PRIVACY & LEGAL NOTICE - QOMMODITY RECRUITING PRIVACY POLICY

2. SCOPE

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This Privacy Policy applies to Qommodity’s processing of personal information of job applicants, potential candidates for employment, those who have participated in recruiting events and others who have expressed an interest in Qommodity.
 

For additional information about our processing activities in connection with your general use of Qommodity websites and our use of cookies and similar technologies that is outside the scope of this Privacy Policy, please see our General Privacy Policy.

 

3. WHO IS RESPONSIBLE FOR PROCESSING YOUR PERSONAL INFORMATION

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Qommodity QAAA B.V., having its registered address at Landhuis Joochi, Kaya Richard J. Beaujon Z/N, Willemstad, Curaçao, and the local Qommodity entit(y)(ies) of the countr(y)(ies) in which you applied for a job offer, are responsible for processing your personal information as described in this Privacy Policy. 

 

Qommodity may use data analytics and algorithms to help recruiters sort through candidate and application information. Algorithms help reduce the application or resume review time and assist in identifying candidates based on professional qualifications, skills, and experience commensurate with the relevant requisition. The algorithms analyze that data and compare it to our historical data on successful and unsuccessful candidates. Automated results are always evaluated by Qommodity recruiters and are never the sole source of considering a candidate for employment.

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4. WHICH CATEGORIES OF PERSONAL INFORMATION DO WE PROCESS AND FROM WHICH SOURCES

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We process personal information that you provide directly to us, such as when you register in the Qommodity Recruiting Cloud, submit a job application on the Sites or in connection with a recruiting event, or when we conduct a remote or in-person interview. We may also receive personal information about you from other sources, such as from references, in connection with background or employment checks, target companies where Qommodity conducts due diligence related to a potential acquisition of your employer, and from third party sources like professional headhunters or recruiting firms, data brokers or if allowed by applicable law other sources such as Sites. Sites include, without limitation, social sites where you have created a public page or profile or otherwise given permission so that recruiters can access your information on these sites. They also can include vendor sites where Qommodity has invited you to participate in assessments, evaluations or online interviews. Online video interviews are subject to supplemental privacy terms.

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Qommodity may process the following categories of personal information for our recruitment activities as further described in Section 5 of this Privacy Policy:

 

• name and contact details

• educational background

• employment background

• job qualifications and work eligibility, including your nationality, country of residence, and visa and immigration status

• jobs in which you have expressed an interest or for which you would like to submit an application

• CV, resume or transcripts, and any supporting documentation attached to your resume such as copies of certificates and diplomas

• employment references

• compensation details, such as salary information, depending on your region

• background check information, such as a verification of your educational and professional background, and other relevant information subject to Qommodity policies and applicable laws

• information about your personality, competency, ability and suitability for a position 

• certain types of sensitive personal information as described in Section 12 below

 

5. WHY AND HOW DO WE USE YOUR PERSONAL INFORMATION

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We use personal information for the following purposes:

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• to communicate with you and respond to your requests or application

• for recruitment, evaluation, background screening and hiring purposes

• to enable your use of the Qommodity Recruiting Cloud

• to analyze, develop and improve the Qommodity Recruiting Cloud, our recruiting activities and Qommodity products and services

• to maintain the security of the Qommodity Recruiting Cloud and our sites, systems and networks

• to comply with applicable laws and regulations and to operate our business

 

These purposes are described below in further detail.

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To communicate with you and respond to your requests or application

If you get in touch with us (for example, through Qommodity Recruiting Cloud, contact forms on the Sites, contact with our recruiters or at events or via Sites) we process information about you to communicate with you about your application or job interests. For example, we may update you on the status of your application, inform you about new vacancies or invite you for recruitment activities such as a phone or in-person interview.

