Privacy Policy

JOBBRELLA AB

Last updated 2024-02-01

Scope of this policy

This privacy policy (“Policy”) describes how Jobbrella AB (559457-4898) (hereafter Jobbrella, we, us, our) collects, uses, and discloses your personal information when you visit our website, www.jobbrella.se, or when you use any of the services we provide (collectively, the “Services”).

Please read this Policy carefully to understand how we handle information that identifies or is capable of identifying you (“personal information”). Please read this Policy prior to using our Services, in order to understand how we collect, use, and disclose (together “process”) your personal information as well as the privacy rights that may apply to you.

This Policy covers our treatment of the personal information that we collect when you use the Services. It also applies to personal information collected offline. This Policy does not apply to the practices of entities that we do not own or control, such as our clients; activities of individuals that we do not employ or manage; or other websites or digital services to which this Policy does not link. Unless otherwise indicated, the information below applies to the Services generally.

We only collect and process personal data about you when we need to, and for a specific purpose – which of course is different depending on your relationship with us.

Please refer to the category below that best matches you, to learn more about why we need your personal data, what data is needed for that purpose, and how we process it. You will also learn under what circumstances we share that data with suppliers or partners.

LEGAL BASES THAT APPLY TO OUR PURPOSES

In order for us to be able to process your personal data, we must have a legal basis for each personal data processing. There are six available legal bases under the General Data Protection Regulation (EU) 2016/679 (GDPR) and there are four that are relevant to us: Consent  You have given us permission to process your personal data for a specific purpose, being fully informed about what data we process, how, and why. You can withdraw your consent at any time, after which we will stop any process for this purpose, without a negative impact on any contract with us. Agreement You have entered into an agreement with us or have asked us to do so. We will manage your personal data to fulfill the terms and conditions of the agreement. Legal obligation We, as a company, must process your personal data in order to comply with legislation. Legitimate interest When we have a legitimate interest in processing your data, the purpose is similar to that which it was collected, and while there is little risk of the processing infringing on your privacy, we may rely on the legal basis of legitimate interest. Before we process your personal information to pursue our legitimate interests for the purposes set out above, we determine if such processing is necessary and carefully consider the impact of our processing activities on your fundamental rights and freedoms. On balance, we have determined that such processing is necessary for our legitimate interests and that the processing which we conduct does not adversely impact on your rights and freedoms.

Please refer to the relevant category of data subjects below to learn more about what specific legal basis we use for each purpose.

YOUR RIGHTS

You may have the right to request access to, rectification, or erasure of your personal information, or restriction of processing or object to processing of your personal information, as well as the right to data portability, in accordance with applicable laws. The following is a summary of what these rights involve:

• The right of access enables you to receive a copy of your personal information.

• The right to rectification enables you to correct any inaccurate or incomplete personal information. We encourage you to review your account information regularly to ensure it is accurate and up to date. 

• The right to erasure enables you to ask us to delete your personal information in certain circumstances, for example where it is no longer necessary for us to process it or if you consider it is being unlawfully processed. Your request can be refused if the processing is necessary to comply with a legal obligation or for the exercise or to defend legal claims.

• The right to restrict processing enables you to ask us to restrict the processing of your personal information in certain circumstances, for example if you want us to verify its accuracy or our legitimate interests in processing it.

• The right to object enables you to object to your personal information being processed on the basis of our legitimate interests (or those of a third party). We will stop such processing unless there are compelling legitimate grounds for the processing or the processing is necessary for the exercise or defence of legal claims. You also have the right to object to us processing your personal information for direct marketing purposes. We will stop such processing as soon as we receive your request. There are no exemptions or reasons for us to refuse. 

• The right to data portability enables you to request us to transmit personal information, that you provided to us, to a third party without hindrance, or to give you a copy of it so that you can transmit it to a third party.

• The right to withdraw consent enables you, at any time, to withdraw your consent to your personal information being processed where the processing is based on your consent. Withdrawing your consent does not affect the lawfulness of processing based on consent before its withdrawal. 

Note that these rights are not absolute and may therefore be subject to applicable exceptions, such as the interest of other individuals, or when the processing of is necessary to comply with a legal obligation or for the exercise or defence of legal claims. Any requests to exercise your rights should be addressed to [email protected]. We will respond to your request in writing, including by electronic means, within 30 days of receipt of your request. We may request proof of identification to verify your request. We have the right to refuse your request in some circumstances, which we will explain to you in our response. 

