Please read this Policy carefully before browsing this Website. We will process your data onlyasdescribed in this Policy. Our Websites are not directed to children under the age of 16, and wedonot knowingly collect personal data from children of this age group.
Should you have any questions or comments as for this Policy, please contact us at firstname.lastname@example.org
2. WHAT DOES BLOCK360 HAVE TO DO WITH YOUR DATA?
In light of the EU General Data Protection Regulation (“GDPR”), Block360 is a controller and aprocessor of the personal data submitted through this Website and collected in other ways. Beingacontroller means that we are responsible for deciding how we hold and use personal informationaboutyou.
Block360 uses a third-party “Workable” for recruitment processing services. By submitting anonline application for any vacancy placed on our Website you expressly submit your personaldata,contact information, CV and any other information you choose, and agree that it will becollectedand processed by both Block360 and Workable. In such case Block360 stays the datacontroller and Workable becomes the processor ofyourdata.
3. WHAT DATA ABOUT YOU DO WE COLLECT?
We only collect information about you that is necessary for us to allow you to use the Websiteorcontact us, and only to the extent specifically provided in this Policy.
3.1 Information we obtainfromyou
When you contact us via email or via the contact form, you provide us your name, phone number,e-mail address, communication content and data associated with the communication.
Examples of personal data that you provide to us when applying for a vacancy are full name,e-mail,phone number, location, any other information you choose to provide in your CV or together withit.You might also choose to provide us with any other personal data, for example the personal dataof acandidate for work whom you want to refer. From time to time, Block360 also receives personalinformation about individuals from third parties around the world. This may happen if youpublishyour CV on the Internet on some job boards, giving them the consent to use and transmit yourdata,if someone recommended you for potential employment and in other similar cases. We encourage youtoreview the privacy policies of any third-party websites before providing your information tothem.
3.2 Information we obtainfromyour use of our Websites
When you visit our Websites we may collect the following information about you:
information about your device(s), in particular, hardware model, version of theoperatingsystem;
information about your visits to and use of this Website, including your IP address,geographical location, browser type and version, referral source, page views and Websitenavigation paths;
cookies. For more information on the cookies being used on the Website and how you canoptout, please visit the section 7 of this Policy.
4. WHY DO WE PROCESS YOUR PERSONAL DATA?
We will only process your personal data where we have a legal basis to do so. The legal basiswilldepend on the reasons we have collected and need to use your personal data for. We may processyourpersonal data because:
you have consented to us using your personal data
we need to comply with a legal obligation
it is in our legitimate business interests
More specifically, personal data submitted to us through this website and personal data wecollectedfrom you or third parties or from public sources will be used for the purposes based on thelegalgrounds as follows:
if you have contacted us via this website or otherwise, we may process your personal data to beableto answer your questions, to organize the meeting, call, zoom or other communication. Pleasenotethat this communication may be recorded and stored by Block360 representative in Block360corporate system.
4.2 Marketing and publicrelations, based on your consent, art. 6 para. 1 a GDPR:
if you are a visitor of our website, we may, by way of cookies, process your data tocarryout marketing research and to analyze the characteristics of this website visitors, toassess the impact of our marketing communication and to adjust it to the detectedtendencies, to plan our future marketing activities, to prepare analytics and profilingforbusiness intelligence, to target our advertising.
if you are our subscriber, you receive or would like to receive our marketing materials,wemay process the personal data you provided to us to spread promotional materials, tomakeannouncements about additions and changes concerning our services, to send you e-mailnotifications, to send you our email newsletters.
a) based on your consent, art. 6 para. 1 a GDPR: if you are a potential employee, we may process your personal data to assist you with ongoing orfuture employment or cooperation with Block360, to enable you to submit your resume, apply forjobs online or express your interest in relocation.
b) based on Block360 legitimate interest, art. 6para. 1 f GDPR:
in specific cases, and only upon the client’s request, we may show your CV to apotentialclient for business engagement or to current client to confirm the high level of skillsofour members of staff providing the services. Also, to fulfill its complianceobligations,our client may need to check your biography more closely before providing you with theaccess to its protected data and facilities. Therefore, we may ask you to provide morespecific information, such as tax number, work permission, citizenship, criminalbackgroundand other additional and specific background checks required by particular clients toprovide you with an access to clients’ systems and premises.