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For recruitment, evaluation, and background screening and hiring purposes

We process information about you to connect the right candidate with the right job at Qommodity and evaluate whether you are the right applicant for a position. We may therefore include information about you in our recruitment databases to manage Qommodity’s candidate selection and recruiting processes. If you are selected for a position at Qommodity, information about you will also be used to facilitate the hiring process. Please be aware that, prior to hiring you and in order for Qommodity to be able to extend an offer to you, you may be requested to complete a background check in accordance with Qommodity policies and local law. For more information about this background check and the processing of information about you in connection with a background check. Depending on your region, additional details regarding our use of background check information about you may also be specified in the applicable privacy notices and/or policies of our background check service provider.

Qommodity may invite you to participate in assessments to evaluate your suitability for a position. In evaluating your suitability for the position, Qommodity may access your assessment and receive results from the Sites. 

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To enable your use of the Qommodity Recruiting Cloud

When you choose to register with us to set up an Qommodity Recruiting Cloud account, once available, we need to process your personal information so that we can create and administer your personal account. Upon creating your account, we will send you your personal login information. This personal information enables us to administer your account (such as authenticating your access or changing your password at your request).

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To analyze, develop and improve the Qommodity Recruiting Cloud, our recruiting activities and Qommodity products and services

In order to analyze, develop and improve Qommodity Recruiting Cloud, our recruiting activities and Qommodity products and services, Qommodity may process information about you, for example if you encountered any problems in using Qommodity Recruiting Cloud or if it is not functioning as expected. We may also process information about you to develop and test new products or system versions, patches and updates.

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To maintain the security of the Qommodity Recruiting Cloud

We may use personal information about you as necessary to maintain the security of the Qommodity Recruiting Cloud, and our sites, systems and networks. For example, we may process information about you when investigating suspicious activity on our sites, systems and networks.

 

To comply with applicable laws and regulations and to operate our business

In some cases, we may process information about you to comply with applicable laws and regulations, such as legally mandated reporting or other legal process requests. We may also process information about you in the performance and organization of our business and internal management, for example to conduct audits and investigations, for mergers and acquisitions, finance and accounting, archiving and insurance purposes and in the context of dispute resolution.

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6. FOR INFORMATION COLLECTED ABOUT YOU IN THE EU/EEA AND OTHER RELEVANT REGIONS, WHAT IS OUR BASIS FOR PROCESSING

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For information about you collected in the EU/EEA and other relevant regions, our basis for processing is the following:

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• We have a legitimate interest in processing your contact and related information in order to consider your candidacy for employment, to communicate with you and to respond to your requests.

• Your use of the Qommodity Recruiting Cloud and the processing of information about you for recruiting purposes is based on your consent. Please note that you can always close your account and withdraw your consent, although this may affect our ability to consider you for employment at Qommodity.

• Any processing of your sensitive personal information in connection with your job application is based on your explicit consent. Please note that you can always close your account and withdraw your consent, although this may affect our ability to consider you for employment at Qommodity.

• The processing of information about you as part of our offline and online recruitment activities outside the Qommodity Recruitment Cloud is based on our legitimate interest in finding the best person for a specific job.

• In case you were not selected for the position but we would like to contact you about future job opportunities that may be of interest to you, we may process the relevant contact and related information provided by you as part of your initial application, based on our legitimate interest to find the best possible candidate for the position.

• Our processing of information about you to analyze, develop and improve the Qommodity Recruiting Cloud, our sites and Qommodity products and services is based on our legitimate interest in enhancing the effectiveness, user experience, and functioning of the Qommodity Recruiting Cloud, our sites, and our products and services.

• Our processing of information about you for security purposes is based on our legitimate interest in protecting Qommodity systems and networks.

• Our processing of information about you for legal and regulatory purposes is based on a legal obligation or on Qommodity’s legitimate interest in complying with applicable laws and regulations.

• Our processing of information about you for business operations purposes is based on our legitimate interest in operating our business in an efficient and appropriate manner.

• Our processing of personal information also will be as necessary to enter into a contract with you for employment purposes.

