Privacy Policy of Choosy

This Privacy Policy applies to the processing of personal data by Choosy, with its registered address at Rua Friães de Baixo, 295, 4780-476 Santo Tirso, Portugal, hereinafter referred to as “Choosy“, “we“, “us“, or “the Controller“.

This Privacy Policy provides a framework of understanding about the personal data that are collected by the Data Controller (as defined below), as required by law, including the provisions of the European Union’s General Data Protection Regulation (‘GDPR’). Personal data will be controlled and processed by the Data Controller in accordance with the terms of this Privacy Policy.

This Privacy Policy applies to:

our job candidates and recipients of our career services;
our associates, who are people we source or place on assignment with one of our clients, or individuals to whom we provide outplacement or career transition services;
users of the websites and apps (the “Sites”); and
representatives of our business partners, clients and vendors.

The Privacy Policy describes the types of personal data or personal information we collect, how we use the information, how we process and protect the information we collect, for how long we store it, with whom we share it, to whom we transfer it and the rights that individuals can exercise regarding our use of their personal data. We also describe how you can contact us about our privacy practices and to exercise your rights. Our privacy practices may vary among the countries in which we operate to reflect local practices and legal requirements, and you can view specific local terms by going to local websites.

Information We Collect

We may collect personal data about you in a variety of ways, such as through our Sites and social media channels; at our events; through phone and mail; through job applications; in connection with in-person recruitment; or in connection with our interactions with clients and vendors. We may collect a selection of personal data dependent on the nature of the relationship, including, but not limited to:

contact information (such as name, postal address, email address and telephone number);
username and password when you register on our Sites;
information you provide about friends or other people you would like us to contact (the Data Controller assumes that the other person previously gave an authorization for such communication); and
other information you may provide to us, such as in surveys or through the contact us on our Sites or e-mails.

In addition, if you are an associate or job candidate, you apply for a position or create an account to apply for a position, we may collect the following types of personal data:

employment and education history;
language proficiencies and other work-related skills;
Social Security number, national identifier or other government-issued identification number;
date of birth;
gender;
bank account information;
citizenship and work authorization status;
tax-related information;
information provided by references; and
information contained in your resume or C.V., information you provide regarding your career interests, and other information about your qualifications for employment.

And where required by law and/or an explicit consent has been provided by you:

background checks;
health-related information;
results of drug tests;
criminal records information, but only when it is explicitly required by applicable Portuguese law for the specific role for which you are applying.

In addition, we may collect information you provide to us about other individuals, such as information related to emergency contacts and the age of your children.

How We Use the Information We Collect

The Data Controller collects and uses the data gathered for the following purposes (as permitted under local law):

providing workforce solutions and connecting people to work;
creating and managing online accounts;
processing payments and bookkeeping obligations;
managing our client and vendor relationships;
to send promotional materials, alerts regarding available positions and other communications, only if you have provided your explicit consent for such communications (e.g., by subscribing to our newsletter). You may withdraw this consent at any time;
where permitted under law, communicating about, and administering participation in, special events, promotions, programs, offers, surveys, contests and market research;
responding to individuals’ inquiries and claims;
operating, evaluating and improving our business (including developing, enhancing, analyzing and improving our services; managing our communications; performing data analytics; and performing accounting, auditing and other internal functions);
protecting against, identifying and seeking to prevent fraud and other unlawful activity, claims and other liabilities;
complying with and enforcing applicable legal requirements, relevant industry standards, contractual obligations and our policies.

Cookies: Our website uses cookies to enhance your experience. For detailed information on the types of cookies we use and how to manage your preferences, please refer to our separate Cookie Policy.

All processing will be carried out based on adequate legal grounds which may fall into a number of categories, including:

consent or an explicit consent from the data subject, where required by applicable law;
ensure that we comply with a statutory or contractual requirement;
a requirement necessary to enter into a contract (e.g., processing your personal data to ensure that your wages and taxes are paid);
it is essential and necessary for the legitimate interest of the Data Controller (e.g., letting the user access the website to be provided with the services offered).

In addition to the activities listed above, if you are an associate or job candidate and you apply for a position or create an account to apply for a position, as permitted under local law, we use the information described in this Privacy Policy for the following purposes:

providing you with job opportunities and work;
providing HR services to you, including administration of benefit programs, payroll, performance management and disciplinary actions;
providing additional services to you, such as training, career counselling and career transition services;
assessing your suitability as a job candidate and your associate qualifications for positions;
performing data analytics, such as (i) analyzing our job candidate and associate base; (ii) assessing individual performance and capabilities, including scoring on work-related skills; (iii) identifying skill shortages; (iv) using information to match individuals and potential opportunities; (v) analyzing pipeline data (trends regarding hiring practices).