You also have the right to lodge a complaint with the data protection authority, in particular in your place of residence, place of work or place of an alleged infringement, if you consider that our processing of your personal information data infringes applicable data protection laws.

We will inform you in advance if we intend to further process or disclose your personal information for a purpose other than the purposes set out in this data privacy policy. We take all reasonable steps, as required by law, to assure the safety, privacy and integrity of such data and information and, where appropriate, enter into contracts with such third parties to protect the privacy and integrity of such data and any information supplied. You can obtain further information concerning recipients of your personal information from, [email protected], where applicable.

DATA SUBJECTS

1. Candidates

When you apply for a job at a company other than us, which uses our Service, that company is generally considered the data controller for personal data processing. They are responsible to inform you about this, please check their privacy policy. However, we also collect a limited amount of personal data about you, and uses it for its own purposes in relation to the provision of our Services to our customers. When doing so, we act as a data controller. 

Why do we process your personal data?

• Perform our Services to our customers, including manage your application for job vacancies, which means that we evaluate your competences – professional knowledge and experience, talent, motivation, and personality.

• Continuous communication about the jobs you applied for.

• Other statistical purposes, e.g. to maintain and develop the quality of our services.

• For development and research purposes.

Personal data that we collect and process

• Name

• E-mail address.

• Mobile phone number.

• Competences and previous experience through your CV, your LinkedIn or Facebook profile (if you registered your application through any of these channels), through interviews and based on the knowledge and experience you inform us of.

• Test results, if you performed tests as part of the recruitment process.

• Photography, if you included one in your CV.

• Personal identity number, if you are a final candidate in a process, we need to be able to validate your identity.

• Other personal data you choose to share with us in your CV and possibly other uploaded documents.*

* We advise you not to provide us with sensitive personal information regarding ethnic origin; political opinions; religious or philosophical beliefs; membership of trade union, information on health, and information on gender affiliation. We, therefore, reserve the right, without your consent, to delete all the above information, as well as personal information relating to others than yourself.

How we collect your personal data

From you: We received the information from you when you applied for a job.

By us:

• We have collected the data when you have e-mailed, phoned us, or provided contact information when you asked us to contact you.

• We have collected the data automatically during your visits to our website.

From third party:

• We have collected the data from other sources – eg. reference persons, our customers, or job sites such as LinkedIn.

How we disclose your personal data  We share your personal data with sub-contractors (sub-processors) who perform services on our behalf (such as technical, administrative, market-related, or other services) when required for the purposes mentioned above. These suppliers may not use your personal data for their own purposes, which we have regulated in agreements with these suppliers.

Your personal data may also be disclosed when required by law such as, for example, the Discrimination Act or to the Data Protection Authority.

Since our customers uses our Service for parts of their recruiting process, they are themselves controlling the purpose and means and are therefore the data controller (they will inform you about this themselves).

Legal basis for our processing Most of this processing is carried out in our legitimate interests of meeting the purposes described above, to conduct our Services and sometimes based on your consent e.g. where you opt-in to receive marketing from us or third parties.

Data retention We do not retain your information for longer than is necessary for the purpose for which it was collected, unless we are entitled or obliged by law to retain it longer. Retention periods may vary depending on the type of information and the context and purpose of its collection and use. Our retention periods are based on the nature of our relationship with you, legal or regulatory requirements and our business needs. We will regularly review the necessity of the retention of your personal information. We do not keep your personal data for undefined purposes.

2. Employees

When you apply for a job at Jobbrella, we are the data controller of the personal data processing as described below.

Why do we process your personal data?

When you become an employee of Jobbrella, you enter into an agreement with us as an employer. We are also required to process personal data about you to comply with several different types of legislation that we as an employer are subject to.

Personal data that we collect and process

• Name.

• Address.

• Phone number.

• Personal identity number.

• E-mail address.

• Bank account number.

• Salary, pension and benefits.

• Employment history and time reporting.

• Medical history.

• Photographs.

• Family Relationship – Nearest relative as emergency contact. Number of children and their birth year if you have small children for whom you are entitled to compensation from the Swedish Social Insurance Agency.

• Information related to your achievements such as annual follow-ups and completed courses.

Please note that the above list is not exhaustive and other information may be considered.

How we collect your personal data

From you:

• You have stated these yourself in the recruitment process and in connection with the start of your employment, as well as during your employment.

