This Policy informs you about how we collect, use, transfer and protect your personal data. We process it in accordance with the provisions of Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 on the protection of natural persons with regard to the processing of personal data and on the free movement of such data, and repealing Directive 95/46/EC ("General Data Protection Regulation", hereinafter "GDPR"), and with the relevant national legislation on the protection of personal data.

1. WHO ARE WE?

JOBZZLE CONNECT S.R.L., with registered office in Corunca no. 435 D, Mureș County, identified by unique identification code 45904810, registered with the Trade Register under No.: J26/526/2022, is the company that operates the www.camelio.ro website and provides recruitment, personnel selection and HR services to companies and to persons looking for a job.

Our contact details are:

• Address of registered office: Loc. Corunca, nr. 435D, Mureș County
• E-mail address: info@jobzzle.com
• Telephone No.: +40745155992; +40721593387

2. HOW DO WE PROCESS YOUR PERSONAL DATA?

The Company, in its capacity as Controller, processes the personal data of candidates applying for available positions, employees, individual clients, representatives of corporate clients, contractual partners and collaborators, and the data of other individuals who interact with the Company and/or are engaged in contractual relations with it.

Personal data are:

• processed lawfully, fairly and transparently in relation to the data subject;
• collected for specified, explicit and legitimate purposes and not further processed in a way incompatible with those purposes;
• adequate, relevant and limited to what is necessary in relation to the purposes for which they are processed;
• accurate and kept up to date;
• kept in a form which permits identification of data subjects for no longer than is necessary for the purposes for which the data are processed;
• processed in a way that ensures appropriate security of personal data, including protection against unauthorised or unlawful processing and against accidental loss, destruction or accidental damage, by appropriate technical or organisational measures.

3. WHAT TYPES OF PERSONAL DATA ARE PROCESSED AND FOR WHAT PURPOSES ARE THEY PROCESSED?

For website visitors we may collect data through cookies or similar technologies, such as IP address, internet browser, location, web pages accessed on our website, time spent on the website, internet network and device used. For more details on this, please see our Cookie Policy.

In the context of recruitment, we process the following types of personal data: name, surname, address, date of birth, nationality, gender, telephone number, e-mail address, data on professional and/or social experience, education and training, LinkedIn profile, skills and other personal data resulting from the information contained in the CV submitted, and from discussions during the job interview.

For the conclusion and execution of service and partnership/collaboration contracts, we mainly process the following types of personal data: name, surname, ID card/passport number and series, gender, home/residence address, bank account number, e-mail address, telephone number.

In order to complete and submit the contact form ("Contact") on the Company's website www.camelio.ro (hereinafter, the "website"), we process the following types of personal data: name, surname, e-mail, telephone number and, where applicable, other data if left at the initiative of the data subject in the "Subject" and "Content" sections.

We do not use your personal data to send you marketing communications, such as newsletters, unless you expressly consent to such communications by ticking an opt-in box. For this purpose, we only process your e-mail address and we ensure that you have a simple option to unsubscribe at any time, i.e. to withdraw your consent to receive these types of communications.

4. WHAT ARE THE LEGAL GROUNDS ON WHICH THE PROCESSING OF PERSONAL DATA IS BASED?

Your personal data are processed:

• for the conclusion and execution of various contracts, as well as for the steps taken at your request before entering into a contract;
• for the fulfilment of our legal obligations;
• on the basis of consent requested and/or given in advance (in the context of recruitment, for the transmission of marketing communications, etc.);
• for the purposes of the legitimate interests pursued by the Company (e.g. adoption of protection and security measures for our employees, measuring the effectiveness of our own campaigns, exercise of the legitimate rights and interests of the Company in contentious or non-contentious proceedings, etc.).

5. HOW LONG DO WE PROCESS YOUR PERSONAL DATA?

Personal data are stored for the time necessary to achieve the processing purposes mentioned in this Policy or for the time required by law (e.g. for archiving, accounting, etc.).

A candidate's CV will be kept for as long as there is an interest on the part of the natural person and for a period of 2 years after the registration of the last intention to benefit from our services. Before the end of that 2-year period, our company will verify the person's interest in the services offered by sending a confirmation e-mail.

6. TO WHOM DO WE TRANSMIT PERSONAL DATA?

We will not disclose or transfer to any third party any personal data collected from or about you, except to:

• Public authorities and institutions - when there is a legal obligation to do so or for a legitimate interest (defence of the Company's rights in contentious or non-contentious proceedings, etc.).
• Contractual partners or collaborators of the Company who provide us with web hosting, storage of data in the database, storage of CVs, deployment and maintenance services.
• Any third party - if you have given your express and specific consent for that situation and those data.

A candidate's CV will be communicated to companies interested in hiring personnel, in order to carry out matching processes with the existing requirements of the targeted positions.

Where personal data processed by the Company are transferred by the Company directly or through its contractual partners/collaborators outside the European Economic Area, we assure you that such transfers take place in compliance with the GDPR (in particular Article 46 of the GDPR) and with the relevant applicable legal provisions, on the basis of adequate safeguards (standard data protection clauses adopted by the Commission) and provided that there are enforceable rights and effective remedies for data subjects.

