WESTPOLE has implemented a solid compliance program with current legislation on data protection, which includes the adoption of appropriate security measures in line with the principles set out in the Regulation. The specific type and scope of personal data we collect about you depends on your activity on, and interaction with, the Website, as described here below.
a) Personal data collected when you use the WESTPOLE Website for informative purposes only.
Information relating to your Website use
When you use our Website for informative purposes only (e.g., you are visiting the Website pages without registering or otherwise submitting your personal data through the Website), your internet browser automatically collects, and transfers to us, certain basic information relating to your Website use. Such data may include:
your browser type and version
your operating system and interface
the Website from which you are visiting us (referrer URL)
webpage(s) you are visiting on our Website
date and time of your visit
your internet protocol (IP) address
Personal data processed by external social media providers (“Social Media Data”):
Our Website contain share buttons that enable you to share WESTPOLE content with your friends through third party media platforms and/or social networks (such as Facebook (“External Platforms”). The mere use of our Website does not generally involve data processing activities (including data transfers) in relation to the External Platforms. However, when you use the share button, these External Platforms may collect and otherwise process personal data about you. For more information about the scope and purposes of the data processed by the External Platform provider, including your rights and setting option to protect your privacy, please see the privacy notice of the respective External Platform providers.
c) Information collected when you apply for a fob position. We collect information from and about candidates in connection with available employment opportunities at WESTPOLE. The information that we collect regarding our job applicants includes resumes or CVs, that includes academic titles, work history, employment information and references.
d) Information collected when you otherwise interact with us via the Website. The Website enable you to get in touch with us in different ways (for example via e-mail telephone, etc.). The collection of personal data depends on how you interact with us and what information you provide us with. If you contact us via the ‘WESTPOLE concierge contact form’ or if you make any service request as available on the Website, we may collect the following personal data:
First and Last Name
The content of your query
Important Notice: When we collect personal data through forms, including but not limited to electronic forms, we will indicate the mandatory fields via asterisks. Failure to provide the data marked with an asterisk could prevent you from accessing our services. While submitting any data please ensure it is accurate and do not transmit any sensitive data such as health information, political opinions, religious or philosophical beliefs, information on your sex life or sexual orientation, racial or ethnic origin, nor any content which is not expressly requested through a questionnaire or any other collection method, unless this is required in exceptional cases.
Our Website does not offer services specifically directed to children and persons under the age of 18, therefore we do not knowingly collect personal data from children.
Purposes of the processing and legal basis
We process your personal data only if we have at least one of the following legal basis:
to comply with any applicable legal/regulatory obligations
to perform the service requested by you (for example when you subscribe to the newsletter or propose yourself for a job position)
to pursue our legitimate interests or the ones by a third party
once we’ve received your consent to our specific use
The purpose for which we use and process your personal data and the legal basis on which we carry out each type of processing is explained below.
Purposes of the processing
Manage your job application
It is necessary for us to process your personal data in order to manage the recruitment process about your spontaneous application or when responding to a job advertisement published on the site. It will be carried out according to your consent.
Sending communications when you contact us to request information.
We will send electronic communications to you if you have consented to these communications.
Improving our Website, through your experience and your judgments on the quality of the service.
It is in our legitimate interest to improve our services. We consider this use to be proportionate and will not be prejudicial or detrimental to you.
Managing our Website including troubleshooting, data analysis, testing, research, to keep our Website safe and secure and to prevent detect fraud and abuse.
It is in our legitimate interest to continually monitor and improve our services and your experience of the Website and to ensure network security. We consider this use to be proportionate and will not be prejudicial or detrimental to you.
To stop receiving our emails, you may simply click on the “unsubscribe” link at the bottom of the email.
We use your personal data to match your skills, experience and education with specific roles offered by WESTPOLE.
This information is passed to the relevant hiring managers and persons involved in the recruitment process to decide whether to invite you for an interview. WESTPOLE will collect further information if you are invited to the interview (or equivalent) stage and onward. Such information includes interview notes, assessment results, feedback and offer details.
In connection with our recruitment activities including applications and onboarding, we also collect special category data from candidates where we have an employment law obligation to do so. This information is relevant to their future working environment at WESTPOLE or the future provision of employment benefits, or with the individual’s explicit consent, where collecting such information is permitted by law. For example, where allowed under applicable law, we will collect information about an individual’s disabilities in order to analyze the diversity of our workforce. Once onboarded, an individual’s provision of information regarding disabilities will also be used to provide a suitable working environment. However, where a candidate does not voluntarily provide such information, we could be required by law to make our own assessment of such criteria.
Our recruiting website collects personal data of candidates (“you”):
Directly from you, for example, information that you provided when you applied for a position directly through the WESTPOLE career website or when you send us a spontaneous job application.
Through publicly available sources online, such as where you have a professional profile posted online (for example, on your current employer’s website or on a professional networking site, such as LinkedIn)
Results of background screening checks
Legal grounds for processing personal data of our job applicants are:
Explicit consent of the candidate
Our legitimate interest in attracting, identifying, and recruiting talent
Our legitimate interest in processing and managing applications for roles in WESTPOLE, including the selection and selection of candidates
Our legitimate interest in hiring and recruiting candidates by making an offer to successful candidates and conducting pre-employment screening checks
Our legitimate interest in operating our professional Website (including conducting statistical analyzes)
Compliance with a legal or regulatory obligation (when performing background checks to ensure that a candidate is fit to work)
How do we process your personal data?
