Privacy - European Dynamics

Privacy Notice for the General Public

EUROPEAN DYNAMICS (ED) takes your privacy very seriously. This Privacy Notice is intended to set out your rights and answer any queries you may have about how ED processes your personal data. If you need more information, please contact: data.protection@eurodyn.com.

The name EUROPEAN DYNAMICS refers to the EUROPEAN DYNAMICS Group of Companies, which includes EUROPEAN DYNAMICS SA, EUROPEAN DYNAMICS LUXEMBOURG SA, EUROPEAN DYNAMICS BELGIUM SA, EUROPEAN DYNAMICS GROUP HOLDING SA, EUROPEAN DYNAMICS DEUTSCHLAND G.M.B.H., EUROPEAN DYNAMICS AUSTRIA G.M.B.H., EUROPEAN DYNAMICS SWISS AG, EUROPEAN DYNAMICS UK Ltd, EUROPEAN DYNAMICS Netherlands B.V. and EUROPEAN DYNAMICS INTERNATIONAL Ltd.

Our policy and procedures outlined in this notice have been developed in line with the General Data Protection Regulation (EU) 2016/679, in force from 25 May 2018, and applicable laws.

By providing your personal data to ED for any reason you confirm that you acknowledge this privacy notice. If you have provided personal data to ED and you do not agree with this notice, you should notify us immediately.

1. What information do we process?

With the word “processing” we mean any operation performed on personal data including the collection, recording, storage, consultation, use, making available, erasure or destruction of such data.

EUROPEAN DYNAMICS may process a range of personal data about you, which may include indicatively:

Name(s) or alias; gender; birthdate (age), marital status;
Mailing & email address, telephone numbers and other contact details;
A copy of a form of identification such as a national identity card, passport or other form of identity bearing a photograph or not, VAT/ TIN numbers, social security number (if applicable);
Resume, educational and professional qualifications, certifications, employment references, personal skills and interests;
Employment and training history and performance records;
Information about your level of remuneration, including benefit entitlements;
Military service obligations status (if applicable).

ED may process information related to your nationality, with the sole purpose to process visas and work permits, where necessary for the conclusion or execution of a contract.

ED may also process your Criminal Record in order to comply with legal requirements in the context of fulfilling security clearance or similar obligations, in specific cases where necessary for the conclusion or execution of a contract.

2. Why do we process your personal data?

We process your personal data for the purpose you provided this data and in order to protect our legitimate interests as detailed further below. Indicatively, such purposes may be the examination of future collaboration opportunities (other than recruitment), including communicating with you, the establishment or the performance of a contract, e.g. for providing a service/s or a supply of goods etc., or in order to satisfy communication or support purposes, in cases where you are personally engaged either as an individual or as a representative of a legal entity.

3. What is the legal basis of the processing?

In line with the provisions of the GDPR, our processing of your personal data is based upon a specific legal basis, which may include any of the following as applicable:

Your consent;
The establishment of a contract with you or as part of the performance of a contract with you.
Compliance with a legal obligation to which we are subject.
For purposes of the legitimate interests pursued by us, taking into account where such interests may be overridden by the interests or fundamental rights and freedoms of you. Such processing may be indicatively for the following reasons:
- to enable us to comply with regulatory, or contractual obligations we have;
- to prevent, detect, and report fraud, misrepresentation, and other wrongdoing;
- to establish, exercise or defend legal claims;
- for quality assurance purposes; and
- to manage risks.

4. How do we process your information?

EUROPEAN DYNAMICS ensures that personal data is processed in confidence, it is not disclosed to unauthorised third parties and is treated with the highest security.

We will never sell your personal data at all times.

We have internal policies and controls in place to ensure that your data is not lost, accidentally corrupted, or misused. Personal data may be shared with or sent to our designated officers as part of their normal job function; affiliate companies and/or subsidiaries of the Group; client organisations and/or public authorities, for purposes as specified in paragraph 2 above.

Your personal data shall not be transferred to a country or territory outside the EEA, unless that country or territory ensures an adequate level of protection or the appropriate safeguards are in place for the protection of your fundamental rights and freedoms.

Additionally, ED may disclose your personal data if it is required to do so by law or pursuant to a legal process and/or in response to a request from law enforcement authorities or regulatory authorities.

5. Where do we store your information?

We maintain your personal information primarily in electronic form in our secure infrastructure, in the EEA. Where paper copies containing such data exist, they are also adequately and safely stored. Your personal data will be stored in a range of different locations within our internal IT systems (including email).

