Privacy and Cookie Policy

Updated and effective as of 31st of August 2022

PRIVACY POLICY

The controller of your Personal Data is Medvocation Limited, an Irish company located at The Black Church, St. Mary's Place, D07 P4AX Dublin, Ireland (further: „we”). We process your Personal Data in accordance with this Privacy Policy.

You can contact us as follows:

We take your privacy very seriously, investing significant resources as part of our efforts to protect your Personal Data. This includes closely monitoring and carefully adhering to applicable privacy rules provided for in our Privacy Policy and Cookie Policy as well as our Terms & Conditions.

We very much value the trust that our Job Seekers place in us to help them find jobs, and our Clients place in us to help them find great candidates. Our Privacy Policy describes how we work to maintain that trust and protect your information.

This Privacy Policy is meant to help you understand what information we collect, why we collect it and what we do with it.

This Privacy Policy relates to our use of any Personal Data we collect or use in relation to our Services. To provide the Services, we collect and receive information in several different ways. In many cases, you choose what information to provide, although some information is required for us to provide you the Services.

Depending on how you use our Services, the Personal Data we collect from you may vary. Below you will find specific information about processing of your Personal Data tailored to the way you use our Services.

All terms written in capitalised letters used in the following Privacy Policy or in the Cookie policy retain their meaning stipulated in the Terms and Conditions for Clients and in the Terms and Conditions for Job Seekers respectively.

I. Information about processing Personal Data of our Clients and their authorised representants

If you are one of our Clients we process your data since you concluded the Agreement with us and agreed to be bound by the Terms & Conditions for Clients and this Privacy Policy.

If you are one of our Clients’ authorised representatives we process your data since our Client authorised you to act as a User on behalf of it , in particular to use the Website and Services available under the Subscription Plan selected by the Client. We have received your data directly from our Client. The data we receive from our Client : name and surname, work phone number and email address, place of work, position or information about your scope of responsibilities.

1. Purposes of your Personal Data processing and its legal basis
If you are our Client we will process your data to:

• take actions related to processing your registration for the Website and providing electronic services regarding the creation and maintenance of your Client Account. Without the processing of your data, we would not be able to create an account for you on the Website or allow you to access the services we provide. The legal basis for processing your data is that these activities are necessary for the performance of an Agreement with us to which you are a party, as well as taking action at your request prior to entering into that Agreement;
• to perform the Services ordered by you, which is the subject of the Agreement concluded between us. Dependent on the Subscription Plan you chose, such services include enabling you:
  a) to match the Job Seeker Profile with your Job Offers;
  b) to create and maintain a profile of your business (Client Page), display and promote through the Website;
  c) to create and maintain an account for you or your authorised representant (User Account)
  d) to publish and manage your Job Offers;
  e) to receive Applications, including getting Job Seeker Data;
  f) to interact with Job Seekers;
  g) to browse and filter Job Seekers, Job Offers or other Client;
  h) to publish your content on our Blog.
  The legal basis for processing your data is that these activities are necessary for the performance of the Agreement with us to which you are a party;
• to manage your Subscription Plan, including modifying it. The legal basis for processing your data is that these activities are necessary for the performance of the Agreement with us to which you are a party;
• manage your payment for our Services. The legal basis for processing your data is that these activities are necessary for the performance of the Agreement with us to which you are a party;
• contact you for purposes related to your use of the Website with respect to its general functionality, such as handling complaints, including resolving technical issues. The legal basis for processing your data is our legitimate interest that consists in being able to help our Clients using our Services and the Website;
• defend against or pursue any potential claims relating to your use of the Website and Client/ User Account. The legal basis for processing your data is our legitimate interest that consists in being able to assert or defend against claims;
• comply with our statutory obligations arising in particular from tax and accounting regulations. The legal basis for processing this data is its necessity for fulfilling our legal obligations under tax and accounting law;
• prevent potentially illegal or tortious activities, or any other anomalous activities that are detrimental to other users. The legal basis for processing your data is our legitimate interest that consists in being able to prevent fraud and prevent abuse such as spam or fraud;
• conduct direct marketing of our products and services. We will send you marketing materials and offers or call you about them – depending on the method of contact you have chosen. The legal basis for processing your data for marketing our products and services is our legitimate interest that consists in being able to market our products and services.

