Applicant Privacy Notice

Refeyn respects your privacy and is committed to protecting your Personal Data.

The purpose of this Privacy Notice is to provide our applicants with information about how and why we process their Personal Data and to tell them about their privacy rights and how the law protects them.

With that in mind, this Privacy Notice is designed to describe:

Who we are and how to contact us

Your rights relating to your Personal Data

What Personal Data we collect

Personal Data from Third-Party Sources

How we use your Personal Data and why

Who we share your Personal Data with

Data transfers

How we keep your Personal Data secure

How long we store your Personal Data

No automated decisions

Appendix – Detailed Processing Information

Refeyn Ltd., and its subsidiary, Refeyn GmbH (together, “Refeyn”, “we”, “us” or “our”) are the Controllers (as defined in the GDPR) for the purposes of the Processing of your Personal Data described in this Privacy Notice.

Refeyn Ltd.’s address is: Address: Unit 9, Trade City, Sandy Ln W, Oxford OX4 6FF, United Kingdom

Refeyn GmbH’s address is: c/o BRL Boege Rohde Leubbehuesen, Pariser Platz 4 A, 10117 Berlin

To contact us, you can either:

• email us at privacy@refeyn.com; or
• write to us at the postal address noted above

Under certain circumstances, by law you have the right to:

• Request access to your Personal Data. This enables you to receive a copy of the Personal Data we hold about you and to check that we are lawfully processing it.
• Request correction of the Personal Data that we hold about you. This enables you to have any incomplete or inaccurate information we hold about you corrected.
• Request erasure of your Personal Data. This enables you to ask us to delete or remove Personal Data where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your Personal Data where you have exercised your right to object to processing (see below).
• Object to processing of your Personal Data. This right exists where we are relying on a Legitimate Interest (defined below) as the legal basis for our processing and there is something about your particular situation, which makes you want to object to processing on this ground.
• Request the restriction of processing of your Personal Data. This enables you to ask us to suspend the processing of Personal Data about you, for example if you want us to establish its accuracy or the reason for processing it.
• Request the transfer of your Personal Data. We will provide to you, or a third party you have chosen, your Personal Data which you have provided to us, in a structured, commonly used, machine-readable format. Note that this right only applies to Personal Data we process by automated means which you initially provided consent for us to use or where we used the information to perform a contract with you.
• Withdraw consent. This right only exists where we are relying on consent to process your Personal Data.

If you want to exercise any of the rights described above, please contact us using the contact details shown in the “Who We Are and How to Contact Us” section above.

We may need to request specific information from you to help us confirm your identity and verify your right to access your Personal Data (or to exercise any of your other rights). This is a security measure to ensure that Personal Data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information to assist us in responding to your request.

Typically, you will not have to pay a fee to access your Personal Data (or to exercise any of the other rights). However, except in relation to withdrawal of your consent (see above), we may charge a reasonable fee if your request is clearly unfounded or excessive, or, we may refuse to comply with your request in these circumstances.

Please also note that in certain circumstances the rights above will not apply and/or in certain circumstances some categories of Personal Data will be exempt from the scope of those rights. We will notify you where this is the case.

We try to respond to all legitimate requests within one month. Occasionally it may take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.

If you would like to make a complaint regarding this Privacy Notice, you can contact us using the contact details shown in the “Who We Are and How to Contact Us” section above. We will reply to your complaint as soon as we can.

If you feel that your complaint has not been adequately resolved, please note that the GDPR also gives you the right to make a complaint directly to the competent data protection authority:

UK Information Commissioner’s Office

Water Lane, Wycliffe House

Wilmslow - Cheshire SK9 5AF

Telephone: +44 303 123 1113

Website: https://ico.org.uk/make-a-complaint/]

or

Berliner Beauftragte für Datenschutz und Informationsfreiheit

Alt-Moabit 59-61

10555 Berlin

Eingang: Alt-Moabit 6

mailbox@datenschutz-berlin.de

All the Personal Data we collect, both from you and from third parties about you, is outlined in the table below.

