Privacy Policy

Last update: 04.11.20231.

General information, purpose, and acceptance of the privacy policy

This Privacy Policy (referred to as “Policy” hereinafter) contains the relevant information and explains how we process your personal data, how we use it and what your options are in this process when you visit and use our platform and its services.  

Your rights fall under the Regulation (EU) 2016/679 679 (General Data Protection Regulation, hereinafter GDPR)

We respect your privacy and are committed to protecting your data, and we recommend that you read this Policy before using the platform and its services.

According to the definition of art. 4.1 of GDPR, "personal data" means any information regarding an identified or identifiable natural person ("data subject"); an identifiable natural person is a person who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier, or to one or more many specific elements, specific to its physical, physiological, genetic, psychological, economic, cultural or social identity.

When you create an account on the platform, you are required to provide us with your name, surname, email address, date of birth, gender, profession, field of activity, CV, and personal interests. This gives us access to your personal data.

The Policy is not applicable to information collected by any third party, including through any external website that may link to or be accessible from the Platform. In this regard, you have to check directly with each such third party to avoid misunderstandings.

By using this platform you accept the terms of this Policy. If you do not agree with this Policy, you have to stop using our platform and its services. The Policy can be subject to change from time to time, according to the needs of the business and the current legislation. By continuing to use the platform after the revisions, it is deemed that you accepted the revisions, that is why we recommend checking this page from time to time.

2. Responsibility for processing personal data

SC Rookeyz SRL, referred to as Rookeyz is the data controller and is responsible for your personal data (collectively referred to as "Rookeyz", "we", "us" or "our" in this privacy policy).

In accordance with the authorization received from the personal data operators, respectively from the employers who have an account on the platform, in order to carry out their activity in terms of labor recruitment, your personal data is processed as " person authorized by the operator": by:

SC Rookeyz SRL,  with registered office in Romania, Str Drăgănești No. 1Bis, Bl P2, Sc B, Ap 17, et 4, Cam 2, Slatina, Olt county, registered at the Trade Register under no.: J28/665/2022, having CUI: 46352498, subscribed and fully paid-up capital 200 RON
Phone: +40 738 468 324

3. The data we collect about you

We may collect, store, process and transfer different kinds of personal data as follows:
A. Creating the User accountIn order to create a User account, you might be required to provide us with identity and contact data such as: name, surname, email, mobile phone number, date of birth, company details (for Employer Users) and so on.
B. Registered User account
a) Activity Data: as Candidate - details about how you use our platform, jobs and videos that you have seen, applied for and/or are interviewing for, feedback about your progress in relation to job applications, and messages that you send to and/or receive from Employers on our platform. As Employer - details about how you use our platform, jobs and videos that you have posted, have received applications for and/or are interviewing for, feedback about your progress in relation to Candidates, and messages that you send to and/or receive from Candidates on our platform
b) Profile Data: as Candidate - username and password, name and surname, photos, CV, education, work history including details of roles, projects and your salary (if you choose to provide them), your interests, preferences and feedback, languages that you speak, skills and your job search preferences, gender. As Employer - username and password, name and surname, photos, video interviews, jobs, including details about the job, your interests as an Employer, preferences and feedback, job listing preferences.
c) Technical Data: internet protocol (IP) address, operating system, browser type and version including plug-ins, time zone setting and location, and other relevant technology on the devices you use to access the platform.
d) Usage Data: information about how you use our platform products and services and information we have received from you as a result of email or chat requests, participation in our surveys and/or questionnaires.
e) Marketing and Communications Data: your preferences in receiving marketing communication from us and our third parties.
f) Aggregated Data: statistical or demographic data for any purpose that can be derived from your personal data but is not considered personal.

C. Cookies

We use cookies and similar technologies to recognize you and your devices. We also allow other people to use cookies. How we use these technologies is described in the Cookie Policy.

When Platform (including cookies or similar technologies from others' websites), we receive information about your IP address, IP-based location, proxy server, operating system, web browser and plug-ins, the device identifier. If you use our services from a mobile device, that device will send us data about your geographic location, based on the settings of the mobile device used. We will ask you to opt-in before using geolocation or other tools to identify your location.

D. Data obtained from third parties

We receive information about your visits and interaction with services provided by other entities when you visit services of other providers that include advertisements, cookies or similar technologies.

