SEON Recruitment Privacy Notice

This privacy notice (“Privacy Notice”) describes how SEON use the personal data of applicants (“you”) in connection with your application for open positions at SEON. At SEON we are committed to protecting your personal data and to respect your right to privacy.

When SEON processes your personal data on the basis of its legitimate interest (see Section 6 of this Privacy Notice) you have the right to object to that processing (see Section 10.1.5). If you wish to exercise this right, please contact SEON at the email contact details specified in Section 2. When SEON processes your personal data on the basis of your consent, you have the right to withdraw your consent.

The data controller of your personal data is

SEON Technologies Kft.

Registered seat: H-1072 Budapest, Rákóczi út 42. 7. em

Company registration number: 01-09-292732

(hereinafter referred to as “SEON”, “we”, “us” or “our”) 

For any inquiries about this privacy notice, please contact any SEON entity at the following email address: legal@seon.io

SEON appointed a DPO. For any inquiries about this Privacy Notice, you may contact our DPO at dpo@seon.io.

SEON collects the following categories of your personal data:

• Personal identification and communication information (e.g. your name, home address, phone number, email address, date of birth, gender, correspondence);
• Application-related information (e.g. curriculum vitae (CV), cover letter, employment history, education history, qualifications and skills, hobbies, publications, assessment scores, position preferences, desired salary, interests and aspirations background information (e.g. public social media profile information), notes made during interviews, conclusions drawn during the hiring process, history of the hiring process).
• Special categories of data (e.g. sensitive personal data, criminal history, personal data revealing racial or ethnic origin, health-related data, data concerning a person’s sexual orientation). 

We may collect special categories of personal data (sensitive personal data) about a candidate to the extent permitted to do so by applicable laws (e.g., U.S. equal opportunity laws)  to support our efforts to create an inclusive and diverse work environment. We only collect special categories of personal data (sensitive personal data) that a candidate voluntarily discloses during the recruiting process. Please keep in mind that providing these types of information is optional and has no impact on the outcome of your application.

For certain positions, we have the appropriate legal basis and right to process your criminal history. Where we do so, we only do so in accordance with our Privacy Policy, the principles in Article 5 GDPR, and the prevailing legislation in the area of criminal background checks as updated from time to time.

In general, SEON collects personal data from you directly when you apply for a job and throughout the job application or recruitment process.  SEON may also collect personal data from other persons (i.e. recruitment agencies, online testing tools), or from other publicly available sources (i.e. social media providers, etc.) and combine it with the personal data you provide us. For example, we may collect your personal data from:

• Job board websites you may use to apply for a job with us;
• Prior employers that provide us with employment references;
• Professional references that you authorise us to contact;
• Pre-employment screening services, such as background check providers (where permitted by law);
• Employment agencies and recruiters;
• Your educational institutions;
• Your public social media profile or other publicly-available sources;
• Online activity information that we and our service providers collect using server logs, “cookies” and similar technologies on the Careers Site. Please see our Privacy Policy for more information.

• If your application is successful: We will retain your personal data until the employment agreement is concluded with you. When you become our employee, some of your personal data will become a part of your employee file and will be processed in accordance with our employee privacy notice which will be provided to you in a timely manner.
• If your application is not successful: SEON will retain your personal data for 2 years after the recruitment procedure is finished to create and maintain applicant community and to protect our rights and interest if we are need to, or until you object (whichever is earlier). After 2 years we will ask for your consent to retain your personal data for 2 more additional years.

SEON collects, uses and processes your personal data on the following legal basis and for the purposes set out below:

Personal data will be primarily processed by the employees in SEON’s recruiting department and the relevant hiring managers. This includes sharing your personal data between SEON group entities. Please note that we share your personal data with SEON entities outside of the EEA, in particular, we transfer your personal data to the UK. Data transfers to the UK are currently not restricted. SEON will make sure that it provides an appropriate safeguard to the data transferred if such becomes necessary.

Your personal data will be shared with the following categories of business partners that provide us services to achieve the above listed purposes: cloud providers, applicant tracking system providers, head-hunters, recruitment agencies, social media providers, and (online) testing tools providers. Please note that we share your personal data with some business partners outside of the EEA, in particular, we transfer your personal data to the US. In these cases, we enter into standard contractual clauses adopted by the European Commission with these business partners to ensure the adequate protection of your personal data. A copy of these safeguards can be obtained for your review on request by using the contact details specified in this Privacy Notice.

Your personal data will only be shared by us for the purposes specified in this Privacy Notice.

SEON does not carry out automated decision-making or profiling based solely on automated processing in relation to your personal data.

We will only send you marketing emails or contact you about our future career opportunities if you’ve given your consent to this. We may personalise content based on the information you’ve provided. Should you change your mind after having opted in for marketing activity, you can update your preferences or unsubscribe from any direct marketing email. If you no longer wish to receive recruitment marketing messages, you can unsubscribe using the link provided in the marketing messages, or you can contact us using the contact details provided in this Privacy Notice.