 

Identity Data

First name, middle name(s), surname, title, national identification and/or passport details, national insurance / social security number or other tax-related information, driver’s licence, photographs.

Contact Data

Your home address, work address, email address and telephone numbers.

Biographical Data

First name, middle name(s), surname, maiden name, marital/civil partnership status, title, date of birth, gender, education history, professional history, professional qualifications and memberships, references, information relating to references such as referees’ names and contact details, information contained within letters of application and CVs, language proficiencies and other skills, certifications, certification expiration dates and information necessary to complete background checks.

Immigration Data

National identification and/or passport number, details of residency and/or work permit and other information that would allow us to verify your eligibility to work for us in your relevant role.

Engagement Data

Title and description of your prior roles, department, work location, dates of prior employment/engagement, employment/engagement status and type (e.g., full-time/part-time), terms of employment/engagement, contracts, work history (current, past, or prospective), training and learning program participation, termination date(s) and reason, length of service, willingness to relocate, current salary, desired salary, employment/engagement preferences, information necessary to complete background checks, drug and/or alcohol tests, and other screens permitted by law.

Facilities Data

Information about your access to Refeyn offices and facilities (e.g., keycard scans and security camera footage).

Other Data

This might include data not listed above that you provide to us, such as your feedback and survey responses where you choose to identify yourself.

Special categories of Personal Data 

To the extent permitted by applicable laws we may also collect and process a limited amount of Personal Data falling into special categories, sometimes called “sensitive personal data”. This term includes information relating to such matters as physical or mental health (including details of accommodations or adjustments) or ethnicity data.

In addition to the Personal Data that we collect from you directly, in certain circumstances, we may also collect Personal Data from third-party sources. Please see below for a list of the types of third-party sources from which we may collect your Personal Data (including whether the source of that Personal Data is publicly available):

• Agencies or recruiters that refer you to us.
• Job board websites you may use to apply for a job with us.
• Prior employers, companies or persons, when they provide us with references.
• Professional references that you authorise us to contact.
• Providers of background check, credit check, or other screening services (where permitted by law).
• Your social media profiles or other publicly-available sources (information gathered from these sources is publicly-available).

In respect of each of the purposes for which we use your Personal Data, the GDPR requires us to ensure that we have a “legal basis” for that use. Most commonly, we will rely on one of the following legal bases:

• Where we need to take steps at your request prior to entering into a contract with you (“Contractual Necessity”).
• Where we need to comply with a legal or regulatory obligation (“Compliance with Law”).
• Where it is necessary for our legitimate interests and your interests and fundamental rights do not override those interests (“Legitimate Interests”). More detail about the specific legitimate interests pursued in respect of each purpose we use your Personal Data for is set out in the table below.

The table below shows at a very high-level how we may use your Personal Data and the relevant legal bases we rely upon for that use.

For more information – see the Appendix to this Notice. In that Appendix, we have set out in detail the purposes for which we may use your Personal Data, the legal bases we rely on in respect of each such purpose (including details of any legitimate interests pursued, where applicable), and the categories of Personal Data typically used for the relevant purpose.

 

We have put in place appropriate security measures to prevent your Personal Data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed.

We limit access to your Personal Data to those employees and other staff who have a business need to have such access. All such people are subject to a contractual duty of confidentiality.

We have put in place procedures to deal with any actual or suspected Personal Data breach. In the event of any such breach, we have systems in place to work with applicable regulators. In addition, in certain circumstances (e.g., where we are legally required to do so) we may notify you of breaches affecting your Personal Data.

Refeyn’s retention periods for Personal Data are based on business needs and legal requirements.  We retain Personal Data for as long as is necessary for the processing purpose(s) for which it was collected, as set out in this Privacy Notice, and any other permissible, related purposes. For example, we may retain certain information to comply with regulatory requirements regarding the retention of such data, or in the event a litigation hold is imposed. 

When Personal Data is no longer needed, we either irreversibly anonymise the data (and we may further retain and use the anonymised information) or securely destroy the Personal Data.

Refeyn does not envisage that you will be subject to decisions or profiling that will have a significant impact on you based solely on automated decision-making.