Privacy Policy

Candidate data protection statement

Welcome to Lugera Talent Solutions d.o.o. for employment, Zagreb, Ulica fra Grge Tuškana 37, OIB: 31110908306, MBS: 080492874, agency ID no. 6/04 from 21.06.2004. and license number: 178/20 from February 17, 2020. and Lugera Outsourcing d.o.o. for services, Zagreb, Ulica fra Grge Tuškana 37, OIB: 07018964853, MBS: 080639348. We look forward to working with you to help you develop your career today. As you would expect from us, we collect and process your personal data in order to properly provide services.

We welcome visitors and users of the Lugera Outsourcing domain https://www.storadis.hr, which is associated with the domain of our business partner The Jobber Partnership B.V., Prinsesselaan 6, 1942 AH Beverwijk, Netherlands, VAT no.: NL851631976B01, Company reg. no.: 55267556, storadis.staa.agency.hr through which a portal for finding a job with the new matching technology STAA – Sales & Talent Acquisition Application is available.

Lugera is committed to protecting and respecting your privacy. This Candidate Privacy Statement describes your privacy rights in relation to your data that we process and the steps we take to protect your privacy. We are aware that the text is long, but nevertheless, please read this Statement very carefully. Below is a table of contents to help you find the desired parts of the Statement.

Index

Explanation of the name

What personal data does Lugera collect and process?

Why do we use your personal data?

How do the regulations regulate it?

Are you obliged to give us the personal data we ask for?

Do we process your personal data without any human intervention?

How long do you keep my personal data?

Do we transfer your personal data to third parties?

Do we transfer your personal data outside the European Union?

What are your rights?

What is the protection of personal data in Lugera’s systems?

How do we change this Statement?

Explanation of the name

First of all, we need to clarify the meaning of certain words in this Statement.

It may seem obvious, but in this Statement we will address you as a job seeker, “Candidate” or “you”. When we talk about “us” or “company” we mean Lugera Talent Solutions d.o.o. and Lugera Outsourcing d.o.o. Lugera provides various services in the field of human resources (Human Resources), such as: employment, assignment of workers, payroll processing, search and selection of personnel, testing, career transformations, talent development, training and education, outplacement and international mobility (“our activities” ).

In performing our activities, we use several IT systems. The portal allows you to search and apply for jobs advertised by Lugera and other advertisers that match your interests, abilities and/or experiences in the areas you have expressed interest in working for, but you can also be offered with different jobs.

Finally, this is a Data Statement about people like you and your family. It contains facts about you, but also other people’s opinions about you and your opinions (eg “I’m a football fan”). It is not about Lugera data (although sometimes this data overlaps). This type of information is sometimes referred to as “personal information”, personally identifiable information” or “PII”. In this Statement, we use the name “personal data”.

What personal data does Lugera collect and process?

Personal data collected and processed by Lugera including, but not limited to:

your name, date and place of birth, contact information and qualifications (education, courses and internships), documents proving your identity and right to work and any other information you have provided in your CV;

  • if you log into the Portal using your LinkedIn or any social network account: your profile information;
  • if you contact us, we will keep a record of that correspondence;
  • feedback about you from our staff and third parties; a record of when you provide feedback about others;
  • your feedback about us and our services through satisfaction surveys;
  • we also collect data about your visits to our websites/Portal including (without limitation) your IP address, browser data, timestamps, locations, traffic data in the country, location data, network logs and other communication data and the sources you access. Using this data, your visit to our website/Portal will be easier in the future as well. For example, we will suggest jobs operated by branches near where you were when you contacted us;
  • we also collect information for marketing purposes and analysis, including notifications about your responses to email, sms, phone and other marketing campaigns. We will ask for your express consent before sending marketing communications via the above communication methods;
  • photos and videos of your participation in video interviews and trainings or similar events (at these events you will have the option to ask not to be filmed or photographed);
  • information about the disability and accommodations we should take into account in your workplace; and
  • in some cases, we will also collect other sensitive data, not just disability-related details, where we are permitted to do so by regulation.

 

We would also like to inform you that Lugera, as part of the selection process, will perform all necessary candidate assessments, which may require the processing of submitted data, and will include the assessment results in its candidate database as part of the selection process.

You are also informed that, as part of the selection process, the recruiting entity may check your public profile details on social media (Facebook, Twitter, LinkedIn, etc.) and also other public information and records, for the sole purpose of evaluating and determining your experience and professional skills, and to determine whether your profile is in line with Lugera’s organizational culture and values.

