Privacy Policy

Introduction

The Privacy Policy set out below will govern the protection and processing of your personal data that is collected or submitted, by using the website www.kpaxmarketing.com (the "Website").

The Website is owned and operated KPAX Marketing Online Ltd., a limited liability company registered in Cyprus, whose address is 1 Anapafseos, 2nd Floor Limassol, Cyprus ("us", "we", "our" or "KPAX Marketing").

You are deemed to have read, understood, agreed to, and consented to the processing of your personal data under the terms of this Policy by submitting your acceptance on the relevant notifications posted on the Website.

We keep our privacy policy under regular review. This privacy policy was last updated on 05/01/2023.

If we make any material updates to this Policy, we will inform you.

We hope you will find this page helpful, but should you have any concerns or questions, regarding Data Protection, please feel free to contact our Data Protection Officer at [email protected]

What Kind of Personal Data Do We Collect?

Candidate Data

We need to process certain information about you in order to provide you with the best possible employment opportunities that are tailored to you.

We only request information that will genuinely assist us in assisting you, such as your name, contact information, education details, employment history, emergency contacts, immigration status, financial information (where financial background checks are required), and social security number (and of course you may choose to share other relevant information with us).

We may also collect information about your health, diversity information, or details of any criminal convictions where appropriate and in accordance with local laws and requirements.

Website Users

We collect a limited amount of data from our Website Users, which we use to help us improve your website experience and manage the services we provide. This includes information such as how you use our website, how frequently you access it, and when our website is most popular.

What Is Our Legal Basis For Processing Your Personal Information?

When you provide us with your information, we will do everything we can to protect it. According to GDPR, we are required to inform you of the legal basis on which your data is processed.

We are using Legitimate Interest as our legal basis for processing the following data:

Legitimate Interest – Article 6(1)(f) says:

“processing is necessary for the purpose of the legitimate interest pursued by the controller or by the third party except where such interests are overridden by the interests or fundamental rights and freedoms of the data subject which require protection of personal data”

When you send us your CV, you can expect us to contact you about your job search and any potential suitable vacancies. You may not be successful in your initial application, but by using the information you provided, we can notify you of any future vacancies that may be suitable for you.

We will always have an initial phone conversation with you to fully understand your previous career experience and what you are looking for. We also tell you what you can expect from us and how we will use your data. We will arrange face-to-face meetings, but if this is not possible, we will use Skype, Facetime, or other video conference platforms to complete them.

How Do We Gather Your Personal Information?

Candidate Data

There are two main ways in which we collect your personal data:

1. From third parties; and
2. Directly from you

Referees And Emergency Contacts

We only collect your contact information when a Candidate or a member of our Staff names you as their emergency contact or when a Candidate gives it to us so that you can serve as a referee.

Website Users

When you visit our website, we collect your data automatically through cookies in accordance with your browser's cookie settings. If you want to learn more about cookies, including how we use them and what options you have, please see the Cookies section below.

How Do We Use Your Personal Information?

Candidate Data

Candidate data is typically used in 3 ways:

We've listed below the various ways we may use and process your personal data for this purpose, where appropriate and in accordance with any applicable local laws and requirements.

Please keep in mind that this is not an exhaustive list.

1) Recruiting

• Collecting your data from you and other sources, such as LinkedIn;
• Storing your information (and updating it as needed) on our database so that we can contact you about recruitment;
• Comparing data about you to vacancies that we believe are a good fit for you;
• Allowing you to submit your CV, or receive alerts about jobs that we believe may be of interest to you;
• Fulfilling our obligations arising from any contracts entered into between us, such as as a Temporary Worker;
• Fulfilling our obligations arising from any contracts entered into between KPAX Marketing and third parties in relation to your recruitment;
• Facilitating our payroll and invoicing processes;
• Conducting customer satisfaction surveys;
• Verifying the information you've provided by using third-party resources (such as psychometric evaluations or skills tests), or requesting information (such as references, qualifications, and potentially any criminal convictions, to the extent that this is appropriate and in accordance with Cyprus and Malta laws);
• Meeting our legal obligations in the detection of crime or the collection of taxes or duties;
• Processing your data to send you targeted, relevant marketing materials or other communications we believe will be of interest to you.

2) Marketing Actions

We may send you information that we believe you will find interesting on a regular basis. We may use your data for the following purposes in particular, where appropriate and in accordance with laws and requirements.

Please keep in mind that this is not an exhaustive list.

To:

Allow us to develop and market additional products and services;

• Promote our full range of recruitment services to you (permanent, temporary, contract, outplacement, MSP programs, and RPO services);
• Send you information about reports, promotions, offers, networking and client events, and general industry sector information that we believe may be of interest to you; and

We may require your consent for some aspects of these activities that are not covered by our legitimate interests, and depending on the circumstances, we will do so through an opt-in or soft-opt-in process (which we explain further below).

Soft opt-in consent is a type of consent that applies when you previously engaged with us (for example, by submitting a job application or CV, or registering a vacancy to be filled). We will take your consent as given under 'soft opt-in' consent unless and until you opt out.

