- (i)“HAPPYFORCE”, “we,” “our” and “us” means HAPPYFORCE, S.L. and its affiliates.
- (ii)“Controller” for the purposes of the GDPR, other data protection laws applicable in member states of the European Union and other provisions related to data protection is HAPPYFORCE, S.L. C/Nicaragua 27, 3C, 08029, Barcelona.
- (iii)“Personal Information” generally has the same meaning as personal data or personal identifiable information (PII). Personal Information is defined in the data privacy laws applicable in your country. It includes any information relating to an identified or identifiable natural person. This means any individual who can be identified directly or indirectly by reference to an identifier such as name, identification number, location data, online identifiers (for example, IP addresses – if they can be used to identify you) or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person. Put simply, this includes data which either by itself or with other data held by us or available to us, can be used to identify you.
HAPPYFORCE is committed to the following key principles:
PRINCIPLE 1. WE LIMIT HOW, AND WITH WHOM, WE SHARE YOUR PERSONAL INFORMATION.
HAPPYFORCE will only share your Personal Information with others for the following purposes:
at your request;to process or service a transaction or product authorized or requested by you; this may include sharing within the HAPPYFORCE group of entities; when required by law to disclose such information to appropriate authorities;to companies that assist us in marketing, recruiting, placement and servicing our products and services; for example, in order to support our information technology or to handle mailings on our behalf; andto our professional advisers.
PRINCIPLE 2. PURPOSE AND LEGAL BASIS OF THE PROCESSING
(i) Personal Information:
Information we receive from you when (i) you visit www.myhappyforce.com and other HAPPYFORCE websites and (ii) any other information you subsequently provide to us orally, in writing or through the internet: this may include your full name, postal address, e-mail address, employer/business and professional information, job titles, telephone and fax numbers, demographic information, IP address
The Personal Information is used in providing the website and answering requests from you (e.g. if you choose to register to receive information about our products and services or if you enquire about these, we will use your Personal Information in order to respond).
(i) Legal Basis:
The processing is necessary for the performance of a contract to which you are party or in order to take steps at the request of you prior to entering into a contract. Processing is necessary for the purposes of our legitimate interests, i.e. providing a website for information and use.
(ii) Personal Information:
Name, address, e-mail address and other information about your transactions and communications with us.
The Personal Information is used to process or service a transaction or product authorized or requested by you.
(ii) Legal Basis:
The processing is necessary for the performance of a contract to which you are party or in order to take steps at the request of you prior to entering into a contract.
(iii) Personal Information:
Name, address, e-mail address and other contact information
To periodically contact you to inform you of new products and/or services we provide or that we consider to be of interest to you.
(iii) Legal Basis:
(iv) Personal Information:
IP address and other information submitted by your browser
To diagnose any problems with our server and administer our website.
(iv) Legal Basis:
Processing is necessary for the purposes of our legitimate interests, i.e. providing a website for information and use.
(v) Personal Information:
Application data, including your name, address, CV, birthdate
Processing is required to enable us to administer the recruiting process, including the set-up of an electronic job applicant HR file, managing your application, organizing interviews. We may retain your Personal Information following your unsuccessful application so that we may contact you in case of future job vacancies. Your data may also be shared with other HAPPYFORCE group companies to consider your application for other job openings.
(v) Legal Basis:
Primarily, the processing is necessary to take steps for entering into a contract with you. We also have a legitimate interest to (i) store your data for a period of up to 2 yearsfollowing the conclusion of an unsuccessful application and/or (ii) to share it with the HAPPYFORCE group of entities and/or (iii) to retain and use your data as far as necessary for the establishment, exercise or defense of legal claims.
(vi) Personal Information:
All of the above
For compliance with legal and regulatory requirements and corporate governance obligations.
(v) Legal Basis:
Processing is necessary for compliance with legal obligations to which we are subject.
We collect Personal Information for the purposes described above when you visit www.myhappyforce.comand other HAPPYFORCE websites and from public sources, such as recruiting and business portals (i.e.www.linkedin.com).
PRINCIPLE 3.WE ESTABLISH SAFEGUARDS TO HELP ENSURE THE SECURITY AND CONFIDENTIALITY OF YOUR INFORMATION.
HAPPYFORCE restricts access to your company’s information to our employees who need it to do their job. Employees with access to your information are required to strictly maintain the confidentiality of such information.
HAPPYFORCE maintains physical, electronic and procedural safeguards that comply with Industry standards to protect your company’s information. We routinely test our information systems and websites to help ensure that unauthorized access does not occur.