If you are our Client’s authorised representant we will process your data to:

• process your registration for the Website and provide electronic services regarding the creation and maintenance of your User Account. The legal basis for processing your data is our legitimate interest in being able to perform the Agreement concluded with the Client you represent;
• perform the Services ordered by the Client that authorised you to act on its behalf. The legal basis for processing your data is our legitimate interest in being able to perform the Agreement concluded with the Client you represent.

2. Retention period for your Personal Data

If you are our Client we will process your data until either you or we terminate the concluded Agreement between us (whichever is earlier) and thereafter your data will only be processed for the purposes of pursuing our interests, including the statute of limitations for any claims we may have.

Please be informed that if you terminate your Account, all information or content associated with this Account will be deleted from databases. Information may still be available for some time due to the delay in processing such removal by servers.

With regard to data covered by tax and accounting records, your data will be processed by us for a period required by law.

If you are our Client’s authorised representative we will process your data until either the Client you represent or we terminate the concluded Agreement or your authorisation is revoked by the Client (whichever is earlier).

3. Recipients of your Personal Data

We will transfer your data to Job Seekers who use our Services to give them access to your contact details.

We will transfer your Personal Data to our suppliers to whom we outsource Personal Data processing services, such as providers of:

• IT, data storage and website hosting services;
• online payment service providers;
• marketing and data analysis services.

Such entities shall process data based on a contract with us and only in accordance with our instructions.

We will also transfer your data to our legal and compliance advisors.

4. Data transfers

As a global business, we access and transfer information around the world. If you are based in the EU or the Client you represent is, this means that we access and transfer your Personal Data outside the EU, including in and to the United States.

The privacy protections and the rights of authorities to access your Personal Data in some of these countries may not be the same as in your home country. When we transfer information to persons outside the EU we take reasonable steps to ensure that the recipients of such information do not breach the Ireland Privacy Principles (and where appropriate the GDPR) in relation to that information by entering into binding contractual arrangements with such third parties.

In particular, where we transfer information to countries that are not viewed as providing adequate protections, we generally rely on an approved mechanism known as the ‘standard contractual clauses’ to protect the information transferred. These are template contracts published by the European Commission containing approved commitments to protect the privacy and security of the information transferred.

5. Your rights as our Client or our Client’s authorised representant related to the processing of Personal Data

As our Client or our Client’s authorised representant you have the following rights related to the processing of Personal Data:

• the right to object to the processing of your data due to your particular situation;
• the right of access to your Personal Data;
• the right to request the rectification of your Personal Data;
• the right to request the erasure of your Personal Data;
• the right to request restriction of the processing of your Personal Data;
• the right to transfer your Personal Data, i.e. the right to receive your Personal Data from us in a structured, commonly used, machine-readable IT format. You can transfer these data to another data controller or request that we transfer your data to another controller. However, we will only do so if it is possible to send such data in technical terms. You have the right to transfer Personal Data only in terms of data that we process on the basis of the Agreement concluded between us.

To exercise the above rights, please contact us. You can contact us as follows:

• by letter to the following address: Medvocation Limited, The Black Church, St. Mary’s Place, D07 P4AX Dublin, Republic of Ireland;
• by email: [email protected];
• by phone: +353 1 254 8201.

Right to object

As we process your data on the basis of our legitimate interest, you have the right to object to the processing of your data due to your particular situation.

If we process your data for the purposes of direct marketing, you shall have the right to object at any time to such processing.

Right to lodge a complaint with a supervisory authority

You also have the right to lodge a complaint with your local supervisory authority or the Data Protection Commission - the Irish supervisory authority for the protection of Personal Data - if you consider that processing of your Personal Data is contrary to the data protection law.

6. Requirementto provide Personal Data

It is necessary for you to provide your data in order to enter into the Agreement with us and use our Services. Without the processing of your data, we would not be able to create your Account or allow you to access the Services we provide.

II. Information about processing Personal Data ofthe Job Seekers

If you are a Job Seeker, we process your data as you decided to use our Platform (either our Website or Mobile Application) looking for employment opportunities or career information in the healthcare industry and concluded the Agreement with us, thus agreeing to be bound by the Terms & Conditions for Job Seekers and this Privacy Policy.

