Emerald Zebra understands that your privacy is important to you and that you care about how your personal data is used and shared online. We respect and value the privacy of everyone who visits this website, www.emeraldzebra.cy (“Our Site”) and will only collect and use personal data in ways that are described here, and in a manner that is consistent with Our obligations and your rights under the law.
1. Definitions and Interpretation
In this Policy, the following terms shall have the following meanings:
“Account” means an account required to access and/or use certain areas and features of Our Site;
“Cookie” means a small text file placed on your computer or device by Our Site when you visit certain parts of Our Site and/or when you use certain features of Our Site. Details of the Cookies used by Our Site are set out in section 13, below;
“Cookie Law” means the relevant parts of the Privacy and Electronic Communications (EC Directive) Regulations 2003;
“personal data” means any and all data that relates to an identifiable person who can be directly or indirectly identified from that data. In this case, it means personal data that you give to Us via Our Site. This definition shall, where applicable, incorporate the definitions provided in the EU Regulation 2016/679 – the General Data Protection Regulation (“GDPR”);
“We/Us/Our” means Emerald Zebra, a limited company registered in Cyprus under company number HE418998, whose registered address is 12a Evripidou Street, Agia Zoni, 3031, Limassol, Cyprus.
2. Information About Us
2.1 Our Site is owned and operated by Emerald Zebra Ltd, a limited company registered in Cyprus under company number HE418998, whose registered address is 12a Evripidou Street, Agia Zoni, 3031, Limassol, Cyprus.
2.2 Our Data Protection Officer can be contacted by email via email@example.com, or by post at our registered address above.
3. What Does This Policy Cover?
4. Your Rights
4.1 As a data subject, you have the following rights under the GDPR, which this Policy and Our use of personal data have been designed to uphold:
4.1.1 The right to be informed about our collection and use of personal data;
4.1.2 The right of access to the personal data we hold about you (see section 12);
4.1.3 The right to rectification if any personal data we hold about you is inaccurate or incomplete (please contact Us using the details in section 14);
4.1.4 The right to be forgotten – i.e. the right to ask us to delete any personal data we hold about you (we only hold your personal data for a limited time, as explained in section 6 but if you would like us to delete it sooner, please contact us using the details in section 14);
4.1.5 The right to restrict (i.e. prevent) the processing of your personal data;
4.1.6 The right to data portability (obtaining a copy of your personal data to re-use with another service or organisation);
4.1.7 The right to object to us using your personal data for particular purposes; and
4.1.8 Rights with respect to automated decision making and profiling.
If you have any cause for complaint about Our use of your personal data, please contact us using the details provided in section 14 and We will do our best to solve the problem for you.
5. What Data Do We Collect?
5.1 Surname & given names;
5.2 education history;
5.3 employment history;
5.4 immigration status;
5.5 current remuneration (if any);
5.6 career goals;
5.7 current job title;
5.8 contact information such as email addresses and telephone numbers;
5.9 demographic information such as post code, preferences, and interests;
5.10 IP address;
5.11 web browser type and version;
5.12 operating system;
5.13 a list of URLs starting with a referring site, your activity on Our Site, and the site to which you might exit;
6. How Do We Use Your Data?
6.1 All personal data is processed and stored securely, for no longer than is necessary in light of the reason(s) for which it was first collected. Data is archived for 48 months after a candidate is placed, or if the candidate requests removal of their data, it will be done in a reasonably short time period after the request. We will comply with our obligations and safeguard your rights under the GDPR at all times. For more details on security see section 7, below.
6.2 Our use of your personal data will always have a lawful basis, either because it is necessary for our performance of a contract with you, because you have consented to our use of your personal data (e.g. by subscribing to emails), or because it is in our legitimate interests. Specifically, we may use your data for the following purposes:
6.2.1 To assess your suitability for employment with any of our clients;
6.2.2 Providing and managing your account;
6.2.3 Providing and managing your access to our site;
6.2.4 Personalising and tailoring your experience on our site;
6.2.5 Supplying our services to you (please note that we require your personal data in order to enter into a contract with you);
6.2.6 Personalising and tailoring our services for you;
6.2.7 Replying to emails from you;
6.2.8 Supplying you with emails that you have opted into (you may unsubscribe or opt-out at any time by clicking the unsubscribe link at the footer of each email);
6.2.9 Market research;
6.2.10 Analysing your use of our site to enable us to continually improve our site and your user experience;
6.3 With your permission and/or where permitted by law, we may also use your data for marketing purposes which may include contacting you by email and / or telephone and/or text message with information, regarding our services. We will not, however, send you any unsolicited marketing or spam and will take all reasonable steps to ensure that we fully protect your rights and comply with our obligations under the GDPR.
