IMPORTANT INFORMATION FOR JOB APPLICANT ON HOW WE COLLECT, USE AND STORE INFORMATION ABOUT YOU

Date last updated: 2019-10-10

At Vinted group we care about protection of information relating to you. We follow the requirements of the so-called European Union General Data Protection Regulation (GDPR) and other laws protecting information about you at our Company. For more information, please carefully read this Privacy Policy. In case of no further specification, “we” or “the Company” hereinafter refer to the specific Vinted entity were you have applied for a job (please see Section 2 below for more information).

1. How should I read this Privacy Policy?

This Privacy Policy will answer the most important questions about how we collect, use and store information relating to you. This is important to you – please read this Privacy Policy carefully.

2. Who is responsible for protecting my information and what are the contact details of the Data Protection Officer?

When you apply for a position with Lithuanian company, Vinted UAB is the data controller and as such responsible for protecting your information. If you apply for a position with the German, Czech or Polish company, Vinted UAB is responsible (the controller) for organising the recruitment process and the German, Czech or Polish companies (depending on which country you applied at) are responsible for supporting the relevant recruitment process. Please find the contact details of the companies and their Data Protection Officers below.

Vinted, UAB (Lithuanian company)
Our identification number is: 302767152
Our address is: Žirmūnų str. 70-701, LT-09124 Vilnius
Our Data Protection Officer’s e-mail address: dpo@vinted.lt

Kleiderkreisel GmbH (German company – additionally in case you have applied for a job at this entity)
Our identification number is: HRB 184585 B
Our address is: Wallstraße 65, 10179 Berlin
Our Data Protection Officer’s e-mail address: dpo@kleiderkreisel.de

Vinted s.r.o. (Czech company - additionally in case you have applied for a job at this entity)
Our identification number is: 29130182
Our address is: Zenklova 32/28, Libeň (Praha 8), 180 00 Praha
Our Data Protection Officer’s e-mail address: dpo@vinted.cz

Friendly Fashion Sp. z.o.o. (Polish company - additionally in case you have applied for a job at this entity)
Our identification number is: 0000448543
Our address is: przy ul. Grzybowska 2 lok. 29 00-131 Warszawa
Our Data Protection Officer’s e-mail address: dpo@vinted.pl

3. Why do you collect information about me?

When you apply for a job at Vinted, we collect, use and store only that information which is necessary to assess your application and your suitability to enter into employment contract and suggest a job offer for you. Additionally, you may also provide us information on you which is not necessary but which you provide us on a voluntary basis.

4. Which information about me do you collect?

We collect, use and store that information which is necessary for the purpose set forth in Section 3 (what is necessary depends on job ad and our requests; for example, for some positions certificates are necessary) and that information which you voluntarily provide us:

• Name and surname
• E-mail address
• Telephone number
• Address
• Personal no. (when we enter into a non-disclosure agreement)
• Education
• Languages proficiency
• Certifications
• Recommendations
• Additional training
• CV
• Attachments to your CV
• Cover letter
• Employment history
• Current company
• Non-disclosure agreement
• Tryouts agreements
• LinkedIn URL
• GitHub URL
• Personal website URL
• The tasks performed by you
• Interview notes about you
• Recruitment agency's assessment of you
• Desired salary
• Other information submitted by you

5. Why are you legally allowed to collect my information?

We collect information lawfully about you because:

• We have the intention to enter into a contract with you (Art. 6 (1) (b) of GDPR) – when you apply for a particular job position and we assess your suitability for the role;
• You have given a consent to the processing of your personal data (Art. 6 (1) (a) of GDPR) – when you permit Vinted to contact you about the future job opportunities within the three years after your first application;
• We have legitimate interest to contact you and offer a job opportunity (Art. 6 (1) (f) of GDPR) – when you publish your contact details on LinkedIn platform;
• You have given a consent to the processing of your personal data (Art. 6 (1) (a) of GDPR) – when you provide us information that goes beyond what is strictly necessary and which you provide on a voluntary basis;
• We never ask special categories of data (e.g. health data) as a mandatory during recruitment process. If you nevertheless and against our will provide us with such data, the legal basis for processing is your consent (Art. 9 (2) (a) of GDPR).

6. Which information do I have to provide you with and why?

Please refer to Section 3 above - you have to provide us with the information which is necessary (what is necessary depends on job ad and our requests; for example, for some positions certificates are necessary) to assess your application and your suitability to enter into employment contract and suggest a job offer for you. You are not legally obliged to provide us with your personal information under statutory requirement. However, in case you do not provide us with this information, we will not be able to assess your application and your suitability to enter into employment contract and suggest a job offer for you. You do not have to provide us information that is not necessary (but voluntarily provided by you) for the aforementioned purposes.

