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Privacy Policy for the Boozt Group recruitment and employer branding

Boozt Group manages its employer branding and recruitment process through its career site (the “Career Site”) and by using a related applicant tracking system.

Boozt Fashion AB (556710-4699) is the entity acting as data controller for the processing of your personal data on the Career Site. If you have any questions about how we process data about you, don't hesitate to contact us at privacy@boozt.com or by other means, as described in clause 11 below.

In this privacy policy, we explain how we process your personal data if:

1. You visit our Career Site (you being a “Visitor”)
2. You connect with us via our Career Site, to create a profile with us and receive information about current or future vacancies with us (you being a “Connecting Candidate”)
3. You apply for a position with us, via our Career Site or a third party service (you being an “Applying Candidate”)
4. We collect information about you from other parties, sites and services, since we believe your profile is of interest for our current or future vacancies (you being a “Sourced Candidate”)
5. We receive information about you from our employees or partners, since they believe your profile is of interest for our current or future vacancies (you being a “Referred Candidate”)
6. We receive information about you from a Candidate, who lists you as their reference (you being a “Reference”).

This privacy policy also describes what rights you have when we process your personal data, and how you can exercise these rights.

When we use the term “Candidate” in this privacy policy, we are referring to each of Connecting Candidates; Applying Candidates; Sourced Candidates; and Referred Candidates, unless it’s stated otherwise.

Our processing of your personal data is subject to the rules of the General Data Protection Regulation (hereinafter GDPR), national data protection legislation, supplementary guidelines and opinions from the European Data Protection Board and national supervisory authority.

1. What personal data do we process?

The personal data that can be collected by us might include:

Career Site visitors

• Device information: If you visit our Career Site, we will collect information about your device, such as IP address, browser type and version, session behaviour, traffic source, screen resolution, preferred language, geographic location, operating system and device settings/usage.

• Technical and statistical data: If you visit our Career Site, we will collect technical and statistical data about your use of the site, such as information about which URLs you visit, and your activity on the site.

Candidates

• Contact details: Such as your name, email address, telephone number and physical address.

• Information in your application: Such as your CV, cover letter, work samples, references, letters of recommendation and education.

• Communications data: We will collect and store your communication with us, including the information you provided in the communication. This may include the content of emails, video recordings, messages on social media, the information you add to your account with us, surveys, etc.

• Data from interviews, assessments and other information from the recruitment process: Such as assessments and tests made, salary requirements.

• Information in your public profile: Meaning the information we collect about you from public sources related to your professional experience, such as LinkedIn or the website of your current employer.

• Information provided by references: Meaning the information we receive from our employees or partners who refer you to us, or by the persons you have listed as your references.

2. Where do we receive your personal data from?

Directly from you: most of the information that we process about you, we receive directly from you, for example when you apply for a position with us or connect with us. You can always choose not to provide us with certain information. However, some personal data is necessary in order for us to process your application.

Data we create ourselves or in cooperation with you: Information about your application and profile is usually created by us, or by us in cooperation with you, during the recruitment process. This may for example include information received from our interviews with you, as well as assessments and tests made by you.

From references: If you provide us with references, we may collect information about you from them. In addition, we may receive information about you from our employees or partners (such as recruitment service providers), when they believe your profile is of interest for our current or future vacancies.

From public sources: We may collect personal data about you from public sources, such as LinkedIn or the website of your current employer.

3. For what purpose and what legal basis do we process your personal data?

• To process your application

When you apply for a position, we process your personal data to facilitate the process of recruitment. This involves handling and evaluating the application, administering tests and assessments, conducting interviews, and taking the appropriate measures prior to entering into a contract with you.

When you register your interest in working at Boozt in the form of an open application to a specific department, we will process your data to match your candidate profile against future open positions at that department.

• To evaluate your professional profile on our own initiative

We may collect and process data about you that you have disclosed on your public profiles such as LinkedIn. This also includes communicating with you regarding your profile.

• To contact you to ask for your participation in surveys

We may send you requests for feedback to get to know your satisfaction, and to be able to respond to your feedback.

The legal basis for processing personal data for processing your application, evaluating your professional profile on our own initiative and contacting you to ask for your participation in surveys is based on our legitimate interest, which is considered to outweigh your interest in your personal data not being subject to processing based on GDPR Article 6 (1)(f). You may object to the processing of your data which is processed based on our legitimate interest. If you wish to do so, reach out to us at privacy@boozt.com.

• To notify you about new positions

We process your data to notify you about new positions at Boozt Group which match your interest if you have subscribed to new jobs in your profile. We also process your data when you have given us your permission to do so after the standard retention period is over.