By us:

• The data has been generated associated with your employment. For example, data about your attendance, sick leave and vacation.

From third parties:

• The data has come from other sources such as authorities, third-party suppliers who provide services for us (salaries), and from reference persons and customers.

How we disclose your personal data 

We share your personal data with third party providers that we use to perform services on our behalf (such as technical, administrative, market related, or other services) when required for the purpose of managing your employment. These third-party suppliers may not use your personal data for their own purposes, which we have regulated in agreements with these suppliers.

We share data within our company group, based on our legitimate interest and for administration purposes.

Legal basis for our processing

As our employee, you have an employment contract. When you later end your employment, we must, according to Swedish law, further process some of your personal data, for example to ensure you get the right pension (legal obligation). We may also keep some of your personal data based on your consent, to act as a reference for future employment elsewhere.

Data retention 

We will keep your personal data as long as is needed to fulfill our obligations from your employment, to fulfill legal obligations, or as long as your consent is valid, based on the purpose and legal basis of the processing. We do not keep data just for the sake of keeping data.

3. Suppliers

Why do we process your personal data?

We may process personal data about you (as an employee of our supplier), to maintain our professional relationship and ensure continued services between our companies. This may apply to personal data concerning customer managers, support functions, service personnel, finance department or other key personnel.

Personal data that we collect and process

• Name.

• Title.

• Phone number for work.

• Mail address to work.

How we collect your personal data

From you:

• Through emails and information by phone.

By us:

• We have found the data on your company’s website.

From third party:

• We have received the data from your employer or colleague.

How we disclose your personal data 

We share your personal data with sub-contractors (sub processors) who perform services on our behalf (such as administrative, market-related or other services) when required for the purposes mentioned above. These suppliers may not use your personal data for their own purposes, which we have regulated in agreements with these suppliers.

Legal basis for our processing

We have a legitimate interest based on a contract with your employer.

Data retention

We will save your data for as long as you are an important contact for us regarding our professional relationship. If it comes to our knowledge that your duties at your company have changed or that you no longer are employed, the data will be deleted.

4. Customers and potential customers

Why do we process your personal data?

Customer: If you work at one of our customer companies, as a recruitment manager or as a contact person, we process certain personal data to be able to maintain our professional relationship and to provide the service to our customers as well as keep you updated by periodic emails. Further, to comply with legislation eg. Book-keeping Act and tax law.

Potential customers: To be able to offer our services to companies that don’t know about us or don’t buy services from us, we collect contact information for key people at companies that we want to be able to contact and process for marketing purposes.

Customer service requests: Information you provide helps us respond to your customer service request and support needs more efficiently.

Personal data that we collect and process

• Name.

• Title (your workplace/where you work).

• Phone number for work.

• Mail address to work.

• IP address.

• Notes on our cooperation and / or dialogues.

How we collect your personal data

From you:

• When you create an account on our website.

• By visiting our website, signing up for and visiting any of our events.

• Subscribing to newsletters.

By us:

• We will continuously update our CRM database. This means that we continuously work on having an updated and up-to-date database of current and correct contact information. This will be done through contacts with you by phone, e-mail, social media and in personal meetings, but also through external sources.

• Notes about our discussions and decisions.

From third party:

• From your employer or colleague.

• We have found the data on the Internet. It can be from the company’s website or at job sites such as LinkedIn (publicly accessible sources).

• We have purchased data from external sources.

How we disclose your personal data 

We share your personal data with sub-contractors that we use to perform services on our behalf (such as technical, administrative, market-related or other services) when required for the purpose of managing our collaboration or for us to process you as a potential customer. These sub-contractors may not use your personal data for their own purposes, which we have regulated in agreements with these suppliers.

We share data within our company group, based on our legitimate interest and for administration purposes.

Legal basis for our processing

When we provide services as well as market ourselves to other companies and process personal data of their employees, we use legitimate interest as a legal basis. When you have created an account with us and accepted the terms and conditions, we will process your personal data based upon your consent. For personal data processing to comply with legislation, eg. Book-keeping Act, we base the processing on legal obligations.

Data retention

As long as you are an important contact for us regarding our professional relationship, we will save your data. If it comes to our knowledge that your duties at your company have changed or that you no longer are employed, the data will be deleted. For the processing based upon consent, we will process your personal data until you revoke your consent.

5. Other data subjects

Why do we use your personal data?