Why do we use your personal data?

Lugera collects and processes personal data:

  1. to provide you with the services you expect from us, such as searching for a suitable job/assignment to apply for, assistance with training or facilitating the process of applying for jobs/assignments. This includes sending your CV to potential employers for consideration and notifying you of future employment opportunities via email, telephone, post and/or other communication methods;
  2. with your consent, we may use your contacts for direct marketing purposes, for example via e-mail, messages or telephone;
  3. for further development, testing and improvement of our websites/Portals or other existing or new systems/procedures in order to provide you with better services; this is carried out in the context of new information technology (IT) systems and procedures so that information about you will be used when testing those new IT systems and procedures when it is not possible to fully realize the operation of the new IT system with imaginary data (so-called dummy data) .
  4. for the purpose of study and statistical and analytical research, for example to compare the effectiveness of our mediation of candidates in different business sectors and in different geographical areas and to identify factors that can influence these identified differences;
  5. to transfer data to third parties (see below);
  6. to fulfill legal obligations when necessary; and
  7. we will also process your data:
  8. to improve the safety and protection of people, space, systems and equipment;
  9. to monitor compliance with internal policies and procedures;
  10. to manage communication and other systems (including internal contact databases);
  11. for investigating and responding to incidents and complaints:
  12. in the case of photos or videos of training courses, for internal reporting on the fact that the courses were held and their content (for example in internal coordination) and also for internal marketing of similar courses and external marketing of the same to third parties. In this case, we will ask you for your express consent and
  13. to participate in possible purchases or sales or joint ventures, of all or some parts of the business or company.

 

Why and on what basis do we use personal data?

We are required by law to have a legal basis for processing your personal data. Legal bases can be:

  1. Performance of a contract or taking steps before entering into a contract: When you already work with, or intend to work through, Lugera, our processing of personal data for all these purposes is based on the basis of processing such as the performance or conclusion of a contract (purposes 1, 6 and 7 above ). These services may be such as offering suitable jobs for you to apply for or assisting with training and the application process.
  2. Compliance with legal obligations: Sometimes processing is necessary to fulfill legal or regulatory obligations (purpose 6). Public authorities, such as tax, financial or data protection authorities, may request personal information from us and provide us with a legal reason for disclosing information about you (eg preventing or detecting a crime). In such circumstances, we are required by law to provide the authorities with your information.
  3. Fulfillment of our legitimate interests: Processing is necessary in the legitimate interests of Lugera in exercising its fundamental rights and the fundamental rights of its employees to conduct business in a way that does not unduly affect your interests or fundamental rights and freedoms (purposes 1, 3, 4, 5 , 6 and 7 above). This means that when processing is necessary for the legitimate interests of Lugera, we balance your interests or fundamental rights and freedoms against our legitimate interest in the processing. This ensures that we do not process data in such a way that your interest and fundamental rights override our interest in such processing

Further processing of your personal data on grounds other than those listed will only be based on your consent, which is the basis for further processing.

Are you obliged to give us the personal data we ask for?

You are not obliged to provide us with your personal data, however, but in order for us to work with you or provide you with our services, you must provide us with the necessary minimum. If you provide us with limited personal data in some cases, this may also result in a limitation of the services we perform for you.

Do we process your personal data without any human intervention?

From time to time we process your personal data without human intervention. Lugera may use automated systems/processing and automated decision-making (such as profiling) to provide business customers and you with the requested services. For example, when our business clients are looking for job candidates we may search our existing candidate lists using automated criteria that take into account your availability, skills, salary and in some cases previous feedback we have received from our business clients to compile a list of shortlisted candidates who ranks the candidates who best meet the needs of the business client. This means that sometimes your position in the ranking may be higher than the position of other candidates depending on how the above factors match the needs of the business client.

How long do you keep my personal data?

Lugera stores your personal data from your registration until the termination of your profile. You can cancel your profile at any time. In this case, it may happen that we continue to process some of your personal data if we are required to do so by the regulations and for the time specified by the regulations, for example for the purpose of proving the service we have provided to you. If you have successfully found a job through us, Lugera will need to retain your personal data to comply with applicable legal and contractual obligations. In general, we store your personal data related to taxes and financial data for a period of 11 years, data related to employment contracts and payrolls and salary permanently, while we store other personal data for the period in which it is possible to manage this data legal procedures.

How long do you keep my personal data?