The legal basis for such processing is the consent given by you to such processing in accordance with Article 6(1)(a) GDPR. You have the right to withdraw your consent at any time.

• To collect information about your use of the Career Site, using cookies and other tracking technologies, as described in our Cookie Policy.

We process information collected through cookies and other similar tracking technologies to understand how you use our Career Site. You can read more about cookies on our Career  Site in our Cookie Policy.

The legal basis for such processing is the consent given by you to such processing in accordance with Article 6(1)(a) GDPR. You have the right to withdraw or change your consent at any time. To do so, you can reject the cookies on the Career Site in the tab “Manage Cookies”.

• To protect and enforce our rights, interests and the interests of others, for example in connection with a legal claim

If necessary, we may process your personal information in order to be able to establish, exercise or defend legal claims, protect and enforce our rights, interests or the interests of others.

The legal basis for the above processing is legitimate interest based on GDPR Article 6 (1)(f). You may object to the processing of your data which is processed based on our legitimate interest. If you wish to do so, reach out to us at privacy@boozt.com.

4. For how long will we process your data?

If you are a Connecting Candidate (only), we keep your personal data for as long as you remain connected with us.

For other types of Candidates, we keep your personal data to decide if you are a suitable candidate for the relevant vacancy(ies) with us.

If you don’t succeed in the initial recruitment process, we keep your personal data for as long as needed to consider, and potentially contact you, for relevant future job openings. The application documents of candidates who were not hired for the position that they have applied for are stored until the expiration of the applicable appeal period, in accordance with anti-discrimination legislation (2 years).

If you are hired, we will keep your personal data during your employment, for other purposes than those stated above, which you will be informed of.

If our processing of personal data is based on your consent, we will retain your personal data until you withdraw your consent. However, we will under all circumstances delete your personal data if the purpose behind our processing of such data ceases.

If you are a Reference, we keep your personal data for as long as we keep the personal data of the Candidate for whom you acted as a reference.

5. Who do we share your personal data with?

Boozt may share your data with internal recruiters, prospective managers, and prospective colleagues across group companies. We may also use and share your personal data to external recruiters who are directly involved in a relevant recruitment process.

Furthermore, we may engage data processors for processing of your personal data, when it is necessary and compatible with the purposes for which we have collected the data. Data processors are companies that process data on our behalf and according to our instructions. For instance, we share your personal data with our suppliers who provide services and functionality in our employer branding- and recruitment process.This includes recruitment service providers and the supplier of our Career Site and related applicant tracking system.

For the handling of job applications and processing of personal data in relation to recruitment processes, Boozt has engaged Teamtailor AB, a provider of an IT-system for e.g. collection of job applications and communication with applicants, as data processor. We may also attract data processors to conduct tests and assessments necessary to evaluate your skills and competences for the position. In addition, we may share your personal data with external relocation companies to help the candidate with the process of relocation before the start of their contract

If we are legally obliged to share your personal information with the national tax authority, the police or others, we will do so.

If needed to protect or defend our rights, we share your personal data with public authorities or with other parties involved in a potential or existing legal proceeding. This can for example be in case of discrimination claims.

6. Where do we process your personal data?

Since some of our service providers are located outside the EU/EEA, we may transfer your data to a third country. We always ensure that such transfer takes place only if it is permitted and carried out in accordance with applicable laws and without impairing your statutory rights. We also ensure that the service provider in question guarantees by agreement or otherwise that privacy is maintained at the same level of protection as the EU. That includes safeguarding such data transfer with necessary organisational and technical security measures. We often rely on Standard Contractual Clauses (SCC) introduced by the European Commission. In addition to that, we rely on adequacy decisions passed by the EU Commission provided that the conditions for adequacy (if any) are fulfilled.

Personal data may be transferred outside the EU/EEA to the following service providers:

If you receive invitation link to PI Assessments -  Predictive Index LLC (101 Station Drive, Westwood, MA, USA, 02090. See Privacy Policy of Predictive Index here:

https://www.predictiveindex.com/privacy/privacy-respondent/

If you accept an offer from us - Provider of HR infrastructure - Hi Bob Limited (The Buckley Building 49 Clerkenwell Green, London, UK). See Privacy Policy of HiBob here: https://www.hibob.com/privacy/privacy-policy-end-users/

7. What are your rights as a data subject and how can you exercise them?

If you want to exercise any of the rights listed here, we suggest that you:

• Visit the Data & Privacy page on our Career Site, where we offer features to let you exercise your rights;

• Log in to your account with us, where you can use the settings in the account to exercise your rights; or

• Contact us directly at privacy@boozt.com.