Legitimate Interest

The Data Controller may process personal data for certain legitimate business purposes, which includes some or all of the following:

where the process enables us to enhance, modify, personalize or otherwise improve our services/communications for the benefit of our clients, candidates and associates;
to identify and prevent fraud;
to enhance security of our network and information systems;
to better understand how people interact with our websites;
for direct marketing purposes;
to provide postal communications to you which we think will be of interest to you;
to determine the effectiveness of promotional campaigns and advertising.

Whenever we process data for these purposes, we will ensure that we keep your rights in high regard and take account of these rights by conducting a balancing test to ensure that our legitimate interests are not overridden by your interests or fundamental rights and freedoms.

How We Process and Protect Personal Information

We process the personal data we collect, also by automated means, for the purposes defined above and for a specific period of time, which complies with our internal retention policy, in order to ensure that the personal data are not kept longer than necessary.

We maintain administrative, technical and physical safeguards designed to protect the personal data you provide against accidental, unlawful or unauthorized destruction, loss, alteration, access, disclosure or use. In order to ensure the appropriate security and confidentiality of the personal data, we apply the following security measures:

Encryption of data in transit;
Strong user authentication controls;
Hardened network infrastructure;
Network monitoring solutions.

How Long We Store the Data We Collect

We store in our systems the personal data we collect in a way that allows the identification of the data subjects for no longer than it is necessary in light of the purposes for which the data was collected, or for which that data is further processed.

We determine this specific period of time by taking into account:

The necessity to keep the personal data in order to provide our services to you (e.g., we retain candidate data for as long as we are actively considering you for a position);
In order to safeguard a legitimate interest of the Controller as described in the purposes above;
The existence of specific legal obligations, such as Portuguese labor law or tax law, which may require us to retain certain data (e.g., payroll records) for a period of up to 10 years;
As a general rule, we retain candidate data for a period of 5 years from our last contact, after which it is securely anonymized or deleted, unless a longer retention period is required by law.

Information We Share

We do not disclose personal data that we collect about you, except as described in this Privacy Policy or in separate notices provided in connection with particular activities. We may share personal data with vendors who perform services on our behalf based on our instructions. We do not authorize these vendors to use or disclose the information except as necessary to perform services on our behalf or comply with legal requirements. We also may share your personal data (i) with our subsidiaries and affiliates; (ii) if you are a job candidate, with clients who may have job opportunities available or interest in placing our job candidates; and (iii) with others with whom we work, such as job placement consultants and subcontractors, to find you a job.

In addition, we may disclose personal data about you (i) if we are required to do so by law or legal process; (ii) to law enforcement authorities or other government officials based on a lawful disclosure request; and (iii) when we believe disclosure is necessary or appropriate to prevent physical harm or financial loss, or in connection with an investigation of suspected or actual fraudulent or illegal activity. We also reserve the right to transfer personal data we have about you in the event we sell or transfer all or a portion of our business or assets (including in the event of a reorganization, dissolution or liquidation).

Data Transfers

We also may transfer the personal data we collect about you to countries outside of the country in which the information originally was collected. Those countries may not have the same data protection laws as the country in which you initially provided the personal data. When we transfer your information to other countries, we will protect that data as described in this Privacy Policy and such transfers will be in compliance with applicable law.

Your Rights as Data Subject

When required by applicable law, a data subject can exercise the following rights free of charge. We will respond to your request within one month (30 days) of receiving it, unless the request is complex or you have made several requests, in which case we may extend this period by a further two months.

a) Right of access: A data subject has the right to access his or her personal data concerning which in order to verify that his or her personal data is processed in accordance with the law.

b) Right to rectification: A data subject has the right to request the rectification of any inaccurate or incomplete data held about him or her, in order to protect the accuracy of such information and to adapt it to the data processing.

c) Right to erasure: A data subject has the right to request that the Data Controller erases information about him or her and to no longer process that data.

d) Right to data portability: The data subject has the right to request the data portability meaning that the data subject can receive the originally provided personal data in a structured and commonly used format or that the data subject can request the transfer of the data to another Data Controller.

e) Right to lodge a complaint: If you have any inquiries regarding how we process your personal data, or would like to lodge a complaint, please contact us by using the form below. If you lodge a complaint, our Data Privacy Officer will get in touch with you. You also have the right to lodge a complaint with a supervisory authority if you consider that the processing of personal data infringes GDPR.

Whenever the processing is based on consent, the data subject may withdraw their consent at any time.

Updates to Our Privacy Policy

This Privacy Policy may be updated periodically to reflect changes in our privacy practices and legal updates. For significant changes, we will notify you by posting a prominent notice on our sites indicating at the top of each Policy when it was most recently updated.

How To Contact Us

If you have any questions or comments about this Privacy Policy, or if you would like to exercise your rights, please contact us using one of the methods indicated on the Feedback page of the Site or using the contacts indicated on the Site:

Email: geral@choosy.pt
Tel: +351 252 061 267
Address: Rua Friães de Baixo, 295, 4780-476 Santo Tirso – Portugal