4. How we use your personal data and why we collect them

We will only collect and use your personal data according to the law in the following ways:
4.1. Use of the services by Candidate UsersIn order to use the platform and its services, you must have a User account. This will grant you access services like: uploading a CV, registering your job and career preferences, viewing job posts, applying for jobs, contacting Employers, receiving notifications, announcements, alerts, advertisements and so on.

The legal basis for this is: art. 6(1)(b) GDPR – conclusion and execution of the contract.

In the case that you apply for a job with an Employer from abroad, for the ones that are outside the EU jurisdiction, your data may be transferred to such a jurisdiction.

The legal basis for this is: art. 6(1)(b) GDPR – conclusion and execution of the contract

.The data that we receive from you will also be used to optimize the way we make job suggestions for you and to filter Candidate Users according to the Employer interests in order to provide efficient results.The legal basis for this is: art. 6(1)(f) GDPR – legitimate interest.

4.2. Use of the services by Employer Users

In order to use the platform and its services as an Employer user, you must have an account. This will grant you access to services like: uploading job announcements, uploading video interviews, registering your Candidate preferences, viewing and filtering Candidates, contacting Candidates, receiving notifications, announcements, alerts, advertisements and so on.

The data we process is for the purpose of managing the contractual or pre-contractual relationship with Employer Users.

The legal basis for this is:
- art. 6(1)(b) GDPR – concluding and executing the contract or performing pre-contractual formalities. (for authorized natural persons)
- art. 6(1)(f) GDPR – legitimate interest. (for personal data of the representatives of the Employer Users)

Rookeyz has a legitimate interest in carrying out our contractual relationships with our corporate customers in a proper way. The rights and interests of natural persons (i.e. the representatives of the Empoyer Users) are not prejudiced because, from the perspective of the client, a legal entity, the processing is necessary in the context of the work relations/collaboration that they have with the natural persons whose data is provided/associated with the Employer User account.

Also, based on legitimate interest, we use certain personal data associated with a Employer User account to prevent possible fraud / abusive use of the facilities offered by the Platform to Employer Users.

4.3. User relationship management and support

We process and use a series of personal data in order to manage the relations with Users of the Platform, when we are contacted with questions or requests regarding platform functionalities.
The legal basis for this is: art. 6(1)(f) GDPR – legitimate interest consisting in our interest in providing adequate services to all Users.

4.4. Communications regarding Services

The services that we provide include communications from Rookeyz to the Users. The Users are notified regarding relevant interactions with their account (ex. if the CV is viewed, or an application for the job has taken place)

We process this data based on our legitimate interest art. 6(1)(f) GDPR. The communications are related to the provisions of the Services that we provide and are requested, therefore we believe that our legitimate interest does not infringe the data of the Users.

4.5. Tailored content and marketing

In order to send you promotional materials, we will use data that you have provided and information about the usage of the platform. The promotional materials are used to inform you about services that we or our partners offer, invitations for surveys, communication of information that might be of interest to you and promotional material and marketing communications for ourselves and or our partners.

The legal basis for this is:
- art. 6(1)(a) GDPR – consent.
- art. 6(1)(f) GDPR – legitimate interest

4.6. Opting out

As a User, you can unsubscribe from these communications at any given time and you can ask us to stop sending you marketing or job notification messages by following the opt-out links on any marketing message sent to you or by directly asking to stop if those communications happen through WhatsApp messages.

4.7. Analysis of the operation of the Platform, cookies and similar technologies communications

The personal data that you as a User provide, will be used to analyze the way the platform and the services are performing. We do this in order to ensure the good functionality of the platform and in order to improve the way it works. We will also be using cookies and similar technologies that help us in the process.

The legal basis for this is:
- art. 6(1)(f) GDPR – legitimate interest
- art. 6(1)(f) GDPR – legitimate interest for necessary and functional cookies
- art. 6(1)(a) GDPR – consent for analytics, tracking and behavioral advertising cookies.

4.8. Legal obligations

Sometimes, in order to fulfill the legal obligations that are required of us, data processing is needed. (Legal basis: art. 6(1)(c) GDPR – execution of a legal obligation) that fall to us, such as:

For example keeping accounting records, reporting to tax authorities and paying taxes or data archiving according to legal requirements.

4.9. Defense of rights and interests in court

We can also process personal data for the establishment, exercise or defense of a right in court in a procedure before a court, an administrative procedure or other official procedures in which the Company is involved

The legal basis for this is: art. 6 (1)(f) GDPR – defense of the rights and interests of the operator.

