DATA PROTECTION POLICY REGARDING THE PROCESSING OF PERSONAL DATA OF THIRD PARTIES

(A) Scope

This policy of Trimetis AG applies to all third parties.

We have extensive responsibilities in connection with the protection of Personal Data of Our Clients or Candidates. We ensure compliance with the General Data Protection Regulation (GDPR) in close cooperation with our clients or business partners.

In accordance with our obligations under the GDPR, we would like to provide you with the following information about how we use Personal Data.

(B) Processing of Personal Data

Collection of Personal Data: We may collect Your Personal Data when performing our services. This Personal Data may be collected for example from the following sources:

Personal Data which has been provided by you (for example, if you provide us with your CV or if you contact us via e-mail, telephone etc.).
If we have connected you with any of our clients subject to your consent.
Personal Data provided by Trimetis group.
Personal Data available on social media, respectively publicly available Personal Data.
Personal Data which has been provided by third parties, such as references by former employers or other third parties.

Personal Data of third parties provided by You: If you provide us with Personal Data of third parties in specific circumstances (for example by way of an e-mail recommending such third party attaching their CV), We assume that you have obtained the consent of such third party and that such disclosure is in accordance with our data protection policy. Please do not transfer any Personal Data of third parties unless this is in accordance with the previous sentence.

Relevant Personal Data: Personal Data can include the following:

information based on a CV such as name and address as well as any further contact details including telephone numbers and e-mail-addresses, education, professional experience, qualifications, degrees and certificates, further qualifications, language and any other skills;
age/date of birth;
nationality/citizenship;
family status;
professional title and functions;
position within the organisational structure as well as reporting lines;
salary and remuneration including any other benefits like performance bonuses and other finance-related information (such as shares in the company);
holiday entitlement;
information relating to suspensions of operations and pension entitlements;
performance reviews;
assessment and suitability/matching for a specific position;
social media presence;
any memberships as well as any voluntary work and hobbies;
shares in companies;
third party feedback relating to Candidates and obtaining of references;
records of our contact history with you;
if required in a mandate: official ID, passport or visa; criminal records;
background checks: information obtained during background checks performed subject to your express consent (e.g., details relating to your previous employment relationships or information relating to your place of residence).

Legal basis for the Processing of Personal Data: The Processing of Personal Data for the purposes specified in this policy is based on the following:

the data subject has given consent to the Processing of their Personal Data (consent is not required, if there is an alternative legal basis for the Processing);
the Processing is necessary for the performance of a contract to which the data subject is party or to take steps at the request of the data subject prior to entering into a contract;
statutory requirement;
Processing is necessary in order to protect the relevant interest of an individual person; or
the Processing is justified by our, or a third party’s legitimate interest and such interest is not overridden by the interest, fundamental rights, and freedoms of the data subject. We rely on legitimate interest as a legal basis for
the performance of our services owing to our clients
the management and sustainable development of our business; and

Processing of Sensitive Data: We do not Process Sensitive Data unless in exceptional circumstances, if, for example

the Processing is required by law;
this is required to comply with your legal rights; or
You give your express consent.

Purposes for which We may Process Your Personal Data: pursuant to applicable law to perform Our services:

Finding potential candidates on behalf of our clients for the placement of positions. If required, subject to prior advertisements.
Individual communication: Any type of individual communication with you (including e-mails, calls, text messages, use of social medial, messenger services, via mail or in person); keeping information on file for the purpose of notification of employment opportunities (external or internal at your current employer) in connection with search mandates.

(C) Disclosure of Personal Data to third parties

We may disclose your Personal Data within the Trimetis group for legitimate purposes. We may also disclose relevant demographic information to our clients for purposes specified in this policy.

Furthermore, we may disclose your Personal Data to:

Our clients, to provide our services in accordance with this data protection policy;
tax advisors, auditors, lawyers, and other external advisors of Trimetis group, which are subject to a professional secrecy or contractual confidentiality obligation.

(D) International transfer of Personal Data

As we offer our services on a global level, we may have to disclose Your Personal Data within the Trimetis group, clients, or third parties as defined above in section (C) for the purposes specified in this policy.

If we transfer your Personal Data outside of Austria, such transfer is exclusively based on valid agreements.

(E) Data security

We implement appropriate technical and organisational measures in accordance with applicable law to protect Your Personal Data against accidental or unlawful destruction, alteration, unauthorized disclosure, or access and any other unlawful or unauthorized Processing.

However, it is your responsibility to ensure that you provide any Personal Data in a secure manner.

(F) Data minimization

We will only process your Personal Data to the extent required for the purposes specified in this policy.

(G) Storage

We will only store your Personal Data if there is a legitimate purpose for such storage.

We may store Personal Data during the existing client relationship and, following its termination, if there is a corresponding statutory retention obligation, or a party could assert any claims arising from or in connection with the client relationship or in the event of any other justified reasons. We may also retain Personal Data to include you in future search and selection processes and to contact you accordingly and, if applicable, also if this would exceed the scope of an actual job opportunity.

(H) Your rights

Your rights in accordance with applicable law as a data subject in connection with our processing activities are the right to access, rectification, erasure, restriction of Processing or, if applicable, to object to the Processing, to data portability and to lodge a complaint with the competent supervisory authority.

(I) Cookies

To improve the functionality of our website and to make usage more comfortable, we use cookies. Cookies are small text files that are stored on your computer or any other hardware if you visit a website (including our website).

They collect information about your hardware, browser and in some cases, your online preferences. The saving of cookies on the accessing device can be prevented by appropriate settings in the browser. However, this could limit the scope of our offer.

Most of the cookies we use are technical, so-called “session cookies”. These are automatically deleted when you leave our website. Other cookies remain stored on your device until you delete them yourself. Cookies enable us to recognize the browser when we visit our website again.

(J) Terms of use

Any use of our websites is subject to our data protection.

(K) Contact

Should you have any comments or questions in connection with this data protection policy or in the event of any other request relating to the Processing of Personal Data by Trimetis AG, please contact:

office@trimetis.com