addition to the personal details listed above, fairsystems may collect additional personal details for recruitment/employment purposes, such as national identification number, social security number, insurance information, marital/civil partnership status, domestic partners, dependents, emergency contact information, and military history.|
|Education information and professional or employment-related information.||fairsystems may collect information about your education and professional or employment-related information, such as your employment history.|
|Sensitive data for recruitment purposes.||fairsystems may collect certain types of sensitive information when permitted by local law or with your consent, such as health/medical information (including disability status), trade union membership information, religion, race or ethnicity, minority flag, and information on criminal convictions and offenses. fairsystems collects this information for specific purposes, such as health/medical information in order to accommodate a disability or illness (subject to legal limits on the timing of collection of such information and other applicable limitations) and to provide benefits; background checks, and diversity-related personal information (such as race or ethnicity) in order to comply with legal obligations and internal policies relating to diversity and anti-discrimination.|
|Documentation required under immigration laws.||fairsystems may collect data on citizenship, passport data, and details of residency or work permit (a physical copy and/or an electronic copy).|
|Financial information for payroll/benefits purposes||fairsystems may collect your banking and other relevant financial details we need for payroll/benefits purposes.|
|Talent management information.||Information necessary to complete a background check, details on performance decisions and outcomes, performance feedback and warnings, e-learning/training programs, performance and development reviews (including information you provide when asking for/providing feedback, creating priorities, updating your input in relevant tools), driver’s license and car ownership information, and information used to populate biographies.|
|Requested recruitment information||Information requested to provide during the recruitment process, to the extent allowed by applicable law.|
|Recruitment information you submit||Information that you submit in résumés / CVs, letters, writing samples, or other written materials (including photographs).|
|Information generated by us during recruitment||Information generated by interviewers and recruiters related to you, based on their interactions with you or basic Internet searches where allowed under applicable law.|
|Recruitment information received from third parties||Information related to you provided by third-party placement firms, recruiters, or job-search websites, where applicable.|
|Audiovisual materials||Photograph, and images/audio/footage captured/recorded on CCTV or other video systems when visiting our office or captured in the course of recruitment events or video recruitment interviews or during any other virtual and live events (including recordings during virtual workshops or similar events).|
|Recommendations||Recommendations related to information provided on your behalf by others.|
|Immigration||Documentation and related information required under immigration laws.|
|Employment history and background checks||Information about your prior employment, education, and where applicable and allowed by applicable law, credit history, criminal records, or other information revealed during background screenings.|
|Diversity related information||Information about race, ethnicity, religion, disability, and gender, for purposes of government reporting where required by law, as well as to understand the diversity characteristics of the fairsystems workforce, subject to legal limits.|
|Assessment information||Information generated by your participation in psychological, technical, or behavioral assessments. You will receive more information about the nature of such assessments before your participation in any of them.|
The above-mentioned categories of personal data have been obtained either directly from you (for example, when you provide information to sign up for a newsletter or register to comment on a forum website) or indirectly from certain third parties (for example, through our website’s technology). Such third parties include our affiliates, public authorities, public websites, social media, suppliers, and vendors.
For which purposes and on which legal basis do we use your personal data?
fairsystems uses your personal data only where required for specific purposes. Please view the table below for (i) a list of the purposes for which fairsystems uses your personal data and (ii) an overview of the legal basis for each such purpose.