4.10. Cookies

You have the ability to refuse all or some browser cookies. If you choose to do this, please take into consideration that parts of the website might become unusable, inaccessible or stop functioning properly.

4.11. Change of purpose

Your personal data will be used only for the purposes we collected it, unless we need to use it for another reason that we believe is aligned with the original purpose.

If and when we need to use your personal data for an unrelated purpose, we will notify you and will explain to you the legal basis for this choice.

It is possible that we may process your personal data without your knowledge or consent, according to the established rules, where it is required or permitted by law.

4.12. Disclosure of personal data

When processing your personal data, we may disclose and share your personal data with the following parties:
• Persons and/or entities (from EEA or third countries) that are service providers of IT, software and/or system administration services (data centers, payment facilities, e-mailing/messaging platforms, etc)
• Third party Employers including, if applicable, those located outside the EEA, that use our platform and services to recruit Candidates;
• When we are required to disclose personal data in order to comply with any legal obligation or decision of a judicial authority, public authority or government body;
• When required and permitted under applicable law, we will disclose your personal data with third party providers of cookies and similar technology;
• Third parties to whom we may choose to sell, transfer or merge parts of our business or our assets;

4.13. How long we will use your personal data

We will retain your personal data for as long as reasonably necessary to fulfill the purposes for which we collected it, including for the purposes of satisfying any tax, regulatory, legal, regulatory, accounting, reporting requirements or archiving rules.

We may retain your personal data for a longer period in the event of a complaint or if we reasonably believe there is a prospect of litigation with respect to our relationship with you.

The Candidate User Data will be retained as long as the User account is active on the Platform. The data will be erased if the User requests the deactivation or deletion of the account, or after a period of 10 years after the account becomes inactive.

For Employer User accounts, the data will be kept for the entirety of the contractual period and the period required by law for archiving and keeping financial-accounting records.

In the case of data relating to cookies and similar technologies, they will be kept according to the term set by the respective technologies which can be from the duration of the browsing session to a duration of up to 2 years (for analysis cookies).

In certain circumstances, we will anonymize your personal data (to remove association with you) for research or statistical purposes. In this case, we may use this information indefinitely without further notice to you.

4.14. Data security

Rookeyz has put in place security measures that are appropriate to prevent your personal data from being accessed in an unauthorized way, altered, disclosed, used or accidentally lost.

The access is limited to the employees, agents, contractors, and other third parties that have a business need to know and they will process your personal data based on our instructions.

Rookeyz has internal procedures to deal with suspected personal data breaches and will notify you and any applicable regulator of a breach where we are legally required to do so.

4.15. Your legal rights as a data subject

In accordance with the law, you have the following rights in relation to your personal data
:a) The right to accessYou have the right to access the personal data that we have stored. You can also obtain information about if and how we process your personal data.
b) The right to correct dataYou can request that we change, correct or complete your incorrect or incomplete personal data.
c) The right to erasure of your personal dataYou can request that we delete the personal data that we have in the following conditions:
- it is no longer necessary for the purposes for which we collected and processed it;
- you have withdrawn your consent for data processing, and we can no longer process them on other legal grounds;
- the data are processed against the law;
- the data must be deleted according to the relevant legislation.
d) The right to withdrawal of consent and right of opposition
You can withdraw your consent to data processing based on consent at any time. You can also object at any time to processing for marketing purposes, including profiling for this purpose, as well as processing based on the legitimate interest of the Company, for reasons related to your specific situation.
e) The right to restriction of processing your personal dataYou can, under certain conditions, request the restriction of processing of your personal data
f) The right to personal data portabilityTo the extent that we process data by automated means, you may, under the law, request that we provide your data in a structured, frequently used and machine-readable form. If you ask us to do so, we may transfer your data to another entity if technically possible.
g) The right to file complaints to the competent authorityIf you believe that your rights have been violated, you have the right to file a complaint with the following data processing supervisory authority.
The National Authority for the Supervision of Personal Data in Romania
G-ral Blvd. Gheorghe Magheru 28-30 Sector 1, postal code 010336 Bucharest, Romania

If you wish to exercise any of the rights set out above, please contact us using the contact details set out in Section 2 (Contact details DPO).

4.16. Time limit to respond

Rookeyz will try to answer all legitimate requests within one month. In the case that there is a particularly complex request, or we are overwhelmed with a large number of requests, it may take us longer and we will notify you and keep you updated.