10.1 Rights of data subjects

Pursuant to Articles 15-21 of the GDPR, in relation to your personal data processed by SEON you are entitled to:

• access personal data;
• request rectification of personal data;
• request erasure of personal data;
• request restriction of the processing of personal data;
• object to the processing of personal data;
• receive the personal data and transmit personal data to another controller, if the relevant legal requirements are met (right to data portability, see below in Section 7.1.6);
• withdraw your consent at any time if the processing is based on your consent.

If you wish to exercise any of your rights, please contact us at the email contact information indicated in Section 2 of this Privacy Notice. SEON will provide information on the actions taken on your request without undue delay, and in any event within 30 days of the receipt of the request. If we do not take any action on your request, we will inform you without delay and at the latest within 30 days of the receipt of the request of the reasons for not taking action and on the possibility of lodging a complaint with a data protection supervisory authority and seeking judicial remedy. If you do not agree with the answer or measures applied by SEON, remedies are available as set out in Section 7.2. SEON informs all recipients of all rectification, erasure, or restriction of processing to whom personal data was disclosed except if it is impossible or requires disproportionate effort. On request, SEON provides information on recipients. 

You can also exercise some of your rights via the settings available in our applicant tracking system.

10.1.1 Right to access

You have the right to obtain from SEON confirmation as to whether or not their personal data are being processed. If your personal data is processed you have the right to access to the personal data, (or obtain a copy) and to receive information about the circumstances of the data processing. The information requested may include but are not limited to the following: the purposes of the processing; the categories of personal data concerned; the recipients or categories of recipient to whom the personal data have been or will be disclosed by SEON; the planned period for which the personal data will be stored; where the personal data are not collected from you, any available information as to their source, etc.

10.1.2 Right to rectification

You have the right to obtain from SEON without undue delay the rectification of inaccurate personal data and to have incomplete personal data completed.

10.1.3 Right to erasure (“right to be forgotten”)

You have the right to request from SEON the erasure of your personal data without undue delay where one of the following applies:

• the personal data are no longer necessary for the purposes for which they were processed;
• the consent on which the processing is based is withdrawn, and where there is no other legal ground for the processing;
• you object to the processing and there are no overriding legitimate grounds for the processing;
• the personal data have been unlawfully processed by SEON;
• the personal data have to be erased for compliance with a legal obligation.

SEON does not erase the personal data where the processing is necessary for any of the following reasons: (i) for exercising the right of freedom of expression and information; (ii) for compliance with a legal obligation which requires processing; (iii) for the establishment, exercise or defence of legal claims.

10.1.4 Right to restriction of processing

You have the right to obtain from SEON a restriction of processing where one of the following applies:

• you contest the accuracy of the personal data. In this case the restriction applies for a period enabling SEON to verify the accuracy of the personal data;
• the processing is unlawful and you oppose the erasure of the personal data and request the restriction of their use instead;
• SEON no longer needs the personal data for the purposes of the processing, but you require them for the establishment, exercise, or defence of legal claims;
• you have objected to the processing. In this case the restriction applies for the period of the verification whether the legitimate grounds of SEON override yours.

Where processing has been restricted, such personal data will, with the exception of storage, only be processed with your consent or for the establishment, exercise or defence of legal claims or for the protection of the rights of another natural or legal person or for reasons of important public interest of the Union or of a Member State. You will be informed by SEON before the restriction of processing is lifted.

10.1.5 Right to object to processing

You have the right to object, on grounds relating to your particular situation, at any time to any processing of your personal data, which is based on the legitimate interests pursued by SEON. In this case, SEON will no longer process the personal data unless it demonstrates compelling legitimate grounds for the processing which override your interests, rights, and freedoms or that are related to the establishment, exercise, or defence of legal claims.

10.1.6 Right to data portability

If it does not adversely affect the rights and freedoms of others, you have the right to receive your personal data (which you provided to SEON) in a structured, commonly used, and machine-readable format and you also have the right to have the personal data transmitted directly from SEON to another controller, if the following cumulative conditions are fulfilled:

• the processing is based on your consent, or it is necessary for the performance of a contract to which you are a party or in order to take steps at your request prior to entering into a contract; and
• the processing is carried out by automated means, i.e. the processing is carried out in an IT system instead of a paper form.

10.2 Remedies

If you do not agree with the communication or actions taken by SEON, you have the right to lodge a complaint with the data protection supervisory authority in the EU Member State of your habitual residence, place of work or place of alleged infringement, in particular, with the following supervisory authority:

Hungarian National Authority for Data Protection and Freedom of Information - Address: 1055 Budapest, Falk Miksa utca 9-11; mailing address: 1363 Budapest, Pf. 9.; tel.: +36-1-391-1400; e-mail: ugyfelszolgalat@naih.hu; website: naih.hu

SEON may amend this Privacy Notice. In such a case, SEON publishes the updated version of the Privacy Notice. SEON will always provide you with adequate information on the major changes.

Effective from August 15, 2022