 

7. FOR HOW LONG DO WE RETAIN PERSONAL INFORMATION

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Qommodity maintains your personal information for the following retention periods:

• If you create an account on the Qommodity website, your account information will be retained for as long as your account is actively maintained. Your account will be deemed inactive and your account information will be deleted after five (5) years of inactivity.

• Qommodity will retain your personal information related to your application for a position (such as your curriculum vitae/resume or the position to which you applied, assessment results) for up to five (5) years from the date you applied. 

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To the extent permitted or required by law, or as requested by you, Qommodity may delete your personal information at any time. As a result, you should retain your own copy of any information you submit to us. In some cases, in order to comply with applicable law or a legal obligation, Qommodity may deny your request to delete personal information and may retain your personal information for longer than five (5) years. 

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8. WHEN AND HOW CAN WE SHARE YOUR PERSONAL INFORMATION

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Sharing within Qommodity

As a global organization information about you may be shared throughout Qommodity’s worldwide organization. See also Section 9 of this Privacy Policy. Qommodity employees are authorized to access personal information only to the extent necessary to serve the applicable purpose(s) and to perform their jobs and are bound by appropriate confidentiality agreements. 

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Sharing with third parties

Where necessary, we share personal information with third parties as described below.

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• Third-party service providers (for example, website management, information technology and related infrastructure provision, background or employment check service providers, auditing, and other similar services) in order for those service providers to perform business functions on behalf of Qommodity.

• Relevant third parties in the event of a reorganization, merger, sale, joint venture, assignment, transfer or other disposition of all or any portion of our business, assets or stock (including in connection with any bankruptcy or similar proceedings).

• As required by law, such as to comply with a subpoena or other legal process, when we believe in good faith that disclosure is necessary to protect our rights, protect your safety or the safety of others, investigate fraud, or respond to government requests, including public and government authorities outside your country of residence, for national security and/or law enforcement purposes.

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When third parties are given access to your personal information, we require them to abide by contractual, technical and organizational measures designed to ensure that your personal information is processed only to the extent that such processing is necessary, consistent with this Privacy Policy, and in accordance with applicable law. Note that some of these third parties, such as our background check service providers may also maintain additional privacy policies and notices on behalf of Qommodity. 

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9. HOW IS PERSONAL INFORMATION HANDLED GLOBALLY

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Qommodity is a global corporation and personal information is transferred, accessed, and stored globally including in countries or regions outside of the one in which you reside. If your personal information is transferred to an Qommodity recipient or third party in a country that does not provide an adequate level of protection for personal information Qommodity will take measures designed to ensure that your personal information is adequately protected and where required, transferred subject to appropriate transfer mechanisms such as EU Standard Contractual Clauses or similar legally recognized standard contractual clauses. 

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10. HOW IS YOUR PERSONAL INFORMATION SECURED

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Qommodity has implemented appropriate technical, physical, and organizational measures designed to protect your personal information against accidental or unlawful destruction or accidental loss, damage, alteration, unauthorized disclosure or access as well as all other forms of unlawful processing (including, but not limited to, unnecessary collection) or further processing. 

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11. WHAT ARE YOUR CHOICES

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Depending on your country (or state) of residence, you may have certain choices and rights in relation to our use of information about you, such as the right to access, correct and update, erase or delete, and obtain a copy of your personal information.

• Withdraw consent - You may request to withdraw the consent you have previously provided for the processing of your personal information.

• Delete personal information - You can erase or delete all or some of your personal information in the Qommodity Recruiting Cloud. 

• Change or correct personal information - You can edit some of your personal information in the Qommodity Recruiting Cloud. 

• Object to, or limit or restrict use of personal information - You can ask us to stop using all or some of your personal information.

• Right to access and/or receive a copy of your personal information - You can also obtain a copy of some of your personal information in machine readable form in the Qommodity Recruiting Cloud. 
   

You can exercise these choices in accordance with applicable laws as specified on our Privacy Choices page, or by filling using the contact form. 

