(A) This Notice
This Notice is issued by HRsolution International AG on behalf of itself, its
its affiliates (together, “HRsolution International AG”, “we”,
“us” and “our”) and
addressed to candidates, referees, sources, clients and other individuals outside
organisation with whom we interact, including clients, visitors to our Sites, and
other users of
our services (together, “you”). Defined terms used in this Notice are explained in
For the purposes of this Notice, HRsolution International AG is the Controller.
are provided in Section (R) below.
This Notice may be amended or updated from time to time to reflect changes in our
with respect to the Processing of Personal Data, or changes in applicable law. We
you to read this Notice carefully, and to regularly check this page to review any
might make in accordance with the terms of this Notice.
(B) Collection of Personal Data
Collection of Personal Data: We may collect Personal Data about you
from the following
Data you provide: We may obtain your Personal Data when you provide it to
where you contact us via email or telephone, or by any other means, or when you
provide us with your CV or business card).
Relationship data:We may collect or obtain your Personal Data in the
of our relationship with you (e.g., if you purchase a service from us, from
or other communication exchange between us).
Data you make public:We may collect or obtain your Personal Data that you
manifestly choose to make public, including via social media (e.g., we may
information from your social media profile(s) such as Xing, LinkedIn, Facebook
Site data:We may collect or obtain your Personal Data when you visit any
of our Sites
or use any features or resources available on or through a Site.
Registration details:We may collect or obtain your Personal Data when you
register to use, any of our Sites, or services.
Content and advertising information:If you choose to interact with any
content or advertising on a Site, we may receive Personal Data about you from
relevant third party.
Third party information:We may collect or obtain your Personal Data from
parties who provide it to us (e.g., credit reference agencies; law enforcement
authorities; previous employers in form of a reference check etc.).
(C) Creation of Personal Data
We may also create Personal Data about you, such as records of your interactions
with us, and
any interactions we have with clients on your behalf.
(D) Categories of Personal Data we may Process
We may Process the following categories of Personal Data about you:
Personal details:given name(s); preferred name; photograph; employment
education; and other typical CV content.
Demographic information:gender; date of birth / age; nationality;
salutation; title; and
Contact details:correspondence address; telephone number; email address;
of your public social media profile(s).
Consent records:records of any consents you may have given, together with
and time, means of consent and any related information (e.g., the subject matter
Data relating to our Sites:device type; operating system; browser type;
settings; IP address; language settings; dates and times of connecting to a
username; password; security login details; usage data; aggregate statistical
Employer details:where you interact with us in your capacity as an
name, address, telephone number and email address of your employer, to the
Salary and other employment details:where these are necessary for us
and your employer services. This can include sick days or other health related
(pregnancy, disability, religious affiliation etc.) required for payroll
purposes if we are
providing such services to your employer and yourself.
Content and advertising data:records of your interactions with our online
and content, records of advertising and content displayed on pages displayed to
and any interaction you may have had with such content or advertising (including
mouse hover, mouse clicks, any forms you complete (including incomplete forms
submitted) and any touchscreen interactions).
Views and opinions:any views and opinions that you choose to send to us,
post about us on social media platforms.
(E) Lawful basis for Processing Personal Data
In Processing your Personal Data in connection with the purposes set out in this
may rely on one or more of the following legal bases, depending on the
Consent:We may Process your Personal Data where we have obtained your
express consent to the Processing (this legal basis is only used in relation to
Processing that is entirely voluntary – it is not used for Processing that is
obligatory in any way);
Legitimate interests:We may Process your Personal Data where we have a
interest in carrying out the Processing for the purpose of managing, operating
promoting our business, and that legitimate interest is not overridden by your
fundamental rights, or freedoms;
Contractual necessity:We may Process your Personal Data where the
necessary in connection with any contract that you may enter into with us;
Compliance with applicable law:We may Process your Personal Data where
Processing is required by applicable law; or
Vital interests:We may Process your Personal Data where the Processing is
to protect the vital interests of any individual.
(F) Sensitive Personal Data
We do not seek to collect or otherwise Process your Sensitive Personal Data in the
course of our business. Where it becomes necessary to process your Sensitive
for any reason, we rely on one of the following legal bases:
Compliance with applicable law:We may Process your Sensitive Personal
the Processing is required or permitted by applicable law (e.g., to comply with
diversity reporting obligations);
Detection and prevention of crime:We may Process your Sensitive Personal
where the Processing is necessary for the detection or prevention of crime
the prevention of fraud);
Establishment, exercise or defence of legal rights:We may Process your
Personal Data where the Processing is necessary for the establishment, exercise
defence of legal rights; or
Consent:We may Process your Sensitive Personal Data where we have, in
with applicable law, obtained your prior, express consent prior to Processing
Sensitive Personal Data (this legal basis is only used in relation to Processing
entirely voluntary – it is not used for Processing that is necessary or
obligatory in any
(G) Purposes for which we may Process your Personal Data
The purposes for which we may Process Personal Data, subject to applicable law,
Provision of services to you:providing our Sites, or services to you;
with services that you have requested; providing you with promotional items at
request; and communicating with you in relation to those services.