Right to be informed

You have the right to be informed about how we process your personal data. You also have the right to be informed if we plan to process your personal data for any purpose other than that for which it was originally collected.

We provide you with such information through this privacy policy, through updates on our Career Site (see also Section 10 below), and by answering any questions you may have for us.

Right of Access

If you require information regarding which personal data we process about you, you can request access to such data, including a copy to it. Please note that if we receive a subject access request, we may ask for additional information so that the information is given to the correct person.

You have the right to request information about the personal data that is processed by visiting the Data & Privacy page on our Career Site. Alternatively, you can contact us in writing at privacy@boozt.com.

Please note that for any further copies, we have a right to charge a reasonable fee on the basis of the administrative costs for such demand in accordance with Article 15(3).

Right to change your data (“Right to rectification”)

You have the right to change, where necessary, inaccurate personal data. Within the stated purpose, you also have the right to supplement any incomplete personal data. You can do so by logging in to your account with us. Alternatively, you can contact us in writing at privacy@boozt.com.

Right to have your personal data deleted (“right to be forgotten”)

You may request the deletion of the personal data we process about you if:

1. personal data is no longer necessary for the purposes for which it has been collected or processed;
2. you withdraw your consent from processing which required your consent as a legal ground;
3. personal data is processed in an unlawful way;
4. the personal data must be deleted to comply with a legal obligation we are subject to.

Please note that we may deny your request if the processing is necessary for us to establish, enforce or defend legal claims.

You can request your data to be deleted by visiting the Data & Privacy page on our Career Site. Alternatively, you can contact us in writing at privacy@boozt.com.

Right to restrict processing

You have the right to obtain restriction of our processing of your personal data where one of the following applies:

1. you have disputed the accuracy of the personal data and you are awaiting our decision on whether the personal information is correct;
2. the processing is unlawful, and you oppose the erasure and request restriction instead;
3. the personal data is no longer necessary for processing, but it is required by you for the establishment, exercise or defence of legal claims, or
4. you have objected to a processing (see below) and pending the verification whether the legitimate grounds override your rights and freedoms.

Right to access and to request a transfer of your personal data to another recipient (“Right to data portability”)

If our right to process your personal data is based on your consent or performance of an agreement with you, you have the right to request the data that relates to you and which you have provided to us to be transferred to another data controller (so-called data portability). A prerequisite for data portability is that the transfer is technically feasible and can be automated.

Right to object

You have the right to object to any processing which is based on legitimate interest at any time. We will then assess whether our legitimate interest override your interests, rights and freedoms, or whether your personal information is necessary for the establishment, exercise or defense of legal claims.

If your personal data is processed for the purpose of direct marketing, you have the right to withdraw your consent to this at any time and we will no longer process your personal data.

8. Cookies

Cookies are passive text files that are stored in the internet browser on the your device, such as computer, mobile phone or tablet, when using Teamtailor to apply for positions at Boozt. We use cookies to improve the User’s usage of the Service and to gather information about, for example, statistics about the usage of the Service. This is done to secure, maintain and improve the Service. The information that is collected through the cookies can in some instances be personal data and is, in such instances, regulated by our Cookie Policy.

Users can at any time disable the use of cookies by changing the local settings in their devices. Disabling of cookies can affect the experience of the Service, such as disabling some functions in the Service.

9. What organisational and technical security measures do we implement?

We prioritize the personal integrity and therefore work actively so that the personal data is processed with utmost care. We have taken appropriate technical and organizational security measures to protect your personal data against unlawful and unauthorized processing, e.g. we use secure and controlled IT-systems to protect the privacy, integrity and availability of personal data for which we are data controller, and our security is checked regularly to determine whether our user information is handled securely and always taking your rights as a user into account.

10. Updates to this policy

The rapid development in the digital and technical field means that changes to our processing of personal data may be necessary. We thus reserve the right to update and amend this privacy policy. You can always find the current policy at our platforms. In case of substantial changes, we will notify you in the form of a visible notice on our platforms.

11. What can I do if I have questions or if I am dissatisfied with the processing?

We are happy to help you if you have any questions about how we process your personal data. Should you have questions, contact us in writing at privacy@boozt.com or at the address written below.

Attention: HR Department

c/o Boozt Fashion AB

Box 4535

203 20 Malmö, Sweden

If you believe that we have not processed your information in accordance with our obligations, you have the right to complain about this to the national Supervisory Authority in your country which you will find here: https://edpb.europa.eu/about-edpb/board/members_en