 

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12. DOES QOMMODITY COLLECT SENSITIVE PERSONAL INFORMATION

 

Qommodity not only respects but celebrates Diversity and Inclusion in its workforce. Qommodity also maintains an equal opportunity program in some countries in accordance with applicable law. As part of Qommodity’s efforts to create and foster a diverse and inclusive workforce and/or to monitor equal opportunity, Qommodity may request and process sensitive personal information related to gender, identity, religious or political affiliation, sexual orientation, age, language, abilities/disabilities, veteran status, race, ethnicity, or other defining characteristics. You may also voluntarily disclose such sensitive personal information with Qommodity during the recruiting process. If not expressly required by the job advert, Qommodity does not otherwise require applicants or candidates to disclose this information in connection with a job application or as part of our recruiting efforts. However, if you elect to share such information with Qommodity, it will not be used in the hiring or selection process or to determine eligibility for any role. 

Further, if you have a disability and would like Qommodity to consider any accommodation, you may disclose or provide that information during the recruiting process. 

 

 

13. WHAT ARE YOUR RESPONSIBILITIES

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You are responsible for the personal information that you provide or make available to Qommodity, and you must ensure it is truthful, accurate, and up-to-date in all respects. You must ensure that the information provided does not contain material that is obscene, defamatory, or infringing on any rights of any third party; does not contain malicious code; and is not otherwise legally actionable. Further, if you provide any personal information concerning any other person, such as individuals you provide as references, you are responsible for providing any notices and obtaining any consents necessary for Qommodity to collect and use that information as described in this Privacy Policy. If you provide misleading, inaccurate, or incomplete information or create multiple or redundant accounts in Qommodity Recruiting Cloud, Qommodity may determine you are ineligible for employment and/or ban you from using Qommodity Recruiting Cloud. You understand that this Privacy Policy does not form part of any employment contract you may be offered in connection with your employment at Qommodity.​

 

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14. SUPPLEMENTAL RECRUITING PRIVACY POLICY TERMS

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In addition to the terms you accepted when you applied on Qommodity Recruiting Cloud you hereby agree to these supplemental terms and use of your personal information as set out in these Supplemental Recruiting Privacy Policy Terms (Supplemental Privacy Policy). Notwithstanding anything to the contrary contained in the Qommodity Recruiting Privacy Policy (Privacy Policy), when you use a third party site or Qommodity provided technology (such as Zoom) to participate in an online video interview, you consent and agree to the use of your personal information as set out in this Supplemental Privacy Policy; such third party sites or Zoom may maintain own terms of use and privacy policies for your use of those platforms, for which Qommodity disclaims any responsibility. Capitalized terms used but not defined herein have the meaning given to them in the Privacy Policy.

 

Personal information captured in a video recording may include personal information such as your voice and image. Information learned about you through online interviews and evaluations used in connection therewith can include information about your personality, behavior, and suitability for a particular position. Sensitive personal information may be revealed in a video interview such as racial or ethnic origin, religion or philosophical beliefs, sexual orientation, membership in a trade union, political affiliation, physical or mental health or condition, commission or alleged commission of an offense or related proceedings or job evaluations or educational records. Qommodity does not require and asks that you do not provide such information as part of these interviews. If you do not consent to your personal information being recorded or used as set out in this Supplemental Privacy Policy, do not apply through this process. 

 

Qommodity will store a copy of the interview in accordance with its retention policies but will not retain the video for longer than is necessary to evaluate a candidate or as is otherwise permissible by applicable law. You understand that Qommodity will not advance all candidates nor will submission of a video interview guarantee a job offer. Qommodity reserves the right to make an offer or deny an interview, in its sole discretion, to candidates who submit an interview through this process, or who elect an accommodation to interview through phone or in some cases, in person with an Qommodity recruiter. Any candidate, who Qommodity determines in its sole discretion, has tampered with a video, shares unlawful or prohibited Content or violates Qommodity’s Terms of use, understands that all Content may be used as set out in the Terms of Use, including, to provide Content to law enforcement.

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End of Qommodity Recruiting Privacy Policy. 

Version 1.24