|Managing our contractual and/or employment relationship with you.||Necessary for the performance of a contract to which you are a party.|
|Recruitment.||Justified on the basis of our legitimate interests for ensuring that we recruit the appropriate employees.|
|Facilitating communication with you (including in case of emergencies, and to provide you with requested information).||Justified on the basis of our legitimate interests for ensuring proper communication and emergency handling within the organization.|
|Operating and managing our business operations including or being part of the provision of our services to our clients and their employees/contractors and their customers, for example in collecting their data as part of surveys, data analytics, Marketing research, or other purposes.||Justified on the basis of our legitimate interests for ensuring the proper functioning of our business operations.|
|Complying with legal requirements.||Necessary for compliance with a legal obligation to which we are subject.|
|Monitoring your use of our systems (including monitoring the use of our website and any apps and tools you use).||Justified on the basis of our legitimate interests of avoiding non-compliance and protecting our reputation.|
|Social listening (Identifying and assessing what is being said about fairsystems and our clients on social media (only publicly accessible content) to understand the sentiment, intent, mood, and market trends and our stakeholders’ needs and thereby improving our services. We do this through keyword searches and our goal is to gain insights into conversation trends over a specified period and not to identify an individual. To achieve this, we analyze and monitor conversation streams and monitor publicly available opinions, statements, or other interactions on social media channels.)||Justified on the basis of our legitimate interest of protecting our assets and our brand on social media|
|Improving the security and functioning of our website, networks, and information.||Justified on the basis of our legitimate interests for ensuring that you receive an excellent user experience and our networks and information are secure.|
|Undertaking data analytics, i.e. applying analytics to business operations and data to describe, predict and improve business performance within fairsystems and/or to provide a better user experience. (more details on how we run analytics on our website can be found in our cookies policy).||Justified on the basis of our legitimate interests for ensuring the proper functioning of our business operations.|
|Marketing our products and services to you (unless you objected against such processing, as further described in the section “How do we use personal data for marketing purposes?” below).||Justified on the basis of our legitimate interests for ensuring that we can conduct and increase our business.|
|Specific Recruitment/Employment Purposes||Legal basis|
|Assess your suitability for employment for the role for which you are applying, as well as future roles that may become available.||Justified on the basis of fairsystems’ legitimate interests of ensuring that it recruits the appropriate employees.|
|Manage your application.||Justified on the basis of fairsystems’ legitimate interests of ensuring that it recruits the appropriate employees.|
|Facilitate communication with you.||Justified on the basis of fairsystems’ legitimate interests of ensuring proper communication within the organization and with you.|
|Perform administrative functions (e.g. reimburse you for interview-related expenses).||Justified on the basis of fairsystems’ legitimate interests of ensuring that it recruits the appropriate employees.|
|Perform data analytics, including analysis of our applicant pool in order to better understand who is applying to positions at fairsystems and how to attract and keep top talent.||Justified on the basis of fairsystems’ legitimate interests of ensuring that it continually improves its recruitment processes.|
|In some cases, record your online interview for review by additional recruiters and hiring managers.|
|If you register on our Careers website, we may enter you into a database to receive future mailings about fairsystems’ positions and events. You may also receive personalized job recommendations while browsing our Careers website.|
|Administration of employee benefits||Justified on the basis of fairsystems’ legitimate interests of ensuring that our employees receive the applicable benefits.|
|Perform any legally-required reporting and respond to legal process.||Compliance with a legal obligation.|
Where the above table states that we rely on our legitimate interests for a given purpose, we are of the opinion that our legitimate interests are not overridden by your interests, rights, or freedoms, given (i) the transparency we provide on the processing activity, (ii) our privacy by design approach, (iii) our regular privacy reviews and (iv) the rights you have in relation to the processing activity. If you wish to obtain further information on this balancing test approach, please contact fairsystems’ Data Privacy Officer.
We will process your personal data for the purposes mentioned above based on your prior consent, to the extent such consent is mandatory under applicable laws.
We will not use your personal data for purposes that are incompatible with the purposes of which you have been informed unless it is required or authorized by law, or it is in your own vital interest (e.g. in case of a medical emergency) to do so.
What about sensitive data?
We do not generally seek to collect sensitive data (also known as special categories) through this site or otherwise. In the limited cases where we do seek to collect such data, we will do this in accordance with data privacy law requirements and/or ask for your consent.
The term “sensitive data” refers to the various categories of personal data identified by data privacy laws as requiring special treatment, including in some circumstances the need to obtain explicit consent from you. These categories include racial or ethnic origin, political opinions, religious, philosophical, or other similar beliefs, membership of a trade union, physical or mental health, biometric or genetic data, sexual life or orientation, or criminal convictions and offenses (including information about suspected criminal activities).