6. How long do we process your data?

We process your personal data for as long as it is necessary for the purpose it is collected; indicatively:

Where your personal data is processed based on your consent, we process your data accordingly until you withdraw your consent.
Where your data is processed in relation to our contractual rights and obligations towards you or third parties, you being implicated in any way through the performance of such contracts with third parties (e.g. as a subcontractor), we will process your data for as long as it is necessary to fulfil such contractual rights and obligations.
Where we process your data for the purposes as presented in paragraph 2 above, we retain data for as long as it is necessary in order to comply with relevant legal, contractual, accounting, or reporting purposes or to establish, exercise or defend against legal claims.

In all cases, we store your data securely and ensure that access to your data is only available for the reasons stated in paragraph 2 above.

7. What are your rights?

You have the following rights regarding the processing of your personal data:

If we process your information based on your consent, you may withdraw your consent at any time.
You may request access and obtain a copy of your data. We will try to honour this request as soon as possible depending among others on the amount and complexity of this data.
You may request for your data to be deleted in case where:
- Your personal data is no longer necessary for the purposes presented in paragraph 2 above.
- You object to the processing and there are no overriding legitimate grounds for the processing.
- Your personal data has been unlawfully processed.
- Applicable laws mandate the deletion of your data.
You may request the correction and/or update of the personal data that you provided.
You may object to the processing of your data if our processing is based on reasons other than your consent. We will examine your objection and respond to you with our position.
You may request restriction of processing (if applicable)

You may, at any time, exercise your rights, by contacting data.protection@eurodyn.com. If there are any doubts as to the identity of the individual submitting the request, we may ask you for proof of identity to ensure that we are not sharing your personal data with anyone else but yourself. We will try to comply with your request regarding the processing of your personal data as soon as possible and normally no later than 30 days after we receive your request. We will notify you if we justifiably cannot address your request or if we require additional time.

If you believe that ED has not complied with your data protection rights, you can contact our Data Protection Officer through the following email address: dpo@eurodyn.com. If you are not satisfied with our response, you may contact the competent Data Protection Authority.

8. Effect of the Notice and changes to the Notice

We reserve the right to update this Notice from time to time without any prior notification. You may determine if any such revision has taken place by referring to the date on which this Notice was last updated. Your continued collaboration in the context of our agreed activities constitutes your acknowledgement and acceptance of such changes.

Last updated: 15.11.2019

Privacy Notice for Job Applicants

EUROPEAN DYNAMICS (ED) takes your privacy very seriously. This Privacy Notice is intended to set out your rights and answer any queries you may have about how ED processes your personal data specifically as part of the recruitment process. If you need more information, please contact: data.protection@eurodyn.com.

The name EUROPEAN DYNAMICS refers to the EUROPEAN DYNAMICS Group of Companies, which comprises EUROPEAN DYNAMICS SA, EUROPEAN DYNAMICS LUXEMBOURG SA, EUROPEAN DYNAMICS BELGIUM SA, EUROPEAN DYNAMICS GROUP HOLDING SA, EUROPEAN DYNAMICS DEUTSCHLAND G.M.B.H., EUROPEAN DYNAMICS AUSTRIA G.M.B.H., EUROPEAN DYNAMICS SWISS AG, EUROPEAN DYNAMICS UK Ltd, EUROPEAN DYNAMICS Netherlands B.V. and EUROPEAN DYNAMICS INTERNATIONAL Ltd.

Our policy and procedures outlined in this notice have been developed in line with the General Data Protection Regulation (EU) 2016/679, in force from 25 May 2018, and applicable laws.

By providing your personal data to ED as part of your expression of interest and/ or application for recruitment and as part of the recruitment process, you confirm that you acknowledge this privacy notice. If you do not agree with it, you should notify us immediately. In such cases, ED may not be able to assess your application and consider whether you are suitable for a position, nor will it be able to further proceed with the recruitment.

1. What information do we process?

With the word “processing” we mean any operation performed on personal data including the collection, recording, storage, consultation, use, making available, erasure or destruction of such data.

EUROPEAN DYNAMICS processes a range of personal information about you. This may include indicatively:

Name(s) or alias; gender; birthdate (age), marital status;
Mailing & email address, telephone numbers and other contact details;
A copy of a form of identification such as a national identity card, passport or other form of identity bearing a photograph or not, VAT/ TIN numbers, social security number (if applicable);
Resume, educational and professional qualifications, certifications, employment references, personal skills and interests;
Employment and training history, online test results, interview evaluations and performance records;
Information about your level of remuneration, including benefit entitlements;
Work-related health issues and disabilities;
Military service obligations status (if applicable).