For the majority of people, this is advantageous because it allows us to suggest other jobs to you in addition to the one you applied for, significantly increasing the likelihood of us finding you a new position.

We must obtain your explicit consent for any other type of e-marketing.

If you have any questions about how we obtain consent, please email us at [email protected]. If you are unhappy with our marketing approach, you have the right to withdraw your consent at any time.

3) Monitoring Of Equal Opportunities And Other Sensitive Personal Data

We are committed to ensuring that our recruitment processes are consistent with our equal opportunity policy. Some of the data we may in appropriate circumstances collect about you comes under the umbrella of "diversity information". This could include information about your ethnicity, gender, disability, age, sexual orientation, religion or other similar beliefs, and/or socioeconomic status. Where appropriate and in accordance with Cyprus laws, we will use this information anonymously to monitor our compliance with equal opportunities.

Consent

We are required to obtain your consent to the processing of your personal data in relation to certain activities in certain circumstances. This consent will be opt-in consent or soft opt-in consent, depending on what we do with your information.

According to GDPR Article 4(11), (opt-in) consent is "any freely given, specific, informed, and unambiguous indication of the data subject's wishes by which he or she signifies agreement to the processing of personal data relating to him or her by a statement or by a clear affirmative action." In layman's terms, this means:

• You must freely give us your consent, without us putting you under any kind of pressure;
• You must understand what you are agreeing to, so we will provide you with adequate information;
• You should be able to choose which processing activities you agree to and which you do not. Please contact us at [email protected] to update us on your consent and preferences.

We will keep records of the consents you have provided in this manner.

We've already mentioned that we'll be able to rely on soft opt-in consent in some cases. We are permitted to market to you as you do not actively opt-out of receiving these communications.

As previously stated, you have the option to withdraw your consent to these activities. You may do so at any time by contacting [email protected].

Who Do We Share Your Personal Information With?

Where appropriate, we may share your personal data with the following categories of people in various ways and for various reasons:

• Any of our affiliated companies;
• Individuals and organizations that have information about your reference or application to work with us, such as current, former, or prospective employers, educators, examining bodies, and employment and recruitment agencies;
• Tax, audit, or other authorities, when we believe in good faith that the law or another regulation requires us to share this information (for example, in response to a tax authority's request or in connection with any anticipated litigation);
• Third-party service providers who perform functions on our behalf (including external consultants, business associates, and professional advisers such as lawyers, auditors, and accountants, as well as technical support functions and IT consultants who test and develop our business technology systems);
• Third-party outsourced IT and document storage providers with whom we have a processing agreement (or similar safeguards) in place;
• In the case of Candidates and prospective Members of Staff' referees: third parties we have retained to provide services such as reference, qualification, and criminal convictions checks, to the extent that these checks are appropriate and in accordance with local laws.
• If KPAX Marketing merges with or is acquired by another business or company in the future, we may share your personal information with the (potential) new owners of the business or company.

How Long Do We Keep Your Information?

If we have not had meaningful contact with you for (48) months as a candidate, we will delete your personal data from our systems unless we believe in good faith that the law or another regulation requires us to keep it (for example, because of our obligations to the Social Insurance and Tax Authorities or in connection with any anticipated litigation).

For Candidates whose services are provided by a third-party company or other entity, "meaningful contact" with you refers to meaningful contact with the company or entity that provides your services. If we are notified by such a company or entity that it no longer has that relationship with you, we will retain your data for no more than 2 years from that point or, if later, for 2 years from the point we have meaningful contact with you directly.

"Meaningful Contact” means communication (verbal or written) or actively engaging with our online services.

Your Rights

You have the following Data Subject Rights:

• The right to be informed. Transparency in how we are using personal data. Hence, this detailed Privacy Policy.
• The right of access. This enables you to e.g. receive a copy of the personal data we hold about you.
• The right to rectification. Correction/Rectification of the personal data we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected/rectified.
• The right to erasure. This enables you to ask us to erase your personal data [known as the ‘right to be forgotten’] where there is no good reason for us continuing to process it.
• The right to data portability. This gives you the right to receive personal data they have provided to a controller in a structured, commonly used and machine-readable format. It also gives you the right to request that a controller transmits this data directly to another controller.
• The right to restrict processing. This enables you to ask us to restrict the processing of your personal data, i.e. use it only for certain things, if:
  • it is not accurate,
  • it has been used unlawfully but you do not wish for us to delete it,
  • it is not relevant any more, but you want us to keep it for use in possible legal claims,
  • You have already asked us to stop using your personal data, but you are waiting us to confirm if we have legitimate grounds to use your data.
• The right to object. This gives you the right to object to the processing of your personal data. For example, if you object to receiving marketing material you can remove consent for us to send it. The right to object only applies in certain circumstances. Whether it applies depends on your purposes for processing and the lawful basis for processing. Individuals have the absolute right to object to the processing of their personal data if it is for direct marketing purposes. Individuals can also object if the processing is for:
  • a task carried out in the public interest;
  • the exercise of official authority vested in you; or
  • your legitimate interests (or those of a third party);
  • in relation to automated decision making and profiling.

