Privacy Policy

Introduction

Your personal data is safe with us.
The following Privacy Policy describes how we at Zarttech collect, protect, and use the Personal Data you (referred to as “the user” or “you”) may provide on our website (www.zarttech.com) and within any of our services and/or procedures (collectively referred as : "Website" or "Services").
Zarttech is made up of a number of legal entities which we use as infrastructure to provide our Services. However, for data protection purposes the entities in control of all Personal Data processed in connection with our Website and Services are:

Zwart Tech B.V., registered in the Netherlands under the number 77414764, VAT number NL861001461B01, at Wilhelmina van Pruisenweg 35, 2595 AN. Den Haag; and

ZWARTE INTERNATIONAL TECHNOLOGICAL SOLUTION COMPANY LIMITED, registered in Nigeria, registration number 1727537, The Waterside 5 Admiralty Road off Admiralty Way Lekki, 101224.

The terms "Personal Data", "Data Processing", "Data Subject", "Data Controller" and "Data Processor" have the same meaning as under Regulation (EU) 2016/679 - the General Data Protection Regulation ("GDPR"). At Zarttech we process our clients’ data carefully and confidentially. All our services are based on our clients’ trust that their data are in safe hands with us.

1. Types of Data we collect

Category	Description of Data	Purpose of collecting	Type of Data
Identification	Information that can identify a specific person	Performance of a contract, compliance with a legal obligation, Communication	Legal name, copy of (government issued) ID, profile picture, birthdate
Contact	Information that can be used to facilitate contact	Performance of a contract, Communication, Legitimate interest (service improvement)	Email, mobile phone number, physical address
Location	Information on the location of an individual	Performance of a contract, Communication	IP address, physical address
Financial/Account	Information on the financial account of an individual and/or an individual's remuneration	Performance of a contract, compliance with a legal obligation	Bank account, salary
Professional	Information about an individual's past education or professional experience	Compliance with a legal obligation	CV, Role
Communication	Information that has been communicated from or to an individual	Compliance with a legal obligation, Legitimate interest (service improvement)	Email communication and/or any other information an individual has shared voluntarily
Social Situation	Information about social status of an individual	Compliance with a legal obligation,Legitimate interest (service improvement)	dependents

2. Manner of Data collection

There are two ways of collecting your personal data.

You provide them yourself or through third parties (reference or external (recruitment) to us.

We collect data ourselves through e.g. CV databases (such as Instagram and LinkedIn, also known as ‘sourcing’). We do this when we believe you might be interested in working for Zarttech. When the recruiter contacts you, they will indicate where your data was found. They will ask for your permission to contact you in the future concerning a vacancy at Zarttech by means of these data.

Manner of collection	Data you provide	Date we collect
You fill in a form on our website
You fill in a form from a marketing material (ad)
You browse through our website
You receive an email from us
You take part in a meeting with a member of our team
You participate in our company event
You create an account on our platforms
You have allowed your data to be shared by a third party

Under the GDPR, we need to have a lawful basis to legally process your Personal Data. For the described Data Processing, we rely on the following legal grounds:

Consent: (Art. 6(1)(a) GDPR) when we rely on this basis we only process Personal Data about you for the specific purposes you expressly authorise. You can withdraw your consent whenever you wish.

Performance of a contract: (Art. 6(1)(b) GDPR) when we rely on this basis the Data Processing is necessary for the performance of a contract with you or to take steps at your request before entering into such a contract.

Compliance with a legal obligation: (Art. 6(1)(c) GDPR) when we rely on this basis we are obliged to process the relevant Personal Data to comply with our legal obligations.

Legitimate interests: (Art. 6(1)(f) GDPR) when we rely on this basis we process Personal Data as necessary in pursuit of our own, our business partners', or your legitimate interests. When we do this we must ensure that the interests we pursue do not override your fundamental rights and freedoms.

Substantial public interest: (Art. 9(2)(g) GDPR) when we rely on this basis we do it to prevent harm, fraud, money laundering, terrorist financing, child labour and to enable trust safety and compliance.

3. How we process and/or use your personal Data

Processing means any operation or set of operations which is performed on personal data or on sets of personal data. When you apply for a job, we collect, use and store your personal data. One of the reasons for this is to be able to check if you are qualified for the job.
In this Privacy Statement on the procedure for recruitment and selection is declared how we process your data.

How the data is used	Purpose for collecting/ processing your data	Party affected	Category of Data
Administration, performance and termination of the employment contract	Performance of a contract	Employees	Communication, Professional, Financial/Account, Identification, Location, Contact
*Legally required purposes (i.e. managing time off and sick days, pension and retirement administration, tax reporting, establishing and exercising legal claims in connection with the employment relationship)t	Compliance with a legal obligation	Employees, Job applicants	Communication, Professional, Financial/Account, Identification, Location, Contact
Administration, performance and termination of the contractual relationship between Zarttech and the Client	Performance of a contract	Clients	Communication, Professional, Financial/Account, Identification, Contact
Create user accounts	Performance of a contract	Employees	Contact, Identification, Location, Financial/Account, Professional
Hire employees**	Performance of a contract	Client, Employees	Communication, Social Situation, Professional, Financial/Account, Identification, Location, Contact
Identify you and help you solve issues related to the usage of our services	Performance of a contract	Clients, Employees	Contact, Communication
Contact you to improve our services and customer experience	Legitimate interest (service improvement)	Clients, Employees, Partners	Contact, Communication

*We collect data about you based on specific (international) laws and regulations. We also make a copy of your ID when you enter employment (based on legal obligations) and we need your social security number and BVN for our Nigeria Employees due to fiscal obligations.
**In case of a job application, This Privacy Policy applies to all processing of personal data from (potential) candidates pertaining to Zarttech recruitment and selection procedure. The processing is performed by the recruitment department and processing takes place in the Recruitment/Compliance-system. If you enter employment, the Employee Privacy Statement becomes applicable.