7. Where do you get my information from?

Generally, we collect the information directly from you. However, some of the information we obtain from following parties:

• Recruitment agencies;
• Lever Inc. (USA);
• LinkedIn Ireland Unlimited Company, LinkedIn Corporation and other social media sources;
• Vinted employees (referrals);
• MeetFrank OÜ;
• Glassdoor Inc. (USA);
• VšĮ „Investuok Lietuvoje“;
• Other recruitment agents and collaboration platforms.

8. Do you share the information about me?

We share the information about you with the following entities only where necessary and permitted by applicable laws and for the reason listed under section 3 above:
• Vinted, UAB (for the purposes of management of Vinted international group of companies);
• Vinted, Limited (United Kingdom) (for the purposes of management of Vinted international group of companies);
• Lever Inc. (USA) (service provider providing recruiting software);
• Recruitment agencies (service providers providing recruitment services);
• UAB "Easyway.LT" (service provider providing financial services);
• LinkedIn Ireland Unlimited Company, LinkedIn Corporation (USA) (service provider providing social media account to the Company);
• Google Ireland Ltd., Google LLC (USA) (service provider providing e-mail service to the Company);
• Slack Technologies, Inc. (USA) (service provider providing work communications tool to the Company);
• UAB “Dataprotection.lt” (to fulfill DPO duties under GDPR);
• Datenschutz nord GmbH (to fulfill DPO duties under GDPR).

9. Do you disclose information about me outside the European Economic Area?

In most cases, personal data are processed and transferred in the territory of the European Union and the European Economic Area, but when we work together with some of our business partners, the data may be transferred and processed beyond those territories when the adequate level of protection of your personal data is maintained. When this is permitted by law and is required for the reason given in the Section 3 above, we disclose information about you to:

• Lever Inc. (USA) (data is protected in according to Model Contractual Clauses);
• LinkedIn Corporation (USA) (data are protected in accordance with Privacy Shield program);
• Google LLC (USA) (data is protected in accordance with Privacy Shield program);
• Slack Technologies, Inc. (USA) (data is protected in accordance with Privacy shield program).

You may download a copy of the EU-U.S. Privacy Shield Framework at: https://www.privacyshield.gov/EU-US-Framework.

You may download a copy of the Model Contractual Clauses at: https://ec.europa.eu/info/law/law-topic/data-protection/data-transfers-outside-eu/model-contracts-transfer-personal-data-third-countries_en.

10. How long do you use or keep information about me?

When you apply for a particular job position we, in general, will store your personal data until the end of the relevant recruitment process. If you become an employee, we will safe your application information within the employee file. If you do not start working with us, the data is kept in accordance with the applicable limitation periods for claims of rejected applicants under the applicable member states law.

When you permit Vinted to contact you about the future job opportunities we will store your personal data for 3 (three) years.

11. What can I do about my information at your company, which data protection rights do I have?

GDPR and other laws provide you with certain rights, procedures for implementation of and exceptions to these rights. When allowed by law, you can:

11.1. Submit a request for confirmation that the Company is processing the data related to you. If the Company process the data related to you, you can request access to the data processed and related information (Art. 15 GDPR);
11.2. Submit a request to correct inaccurate or incorrect information used or to supplement it when it is not complete (Art. 16 GDPR);
11.3. Submit a request to delete the information we have about you if we use it illegally (Art. 17 GDPR);
11.4. Submit a request to restrict the processing of your information – if you dispute the accuracy of the data or object to the processing of the data, if you do not accept that your data would be deleted which was illegally processed, or if you need the data to claim, execute or defend legal claims (Art. 18 GDPR);
11.5. Object to collection, use and storage of your information at our Company – when we process data based on the Company's and / or third party interests (Art. 21 GDPR);
11.6. Submit a request to transfer (receive) the data that you provided to us under the contract or giving the consent and which we process by automated means, generally using electronic form (Art. 20 GDPR);
11.7. To withdraw any consents given to us regarding information used about you - when we use the data based on your consent (Art. 7 (3) GDPR);
11.8. To lodge a complaint with a supervisory authority, in particular in the Member State of your habitual residence or place of an alleged infringement of the GDPR and seek a judicial remedy (Art. 77 GDPR).

12. Whom may I contact in order to get help regarding protection of my data?

If you have any questions, comments or complaints regarding how we collect, use and store information about you, or if you want to assert any of your rights under the GDPR, our Company has a Data Protection Officer to help you. If you need his / her help, please send an e-mail via contacts referred to in Section 2.

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