ED may process information related to your nationality, with the sole purpose to process visas and work permits, where necessary for the conclusion or execution of a contract.

2. What is the source of this information?

We obtain this information directly from you, our personnel, through our systems and equipment, as well as from third parties such as recruitment agencies, background checking companies or former employers. Information may be generated also during the recruitment process, for example during interviews, and evaluation tests. We may also obtain it from your public profiles available online.

3. Why do we process your information?

We process your information differently in the three consecutive phases of the recruitment process:

a) The period from the announcement of openings and/or the submission of a request for recruitment from the job applicant: During this phase, we only collect and store securely any information you have submitted to us, in order to be assessed for recruitment purposes.

b) The period from our first contact up to the final decision on recruitment or not: During this phase, we process your personal information to make recruitment decisions.

c) The period starting from the recruitment decision onwards: If the decision is positive, then we use your personal information in order to conclude a contract with you and we continue to process your data for the performance of such contract. However, if the decision is not positive, then we process your information in two ways:

We store securely your information and a record of all related communication related to the recruitment process that was undertaken for the specific job application, in order to protect our legitimate interests as detailed further below; and
Conditionally, based upon your consent, we will process your contact information, skills, and experience with the sole purpose to notify you if similar openings become available in the future.

4. What is the legal basis of the processing?

In line with the provisions of the GDPR, our processing of your personal data is based upon a specific legal basis, as follows:

a) During all recruitment phases, for compliance with the legal obligations to which we are subject; for example to record your consent in line with the requirements of the GDPR and/ or for the establishment, exercise or defence of legal claims.

b) During the first and the second recruitment phase, in order to fulfil your request for recruitment towards the establishment of a contract with you.

c) During the second and third recruitment phase, for the purposes of the legitimate interests pursued by us, taking into account where such interests may be overridden by the interests or fundamental rights and freedoms of you.

d) To be able to notify you about new openings, based on your consent. We maintain your contact information, skills, and experience to be able to propose to you relevant employment opportunities in the future. You may withdraw your consent regarding the processing of your data for proposals in the context of such future opportunities at any time, in the same way you provided us with your consent in the first place (e.g. via email).

To clarify, in case c above, we process your personal data indicatively for the following reasons:

to enable us to comply with the legal, regulatory, or contractual obligations we have;
to prevent, detect, and report fraud, misrepresentation, and other wrongdoing;
to establish, exercise or defend our legal claims;
for quality assurance purposes; and
to manage risks.

5. How do we process your information?

EUROPEAN DYNAMICS ensures that personal data is processed in confidence, it is not disclosed to unauthorised third parties and is treated with the highest security.

We will never sell your personal data at all times.

6. Where do we store your information?

7. How long do we process your data?

We process your personal data for as long as it is necessary for the purpose it is collected; indicatively:

Where your personal data is processed based on your consent, we process your data accordingly until you withdraw your consent.
Where your data is processed for the evaluation of your application and the recruitment process is related to our contractual obligations in the context of proposing a service or fulfilling a contract with our clients, we will process your data for as long as it is necessary to propose such services or fulfil such contractual obligations.
Where we process your data for the purposes as presented in paragraph 3 above, we retain data for as long as it is necessary in order to comply with relevant legal, contractual, accounting, or reporting purposes or to establish, exercise or defend against legal claims.

In all cases, we store your data securely and ensure that access to your data is only available for the reasons stated in paragraph 3 above.

8. What are your rights?

You have the following rights regarding the processing of your personal data:

If we process your information based on your consent, you may withdraw your consent at any time.
You may request access and obtain a copy of your data. We will try to honour this request as soon as possible depending among others on the amount and complexity of this data.
You may request for your data to be deleted in case where:
- Your personal data is no longer necessary for the purposes presented in paragraph 3 above.
- You object to the processing and there are no overriding legitimate grounds for the processing.
- Your personal data has been unlawfully processed.
- Applicable laws mandate the deletion of your data.
You may request the correction and/or update of the personal data that you provided.
You may object to the processing of your data if our processing is based on reasons other than your consent. We will examine your objection and respond to you with our position.
You may request restriction of processing (if applicable).

9. Effect of the Notice and changes to the Notice

We reserve the right to update this Notice from time to time without any prior notification. You may determine if any such revision has taken place by referring to the date on which this Notice was last updated. Your continued participation in our recruitment process constitutes your acknowledgement and acceptance of such changes.

Last updated: 15.11.2019