6.4 You have the right to withdraw your consent to us using your personal data at any time, and to request that we delete it.
6.5 We do not keep your personal data for any longer than is necessary in light of the reason(s) for which it was first collected. Data will therefore be retained for the following periods (or its retention will be determined on the following bases):
6.5.1 All personal data collected will be kept active indefinitely on our CRM system from the candidate’s date of registration until they are placed in employment by us. After placement, data will be retained for a further 48 (forty-eight) months, after which time, unless a person expressly asks us to update and have us retain their data, it will, by default, be securely deleted. In the case of candidates who are unplaced by us, but for whatever reason, ask us to withdraw their availability, we will archive the data for 48 months from the date of their request as if they had been placed. Likewise, after a further 48 months, their data will, by default, be securely removed.
6.5.2 If we are requested by a candidate to actively remove their data at any time (as opposed to the candidate merely withdrawing their availability for employment) we will do so within a reasonable period. In this instance, should the person requesting removal have been placed within the previous 48 months, we will only retain data pertinent to potential legalities over that placement contract between us and any client. (e.g Including, but not limited to, the person’s name and the date of their placement).
within a reasonably brief period
7. How and Where Do We Store Your Data?
7.1 We only keep your personal data for as long as we need to in order to use it as described above in section 6, and/or for as long as we have your permission to keep it.
7.2 Your data may be backed up on password protected hard drives in our offices and on cloud servers based within the EU and the United Kingdom.
7.3 Data security is very important to us, and to protect your data we have taken suitable measures to safeguard and secure data collected through our site.
7.4 Steps we take to secure and protect your data include:
7.4.1 Backing up your data online and in the cloud with industry standard password protection.
8. Do We Share Your Data?
8.1 We may share your data with our client companies in order to secure the employment opportunities that you have asked us to find on your behalf. We will not put your details forward to any client company without your express permission either by email, text or verbally over the telephone.
8.2 We may compile statistics about the use of our site including data on traffic, usage patterns, user numbers, sales, and other information. All such data will be anonymised and will not include any personally identifying data, or any anonymised data that can be combined with other data and used to identify you. We may from time to time share such data with third parties such as prospective investors, affiliates, partners, and advertisers. Data will only be shared and used within the bounds of the law.
8.3 The third party data processors used by us and listed below in 8.4 are located outside of the European Economic Area (“the EEA”) (The EEA consists of all EU member states, plus Norway, Iceland, and Liechtenstein). Where we transfer any personal data outside the EEA, we will take all reasonable steps to ensure that your data is treated as safely and securely as it would be within the EU.
8.4 Our third party data processors are FireFish Limited, whose registered office address is: 170-172 Tower Bridge Road, London, England, SE1 3LS; under company number 03854900.
8.5 In certain circumstances, we may be legally required to share certain data held by us, which may include your personal data, for example, where we are involved in legal proceedings, where we are complying with legal requirements, a court order, or a governmental authority.
9. What Happens If Our Business Changes Hands?
9.2 In the event that any of your data is to be transferred in such a manner, you will be contacted in advance and informed of the changes. When contacted you will be given the choice to have your data deleted or withheld from the new owner or controller.
10. How Can You Control Your Data?
10.1 In addition to your rights under the GDPR, set out in section 4, you may be given options to restrict our use of your data. In particular, we aim to give you strong controls on our use of your data for direct marketing purposes (including the ability to opt-out of receiving emails from us which you may do by unsubscribing using the links provided in our emails.
11. Your Right to Withhold Information
11.1 You may access certain areas of our Site without providing any data at all. However, to use all features and functions available on our Site you may be required to submit or allow for the collection of certain data.
12. How Can You Access Your Data?
You have the right to ask for a copy of any of your personal data held by us under the GDPR, no fee is payable and we will provide any and all information in response to your request free of charge, and within a reasonable time period. Please contact us for more details at firstname.lastname@example.org
13.3 In addition to the controls that We provide, you can choose to enable or disable Cookies in your internet browser. Most internet browsers also enable you to choose whether you wish to disable all cookies or only third party Cookies. By default, most internet browsers accept Cookies but this can be changed. For further details, please consult the help menu in your internet browser or the documentation that came with your device.
13.4 You can choose to delete Cookies on your computer or device at any time, however you may lose any information that enables you to access our site more quickly and efficiently including, but not limited to, login and personalisation settings.
13.5 It is recommended that you keep your internet browser and operating system up-to-date and that you consult the help and guidance provided by the developer of your internet browser and manufacturer of your computer or device if you are unsure about adjusting your privacy settings.
14. Contacting Us