CANDIDATE  PRIVACY NOTICE

Scope

In this Notice “Azerion” means the specific Azerion company, which will use and maintain your personal data for recruitment related purposes. For more information on the entity you applied for, please see “Who is responsible for processing your Personal Data?” section below.

As a candidate, Azerion (“we”, “us” or “our”) respects your privacy and recognizes the importance of providing a secure environment for your personal data (that is any information that can be linked or attributed to you, “Personal Data“). We are committed to being transparent about how we collect and process your personal data. This Candidate Privacy Notice (“Notice”) describes how we collect and use personal data about you for recruitment related purposes.

This privacy notice (“Notice”) applies to potential candidates who applied for published job adverts or internally or externally referred to our recruiters or talent managers. It also applies to personal data we can otherwise collect; for example, when we search for new candidates through our screening process on LinkedIn.

Who are we?

Azerion is a high-growth digital entertainment and media platform while also acting as an intermediary service provider by providing a range of services to other parties such as media buyers, publishers and content providers.

Who is responsible for processing your Personal Data?

Azerion Tech Holding BV will be responsible for the processing of your personal data for the further steps in your application, if you are determined as eligible for next stages of the application.

What types of Personal Data do we process and how do we collect it?

When you apply for a vacancy, either directly from you or from a third party such as a website, we collect, use, store and transfer different kinds of personal data. If you require any special arrangements due to any disability or medical condition,  we will process “special categories” of personal data (such as data concerning health, religion, political opinions or philosophical beliefs, sexual preferences or orientation and the data regarding criminal convictions and offences) based on your explicit consent.

We also collect personal information from other external third parties such as references from former and current employees.

The information we collect depends on how you applied for a vacancy and the progress you made. We process the following types of your Personal Data:

Personal Data Provided by You

Uploaded Resume: In the recruitment process, you can apply to Azerion directly or apply via third party job application platforms such as LinkedIn or Indeed. In either type of application, you will be asked to upload your CV. From your resume we generally collect the following categories of personal data but it depends on information you prefer to add to your resume :

• Full name
• Email address
• Telephone number
• Address
• Details on your work/ professional experience (such as current or previous employment, employment period, job title position, responsibilities and/or achievements)
• Details on your education (such as educational institution, education period, completed education and/or acquired qualification),
• Information on further training (such as training courses attended/completed, certificates obtained, details on knowledge of languages,
• Other competences (if provided) (such as information technology skills or driving skills)
• References (if provided)
• Contents of your cover letter (if provided).

Interviews: If you are shortlisted for a position by our recruiters, you will be invited for an online interview via Google Meet. We need your email address to be able to send you an interview. If you prefer to join the interview via phone, your phone number will be processed by Google and will be visible to the recruiter during the interview.

During the interview additional questions can be asked by the interviewer which typically includes questions related to your previous employment, your role and daily tasks in your previous position, your previous salary, confirmation of previous information you shared (salary expectations and notice period or availability) and your visa status and location of residence if you require a work permit to be eligible to work in the European Economic Area (EEA). The interviewer can take notes and make an evaluation about you (we name all this information as interview data).

Correspondence: Depending on the process and necessity, our recruiters can contact you via email and ask for additional information which can include Personal Data.

Job Offers and Contracts: If you are accepted into a position, a job offer will be shared to you via email. Job offers include your name, salary, job title, benefits and information about your work permit (if applicable). If you accept the job offer, your electronic signature is required. If your job offer includes a work permit, your wet signature is requested.

We also hire freelancers through service agreements. If you are a freelancer, we share your service agreement via Docusign which includes your personal information (name, contact details and business name if you have a legal entity for conducting freelance work), service fee for the agreement and a description of the service. Your electronic signature is requested for signing the agreement.

Personal Data we collect from other third parties

Professional Social Network Profiles: In addition to the information you shared with us, we also check your public profile on professional social networks, such as LinkedIn, in order to verify if the information provided to us is correct and to know more about you.