Compliance checks:fulfilling our compliance obligations, including ‘Know
Client’ checks; and confirming and verifying your identity (including by using
reference agencies); and screening against government and/or law enforcement
sanctions lists and other legal restrictions.
Our Sites:operating and managing our Sites; providing content to you;
advertising and other information to you; communicating and interacting with you
our Sites; and notifying you of changes to any of our Sites, or our services.
Communications:communicating with you via any means (including via email,
telephone, text message, social media, post or in person) news items and other
information in which you may be interested, subject to ensuring that such
communications are provided to you in compliance with applicable law;
and updating your contact information where appropriate; and obtaining your
opt-in consent where required.
Communications and IT operations:management of our communications
operation of IT security systems; and IT security audits.
Health and safety:health and safety assessments and record keeping; and
with related legal obligations.
Financial management:sales; finance; corporate audit; and vendor
Surveys:engaging with you for the purposes of obtaining your views on our
Security:physical security of our premises (including records of visits
to our premises;
and CCTV recordings); and electronic security (including login records and
Investigations:detecting, investigating and preventing breaches of
policy, and criminal
offences, in accordance with applicable law.
Legal proceedings:establishing, exercising and defending legal rights.
Legal compliance:compliance with our legal and regulatory obligations
Improving our Sites, services:identifying issues with our Sites, or our
planning improvements to our Sites, or our services; and creating new Sites, or
(H) Disclosure of Personal Data to third parties
We may disclose your Personal Data to other entities within the HRsolution
group, for legitimate business purposes (including operating our Sites, and
to you), in accordance with applicable law. In addition, we may disclose your
We may disclose your personal data to our clients such as companies with whom we
do business, companies from whom we have specific assignments to search for
specific people or companies (not clients) that have indicated an interest in
profiles that they are interested in hiring.
legal and regulatory authorities, upon request, or for the purposes of reporting
actual or suspected breach of applicable law or regulation;
accountants, auditors, lawyers and other outside professional advisors to
International AG, subject to binding contractual obligations of confidentiality;
third party Processors (such as payment services providers; shipping companies;
located anywhere in the world, subject to the requirements noted below in this
any relevant party, law enforcement agency or court, to the extent necessary for
establishment, exercise or defence of legal rights;
any relevant party for the purposes of prevention, investigation, detection or
prosecution of criminal offences or the execution of criminal penalties,
safeguarding against and the prevention of threats to public security;
any relevant third party acquirer(s), in the event that we sell or transfer all
relevant portion of our business or assets (including in the event of a
dissolution or liquidation); and
any relevant third party provider, where our Sites use third party advertising,
or content. If you choose to interact with any such advertising, plugins or
Personal Data may be shared with the relevant third party provider. We recommend
plugins or content.
If we engage a third-party Processor to Process your Personal Data, the Processor
subject to binding contractual obligations to: (i) only Process the Personal Data in
with our prior written instructions; and (ii) use measures to protect the
security of the Personal Data; together with any additional requirements under
(I) International transfer of Personal Data
Because of the international nature of our business, we may need to transfer your
Data within the HRsolution International AG group and to third parties as noted in
(H) above, in connection with the purposes set out in this Notice. For this reason,
transfer your Personal Data to other countries that may have different laws and data
compliance requirements to those that apply in the country in which you are located.
(J) Data security
We have implemented appropriate technical and organisational security measures
protect your Personal Data against accidental or unlawful destruction, loss,
unauthorised disclosure, unauthorised access, and other unlawful or unauthorised
Processing, in accordance with applicable law.
Because the internet is an open system, the transmission of information via the
internet is not
completely secure. Although we will implement all reasonable measures to protect
personal data, we cannot guarantee the security of your data transmitted to us using
internet – any such transmission is at your own risk and you are responsible for
any Personal Data that you send to us are sent securely.
(K) Data accuracy
We take every reasonable step to ensure that:
your Personal Data that we Process are accurate and, where necessary, kept up to
any of your Personal Data that we Process that are inaccurate (having regard to
purposes for which they are Processed) are erased or rectified without delay.
From time to time we may ask you to confirm the accuracy of your Personal Data.
(L) Data minimisation
We take every reasonable step to ensure that your Personal Data that we Process are
the Personal Data reasonably necessary in connection with the purposes set out in
(M) Data retention
We take every reasonable step to ensure that your Personal Data are only Processed
minimum period necessary for the purposes set out in this Notice.