The processing of your personal data is carried out with appropriate procedures and measures to protect the security of your data, in terms of integrity, confidentiality and availability. WESTPOLE uses commercially reasonable measures to keep your personal data confidential and safe. We take appropriate physical, electronic and administrative steps to maintain the security of personal data we collect, including limiting the number of people who have access to our servers, as well as employing electronic security systems and password protections that guard against unauthorized access. While we use commercially reasonable means to ensure the security of information you transmit to us, we cannot guarantee that such information will not be intercepted by third parties. We may, however, prosecute any unauthorized or fraudulent action to the fullest extent permitted by law.
Spoofing, phishing and other risk
Spoofing and phishing and other kinds of attacks are common Internet scams. These scams may occur when you receive an email from what appears to be a legitimate source requesting personal data from you. Please be aware that WESTPOLE will never send you an email requesting you to verify payment card or bank information. If you ever receive an email that appears to be from us requesting such information from you, do not respond to it, and do not click on any links appearing in the email.
How long will we retain your Personal Data?
WESTPOLE will retain your personal data for no longer than is necessary for the purposes for which the personal data are processed and described in the section “Purposes for which we process personal data.” Normally your personal data will be stored for 12 (twelve) months (1 year) on WESTPOLE’s computer systems after which they will be automatically deleted. Your personal data may be stored for longer periods where necessary for the establishment, exercise, or defence of legal claims. Regarding cookies, the storage times are those indicated in the cookie banner and in the detail of your preferences with respect to the specific selection you have made, and which is shown on the section below “Your Cookie Preferences”
Legal Requirements and Protection of Our Company and Others
We may share your personal data in other special circumstances, which include situations when sharing is required by law, or we believe sharing will help to protect the safety, property, or rights of WESTPOLE or other persons.
Transfer of your personal data
Transfer of Personal Data to third countries extra-UE
Personal Data collected automatically while browsing the pages of the Website or freely provided by the User will not be transferred by WESTPOLE to third countries or international organisations outside the EU.
What are your rights and how to contact us?
WESTPOLE grant you the rights to know the personal data processes and related purposes, as well as the ability to revoke the consent in case the consent is the legal basis of the personal data processing. In particular, the following rights can be exercised (*):
Right of access to your personal data: You have the right to ask us for confirmation on whether we are processing your personal data, and access to the personal data and related information
Right to correction: you have the right to have your personal data corrected, as permitted by law
Right to erasure: you have the right to ask us to delete your personal data, as permitted by law
Right to restriction of processing: you have the right to request the limiting of our processing under limited circumstances
Right to data portability: you have the right to receive the personal data that you have provided to us, in a structured, commonly used and machine-readable format, and you have the right to transmit that information to another controller, including to have it transmitted directly, where technically feasible
Right to object: you have the right to object to our processing of your personal data, as permitted by law, under limited circumstances
You also have the right to lodge a complaint with the data protection authority in the European Member State of your habitual residence, place of work or place of the alleged infringement.
(*) These rights apply only for natural persons living in the European Union
In order to exercise any of these rights, please contact us using the “Contact Us” section, or send an email to [email protected], indicating in the subject of the communication that it is a request for “Exercise of Rights pursuant to EU Regulation no. 2016/679”.
Please note that the above rights are not absolute, and we may be entitled to refuse requests, wholly or partly, where exceptions under the applicable law apply. You have the right to obtain a copy of the Personal Data undergoing processing from WESTPOLE. In the event of further copies being requested by the data subject, WESTPOLE may charge a reasonable fee based on administrative costs. The right to obtain a copy shall not affect the rights and freedoms of others. In the event you request to exercise your rights, we may need to verify your identity and, therefore, need you to provide your identifying data and contact data essential to identify and contact you with reference to your request. Possible limitations to the exercise of your rights, and to the consequent obligations of WESTPOLE, can be imposed by the applicable law.
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Third-Party cookies are cookies set by other parties, on the visitor of our Website
Session cookies are cookies saved on your computer which are deleted automatically when you close your browser
Persistent cookies are cookies saved on your computer which are not deleted automatically when you close your browser. Persistent cookies are used to re-identify you upon your next visit.
Your web browser may provide you with some options regarding cookies. Please note that if you delete, or choose not to accept, cookies, you may not be able to utilize the features of the services provided via the Website. We do not process or respond to web browsers’ “do not track” signals or other similar transmissions that indicate a request to disable online tracking of users who visit our Website or use the services provided via our Website.
Strictly necessary cookies. Strictly necessary cookies let you move around the Website and use essential features like secure areas, shopping baskets and online billing. We use strictly necessary cookies to:
Remember information you’ve entered on order forms when you visit different pages in a single web browser session
Identify you as being logged in to our Website
Make sure you connect to the right service on our Website when we make any changes to the way the Website works
Cookies we have defined as strictly necessary will NOT be used to:
Gather information that could be used to advertise products or services to you
Remember your preferences or username beyond your current visit
Personalize our Website and concerned services provided, such as remembering your data so that you will not have to re-enter it during your use of, or the next time you use, our Website and concerned services provided
Other Cookies that can be used to (if you accept them):
Monitor and analyse the effectiveness of our Website and the concerned services provided and third-party marketing activities adapted to your profile
Monitor aggregate site usage metrics such as total number of visitors and pages viewed
You may also disable the installation of cookies by configuring your browser appropriately. For more information, please read the specific information made available (by Chrome, by Explorer, …) Please be aware that restricting cookies may impact your user experience and may prevent you from using parts of our Website or services.