1. Purposes of your Personal Data processing and its legal basis

We will process your data to:

• take actions related to processing your registration for the Platform and providing electronic services regarding the creation and maintenance of your Account. Without the processing of your data, we would not be able to create the account for you on the Website or allow you to access the services we provide. The legal basis for processing your data is that these activities are necessary for the performance of an Agreement with us to which you are a party, as well as taking action at your request prior to entering into that Agreement;
• to perform the services ordered by you, which is the subject of the Agreement concluded between us. Dependent on the Subscription Plan you chose such services include enabling you:
  a) to create and manage your Job Seeker Profile;
  b) to match your Job Seeker Profile with the Job Offers;
  c) to submit Applications;
  d) to interact with Clients;
  e) to browse and filter Job Offers or Clients;
  f) to view, browse or filter content.
  The legal basis for processing your data is that these activities are necessary for the performance of the Agreement with us to which you are a party;
• contact you for purposes related to your use of the Platform and our Services with respect to its general functionality, such as handling complaints, including resolving technical issues. The legal basis for processing your data is our legitimate interest that consists in being able to help the Job Seekers using our Services and Platform;
• defend against or pursue any potential claims relating to your use of our Platform. The legal basis for processing your data is our legitimate interest that consists in being able to assert or defend against claims;
• conduct direct marketing of our products and services. We will send you marketing materials and offers or call you about them – depending on the method of contact you have chosen. The legal basis for processing your data for marketing our products and services is our legitimate interest that consists in being able to market our products and services;
• process your payment data if you consented to pay fees for our Services. The legal basis for processing your data is that these activities are necessary for the performance of an Agreement with us to which you are a party.

2. Retention period for your Personal Data

We will process your data until either you or we terminate the concluded Agreement between us (whichever is earlier) and thereafter your data will only be processed for the purposes of pursuing our interests, including the statute of limitations for any claims we may have.

3. Recipients of your Personal Data

Within the scope of our Services we will disclose your Personal Data to our Clients.

We will transfer your Personal Data to our suppliers to whom we outsource Personal Data processing services, such as providers of :

• IT, data storage and website hosting services;
• marketing and data analysis services;

Such entities shall process data based on a contract with us and only in accordance with our instructions.

We will also transfer your data to our legal and compliance advisors.

4. Data transfers

As a global business, we access and transfer information around the world. If you are based in the EU, this means that we access and transfer your Personal Data outside the EU, including in and to the United States.

The privacy protections and the rights of authorities to access your Personal Data in some of these countries may not be the same as in your home country. When we transfer information to persons outside the EU we take reasonable steps to ensure that the recipients of such information do not breach the Ireland Privacy Principles (and where appropriate the GDPR) in relation to that information by entering into binding contractual arrangements with such third parties.

In particular, where we transfer information to countries that are not viewed as providing adequate protections, we generally rely on an approved mechanism known as the ‘standard contractual clauses’ to protect the information transferred. These are template contracts published by the European Commission containing approved commitments to protect the privacy and security of the information transferred.

5. The existence of automated decision-making, including profiling

We inform you that your Personal Data will be used to performing an automated process of matching your data contained in Job Seeker Profile (basic information about the Job Seeker, his/her skills, qualifications and professional experience) to relevant Job Offers including using our matching algorithm based on the key skills and competencies you require to fulfil a specific role in the company and machine learning functionalities.

In the result of such processing you will see the Job Offers deemed most suitable for your Job Seeker Profile.

6. Your rights as Job Seeker related to the processing of Personal Data

As the Job Seeker who uses our Services via the Platform you have the following rights related to the processing of Personal Data:

• the right to object to the processing of your data due to your particular situation;
• the right of access to your Personal Data;
• the right to request the rectification of your Personal Data;
• the right to request the erasure of your Personal Data;
• the right to request restriction of the processing of your Personal Data;
• the right to transfer your Personal Data, i.e. the right to receive your Personal Data from us in a structured, commonly used, machine-readable IT format. You can transfer these data to another data controller or request that we transfer your data to another controller. However, we will only do so if it is possible to send such data in technical terms. You have the right to transfer Personal Data only in terms of data that we process on the basis of the Agreement concluded between us.

To exercise the above rights, please contact us. You can contact us as follows:

• by letter to the following address: Medvocation Limited, The Black Church, St. Mary’s Place, D07 P4AX Dublin, Republic of Ireland;
• by email: [email protected];
• by phone: +353 1 254 8201.

Right to object

As we process your data on the basis of our legitimate interest, you have the right to object to the processing of your data due to your particular situation.

If we process your data for the purposes of direct marketing, you shall have the right to object at any time to such processing.

Right to lodge a complaint with a supervisory authority

You also have the right to lodge a complaint with your local supervisory authority or with the Data Protection Commission - the Irish supervisory authority for the protection of Personal Data - if you consider that processing of your Personal Data is contrary to the data protection law.