What about data security?
We maintain organizational, physical, and technical security arrangements for all the personal data we hold. We have protocols, controls, relevant policies, procedures, and guidance to maintain these arrangements taking into account the risks associated with the categories of personal data and the processing we undertake.
Where will your personal data be processed?
As a global organization with offices and operations throughout the world, the personal data we collect may be transferred or be accessible internationally throughout fairsystems’ global business and between its entities and affiliates.
Any such transfers throughout fairsystems’ global business take place in accordance with the applicable data privacy laws and in accordance with our corporate rules.
What are the sources we get your personal information from?
If we do not obtain your personal information directly from you, we may obtain it from the following sources: publicly available sources (registers or the internet), fairsystems’ employees, contractors, (prospective) members of the board of directors, shareholders, fairsystems’ affiliates, subsidiaries and newly acquired businesses, employers of our contractors, public authorities, public websites and social media, previous employers, educational institutions, suppliers and vendors (including third-party data providers).
In section 5, you can find more information on the sources of your personal information for marketing purposes.
How long will your personal data be retained by us?
We will retain your personal data only for as long as is necessary. We maintain specific records management and retention policies and procedures so that personal data are deleted after a reasonable time according to the following retention criteria:
- We retain your data as long as we have an ongoing relationship with you (in particular, if you have an account with us).
- We will only keep the data while your account is active or for as long as needed to provide services to you.
- We retain your data for as long as needed in order to comply with our global legal and contractual obligations.
Which rights do you have with respect to the processing of your personal data?
You are entitled (in the circumstances and under the conditions, and subject to the exceptions, set out in applicable law) to:
- Request access to the personal data we process about you: this right entitles you to know whether we hold personal data about you and, if we do, to obtain information on and a copy of that personal data.
- Request a rectification of your personal data: this right entitles you to have your personal data be corrected if it is inaccurate or incomplete.
Object to the processing of your personal data: this right entitles you to request that fairsystems no longer processes your personal data.
- Request the erasure of your personal data: this right entitles you to request the erasure of your personal data, including where such personal data would no longer be necessary to achieve the purposes.
- Request the restriction of the processing of your personal data: this right entitles you to request that fairsystems only processes your personal data in limited circumstances, including with your consent.
- Request portability of your personal data: this right entitles you to receive a copy (in a structured, commonly used, and machine-readable format) of personal data that you have provided to fairsystems, or request fairsystems to transmit such personal data to another data controller.
To the extent that the processing of your personal data is based on your consent, you have the right to withdraw such consent at any time by contacting fairsystems’ Data Privacy Officer. Please note that this will not affect fairsystems’ right to process personal data obtained prior to the withdrawal of your consent, or its right to continue parts of the processing based on other legal bases than your consent.
If despite our commitment and efforts to protect your personal data, you believe that your data privacy rights have been violated, we encourage and welcome individuals to come to fairsystems first to seek resolution of any complaint. You have the right at all times to register a complaint directly with the relevant supervisory authority or to make a claim against fairsystems with a competent court (either in the country where you live, the country where you work, or the country where you deem that data privacy law has been infringed).
Contact us to exercise any of your rights.
2. How do we use personal data when you visit fairsystems’ website?
In addition to the information set out above, the following sections describe how we use personal data when you visit fairsystems’ website:
Which personal data do we gather?
fairsystems collects personal data at its websites in two ways: (1) directly (for example, when you provide personal data to sign up for a newsletter or register to comment on a forum website); and (2) indirectly (for example, through our website’s technology).
We may collect and process the following personal data:
- Personal data that you provide by filling in forms on our website. This includes registering to use the website, subscribing to services, newsletters, alerts, registering for a conference, or requesting a white paper or further information. Pages that collect this type of personal data may provide further information as to why your personal data are needed and how it will be used. It is completely up to you whether you want to provide it.
- If you contact us, we may keep a record of that correspondence.