Application from LinkedIn: When applying for a position via LinkedIn, you have the option to share information with our recruiters about your application; if you choose to share your information, LinkedIn will share your profile and information about your activity (whether you clicked on the apply button or actually applied) with us.

References:  While we have no referral system within Azerion, we review references and recommendations of candidates from our current and former employees as well as third-party individuals or entities. The information referrers share about you generally includes your name, link to your LinkedIn profile, your resume (if you shared with the referrer) and a recommendation from the referrer (on why you would be a suitable candidate Azerion or for a specific position).

Screening for candidates: Our recruiters also search LinkedIn for suitable candidates. During the search, we process Personal Data that you made available in your public profile. Please note that you are able to share additional information with recruiters (for example, your phone number may not be visible in your profile but you can prefer to make it available for recruiters on LinkedIn).

For What Purpose We Process Your Data?

When you apply for a position or we reach out to you regarding a vacancy, we use the information we collect for the following purposes:

• to ensure business continuity
• to be able to reach out to talents around the globe
• to have more information about candidates
• to have a healthy and fair recruitment process
• to assess skills, qualifications, and suitability for a position
• to carry out reference checks, if applicable
• to keep records related to our recruitment process
• to communicate with candidates about the recruitment process
• to search for suitable candidates for open positions
• to take further steps to enter into an employment contract
• to provide necessary visas or work permits for eligibility to work in the EEA (or to verify the right to work)
• to determine the legal requirements for processing of Personal Data
• to respond to requests related to data subject rights
• to comply with our legal obligations

On Which legal basis do we process your Personal Data?

We process your Personal Data for the purposes described in this Privacy Notice, based on the following legal grounds:

Your Consent: We process your Personal Data if you have provided your consent for a specific purpose. For example, we will ask for your consent in order to keep your personal data for future recruitment purposes. You have the right to withdraw your consent at any time by contacting us. Please note that this will not affect any processing carried out before you withdraw your consent.

Performance of a contract: We process your Personal Data for the performance of a contract to which you are a party, for example, the correspondence with you in order to move forward with the recruitment process or the job offer we send.

Compliance with legal obligations to which we are subject: We process your Personal Data to comply with legal obligations for example, for compliance with labour law or potential legal disputes.

Legitimate interests: We also process your Personal Data to the extent that the processing is necessary for our legitimate interests or those of third parties while applying appropriate safeguards that protect your privacy. For example, it is in our legitimate interest to decide whether to appoint you to the work you have applied for, since it would be beneficial to our business to appoint someone to carry out that work.

With whom do we share your Personal Data?

We will not disclose your Personal Data to any party who is not authorized to process them. To manage our recruitment processes, we will share your Personal Data internally with members of our responsible departments (such as department managers or within the HR team) in each case only if access to your Personal Data is necessary for the performance of their roles.

The data that we collect or receive can be processed on our behalf by third-party service providers. We also use processors to help us with recruitment processes. Prior to engaging any third party processor, we perform due diligence to evaluate their privacy, security and confidentiality practices, and execute an agreement around data privacy and security.  Third parties will only process your Personal Data on our instructions and where they have agreed to treat the information confidentially and to keep it secure. We do not allow our third party service providers to use your Personal Data for their own purposes. We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorized way, altered or disclosed. We disclose your Personal Data to the following recipients or categories of recipients. Please note that this Policy does not apply to those parties, and we are not responsible for their collection or use of information:

Electronic Signature and Agreement Cloud: We use a third-party tool for signing and keeping employee contracts. Once an employee contract is shared with you, we kindly ask you to sign the contract with your electronic signature and then the contact is kept in the agreement cloud.

Law enforcement, government authorities or courts: We provide personal data to any competent law enforcement body, regulatory, government agency, court or other third party when we believe disclosure is necessary as a matter of applicable law or regulation, to exercise, establish or defend our legal rights, or to protect your vital interests or those of any other person.