7. Requirementto provide Personal Data

It is necessary for you to provide your data in order to enter into the Agreement with us and use our Services. Without the processing of your data, we would not be able to create your Account or allow you to access the Services we provide.

COOKIE POLICY

By using our Platform (our Website and Mobile App), you accept that Cookies may be placed on your mobile or fixed device, under the conditions provided below.

1. What are Cookies?

A Cookie is a file of limited size, generally made up of letters and numbers, sent by an Internet server to the browser’s cookie file, and located on your computer’s hard disk. A cookie records information about how the user browses the website (page views, date and time, etc.; “Cookie”). When you visit our website again, the cookies allow us to recognize your browser. Cookies may store your preferences and other information but cannot read data off your hard disk or read cookie files created by other sites.

Cookies help us recognize you on the Platform, enhance your user experience, understand usage of the Platform, and show you relevant advertising. Cookies may also be set by other websites or services that run content on the page you're visiting. After you register on the Platform, we may connect information we collect from the Cookies set by us and our partners with other information received from you. The provision of your data via Cookies is voluntary except for those Cookies that we place on your device because we need them for the performance of our Platform and our services.

2. What types of Cookies do we use?

We use two types of Cookies on the Platform: “Session cookies” and “Persistent cookies”.

Session cookies are placed for the duration of your browser use (session), and are deleted when you close your browser or log out of the website.

Persistent cookies are not deleted when you close your browser and remain on your device for the time specified in their parameters or until you delete them.

3. What are Cookies used for?

Cookies transmit information about you and your use of the Platform, such as your browser type, search preferences, job titles, data relating to advertisements that have been displayed to you or that you have clicked on, and the date and time of your use. With the exception of an identifier Cookie that we associate with registered accounts to prevent fraud by members of the Platform, Cookies link to certain unique information such as the job titles that you entered at time of registration or on your profile, but this is not linked to your name.

In addition, we may also provide an employer with code for a Conversion Tracker to place on its Site that pings the Job Seeker web beacon and tracks whenever a Job Seeker has applied to a job on that employer’s website. This Conversion Tracker will attribute an Website to Indeed any time the Job Seeker started their search on Medvocation, despite any intervening activity. We do not have access to the cookies in the employer’s domain. The Conversion Tracker is simply a counter that notifies us that a Job Seeker has applied. If a Job Seeker has disabled the web beacon, the Conversion Tracker will have no functionality.

4. Cookies, Scripts and Related Technologies

When you visit our Website, we and our third-party service providers receive and record Personal Data that you may have provided and your digital signature, such as your IP address. The technologies we use to track your movements around our website include cookies, tracking scripts and pixels, and tagging technologies, which we may employ to understand your preferences, improve your experience on our website, etc. You can control the use of cookies at the individual browser level. If you want to learn more about cookies, or how to control, disable, or delete them, please visit http://www.aboutcookies.org for detailed guidance.

The third-party cookies are placed by the entities listed below:

• Google (Google Analytics, the exact operation and privacy policy of Google Analytics can be found in the document “Information for users of websites and applications using Google Analytics”, which is available at:
  http://www.google.com/analytics/learn/privacy.html);

These cookies may be stored on your end device or in the tools of these third parties. Cookies allow us to identify your interests when you use our Website and to personalise the advertising that is targeted to them, including on Partner websites. You will find the third-party cookies listed in our Cookie Table available in the clause Cookies Table below.

5. Deleting or disabling cookies in your browser

Cookies are only used if you accept them or if you continue browsing the Platform. When you visit the Platform, you are notified that Cookies are used and you are also given the possibility to refuse and remove them.

The fact that we may store, and access “cookies” is due to the consent given by you. You can return to these settings at any time. By default, web browsers allow “cookies” to be placed on your device. These settings can be changed in such a way as to block the automatic handling of cookies in the settings of your web browser or inform on their sending to your device each time.

Alternatively, visit www.aboutcookies.org for comprehensive information on how to control or delete cookies in a wide variety of browsers, including how to delete cookies from your computer. For information on how to do this on your mobile device – such as a smartphone or tablet – please refer to your handset manual.

6. Cookies Table

Cookies that we commonly use are listed below. This list is not exhaustive, but describes the main reasons we typically set cookies.

MEDVOCATION COOKIES

THIRD PARTY COOKIES