Privacy Policy

You can use our services in many ways, for example you may use our mobile application, web application, browse our website or request support. When you use our service or otherwise provide us with information about you for example when creating your profile, we use the information about you to duly provide our services, to make our services better and to provide you with relevant answers to your questions.

Our services are not intended for children under 16 years of age. We do not process personal information of children under 16 years of age. If you were not 16 years old, please do not use our website or mobile app without the permission and supervision of your legal representative.

When you use our services, it is important for us that you fully understand how and why we process your information and that you are acknowledged with your rights.

In this Alfred Jobs Privacy Policy (“Policy”) we explain:

• What information we collect and how;
• How we use the information gathered and on what legal basis;
• How long we process the collected information;
• Who has access to the collected information;
• What are your rights in relation to the collected information and how to apply them.

We have tried to describe everything as clear and simple as possible, but if you do not understand some of the used terms, such as personal information, IP address, or cookies, we suggest that you first familiarize yourself with the glossary of key terms in Annex A to this Policy. However, if anything remains unclear, you can contact us at any time at through the contact section on our website.

The information we collect about you differs on the basis of whether you are an individual who is trying to find employment through the Alfred System (“User”) or a representative of a company which tries to find employees through the Alfred System (“Employer”).

If you are a User, we collect the following information:

• Information you provide us. This is your personal information that you provide us when you contact us, log in to the Alfred System or ask for support. You usually provide this information by filling in and submitting a form on our website, by logging into Alfred System either through your Social Media Account or through SMS, by adding this information to your Alfred System account profile, by filling in a satisfaction survey, agreement or through your support requests. By this means you may provide us with your name, surname, profile image in the Alfred System, e-mail address, phone number, date of birth, your biographic information, education history, work history, attachments (such as CV or certificates), language knowledge, links to your public profiles (e.g. to your website, Facebook or LinkedIn account etc.) and other skills you are gifted with. If you have asked us for support, we collect information about your individual requirements. To improve service and customer support, we also use your voice call records in case you decided to leave a voice message for us.
• Information we receive when you use our services. We collect information on how you use our services, from visiting our website to using Alfred System. The information is following:
• Information about your activity on our website. We use cookies to analyze traffic on our website. When you visit our website, we record your activity on our website, such as the number of pages you visit, length of visit, visited pages, repeated visits, etc. We never associate this information with any of your personal information, such as information that you fill in forms on our website or your IP address. For more information about using cookies, see Annex B to this Policy.
• Information about your activity in the Alfred System. When using the Alfred System, either through our website or through our app, we obtain information on your job application overview, status of your application and your job preferences. For the purpose of analyzing and solving problems related to communication between you and Employers or other support services provided either to you or the Employer, we may have access to your messages with Employers if you or an Employer authorizes so.
• Information about your device. In case of crash reporting and support, we obtain information about the version of the application you use, about your device, including operating system and hardware, stack trace of crash and other information necessary to improve our products and services, and bug fixes. This information, gathered when using Alfred app, is not associated to an individual person in any manner. In case you are connecting to the Alfred System through the web application, we collect information about your operating system, browser, session duration, user-agent header, URL and breadcrumbs. We can also collect and associate the information to your IP address; however, we only use your IP address in case of solving an Alfred System crash to identify that you are the same User that has been affected by the crash and to evaluate how many Users were affected by the same crash. We are not using IP addresses to associate any information about a device to a specific individual.

If you are an Employer, we are the data processor regarding most of your personal information. In that case the information we process about you depends on the Data Processing Terms that your company has agreed to. However, there is still some information that we process as the controller:

• Information we receive when you use our services. We collect information on how you use our services, from visiting our website to using the Alfred System. The information is following:
  Information about your activity on our website. We use cookies to analyze traffic on our website. When you visit our website, we record your activity on our website, such as the number of pages you visit, length of visit, visited pages, repeated visits, etc. We never associate this information with any of your personal information, such as information that you fill in forms on our website or your IP address. For more information about using cookies, see Annex B to this Policy.
• Information about your device. In case of crash reporting and support, we obtain information about your operating system, browser, session duration, user-agent header, URL and breadcrumbs. We can also collect and associate the information to your IP address; however, we only use your IP address in case of solving an Alfred System crash to identify that you are the same User that has been affected by the crash and to evaluate how many Users were affected by the same crash. We are not using IP addresses to associate any information about a device to a specific individual.