In order to exercise any of your rights over your Personal Data, please contact [email protected].

If you believe your privacy rights have been infringed, or you disagree with a decision we have made about your privacy rights, you have the right to complain to the relevant supervisory authority.

Cookie Section

What are Cookies?

'Cookies' are small text files stored in your web browser that enable us to recognize your computer when you visit our website. Cookies are essential to keep certain parts of our website functioning correctly and securely. We also use them to make things quicker, easier and more personal to you and to help us understand how our website is used. They can also be used to present you with more tailored advertising content.

To do all these things, cookies collect some personal information about you whenever you use our website. You can choose whether to accept or reject some or all types of cookies and control this through your device’s browser settings. We will make you aware of this by showing you our cookie banner when you visit our site. If you then continue to use our website without adjusting your browser settings, we will use cookies as set out in the sections below, so to help you make an informed choice it’s important to know why we use the different types of cookie and what that means for your online experience. This section provides you with a summary of the main points and tells you how switching off the different types of cookie will affect your experience on our website.

They also enable KPAX Marketing to find out which advertisement brought you to our website, we may use the KPAX Marketing cookies on your computer. In the event that we do collect such information, you will remain personally unidentifiable, and we will not share this information with any unconnected third-party.

The Cookie Categories

The Cookies we use fall into the following categories:

• Strictly Necessary
  This type of cookie allows you to navigate the website and use essential features like secure areas and online registration. These cookies don’t gather any information about you that could be used for marketing or remembering where you’ve been on the internet. These cookies are essential in our being able to guarantee the performance of our website, should you disable them we won’t be able to ensure your security or predict how our website will perform during your visit.
• Performance
  This type of cookie collects information about how you use our website e.g. which pages you visit, and if you experience any errors. The information collected is anonymous and is only used to help us improve how our website works, gauge what interests our users and assess the effectiveness of advertising.
• Functionality
  This type of cookie remembers your preferences for tools found on our website, so you don’t have to re-set them each time you visit. Some of them are managed by third parties. They may for instance determine whether you see the latest or oldest comments made in relation to an article first. They may also help us greet you by name or remember your choice of language or region).
• Targeting/Tracking
  These cookies are used to analyse what advertising might be most relevant to a user of the website based on the areas of the website that the user visits.

Controlling my Cookies

All modern browsers allow you to see what cookies you have, and to clear them individually or in their entirety by changing your cookie settings. Cookie settings are typically found in the 'options' or 'preferences' menu of your browser, otherwise you should use the 'Help' option in your browser for more details. You may also find the links below helpful:

• Cookie settings in Chrome
• Cookie settings in Firefox
• Cookie settings in Microsoft Edge
• Cookie settings in Safari

You can block cookies by activating the settings on your browser which allows you to refuse the setting of all or some cookies. However, if you use your browser settings to block all cookies (including essential cookies) you may not be to access all or parts of our site. We endeavour to make all parts of our site accessible to everyone but if you block some cookies, particularly Strictly Necessary cookies, your access might be impaired. Unless you have adjusted your browser settings so that it will refuse cookies, our system will issue cookies as soon you visit our site.

Your first visit to our site will generate a pop-up header alerting you to this privacy policy and will re-appear only in the event that you change your cookie settings from time to time.

The Use of Google Analytics

We use Google Analytics for ‘analytical’ purposes such as to keep track of user/customer browsing patterns and to build up a profile for a customised browser experience for you. Google Analytics is a popular web analytics service provided by Google, Inc. Google Analytics uses cookies to help us to analyse how customers use our Website.

Your opt-out choice is applied only to the browser from which you make the choice, so if you use different browsers you will need to opt out in each one. This opt-out is cookie based, so if you delete your cookies, you will no longer be opted out and will need to opt out again. Google Analytics, from which you can control through your browser settings: opt out.

https://tools.google.com/dlpage/gaoptout

Security

KPAX Marketing goes to great lengths to guarantee that your personal and financial information remains 100% secure and confidential. We employ industry standard security protocols (The connection to this site is encrypted and authenticated using TLS 1.2 (a strong protocol), ECDHE_RSA with X25519 (a strong key exchange), and AES_128_GCM (a strong cipher) to ensure that all transactions including deposits and withdrawals are carried out in a totally secure manner. This technology protects you from having your information intercepted by anyone other than ##skinname## while it is being transmitted between you and ##skinname##.

How To Contact Us

You can write to us at the following address:

1 Anapafseos, 2nd Floor

Limassol, Cyprus 3096

Alternatively, you can send an email to: [email protected]

• To access, amend or take back the personal data that you have given to us;
• If you suspect any misuse or loss of or unauthorised access to your personal information;
• If you suspect any misuse or loss of or unauthorised access to your personal information;
• Update your marketing preferences by contacting us

How To Contact The Supervisory Authority

Our Lead Supervisory Authority is Cyprus.

Details of our local supervisory authority and how you can contact them:

Office of the Commissioner of Personal Data Protection

For Personal Data Protection

1, Iasonos Street, 1082 Nicosia

Tel: 22-818456, Fax: 22-304565

Email: [email protected]

www.dataprotection.gov.cy