The criteria for determining the duration for which we will keep your Personal Data
follows: we will retain copies of your Personal Data in a form that permits
for as long as is necessary in connection with the purposes set out in this Notice,
applicable law requires a longer retention period. In particular, we may retain your
Data for the duration of any period necessary to establish, exercise or defend any
(N) Your legal rights
Subject to applicable law, you may have a number of rights regarding the Processing
Relevant Personal Data, including:
the right not to provide your Personal Data to us (however, please note that we
unable to provide you with the full benefit of our Sites, or our services, if
you do not
provide us with your Personal Data – e.g., we may not be able to process your
without the necessary details);
the right to request access to, or copies of, your Relevant Personal Data,
information regarding the nature, Processing and disclosure of those Relevant
the right to request rectification of any inaccuracies in your Relevant Personal
the right to request, on legitimate grounds:
erasure of your Relevant Personal Data; or
restriction of Processing of your Relevant Personal Data;
the right to object, on legitimate grounds, to the Processing of your Relevant
Data by us or on our behalf;
the right to have certain Relevant Personal Data transferred to another
Controller, in a
structured, commonly used and machine-readable format, to the extent applicable;
where we Process your Relevant Personal Data on the basis of your consent, the
to withdraw that consent (noting that such withdrawal does not affect the
any Processing performed prior to the date on which we receive notice of such
withdrawal, and does not prevent the Processing of your Personal Data in
upon any other available legal bases); and
the right to lodge complaints with a Data Protection Authority regarding the
Processing of your Relevant Personal Data by us or on our behalf.
This does not affect your statutory rights.
To exercise one or more of these rights, or to ask a question about these rights or
provision of this Notice, or about our Processing of your Personal Data, please use
details provided in Section (R) below. Please note that:
we may require proof of your identity before we can give effect to these rights;
where your request requires the establishment of additional facts (e.g., a
of whether any Processing is non-compliant with applicable law) we will
your request reasonably promptly, before deciding what action to take.
(O) Cookies and similar technologies
When you visit a Site we may place Cookies onto your device, or read Cookies already
your device, subject always to obtaining your consent, where required, in accordance
some cases, your preferences and browsing habits. We may Process your Personal Data
through Cookies and similar technologies, in accordance with our Cookie Notice .
(Q) Direct marketing
We may Process your Personal Data to contact you via email, telephone, direct mail
communication formats to provide you with information regarding services that may be
interest to you. If we provide services to you, we may send information to you
services, upcoming promotions and other information that may be of interest to you,
contact details that you have provided to us and always in compliance with
You may unsubscribe from our promotional email list at any time by simply clicking
unsubscribe link included in every promotional email we send. After you unsubscribe,
not send you further promotional emails, but we may continue to contact you to the
necessary for the purposes of any services you have requested.
(R) Contact details
If you have any comments, questions or concerns about any of the information in this
or any other issues relating to the Processing of Personal Data carried out by us,
or on our
behalf, please contact:
HRsolution International AG
Toracker Park 11
Tel.:+41(0)71-534 83 83
“Adequate Jurisdiction”a jurisdiction that has been formally
designated by the
European Commission as providing an adequate level of protection for Personal
“Controller”means the entity that decides how and why Personal
Data are Processed.
In many jurisdictions, the Controller has primary responsibility for complying
applicable data protection laws.
“Cookie”means a small file that is placed on your device when
you visit a website
(including our Sites). In this Notice, a reference to a “Cookie” includes
technologies such as web beacons and clear GIFs.
“Data Protection Authority”means an independent public
authority that is legally
tasked with overseeing compliance with applicable data protection laws.
“EEA” means the European Economic Area.
“Personal Data”means information that is about any individual,
or from which any
individual is directly or indirectly identifiable, in particular by reference to
identifier such as a name, an identification number, location data, an online
or to one or more factors specific to the physical, physiological, genetic,
economic, cultural or social identity of that individual.
“Process”, “Processing” or “Processed”means anything that is
done with any
Personal Data, whether or not by automated means, such as collection, recording,
organisation, structuring, storage, adaptation or alteration, retrieval,
disclosure by transmission, dissemination or otherwise making available,
combination, restriction, erasure or destruction.
“Processor”means any person or entity that Processes Personal
Data on behalf of the
Controller (other than employees of the Controller).
“Relevant Personal Data”means Personal Data in respect of which
we are the
Controller. It expressly does not include Personal Data of which we are not the
“Sensitive Personal Data”means Personal Data about race or
opinions, religious or philosophical beliefs, trade union membership, physical
mental health, sexual life, any actual or alleged criminal offences or
identification number, or any other information that may be deemed to be
under applicable law.
“Site”means any website operated, or maintained, by us or on
“Standard Contractual Clauses”means template transfer clauses
adopted by the
European Commission or adopted by a Data Protection Authority and approved by