Lugera stores your personal data from your registration until the termination of your profile. You can cancel your profile at any time. In this case, it may happen that we continue to process some of your personal data if we are required to do so by the regulations and for the time specified by the regulations, for example for the purpose of proving the service we have provided to you. If you have successfully found a job through us, Adecco will need to retain your personal data to comply with applicable legal and contractual obligations. In general, we store your personal data related to taxes and financial data for a period of 11 years, data related to employment contracts and payrolls and salary permanently, while we store other personal data for the period in which it is possible to manage this data legal procedures.

Do we transfer your personal data to third parties?

As we stated earlier, we disclose your personal data to third parties in order to fulfill the previously stated purposes. We do this in the following cases:

To suppliers: For example, we will engage a supplier to perform administrative or operational tasks for us in order to improve the relationship with you. The supplier(s) will be bound by contractual and legal obligations to protect the confidentiality of your personal data and will only have access to your personal data for the purposes of performing their functions; relevant suppliers are in particular information technology (IT) suppliers (who provide or support our IT systems, including data about you), companies for the management of business premises (take care of physical security in our business premises and therefore will be aware of your identity in order to you had access to our business facilities) and financial and accounting management service providers (who may process personal data about candidates for payroll and claims purposes) We also engage suppliers who provide IT technology services and solutions, including video interviews and skills assessment tools ( link)

To our business clients/future employers: we will share your personal data with our business clients who offer jobs/assignments that might interest you, or who are interested in your profile. They are bound by contractual and other confidentiality obligations in relation to your personal data

We will share your personal data with public authorities, police, regulatory or law enforcement authorities if we determine, based solely on our own assessment, that we are legally required or authorized to do so or if it would be reasonable to do so, and

As part of due diligence related to (or implementing) a merger, acquisition or other business transaction, we may need to provide your personal information to the potential seller or buyer and their advisors

Do we transfer your personal data outside the European Union?

We may transfer and process your personal data in one or more other countries within the European Union.

What are your rights?

  • The right to access and obtain a copy of your personal data being processed

You have the right to request confirmation as to whether we are processing any of your personal data. In the event that we process your personal data, you have the right to access your personal data and certain information about how we process it. In certain cases, you can request that we send you a copy of your data in electronic form. If there is a self-service system, we advise you to update your personal data yourself. In some limited circumstances, you also have the right to request the portability of your personal data, which means that we will provide it to a third party at your request.

  • The right to correct your personal data

If you prove that the personal data we have about you is incorrect, you can request the correction of incorrect personal data relating to you. We suggest that you access the self-service system and, if possible, directly update your personal data.

  • Right to erasure/”right to be forgotten”

In certain circumstances, you have the right to request the deletion of personal data relating to you. You can submit a request to delete personal data relating to you at any time, and Lugera will assess whether your request for deletion should be approved. The right to deletion is conditioned by legal rights or obligations that we must comply with in order to retain data. In cases where, in accordance with the law, we determine that a request to delete your personal data should be granted, Lugera will do so without undue delay. Please note that once your personal data is deleted – Lugera will no longer be able to provide services to you. If you want to re-register with Lugera, you will have to re-enter your personal data.

  • The right to limit

In certain circumstances, you have the right to restrict the processing of your personal data. However, in some cases such restriction of processing may limit the services you can receive from us.

  • The right to object

If Lugera’s processing of your personal data is based on Lugera’s legitimate interest (and on no other basis) or the processing relates to direct marketing, you have the right to object to such processing based on your particular situation.

In order to exercise your rights, contact us via the e-mail address osobnipodaci@lugera.hr

Regarding the processing of your personal data, you also have the right to complain to your local authority for the protection of personal data according to the place where you live or work, or where you believe that there has been a problem with your personal data

What is the protection of personal data in Lugera’s systems?

You are responsible for the safe storage of your Portal login information, and in particular the password that we have assigned to you or that you have chosen yourself. These login credentials are for your own use. You are not authorized to share your credentials or other account details with others.

How can you contact us?

If you have any questions regarding this Statement or would like additional information on how your personal data is protected (for example when we transfer it outside the European Union) and/or if you would like to contact Lugera’s personal data protection officer, please send us an e-mail at the address osobnipodaci@lugera.hr.

How do we change this Statement?

The terms of this Statement may change from time to time. We will announce any changes to this Statement through appropriate notices on this website or by contacting you through other communication channels.

The Lugera team

10.02.2023.