We use the information we collect to provide you with our services, in particular to enable you to join the Alfred System, to enable you to work with the Alfred System properly, to give you the opportunity to provide the most relevant information about you to get your desired job or, conversely, to give your company the opportunity to find the most suitable employee. We further use your personal information to maintain, protect and further improve the Alfred System.

The information we collect, including your personal information, is also used to protect ourselves and other Users of our services.

Your e-mail address can be used for sending you newsletters about our services, such as an announcement of planned changes or improvements.

We use the information gathered from cookies to improve the User experience and the overall quality of our services. To do this, we use several third-party services such as Google Analytics and other services listed in Annex B to this Policy.

The legal basis for processing your personal information varies depending on whether you are a User or an Employer:

• If you are an Employer, we process your personal information to fulfill the contract with you, fulfill our legal obligations and protect our legitimate interest.
• If you are a User, we also process your personal information to perform the contract with you, fulfill our legal obligations and protect our legitimate interest, but given that we also pass on your personal information to other controllers - your potential Employers, we need your consent to such activities. Since the provision of information about you to potential Employers is the basic purpose of the Alfred System, we will not be able to provide you with our services unless you give us your consent to pass the information to the Employers..

Every time you apply for an Employer’s job offer, if you are a User, we will ask for your consent to share your personal data in the application and that you have provided in your Alfred profile to this Employer. If you withdraw your application from a specific Employer, this is considered as withdrawal of your consent to share your application with this Employer and Alfred Jobs will retract the information immediately from this Employer.

Be assured that if we at any time would like to use information about you for purposes not contained in this Policy, we will always inform you beforehand and give you the opportunity to stop using our services.

Our legitimate interests in processing your personal information are:

• contacting you in the context of mutual business relations, including direct marketing;
• improving our services;
• repairing errors that occur when using our services;
• ensuring backup and recovery of system and data in the event of service failure;
• protecting the legal claims of Alfred Jobs and our other customers;
• assessing the quality of our services based on your completed satisfaction questionnaire;
• evaluating the success of the marketing actions you have participated in and
• effective customer service support and implementation work.

Your personal information is always stored and processed only for the time necessary to meet the purpose for which it was collected. For example, if you decide to delete your Alfred System account, we will store your personal information for an additional 30 days grace period, in case that you decide to restore your account, and after this period your personal information will be erased.

When we share your personal information with Employers, we grant them access to if for a maximum period of 1 year since your application for a job. After 1 year since your application or when you withdraw the application, the Employer is no longer able to see your personal information in the Alfred System.

It should be noted that we cannot delete your information which an Employer that you contacted may have stored in relation to your job application. Therefore, you must contact the relevant Employer to request such deletion.

Please note that in some cases, we might store some of your personal information for a longer period, especially when prescribed by law (such as tax law) or when we need it to protect our legitimate interests (such as when we have a mutual dispute pending at court and we need the information to prove that you were our customer). In these cases, we store only the personal information necessary for such purpose and delete it as soon as possible.

Alfred Jobs takes care of personal information protection and never sells your personal information to third parties. When you apply for a job at an Employer, we pass your personal information to the Employer. The purpose of allowing the Employer to access your information is necessary in order for the Employer to communicate with you, the User, as its potential future employee.

If you authorize in your Alfred’s Profile so called “head-hunting” with the relevant settings, you agree that Alfred Jobs’ employees may view your information for the purpose of assessing whether you are qualified for a certain job and possibly contact you regarding the job.

Moreover, we may pass your personal information to third parties for the above-mentioned purposes to the extent necessary (see below).