7. WHAT SAFEGUARDS AND GUARANTEES DO WE TAKE?

The Company implements appropriate technical and organisational measures to ensure a high level of security and protection of personal data. We use security methods and technologies, together with internal working policies and procedures, including control and audit, to protect the personal data collected in accordance with the relevant legal provisions in force on the protection of personal data.

8. WHAT ARE YOUR RIGHTS AS A DATA SUBJECT?

Any data subject may exercise the following rights as provided for by the General Data Protection Regulation:

• Right of access;
• Right of rectification;
• Right to erasure;
• Right to restriction of processing;
• Right to portability;
• Right to object to processing;
• Right to withdraw your consent at any time, where the processing is based on consent. The withdrawal does not affect the lawfulness of the processing carried out before the withdrawal;
• Right not to be subject to a decision based solely on automated processing, including profiling;
• The right to lodge a complaint with the National Supervisory Authority for Personal Data Processing (Autoritatea Națională de Supraveghere a Prelucrării Datelor cu Caracter Personal - ANSPDCP) and to go to court.

For any questions or concerns, or in order to exercise these rights, you can contact us by e-mail at: info@jobzzle.com. We reply to requests within one month of receipt; where the request is complex, this period may be extended, and we will inform you accordingly.

9. THE "HR COMPLIANCE QUICK TEST" CAMPAIGN

On the page www.camelio.ro/ro/test-conformitate-hr we make available a short test through which a company can check how it meets its obligations under labour legislation and can request a compliance assessment from us. Because this page collects more data than the rest of the website, we describe that processing separately below. This section supplements the sections above; where it says nothing different, the general rules in this Policy apply.

9.1. What data we collect

• Contact and company data that you enter in the form: name and surname, e-mail address, telephone number, the name of the company you represent and the number of its employees.
• Your answers to the test questions. These answers concern the way in which your company complies with labour legislation and may reveal that certain legal obligations are not, or are not fully, met. We treat them as confidential information and we use them only for the purposes set out below.
• Technical and usage data, recorded first-party in our own database: IP address, browser user agent, the page you came from (referrer), the campaign parameters in the address of the page (UTM parameters), the pages and test steps viewed, the time spent on each step and the related dates and times.

9.2. The cq_sid cookie

In order to link the steps of the same test into a single session, we place a strictly necessary first-party cookie named cq_sid. It contains only a randomly generated identifier, it is httpOnly (it cannot be read by scripts running in your browser), it has a lifetime of 180 days and it is not used to follow you on other websites. Being strictly necessary for the operation of the test, this cookie does not require your consent. More details can be found in our Cookie Policy.

9.3. Why we process these data and on what legal basis

• Contact and company data and your answers to the test - in order to generate your result, to contact you and to prepare a possible compliance assessment or offer. Legal basis: Article 6(1)(b) GDPR - steps taken at the request of the data subject prior to entering into a contract (the request for a compliance assessment and for being contacted).
• Technical and usage data - in order to measure how our campaign performs, how far visitors get through the test, and in order to detect errors and abuse. Legal basis: Article 6(1)(f) GDPR - our legitimate interest in measuring the effectiveness of our own campaign. This analysis is carried out in our own database and no third party receives these data. You may object to this processing at any time (see section 8).
• Marketing communications, if you tick the optional box in the form - Legal basis: Article 6(1)(a) GDPR, your consent. Ticking the box is optional, it does not affect your receiving the test result, and you may withdraw your consent at any time, with effect for the future.

9.4. How long we keep these data

• IP address and browser user agent: deleted or irreversibly anonymised no later than 90 days after they were collected.
• Contact data, company data and answers to the test: for as long as it is necessary to fulfil the purpose for which they were collected, but no longer than 3 years from your last interaction with us, or until you object to the processing or withdraw your consent, whichever comes first.
• Aggregated statistics (for example the number of visits, the number of tests started and completed) are kept for an unlimited period in an aggregated, anonymous form, which no longer allows you to be identified.

9.5. Who receives these data

We do not sell your data and we do not disclose your answers to third parties for their own purposes. Apart from the service providers already mentioned in section 6 (web hosting, database storage, maintenance), which act on our instructions, the only third parties involved in this campaign are the providers of the statistics and advertising cookies (Google and Meta), and only if you have accepted those categories in the cookie banner. They do not receive the answers you give in the test or the contact data you submit in the form. You can find details, and you can change or withdraw your choice at any time, in our Cookie Policy.

9.6. Your rights

All the rights described in section 8 apply in full to the data collected through this campaign: access, rectification, erasure, restriction of processing, portability, objection to the processing based on our legitimate interest, withdrawal of consent, as well as the right to lodge a complaint with the ANSPDCP. To exercise them, write to us at info@jobzzle.com.

The result of the test is an informational estimate and does not constitute legal advice or an audit. The conditions under which the test is made available are set out in our Terms and Conditions.