- We may ask you to complete surveys that we use for research purposes, although you do not have to respond to them.
- Any postings, comments, or other content that you upload or post to a fairsystems’ website.
- Our website collects personal data about your computer, including (where available) your IP address, operating system, and browser type, for system administration, to filter traffic, to look up user domains, and to report on statistics.
- Details of your visits to our website, the pages you view, and resources you access or download, including but not limited to, traffic data, location data, weblogs, and other communication data. Please see the Cookies section below for more information.
How do we use the personal data that we collect from our websites?
We use personal data for the purposes described in the section “For which purposes and on which legal basis do we use your personal data?” above, as well as to provide you with information you request, process online job applications, and for other purposes which we would describe to you at the point where it is collected. For example:
- Links to and from the sites of our partner networks, advertisers, and affiliates.
- Certain programs (widgets and apps) of third parties. Where this is the case, note that such third parties may process your personal data collected through such programs for their own purposes.
We analyze your IP and browser information to determine what is most effective about our website, to help us identify ways to improve it and make it more effective. Please see the Cookies section below for more information.
4. How do we use personal data when you visit our offices?
In addition to the information set out above, this section describes how we use personal data when you visit fairsystems’ offices.
Please click here to receive further details on how we process your personal data when visiting our offices (this sub-page also relates to the potential processing of your personal data through CCTV and access management systems in case such CCTV and access management systems are active.)
If you have any questions on data privacy or you want to let us know about website/marketing permissions, please contact us.
5. How do we use personal data for marketing purposes?
In addition to the information set out above, the following sections describe how we use personal data for marketing purposes:
What are the sources of marketing data?
The bulk of the personal data we collect and use for marketing purposes relates to individual employees of our clients and other companies with which we have an existing business relationship. We may also obtain contact information from public sources, including content made public on social media websites, to make initial contact with a relevant individual at a client or other company.
Do we send targeted e-mails?
We send commercial e-mail to individuals at our client or other companies with whom we want to develop or maintain a business relationship in accordance with applicable marketing laws. Our targeted e-mail messages typically include web beacons, cookies, and similar technologies that allow us to know whether you open, read, or delete the message, and links you may click. When you click a link in a marketing e-mail you receive from fairsystems, we will also use a cookie to log what pages you view and what content you download from our websites, even if you are not registered at or signed into our site.
Targeted e-mails from fairsystems may include additional data privacy information, as required by applicable laws.
Do we maintain Customer Relationship Management (CRM) databases?
Like most companies, fairsystems uses customer relationship management (CRM) database technology to manage and track our marketing efforts. Our CRM databases include personal data belonging to individuals at our client and other companies with whom we already have a business relationship or want to develop one. The personal data used for these purposes includes relevant business information, such as contact data, publicly available information (e.g. board membership, published articles, press releases, your public posts on social media sites if relevant for business purpose), your responses to targeted e-mail (including web activity following links from our e-mails), website activity of registered users of our website, and other business information included by fairsystems’ professionals based on their personal interactions with you.
Do we combine and analyze personal data?
What are your rights regarding marketing communications?
You can exercise your right to prevent marketing communications to you by checking certain boxes on the forms we use to collect your personal data, or by utilizing opt-out mechanisms in e-mails we send to you. You can also exercise the right to discontinue marketing communications to you or to have your personal data removed from our customer relationship management (CRM) databases at any time. In such cases, we will retain minimum personal data to note that you opted out in order to avoid contacting you again.
6. How else might we use your personal data
In addition to the information set out above, the following sections describe other specific uses of personal data by some fairsystems’ affiliates.
7. Contact us
Please click here if:
- You have a general question about how fairsystems protects your personal data.
- You wish to exercise your rights in relation to your personal data rights (as set out in the sections “Which rights do you have with respect to the processing of your personal data?” and “Your rights regarding marketing communications“). Alternatively, you may want to use this link to exercise these rights.
- You wish to make a complaint about fairsystems’ use of your data.
You can also contact fairsystems as data controller of your personal data via our Data Privacy Officer.