PRINCIPLE 4.WE KEEP YOUR PERSONAL INFORMATION FOR AS LONG AS IT IS NECESSARY TO DO SO TO FULFIL THE PURPOSES FOR WHICH IT WAS COLLECTED AS DESCRIBED ABOVE.
The criteria we use to determine data retention periods for Personal Information includes the following: (i) Retention in case of queries:We will retain it for a reasonable period after the relationship between us has ceased in case of queries from you; (ii) Retention in case of claims:We will retain it for the period in which you might legally bring claims against us; (iii) Retention in accordance with legal and regulatory requirements:We will consider whether we need to retain it after the period described in (ii) because of a legal or regulatory requirement, e.g. to comply with tax or fiscal duties; (iv) Retention in case of job applications:If you applied for a job offering with HAPPYFORCE and have not been successful, your application data will be retained in our talent pool for a limited period as defined in Principle 2.
Give Us Your Feedback
Our goal is to protect your privacy. To comment or help us improve, please contact us via email at email@example.com. You may also contact us via written letter at HAPPYFORCE’s address listed above. We may ask you to provide a copy of your proof of identity.
If you consider that we are in breach of our obligations under data protection laws, you may lodge a complaint with the competent Data Protection Authority, which may be the supervisory authority in your country of residence, place of work or of an alleged infringement of data protection laws.
ADDITIONAL INFORMATION WE WANT YOU TO KNOW:
Transfers outside the EU/EEA.We also transfer the Personal Information we process to countries outside the European Economic Area (”EEA”) (e.g., when one of our service providers or equipment is based outside the EEA, such as for hosting your Personal Information). We have put in place adequate safeguards with respect to the protection of your privacy, fundamental rights and freedoms, and the exercise of your rights, e.g. we establish an adequate level of data protection, usually through EU Standard Contractual Clauses based on the EU commission’s model clauses.
Provision of Personal Information / Automated decision making.Please note that the Personal Information we collect from you is necessary to providing the services and the website to you. Failure to provide such data may not enable us to provide our services to you or make our website accessible. We do not use automatic decision-making or profiling of individuals.
Your Rights.You have various rights under data privacy laws in your country. These may include (as relevant): the right to request access to the Personal Information we hold about you; the right to rectification including to require us to correct inaccurate Personal Information; the right to request restriction of processing concerning you or to object to processing of your Personal Information, the right to request the erasure of your Personal Information where it is no longer necessary for us to retain it; the right to data portability including to obtain Personal Information in a commonly used machine readable format in certain circumstances such as where our processing of it is based on a consent; the right object to automated decision making including profiling (if any) that has a legal or significant effect on you as an individual; and the right to withdraw your consent to any processing for which you have previously given that consent.
Marketing Information.With your consent, where relevant, we will keep your name, address and contact details (including telephone numbers and email addresses) in our databases and may from time to time use that information to make you aware of our related products and services as well as updates on developments in our industry sector generally which may be of interest to you. We may contact you in writing, by telephone or email for this. If at any time you decide that you do not want your contact details used for these purposes, you may object or revoke your consent for receiving marketing communications by following the instructions in the relevant marketing communication (e.g., clicking on the “Unsubscribe” button) or by contacting us (see “Give Us Your Feedback” above).
Security Statement.We take reasonable precautions to protect your information. In particular, we implemented appropriate technical and organisational measures designed to ensure a level of security appropriate to the risk, including as appropriate: (a) pseudonymisation (such as where data is separated from direct identifiers so that linkage to an identity is not possible without additional information that is held separately) and encryption, (b) protecting the ongoing confidentiality, integrity, availability and resilience of systems and services used to process your Personal Information, (c) providing the ability to restore the availability and access to Personal Information in a timely manner in the event of a physical or technical incident; and (d) maintaining a process for regularly testing, assessing and evaluating the effectiveness of technical and organizational security measures. When you submit information to us through our website, your information is protected both online and offline. All data transferred to/from the HAPPYFORCE internal network, from/to an external entity, is encrypted to industry standards. Please keep in mind that messages you send to us by Internet e-mail may not be secure. We maintain appropriate physical, electronic and procedural safeguards to ensure the security, integrity and privacy of your personal information within our company. Only those employees who may require your information to perform a specific job are granted access to your organization’s identifiable information. Furthermore, all employees are kept up-to-date on our security and privacy practices.
Effective date: November 6th, 2018