Refeyn Ltd
Privacy Notice
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Applicant Privacy Notice
Welcome to Refeyn’s Applicant Privacy Notice for applicants for employment or other engagements at Refeyn.
What does this Privacy Notice Cover?
Refeyn respects your privacy and is committed to protecting your Personal Data.
The purpose of this Privacy Notice is to provide our applicants with information about how and why we process their Personal Data and to tell them about their privacy rights and how the law protects them.
With that in mind, this Privacy Notice is designed to describe:
- Who we are and how to contact us
- Your rights relating to your Personal Data
- What Personal Data we collect
- Personal Data from Third-Party Sources
- How we use your Personal Data and why
- Who we share your Personal Data with
- Data transfers
- How we keep your Personal Data secure
- How long we store your Personal Data
- No automated decisions
- Appendix – Detailed Processing Information
Important notes:
This Privacy Notice is intended to meet our duties of transparency under the UK’s implementation of the General Data Protection Regulation (the “UK GDPR”) and European Union’s General Data Protection Regulation (the “EU GDPR”) (together, “GDPR”).
It is important you read this Privacy Notice so that you are aware of how and why we are using your Personal Data, your rights, and how the law protects you.
This Privacy Notice does not form an operative part of any future contract you may have with Refeyn and is not intended to create any employment relationship between you and Refeyn.
You should be aware that if you fail to provide certain Personal Data when requested, we may not be able to perform steps necessary to enter into a contractual relationship with you or we may be prevented from complying with our legal obligations (such as to ensure the health and safety of our workers).
We may update this Privacy Notice from time to time. If we do so, we will provide you with and/or make available, a revised Privacy Notice.
Who we are and how to contact us
Who we are.
Refeyn Ltd., and its subsidiary, Refeyn GmbH (together, “Refeyn”, “we”, “us” or “our”) are the Controllers (as defined in the GDPR) for the purposes of the Processing of your Personal Data described in this Privacy Notice.
Refeyn Ltd.’s address is: Address: Unit 9, Trade City, Sandy Ln W, Oxford OX4 6FF, United Kingdom
Refeyn GmbH’s address is: c/o BRL Boege Rohde Leubbehuesen, Pariser Platz 4 A, 10117 Berlin
How to contact us.
To contact us, you can either:
- email us at privacy@refeyn.com; or
- write to us at the postal address noted above.
Your rights relating to your Personal Data
Your rights in connection with your Personal Data
Under certain circumstances, by law you have the right to:
- Request access to your Personal Data. This enables you to receive a copy of the Personal Data we hold about you and to check that we are lawfully processing it.
- Request correction of the Personal Data that we hold about you. This enables you to have any incomplete or inaccurate information we hold about you corrected.
- Request erasure of your Personal Data. This enables you to ask us to delete or remove Personal Data where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your Personal Data where you have exercised your right to object to processing (see below).
- Object to processing of your Personal Data. This right exists where we are relying on a Legitimate Interest (defined below) as the legal basis for our processing and there is something about your particular situation, which makes you want to object to processing on this ground.
- Request the restriction of processing of your Personal Data. This enables you to ask us to suspend the processing of Personal Data about you, for example if you want us to establish its accuracy or the reason for processing it.
- Request the transfer of your Personal Data. We will provide to you, or a third party you have chosen, your Personal Data which you have provided to us, in a structured, commonly used, machine-readable format. Note that this right only applies to Personal Data we process by automated means which you initially provided consent for us to use or where we used the information to perform a contract with you.
- Withdraw consent. This right only exists where we are relying on consent to process your Personal Data.
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How to exercise your rights
If you want to exercise any of the rights described above, please contact us using the contact details shown in the “Who We Are and How to Contact Us” section above.
We may need to request specific information from you to help us confirm your identity and verify your right to access your Personal Data (or to exercise any of your other rights). This is a security measure to ensure that Personal Data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information to assist us in responding to your request.
Typically, you will not have to pay a fee to access your Personal Data (or to exercise any of the other rights). However, except in relation to withdrawal of your consent (see above), we may charge a reasonable fee if your request is clearly unfounded or excessive, or, we may refuse to comply with your request in these circumstances.
Please also note that in certain circumstances the rights above will not apply and/or in certain circumstances some categories of Personal Data will be exempt from the scope of those rights. We will notify you where this is the case.
We try to respond to all legitimate requests within one month. Occasionally it may take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.
Complaints
If you would like to make a complaint regarding this Privacy Notice, you can contact us using the contact details shown in the “Who We Are and How to Contact Us” section above. We will reply to your complaint as soon as we can.
If you feel that your complaint has not been adequately resolved, please note that the GDPR also gives you the right to make a complaint directly to the competent data protection authority:
- UK Information Commissioner’s Office Water Lane, Wycliffe House Wilmslow - Cheshire SK9 5AF Telephone: +44 303 123 1113 Website: https://ico.org.uk/make-a-complaint/
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- Berliner Beauftragte für Datenschutz und Informationsfreiheit Alt-Moabit 59-61 10555 Berlin Eingang: Alt-Moabit 6 mailbox@datenschutz-berlin.de
What Personal Data we collect
All the Personal Data we collect, both from you and from third parties about you, is outlined in the table below.
| Category of Personal Data collected | What this means |
|---|---|
| Identity Data | First name, middle name(s), surname, title, national identification and/or passport details, national insurance / social security number or other tax-related information, driver’s licence, photographs. |
| Contact Data | Your home address, work address, email address and telephone numbers. |
| Biographical Data | First name, middle name(s), surname, maiden name, marital/civil partnership status, title, date of birth, gender, education history, professional history, professional qualifications and memberships, references, information relating to references such as referees’ names and contact details, information contained within letters of application and CVs, language proficiencies and other skills, certifications, certification expiration dates and information necessary to complete background checks. |
| Immigration Data | National identification and/or passport number, details of residency and/or work permit and other information that would allow us to verify your eligibility to work for us in your relevant role. |
| Engagement Data | Title and description of your prior roles, department, work location, dates of prior employment/engagement, employment/engagement status and type (e.g., full-time/part-time), terms of employment/engagement, contracts, work history (current, past, or prospective), training and learning program participation, termination date(s) and reason, length of service, willingness to relocate, current salary, desired salary, employment/engagement preferences, information necessary to complete background checks, drug and/or alcohol tests, and other screens permitted by law. |
| Facilities Data | Information about your access to Refeyn offices and facilities (e.g., keycard scans and security camera footage). |
| Other Data | This might include data not listed above that you provide to us, such as your feedback and survey responses where you choose to identify yourself. |
| Special categories of Personal Data | To the extent permitted by applicable laws we may also collect and process a limited amount of Personal Data falling into special categories, sometimes called “sensitive personal data”. This term includes information relating to such matters as physical or mental health (including details of accommodations or adjustments) or ethnicity data. |
Personal Data from Third-Party Sources
In addition to the Personal Data that we collect from you directly, in certain circumstances, we may also collect Personal Data from third-party
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