3 rd February 2022 V.3

Recruitment Privacy Statement Summary

This privacy statement explains what information we gather about you, what we use that information for and who we give that information to throughout the recruitment process. It also sets out your rights concerning your information and who you can contact for more information or queries as per detailed sections of this statement:
• Who this privacy statement applies to and what it covers
• What information we collect
• From where we collect the information
• How we use the information
• To whom we disclose your information
• Protection of your personal information
• For how long we keep the information
• Your rights
• Your right to complain
• Changes to this privacy statement
• Cookies

Who this privacy statement applies to and what it covers


1. This recruitment privacy statement is to let you know how Chilipay Limited (the “Company”), collects, processes and stores personal information about you as part of the recruitment process. Such information is processed for a number of reasons as detailed herein, such as your application, assessment, pre-employment screening, and your work permit requirements (if any).
2. This privacy statement aims to help you understand:
• What information is collected and from where
• Why we collect your personal information
• How it is processed throughout the recruitment procedure

3. Throughout this notice the term “processing” is used to cover all activities concerning your personal information, and can include any of the following actions in relation to your personal information:

• Collection
• Recording
• Organisation
• Structuring
• Storage
• Adaptation or alteration
• Retrieval
• Consultation
• Use
• Disclosure by transmission
• Dissemination or otherwise making available
• Alignment or combination
• Restriction
• Erasure or destruction


What information we collect


4. As part of the recruitment procedure, we need to process certain personal information about you. We only process your information as necessary for the purposes of progressing your application or as required by law or other regulatory requirements. Failure to provide the information request may prevent us from proceeding with your application.
Here are some examples of the type of personal information (‘Personal Data’) we may process.
• Personal details such as name, address, date and place of birth, personal email address
• Work history/job data; a copy of your CV, previous employers, positions, dates, etc.
• Compensation; basic salary, benefits, bonuses, etc.
• Education and work history including professional qualifications and skills
• Employer feedback/references to include regulated references where necessary
• Nationality/visa/work permit information (e.g., copies of Identity card and/or passport, National Insurance number, etc.)
• Photographs and images from recorded assessments or from onsite CCTV
• Results of pre-employment screening checks (e.g., credit history, criminal records checks where permitted under local law)
• Assessment results e.g., interview assessment, psychometric assessment results, pre-screening calls, technical test results
• Emergency contact details (e.g., Next of kin, contact details of referees, if any)

5. During the recruitment process we may also capture some sensitive Personal Data about you (e.g., personal health). We do this in order to make reasonable adjustments to enable our candidates to apply for jobs with us and to ensure that we comply with regulatory obligations placed on us with regard to our recruitment process


From where we collect the information


6. We collect Personal Data in the following ways:
Careers Websites
We collect your Personal Data when you submit a job application through our career page.
Social Network Sites
We collect Personal Data about you from other sources, including LinkedIn, Facebook and other social network sites when you choose to provide us with a link to your profile on any social network site as part of your job. We will collect the following Personal Data from the following social network sites:
• LinkedIn: Personal Data contained in the following fields: name, headline and summary, job title, current employer, employment history, recommendations and contact details made publicly available (such as phone number and email address). Your LinkedIn connections are not collected.
• Facebook: Personal Data contained in the following fields: first name, last name, email, employer and job title. Your “likes”, “comments”, “friends’ list/details” and “wall posts” are not collected.
• Other social network sites: Personal Data contained in the following fields: first name, last name and public website.

We will not collect your photographs or videos from any social network site unless you submit a photograph or video voluntarily as part of your recruitment application.
We may also obtain your contact details from publicly available sources, including content that you have made public on other social network sites or similar sites for professional purposes, to make initial contact with you for recruitment purposes. If we contact you in this way, you will be given the opportunity to object at any point in time to receiving any further information about career opportunities by contacting us on Jobs@chiliz.com
Recruitment Agencies
Your Personal Data may be provided to the Company by recruitment agencies with whom you have registered an interest in working for the Company. Where a recruitment agency refers you to us, a copy of your personal details shall be processed in our recruitment database based on the information provided and in accordance with this privacy notice.
Other sources
Whilst in most cases you will provide your Personal Data, we may also collect your Personal Data from third parties during the recruitment process such as references from previous employers, subject to receiving your prior consent.


From where we collect the information


7. We collect and use your Personal Data for legitimate human resources and business management reasons including:
• Identifying and evaluating candidates for potential employment, as well as for future roles that may become available
• Record-keeping in relation to recruiting and hiring
• Ensuring compliance with legal requirements, including diversity and inclusion requirements and practices
• Conducting criminal history checks as permitted by applicable law
• Protecting our legal rights to the extent authorized or permitted by law
• Emergency situations where the health or safety of one or more individuals may be endangered

8. We may also analyse your Personal Data or aggregated/anonymized data to improve our recruitment and hiring process and augment our ability to attract successful candidates. We will always make sure that our legitimate interest in doing so does not override your rights and freedoms with regard to the processing of personal data.
9. Following the recruitment process, we shall retain your Personal Data (including the CV) for a period of six (6) months based on legitimate grounds for the purpose of defending and/or responding to any legal claims that may arise. Moreover, subject to obtaining your prior consent, we may decide to process your Personal Data retained during the said six (6) month period for the purpose of considering you for potential future roles with the Company. Should you decide to no longer be contacted by the Company for potential future roles, please contact us at Jobs@chiliz.com