Other third parties: We also disclose your Personal Data in the event of any contemplated or actual reorganization, merger, sale, joint venture, assignment, transfer or other disposition of all or any portion of our business or assets (including in any insolvency or similar proceedings).

Below,, you will see an overview of the third parties we share your Personal Data with, or that may share your Personal Data with us.

Where will my Personal Data be processed?

With regard to certain activities described in this Privacy Notice, your personal data will be processed outside the EU/EEA. We have implemented appropriate safeguards to protect your Personal Data when it is transferred outside the EU/EEA, including the execution of the European Commission’s standard data protection clauses (also known as Model Clauses) to provide safeguards for your Personal Data. You have the right to request a copy of Standard Contractual Clauses for free of charge.

For further information on, or to receive a copy of, the adequate safeguards adopted by us for the international transfer of your Personal Data, please contact us by email at dpo@azerion.com. We will process any request in line with any local laws and our policies and procedures.

How do we protect your Personal Data?

We have implemented appropriate technical and organizational security measures designed to protect your Personal Data against accidental, unlawful or unauthorized destruction, loss, alteration, access, disclosure or use. We update and test our security standards on an ongoing basis. In addition, we take reasonable steps to assure that third parties to whom we transfer your Personal Data provide sufficient protection of Personal Data.

How long do we store your Personal Data?

We will not retain your Personal Data longer than necessary to fulfill the purposes for which the data was collected or to fulfill our legal obligations or necessary for the establishment, exercise of defence of legal claims or resolving disputes. In addition to this, we determine our retention periods based on our accountability obligations (to be able to demonstrate that we complied with our obligations, e.g. preserving records when you exercised one of your data subject rights), statutory requirements in countries that you applied for, the need of Personal Data for any reference to our future actions and the need of Personal Data for business or internal processes. Afterwards, we will delete or anonymize your Personal Data. Additional information on how long your Personal Data is stored by our service partners can be found in the respective third-party list available above.

What are your rights in respect of your Personal Data?

To the extent permitted by applicable data protection laws and regulations, you have the following rights in relation to your Personal Data:

• Access the Personal Data we hold about you, including information such as, for example, the source and categories of data, the processing purposes, the recipients (or categories thereof) and the respective retention period.
• Request an update or correction of your Personal Data so that it is always accurate.
• Receive your Personal Data in a structured, commonly used and machine-readable format, including the right to transfer your Personal Data to another data controller.
• Request the deletion of your Personal Data if you believe that retention is no longer necessary for the purposes indicated above.
• Restrict the processing of your Personal Data for example, if you have contested the accuracy of your Personal Data, and for a period of time that is sufficient to allow us to verify its accuracy.
• Withdraw your consent at any time if your Personal Data is processed with your consent. Please note that this will not affect the lawfulness of data processing based on consent granted prior to its withdrawal.
• Object to the processing on specific grounds relating to your particular situation, in the event and to the extent that we process your Personal Data based on our legitimate interests. In such cases we will no longer process your Personal Data unless we have compelling legitimate grounds for the processing which override your interests, rights and freedoms, or for the establishment, exercise or defence of legal claims. You also have the right to object where we are processing your Personal Data for profiling. In that case, we will stop processing your Personal Data for such purposes.

You can exercise these rights by sending a request to the contact details set out below, providing your name, your email address as well as a description of your request.

If you believe we have not complied with our obligations under applicable data protection laws and regulations, you can lodge a complaint with a competent data protection authority, for example, the Autoriteit Persoonsgegevens in the Netherlands.

How can you contact us?

If you have any queries about this Privacy Notice or how we use your Personal Data, please contact the recruiter responsible for the vacancy our Data Protection Officer via e-mail to dpo@azerion.com You can also send a written request to Azerion, Boeing Avenue 30 1119 PE, Schiphol-Rijk, The Netherlands.

How often do we update this Privacy Notice?

We regularly review and update this Privacy Notice. When there is an important change that will have a relevant impact on the processing of your Personal Data, we will inform you by email if we have your email address.

Third-Party List