We know that you care about your personal data and how it is used. We take the protection of your personal data very seriously and strictly adhere to the rules laid out by data protection laws and the General Data Protection Regulation (GDPR-EU, GDPR-UK). This Privacy Notice will help you understand what personal data Seargin collects, why we collect it and what we do with it.
The abbreviation “Seargin” and the pronoun “we” and its derivatives herein refer to the global organization of Seargin’s related companies, each of which is a separate legal entity. When reading our Notice, please note that it applies to all Seargin companies). The controller of your data is one of the Seargin’s entity listed here (pdf) (see list of Seargin related companies) to which you have provided your personal data, e.g. when applying for a job or when using our contact form.
Please take a moment to familiarise yourself with our privacy practices and let us know if you have any including any requests to exercise your legal rights, please contact our data protection team using the contact information in section 15 of this privacy notice. You have the right to object to certain uses of your personal data including the use of your personal data for direct marketing. See what your rights are and how you can exercise them in section 8 of this privacy notice.
We collect, process and disclose your personal data only for specific and limited purposes. For example, in order to carry out the recruitment process, to assess and handle any complaints, to develop and improve our products, services, communication methods and the functionality of our websites, to provide personalised communication and targeted advertising. For more information, see sections 2.1 and 2.2 . Additionally, Seargin processes your personal data also using automated means. An automated decision is a decision which is made solely by automatic means, where no humans are involved in the decision-making process related to your personal data. Find out more about the automated decision making in section no. 12.0 of this privacy notice.
We collect, process and disclose your personal data for the following purposes:
When we collect and use your personal data for purposes mentioned above or for other purposes, we will inform you before or at the time of collection. Where appropriate, we will ask for your consent to process the personal data. Where you have given consent for processing activities, you have the right to withdraw your consent at any time.
Seargin recruits for its own needs as well as for its clients such as services connected with providing Specialists. Therefore, be mindful that your personal data may also be processed by Seargin’s clients. Such information is provided in job advertisements which specify that the recruitment process is conducted on behalf of the client.
Additionally, note that when you give your consent to participate in a specific recruitment process for a particular job position, that consent also extends to any future recruitment processes. This means that your personal data will be securely stored in Seargin’s database, and will be used to provide you with information on job positions that are tailored to your unique profile and professional experience
The User may withdraw consent to further processing of personal data. It may be done if the withdrawal does not affect the legal use of personal data in activities conducted on the basis of the consent granted before the withdrawal. Personal data may be also processed if the User has been recommended by another person. In such a case, the recommending person enters their own personal data, data of the recommended person with his/her CV. Seargin verifies the received CV taking into consideration the consent, that meets the requirements of the GDPR, of the recommended person to process his/her personal data. If such consent has been granted, Seargin has permission to use the data for recruitment process purposes.
By submitting an inquiry or signing up for a training, conference or other event organized by Seargin, the User may consent to the processing of personal data in order to receive marketing information on products and services offered by Seargin, including newsletters.
User’s consent for processing personal data is the legal basis for sending newsletters. It can be granted while providing one’s e-mail address in the newsletter subscription form or gated content as well as by checking a box while completing a contact or recruitment form. Providing the e-mail address in the newsletter subscription form is a clear affirmative action of consenting to processing personal data as defined in Article 4 (11) of GDPR regarding the definition of consent as well as connected 32nd motif of GDPR explaining the clear affirmative action.
According to the abovementioned motif, a clear affirmative action includes informing Seargin that the User’s e-mail address provided in the form may be used for sending a newsletter that includes Seargin ’s promotional information. It is one of the acceptable forms of consenting to using the provided e-mail address for the defined purpose (such forms also include checking a box located near the content of the consent).
Consent to sending unsolicited marketing information, according to the rules for electronically supplied services, is provided by the user independently and separately by checking a dedicated box located near the content of the consent.
In order to obtain some materials uploaded to Seargin ’s website, it may be necessary to complete a form that requires providing personal data. Such data will be processed according to the consent (Art 6 (1) (a) of GDRP) expressed by a clear affirmative action. If the User wishes to receive other marketing information, he/she may state so by checking a relevant box. If the User does not state so, it means that he/she is not interested in receiving other information thus Seargin will not send it.
We only collect and use personal information about you when the law allows us to. Most commonly, we use it where:
Where legitimate interest is identified as a lawful basis, we will undertake a legitimate interest assessment which is a three-part test covering:
Personal data means any information that can be used to identify directly or indirectly a specific individual. You are not required to provide Seargin the personal data that we request, but if you choose not to do so, we may not be able to provide you with our products or services, or with a high quality of service or respond to any queries you may have. We collect personal information from you, for example, if you register to our website, request product information, call us or use any of our services. You may be asked to provide your personal information when you contact us. The categories of personal information that we may collect, store and use about you include:
We may share your personal information between Seargin’s related companies and use it in a manner consistent with this privacy notice.