References in an employment procedure: References are contacted in a recruitment process. For us to be able to contact the reference we need name and telephone number. In most cases, we also need to know the reference’s position and relationship with the candidate (e.g. manager).

Emergency contacts / closest relative of employees: When someone is employed, we collect a so-called emergency contact, a close relative of the employee whom we can contact if it should happen during working hours or on commitment / travels that takes place within the framework of work.

Social media contacts: People who contact us on social media, by phone, website (including chat) and by email.

If you as an individual have contacted us with questions of any kind, we may save your personal data in order to be able to contact you later on.

Partners and re-sellers: Collaborators, colleagues in our industry, people in professional networks, media contacts etc. We may save your contact information for future communication. We, as a company, must be able to save this information in order to effectively operate in the market and create relationships that promote our and other companies’ growth.

Website visitor: To improve our website, we may use feedback you provide to improve our products and services 

Survey participant: To run a promotion, contest, survey or other website feature or to send information you agreed to receive about topics we think will be of interest to you.

Newsletter / periodic email subscribers: If you decide to opt-in to our mailing list, you will receive emails that may include company news, updates, related products or service information, etc.

Personal data that we collect and process

We may collect personal data from you in a variety of ways, including but not limited to, when you visit our site, register on the website, subscribe to the newsletter, respond to a survey, fill out a form, and in connection with other activities, services, features or resources we make available on our website. We may collect, as appropriate, name, email address and phone number.

We may collect non personal identification information about visitors whenever they interact with our website. Non-personal identification information may include the browser name, the type of computer and technical information about visitors means of connection to our website, such as the operating system and the Internet service providers utilized and other similar information.

How we collect your personal data

From you:

• You have contacted us via social media when you commented on something or was asking us questions within these media.

• We have received personal data from you personally, by mail or business card.

• We have received personal data from you when asking us to be contacted or having contacted us via telephone, social media, website (including chat), info-mail or personal mailboxes.

By us:

• We have found the data in our own individual networks on eg. LinkedIn.

From third party:

• We have received personal data from your employer or colleague.

• We have received personal data from job seekers for reference purposes.

• Someone named you as an emergency contact.

How we disclose your personal data 

We distinguish between people who are in contact with us as a private person and people who are in contact with us as a representative from another company. Personal data for private persons, we are more restrictive with and generally don’t share these data with anyone external. When it comes to personal data for professionals, we are not as restrictive, as sharing contacts within the professional network promotes business and corporate growth. We have the opinion that personal data regarding representatives from a company is not as sensitive to privacy as personal data relating to a private person.

We use sub-contractors that perform services on our behalf (such as technical, administrative, market-related or other services) when required for the purpose of managing contacts with other stakeholders. These sub-contractors may not use your personal data for their own purposes, which we have regulated in agreements with these suppliers.

We share data within our company group based on our legitimate interest and for administration purposes.

Legal basis for our processing

The legal basis for processing personal data for this group may vary depending on in what respect our contact has arisen. In most cases, we will use legitimate interest as a legal basis. If we see that the individual who’s personal data, we processed ends up in one of the other interest groups, the legal basis that is applicable to that group will apply.

If at any time you would like to unsubscribe from receiving future emails, we include detailed unsubscribe instructions at the bottom of each email or you may contact us via our website.

Data retention

References in a recruitment process: The references’ contact details will be saved solely regarding the candidate who has been hired. We save the data and the reference protocol together with the candidate’s other documents for 24 months due to the provisions of the Discrimination Act and possible appeals.

Emergency contacts / closest relatives of employees: Saved as long as someone is employed. The employee is responsible for ensuring that the data is correct and updated.

Social media contacts: Personal data is processed as long as the data is needed to enable and maintain communication.

Partners and re-sellers: During the process of establishing a professional relationship and contact in marketing purposes we will keep the data as long as we maintain a legitimate interest.

Website visitor: We process cookies according to our separate cookie policy. Apart from cookies that are needed for the website to run and any setting you have yourself requested, we only collect data via cookies after and based on your consent. Further processing might be based on other legal bases according to its purpose and as otherwise described in this policy.

Survey participant: We occasionally conduct surveys via our newsletter and other communication with you. This is based on your consent. The personal data is saved and processed for as long as we have your consent, or at most for as long as we need the data for the purpose of the survey.

Newsletter / periodic email subscribers: Until you decide to opt-out of our mailing list. In each email there is information about how to opt-out.