As explained above, your personal information will be shared with registered Users and Employers in the Alfred System. If you are a User, only Employers to whom you have applied for a job may see your personal information. If you are an Employer, your personal information may only be seen by other Employers and Users if you place it into your job offer.

Please note that Alfred Jobs is a part of the Alfred Group and therefore each company within the group has access to your personal information:

• Kind Sheep ehf.;
• Alfred ehf.;
• Stokkur Software ehf.;
• Alfred Jobs s.r.o.;
• Stokkur Software s.r.o.

We may further forward your personal information to cloud service providers who ensure data transfer between us and you, our service technicians and service partners who provide support and maintenance services, our developers, our legal advisors in case of contract preparation or dispute resolution and external accounting and tax advisers.

We share information about your use of our Alfred System with third parties who provide communication and marketing services to us.

We process your personal information on the territory of the European Union and the European Economic Area and pass it on to our US partners in accordance with applicable law. If we pass your personal information to the United States of America, we only use those services that are certified under the Privacy Shield to guarantee an adequate level of protection even after they are transferred. If you are interested in finding out where your specific information is located, you can contact us at alfred@alfred.com.mt at any time and we will happily solve your request.

If we pass on your personal information to third parties, we always do so on the basis of an adequate agreement with these persons to be able to monitor how your personal information is handled by third parties.

Ensuring the security of your personal information is our important duty and commitment. That is why we are trying to make the best possible security precautions to prevent abuse or other unauthorized interference with your personal information. To secure your personal information, we have taken the following measures:

• Risk-based principle. We will periodically review the risks of information security in connection with personal information to ensure that we have adopted sufficient level of personal information security.
• Organizational security. We place an emphasis on securing your personal information against the risks of human failure, in particular:

1. we have adopted and maintain guidelines and internal security documents;
2. we regularly provide training for employees and other staff on the rules of working with personal information and information security risks;
3. we contractually adjust the liability of employees, external collaborators, suppliers and other third parties with access to your personal information;
4. we have adopted and maintain standardized processes for working with your personal information.

• Technical measures. We have implemented important technical measures to ensure the security of your personal information, in particular:

1. server antivirus solution for protection against malware;
2. network security solutions, combining firewalls, network configuration and other technologies;
3. encryption of data transmission in the Alfred System using HTTPS;
4. all personal information is stored securely in the SQL database on servers within the EU/EEA;
5. backup of critical infrastructure and data.

• Physical security. For the protection of personal information in written form and physical protection of IT equipment:

1. we control access to databases with your personal information;
2. we have secured server premises and storage of personal information.

You have the following rights in relation to our processing of your personal information:

• the right of access to personal information;
• the right to rectification;
• the right of erasure (the “right to be forgotten”);
• the right to restriction of processing;
• the right to data portability;
• the right to object against the processing; and
• the right to file a complaint about the processing of personal information.

Your rights are explained below to help you get a clearer idea of what they mean. You can exercise all your rights by writing to us at alfred@alfred.com.mt. You can file a complaint with the Supervisory Authority, which is The Information and Data Protection Commissioner (www.idpc.org.mt).

The right of access means that you may ask us at any time to confirm whether personal information concerning you is processed or not, and if it is, then you have the right to access all the information and information for what purposes, to what extent and to whom it is made available, how long we will process it, whether you have the right to rectification, erasure, restriction of processing, or objection against the processing of personal information, where we obtained the personal information, and whether your personal information is processed for automated decision making, including profiling.

The right to rectification means that you may ask us at any time to correct or supplement your personal information if it is inaccurate or incomplete.

The right to erasure means that we have to erase your personal information if (i) it is no longer necessary for the purposes for which it was collected or otherwise processed, (ii) the processing is unlawful, (iii) you object to the processing, and there are no overriding legitimate reasons for processing, (iv) it is imposed on us by a legal obligation or (v) you have withdrawn a consent with us processing your personal information (provided that the specific personal information has been processed based solely on your consent).

The right to restriction of the processing means that until we resolve any disputed questions about the processing of your personal information, we must restrict the processing of your personal information.