Certain categories of personal data, such as race, ethnicity, religion, health, sexuality or biometric data are classified as “special categories of data” and benefit from additional protection under the European data protection legislation. We do not collect any special category data and we also request you do not provide any special category data in your resume and applications for recruitment. If we still receive such data, we will delete it at the earliest opportunity. If we will process special category data, it will be informed to the data subjects and an article 9 exception will be identified that may allow us to do so.
We may also collect your data through Third Parties which Seargin requires to ensure your or your employer’s satisfaction with our products, services and offerings.
We pride ourselves on ensuring that your personal data is only retained for the period that we need it for, or in accordance with laws, regulations and professional obligations that we are subject to. We will actively review the personal data we hold and delete it securely, or in some cases anonymise it, when there is no longer a legal business or consumer need for it to be retained. All personal information collect has a defined retention period, which is in-line with our retention policy. If you would like to find out how long your information is being retained, please see “additional information”, section 17 of this policy.
We take the responsibility for protecting your privacy very seriously and we will ensure your data is secured in accordance with our obligations under the Data Protection laws. We have in place technical and organisational measures to ensure personal information is secured and to prevent your personal data from being accessed in an unauthorised way, altered or disclosed. We have in place a robust access control policy which limits access to your personal data to those employees, contractors and other third parties who only have a business need to know. The processing of your personal data will only take place subject to our instruction. We have policies and procedures to handle any potential data security breaches and data subjects, third parties and any applicable regulators will be notified where we are legally required to do so. We have ensured that all employees have had information security and data protection training. If you would like more details of the security we have in place, please see “additional information”, section 17 of this policy.
We do not knowingly collect information on children. If we have collected personal information on a child, please contact us immediately using the details in section 15, so we can remove this information without any undue delay.
In this Section, we have summarised the rights that you have under the UK GDPR article 15-21 or EU GDPR article 15-21. Some of the rights are complex, and not all the details have been included in our summaries. Accordingly, you should read the relevant laws and guidance from the regulatory authorities for a full explanation of these rights.
Your principal rights under General Data Protection Regulation are:
You can exercise this right if:
The right of access:
The right to be informed:
The right of rectification:
The right to erasure:
The right to restrict processing:
The right to data portability:
Rights related to automated decision-making.
If you have any question about these rights, please see “additional information”, section 17 of this policy.
Where you have given consent for processing of personal data, or explicit consent in relation to the processing of special category data, you have the right to withdraw this consent at any time, but this will not affect the lawfulness of processing based on consent before its withdrawal.
Where we need to collect personal data by law or in order to process your instructions or perform a contract we have with you and you fail to provide that data when requested, we may not be able to carry out your instructions or perform the contract we have or are trying to enter into with you. In this case, we may have to cancel our engagement or contract you have with us, but we will notify you if this is the case at the time.
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Seargin is active in the recruitment and outsourcing of employees. To optimise the recruitment process and support the management of the employee’s career path, Seargin uses an automated recruitment process consisting of:
The tool will process the data provided by the candidate in the CV, such as:
During the recruitment process, your personal data is used for automated decision in order to improve the recruitment and HR processes. We don’t make decisions based solely on automated decision-making that have a significant impact on you.
If we do, we will notify you and provide you with clear information about our decision to rely on automated processing to make the decision and the legal basis for doing so.
If you would like more detailed information on the automated recruitment process, please contact our compliance team via email at rodo@seargin.com.
Seargin may disclose your personal data, listed in section 4 to some third parties to help deliver our services/products. All third parties are contractually bound to protect the personal data we provide to them. We may use several or all of the following categories of recipients:
In this section, we provide information about the circumstances in which your personal data may be transferred and stored in countries outside the United Kingdom and European Economic Area (EEA).
We may share personal information to third parties outside of the UK and EEA. Any personal information transferred will only be processed on our instruction and we ensure that information security at the highest standard would be used to protect any personal information as required by the UK GDPR, EU GDPR and other Data Protection laws in the EU and the UK.
Where personal data is transferred outside of the EEA and the UK to a country without an adequacy decision, we will ensure appropriate safeguards are in place prior to the transfer. These could include:
For more information about transfers and safeguarding measures, please contact us using the information in section 17.
We take any complaints about our collection and use of personal information very seriously. If you think that our collection or use of personal information is unfair, misleading, or inappropriate, or have any other concern about our data processing, please raise this with us in the first instance.
To make a complaint, please contact us via email on:
Alternatively, you can contact us by Post:
For data subjects based in the UK, our UK representative is Seargin Ltd and can be contacted on gdpr-uk@seargin.com If you wish to exercise your rights under the UK GDPR or have any questions regarding data privacy, please contact them on this email address.
Your trust is important to us. That is why we are always available to talk with you at any time and answer any questions concerning how your data is processed. If you have any questions that could not be answered by this privacy policy or if you wish to receive more in-depth information about any topic within it, please contact our Compliance Team via email on rodo@seargin.com.
We keep this Policy under regular review. This Policy was last updated on 26/03/2024.
We reserve the right to update this privacy notice at any time, and we will provide you with a new privacy notice when we make any substantial updates. We may also notify you in other ways from time to time about the processing of your personal information.