Data that requires consent	How we can process this data	Category of Data
Recording of conference video calls	Consent	Communication
Direct Marketing	Consent	Contact, Communication, Location, Professional
Business reporting and analysis and development of the organisation*	Consent	Contact, Identification, Location, Financial/Account, Professional

*We may use your data in business reports, surveys and for making analyses. In doing so, we may combine data that we have from you. E.g. in order to improve recruitment & selection reports, regarding the numbers of vacancies, the numbers of applicants and the speed of filling vacancies. The results of analyses and accompanying advice are never traceable to you.

Special categories of personal data

Special categories of personal data are sensitive data (e.g. on health, criminal convictions or offences, racial or ethnic origin.) The purpose of this is to protect the interests of financial institutions, of you as an applicant or employee and of our clients, e.g. by detecting fraud.
In case of a specific request to store the special category data, we will only process them if the purpose is clear if there is a basis for processing and the processing is necessary for the purpose. Special categories of personal data like pictures of you or video material may also be processed.

Protection of the applicant’s vital interests

We may process data in order to protect your vital interests. E.g. regarding your medical data. Suppose you are in direct danger (unconscious) and unable to consent to the sharing of your medical data. These data are nonetheless vital to the immediate initiation of medical assistance.

Access to your data

Your personal data are only processed by employees who need access to them, given their function. The employees who are involved in your job application have a duty of confidentiality. We only reuse your data if the new purpose is related to that for which your personal data were initially collected.
We exchange these types of data with third parties. Sometimes we engage third parties who process personal data on our behalf. E.g. external recruitment agencies (like Jobberman, Independent Recruiters) or a research agency. We can only involve third parties if this fits the purpose for which we processed your personal data and the involvement is sufficiently reliable. In addition, the third party can only get our assignment if it demonstrates that suitable security measures are taken and confidentiality is guaranteed. If an assessment is part of your application, we will inform you in advance. Only after you have approved the report, will we save it in your application file.

This is how long we store your data

If you have made an online profile with us, you can use it again for another application at Zarttech. We can no longer view the data of your previous application at that time. Was your application rejected? Then we will delete your personal data no later than six weeks after the end of the application process. This concerns all application data such as your cover letter, CV, e-mail exchange and any screening and/or assessment data. If we do want to store your personal data for a longer period of time, for example, to match them with future vacancies, we will ask your consent. We will delete your data no later than one year after the end of the application procedure.
Are you joining us? Then the application file will be kept for one year after the end of the employment. Your data which were recorded within the framework of 'sourcing' will be deleted as soon as possible if they are no longer relevant for the purpose for which they were collected. If there has been no contact within six months, we will automatically delete all your personal data.

4. Subject Data rights

These are your rights with regard to the processing of your personal data. Specific rights apply to the processing of your personal data.

Rights	Description
Right to access and copy	You can ask us for access to your personal data which are stored by us. This can be information about you that is shown in your public profiles of social media, your uploaded CV and cover letter.
Right to rectification	If the personal data we store about you is incorrect, incomplete or in violation of the law, you can ask us to rectify it.
Right to be forgotten	You may request that your personal data that are stored by us be deleted if you object to these data being processed. E.g. if the processing is unlawful or no longer necessary for the purposes for which the data was collected.
Right to restriction of processing	In certain cases, you may ask to limit the personal data that is processed about you. This means that fewer data will be processed.
Right not to be subject to fully automated decision-making	Fully automated decisions are decisions that are made by computers, not by people (anymore). According to the law, Zarttech may use automated decision making including profiling. At this moment we do not use fully automated decision making in the application procedure.
Right to data portability	Data provided to us on the basis of a contract and/or with your consent may be transferred to another party. Transfer to another party can only happen if this is technically possible. Zarttech will transfer the data provided by you in a structured and readable form.
Right to object	You may object to the processing of your personal data. If you do so, we will make a new assessment to determine whether your data may indeed no longer be used for this purpose. Either way, we always inform you about the motivation for our decision. If you don’t accept the decision, you can lodge a complaint with the Compliance department of Zarttech.

Procedure regarding your rights

If you have made one of the requests described above, we will respond to your request within 60 days of receipt. Depending on the number and complexity of the request, the period may be extended by a further three months. We will of course keep you informed about the progress of your request. In case the data that needs to be provided also includes data from third parties, this third party may be asked in advance whether there are any objections to disclosure. We may ask for further specification of your request. We may also ask for identification, as we want to make sure we are providing information to the correct person. In some cases, we will not meet your request. For example, we do not delete the data if it is of significant importance to us or if there is a legal obligation to store it. We will inform you if this is the case.

For further questions or complaints

This is how you can contact us. For questions or complaints about the processing of personal data, please contact us on our website www.zartech.com on fill in the complaint form or send an email to [email protected]. The Compliance department can be reached via [email protected]. Before any contract is executed, a Data processing agreement is signed on behalf of Zarttech. This agreement binds us to:

Comply with all applicable Data Protection Laws in the Processing of Company/Placed candidate Personal Data; and

Not Process Company/PC Personal Data other than on the relevant Company’s documented instructions

The Company acts as a Data Controller.

The Parties seek to implement a data processing agreement that complies with the requirements of the current legal framework in relation to data processing and with the 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).

We reserve the right to modify this Policy relating to the Website or Services at any time, effective upon posting of an updated version of this Policy on the Website. You can find the date of our last update at the top of the document.