The right to data portability means that you have the right to obtain personal data that concern you and which you have provided to us and which are processed by automatic means and on the basis of consent or contract, in a structured, commonly used and machine-readable format, and the right to have these personal data transferred directly to another controller.

The right to objection means that you may object to the processing of your personal information that we process for the purposes of our legitimate interests, especially for direct marketing purposes. If you oppose processing for direct marketing purposes, your personal information will no longer be processed for this purpose.

This Privacy Policy is effective as of 1. 1. 2021.

Alfred System

Is a software developed by Alfred ehf. for recruitment which may be accessed either through our website or through the Alfred app.

Cookie

A cookie is a small text file that web pages store in your device through your browser. Most websites in the world use cookies. More information about cookies is in Annex B to this Policy.

Firewall

A firewall is part of a computer network that increases security of network traffic, protecting the device from unwanted attacks by others.

IP address

An IP address is the device ID in the network using the Internet protocol.

Malware

Malware is a malicious computer program that has the purpose of intruding into a computer network and damaging it or stealing data.

Personal information

Personal information means all information about your person that we process, and which may lead to your direct or indirect identification.

Privacy Shield

Privacy Shield is a tool to ensure the adequate protection of personal information that is transferred to the United States of America. This tool has been created by the European Commission in cooperation with the governmental authorities of the United States of America.

Device

A device is a personal computer, a server, or a mobile device, including tablet.

Cookies are small text files that websites store on your computer or mobile devices when you start using them. For example, pages will remember your preferences and actions you’ve done (such as logins, language, font size, and other display preferences) so that you do not always have to re-enter them and can browse more easily and comfortably.

Our website, as well as almost every other big website in the world, uses cookies to provide you with the best user experience. Specifically, our cookies help:

• our website to work the way you would expect;
• speed up and better secure our website;
• allow you to share social media posts;
• continually improve our website;
• making our marketing more efficient.

We do not use cookies to:

• collect special categories of personal data;
• transfer personal information to third parties; nor
• get commissions from sales.

Below you can learn more about all the cookies we use.

Cookies used to make the website work properly

We use some cookies to make our website work properly, for example:

• determining if you are logged in or not;
• remembering your search settings;
• remembering if you have accepted our terms and conditions;
• allowing you to add comments to our website;
• remembering if we have already asked you certain questions (e.g. you declined to use our app or take our survey).

Unfortunately, there is no way to prevent using these cookies other than to stop using our website or completely disabling cookies in your web browser.

Third party functionalities

Our website, like most other websites, also includes third-party functionalities. A common example is incorporating a third-party video service onto our website. Deleting these cookies is likely to disable the functionality provided by these third parties. If you do not wish to use these third-party services or do not want us to store third-party cookies on your device, you can opt-out by changing the settings in your web browser.

Our websites include these third-party cookies:

Social site cookies

Allows you to share the content of our websites on social networks or to log in to Alfred System via Facebook, Google or Twitter or to contact someone directly from our website by writing via Messenger.

We use:

• Facebook More information
• Google More information
• Twitter More information

The privacy implications in this area will differ from social network to social network and will depend on the privacy settings you have selected on these networks.

Visitor statistics cookies

We use cookies to compile visitor statistics such as how many people have visited our website, what type of technology they are using (e.g. Mac or Windows, which helps to identify when our website isn't working as it should for particular technologies), how long they spend on the website, what page they look at etc. This helps us to continuously improve our website. These so called “analytics” programs also tell us how people reached our website and whether they have been here before.

We use:

• Google Analytics More information

You can usually turn off cookies by modifying browser settings to prevent them from receiving cookies. If you do, you are likely to limit the functionality of our and a large number of other websites, because cookies are a standard part of most modern websites. Maybe your worries about cookies are related to so-called “spyware.” Please know that rather than turning off cookies in your browser, you can achieve the same goal by installing anti-spyware software that automatically removes cookies that are considered invasive.

Below you will find a link to the cookie settings in each browser:

• Google Chrome
• Mozilla Firefox
• Safari
• Microsoft Edge