To whom we disclose your information


The Company will need to share your personal information internally (both in the country where you may work and in other countries in which the Company has operations) and may require to share it with some external parties or associates of the Company. Some of these third parties and associates will be located outside the European Economic Area (“EEA”), in a country not considered by the European Commission to offer an adequate level of protection. In such cases, apart from all appropriate safeguards that We implement, in any case, to protect Your Personal Data, We have put in place additional adequate measures. For example, We will ensure that the recipient is bound by the EU Standard Contractual Clauses (the EU Model Clauses) designed to protect Your Personal Data as though it were an intra-EEA transfer, and any additional measures as may be required. You are welcome to contact Us for more information regarding the adequate safeguards we have in place in relation to such data transfers. Your information will only be shared if it is necessary or required (for example in order to carry out pre-employment screening or apply for a work permit).
but such transfers will only take place after due notice is given to the Data Protection Commissioner in accordance with applicable law.
10. The recruitment process will involve:
• Assessing and processing your application
• Assessing your suitability (skills, strengths, experience for the role)
• Activities needed to complete the on-boarding and screening process should your application be successful

11. Your Personal Data may be disclosed to any of the following for any of the purposes outlined above:
• Internally, limiting access to what is required by each individual to perform their role in the recruitment process
• Professional advisers, third party service providers, agents or independent contractors providing services to the Company
• Any person to whom disclosure is allowed or required by Law and/or Regulation
• Any court, tribunal, Regulatory Authority or Governmental Entity
• Any criminal records bureau, credit bureau or credit reference agency when conducting background checks
• Third parties to whom we may transfer our rights and/or obligations under any agreement


Protection of your personal information


12. We use a range of physical, organizational, electronic and managerial measures to ensure that we keep your Personal Data secure, accurate and up to date. These measures include:
• Education and training to relevant staff to ensure they are aware of our privacy obligations when handling Personal Data
• Administrative and technical controls to restrict access to Personal Data on a ‘need to know’ basis
• Information security controls, including audit logging technologies, firewall and intrusion prevention systems, content filtering technologies, encryption and anti-virus software
• Physical security measures, such as staff security passes to access our premises

13. Although we use appropriate security measures once we have received your Personal Data, the transmission of data over the internet (including by e-mail) is never completely secure. We endeavour to protect Personal Data when transmitting data over the internet, but we cannot guarantee the security of such data transmitted to us or by us.


For how long we keep the information

Protection of your personal information

14. If you accept an offer of employment with us, any relevant Personal Data collected during your pre-employment period will become part of your personnel records and will be retained in accordance with specific country requirements and subject to our Employee Privacy Notice that shall be made available to you upon commencement of your employment.
15. If you are not selected for the position for any reason, we shall retain your Personal Data (including the CV) for a maximum period of six (6) months based on legitimate grounds for the purpose of defending and/or responding to any legal claims that may arise and, subject to receiving your consent, will process the retained Personal Data to contact you for future potential roles with the Company.
16. Personal Data collected is retained by the Company in accordance with the Company’s applicable policies.

Your Rights


17. You have various rights in relation to your Personal Data. In particular, you have a right to:
• Obtain confirmation that we are processing your Personal Data and request a copy of the Personal Data we hold about you
• Ask that we update the Personal Data we hold about you, or correct such Personal Data that you think is incorrect or incomplete
• Ask that we delete Personal Data that we hold about you, or restrict the way in which we use such Personal Data
• Withdraw consent to our processing of your Personal Data (to the extent that such processing is based on consent)
• Receive a copy of the Personal Data concerning you, which you have provided to us, in a structured, commonly used and machine-readable format and to transmit such Personal Data to another party (to the extent the processing is based on consent or a contract)
• Object to our processing of your Personal Data.
Withdrawing your consent or asking that we delete your Personal Data during the recruitment process would mean that we will be unable to continue processing your application to work with the Company.

18. To exercise any of your rights, file a complaint relating to your privacy or if you have any other questions about our use of your Personal Data, please email the following e-mail address – jobs@chiliz.com.


Your right to complain

19. If you are unhappy with the way we have handled your Personal Data or any privacy query or request that you have raised with us, you also have a right to complain to the Office of the Information and Data Protection Commissioner in Malta. Find out on the IDPC website how to file a complaint. For a list and contact details of national supervisory authorities within the EEA (Data Protection Authorities or DPAs), please visit https://edpb.europa.eu/about-edpb/board/members_en

Changes to this privacy statement

20. We reserve the right to modify or amend this privacy statement from time to time without giving any prior notice. If changes to this Notice have a significant impact on the nature of processing or data subjects concerned, we will do our best to notify you.
21. To let you know when we make changes to this privacy statement, we will amend the revision date at the top of this page. The new modified or amended privacy statement will apply from that revision date. Therefore, we encourage you to periodically review this statement to be informed about how we are protecting your information.

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