Privacy Notice for Job Candidates or Cooperation

Date of publication: 07-06-2024

About the Notice and Noda

This notice explains how Noda treats the personal data of potential employees, interns who applied or were invited to apply for open positions at Noda or to cooperate with Noda as individual contractors.

Noda is the controller of your personal data. The information and contact details of Noda are available at the end of this notice.

Why does Noda need your Data?

Noda uses your personal data to find a person suitable for a currently or future open position at Noda or its group companies or to receive services that you provide.

If you are an individual contractor Noda can use your personal data to perform a compliance check depending on the requirements of the applicable law (for example, in the sphere of money-laundering). If you do not provide Noda with personal data required for such compliance checks, Noda might not be able to work with you as a contactor.

If Noda considers that you are a matching candidate for a job, internship or cooperation, Noda will need your personal data to provide you with a job, internship or cooperation offer.

In cases where you submit a request, complaint or there might be a potential dispute, Noda might use your personal data to resolve the issue.

How does Noda Treat your Data?

This section describes the personal data used for the said purposes, legal bases for using them and retention terms.

A. Finding a person suitable for a currently or future open position at Noda or its group companies and providing you with an offer in some cases

Personal data: LinkedIn profile information, information provided in your CV, place of residence, agreement type, email, experience, education, references, image (can be seen during a video call), assignments performed for Noda, position description, remuneration

Legal basis: a) legitimate interest in ensuring that Noda has qualitative human resources; b) Consent (for keeping the same data for the same purpose for a longer period)

Retention term: if there was no offer or you did not accept it, the data is stored for

• up to 1 year based on your permission for a specific or similar vacant positions

• up to 5 years based on your permission for future job opportunities 

B. Compliance check for individual contractors

Personal data: name, contact information

Legal basis: compliance with regulatory requirements

Retention term: up to 10 years after the cooperation termination

C. Handling requests and resolving disputes

Personal data: any personal data related to the request or dispute

Legal basis: legitimate interest to find a solution and protect interests of Noda, data subject and related parties

Retention term: up to 10 years

If the offer is accepted, the data is retained in accordance with the employee privacy notice provided to you after the offer has been accepted.

Sources and Recipients of Data

Noda receives your Personal Data from you, your LinkedIn and similar social media profiles, recruiters and referring parties. In cases where you act as an individual contractor, Noda also can get your personal data from different compliance services providers.

Noda can also share your personal data with the following recipients:

• Noda group companies

• Data storage services providers

• Electronic communication services providers (such as email services)

• Recruiters and similar services providers, including HR and recruitment platforms

• LinkedIn and similar social media platforms

• Compliance services providers

• Other outsource services providers (such as legal consultants, event organizers and others)

• Regulators, enforcement authorities, courts, arbitration organizations and other similar public or private entities

International Transfers

Noda does not generally transfer personal data outside of the European Union and European Economic Area within the recruitment process. However, it can happen where you or referencing parties are located outside of the said territories. Also, such transfers can take place in the event of compliance checks for individual contractors. Where such transfers happen, we rely on the guarantees provided by the applicable legal acts, for example, as the EU General Data Protection Regulation (GDPR) provides: the adequacy decisions of the European Commission (Article 45 of the GDPR), standard contractual clauses and other safeguards provided by Articles 46 and 49 of the GDPR. If personal data is transferred to the US, Noda may rely on the corresponding personal data transfer framework in force. In certain cases, depending on the involved Noda entity, Noda might also rely on the UK International Data Transfer Addendum to the EU Commission Standard Contractual Clauses.

Data Protection Rights

You can request to:

• access to your personal data or issue a copy of your personal data;

• correct your personal data, if there are any mistakes;

• delete your personal data, where Noda’s legitimate interest is not in force. You cannot request to delete the data used due to the regulatory requirements;

• object against the using of your personal data, where it is based on legitimate interests;

• that the processing of your personal data is restricted;

• submit a complaint to Noda by using the contact information provided below. If Noda does not comply with your request, you can also submit a complaint to a data protection supervisory authority.

Contact information

The controller of your personal data is Noda entity that you are proposed to enter into an agreement with or that is looking for a job candidate or a potential cooperation partner. For more information, please contact Noda by using the email below.

If you have any questions or requests with regards to your personal data, please use the following contact information: dpo@noda.live