4.4 Business relations,basedon Block360 legitimate interest, art. 6 para. 1 f GDPR:
if you are a representative of our current or potential client, vendor or business partner, wemayprocess your personal data to organize the approval, processing and signing of contracts, acts,invoices and other contractual documentation; to promote our new products, works and services;toconfirm the high level of our works and services; to invite you to the meetings and events ororganize them; to comply with economic sanctions and export control list screening, industrystandards, regulators’ requirements and other requirements related to anti-corruption, fraudprevention and anti-money laundering.
4.5 Corporate and investorrelations, based on Block360 compliance obligations, art. 6 para. 1 c GDPR:
if you are a current or potential director or top manager of Block360, we may processyour personal data to organize your participation in corporate meetings, events,businesstrips, to pay your remuneration, to cover related expenses, to maintain our corporaterecords, to make obligatory public disclosures and reports, to execute auditor’srequests,to present the company and its management during the sale process and to perform otherlegalobligations. We also may share this information within Block360, provide some of thisdata to banks, notary, payroll agencies and legal advisors with the purpose of openingof acorporate bank account or other accounts;
if you are a current or potential affiliate of Block360, we may process your personaldata to organize your participation in corporate meetings and events, to provide youwiththe meetings’ materials and our reports, to support you in execution of your rights, tomakeobligatory public disclosures and reports, to execute auditor’s requests and to performother legal obligations, including anti-money laundering requirements and disclosure ofbeneficiaries.
4.6 Security, based onBlock360 legitimate interest, art. 6 para. 1 f GDPR:
if you are a visitor of this website, we may process your personal data to keep thiswebsitesecure, prevent fraud, protect rights and interests of Block360 and third parties,protect Intellectual Property rights;
if you are a visitor of our office, we may process your personal data to monitorphysicalaccess and to ensure security in our office, as well as to prevent, detect andinvestigateany crime, misconduct, incident or accident.
5. HOW CAN WE USE YOUR PERSONAL DATA?
We may process your data by way of collecting, recording, organizing, storing, using,structuring,adapting or altering, retrieving, consulting, aligning or combining, erasing or destructing.
Also, as Block360 is an international group of companies, we may disclose your data bytransmission, dissemination or otherwise making available. To the extent permitted by applicabledata protection laws, your personal data may be transferred between various locations ofBlock360 and thus processed in European Economic Area and outside of it, depending on thepurpose of processing. Such transfer and processing are possible only as reasonably necessaryforthe purposes set out in this Policy and within the scope of legitimate interest of Block360.
We may disclose your personal data to some of our clients for business engagement or to confirmthehigh level of skills of our team members to auditors, agencies, supervisory authorities or tootherexternal service providers on “need to know basis” to perform our contractual obligations.
We may also disclose your personal data:
to the extent that we are required to do so by law;
in connection with any ongoing or prospective legal proceedings;
in order to establish, exercise or defend our legal rights, including providinginformationto others for the purposes of fraud prevention and reducing credit risk.
6. HOW CAN YOU CONTROL YOUR DATA?
You, as a Data Subject, have the right to:
Requestinformation about whether we hold personal information about you, and, if so,what that information is and why we are holding or using it.
Requestaccessto your personal information. This enables you to receive a copy of the personalinformationwe hold about you and to check that we are lawfully processing it.
Requestcorrection of the personal information that we hold about you. This enablesyouto have any incomplete or inaccurate information we hold about you corrected.
Requesterasureof your personal information. This enables you to ask us to delete or remove personalinformation where there is no good reason for us continuing to process it. You also havetheright to ask us to delete or remove your personal information where you have exercisedyourright to object to processing (see below).
Object toprocessing of your personal information where we are relying on a legitimateinterest (or those of a third party) and there is something about your particularsituationwhich makes you want to object to processing on this ground. You also have the right toobject where we are processing your personal information for direct marketing purposes.
Object to automateddecision-making, including profiling, that is not to be subject of anyautomateddecision-making by us using your personal information or profiling of you.
Request therestriction of processing of your personal information. This enables you toaskus to suspend the processing of personal information about you, for example if you wantusto establish its accuracy or the reason for processing it.
Requesttransferof your personal information in an electronic and structured form to you or to anotherparty. This enables you to take your data from us in an electronically useable formatand tobe able to transfer your data to another party in an electronically useable format.
Withdrawconsent.You have the right to withdraw your consent to the collection,processingand transfer of your personal information for a specific purpose at any time. Once wehavereceived notification that you have withdrawn your consent, we will no longer processyourinformation for the purpose or purposes you originally agreed to, unless we have anotherlegitimate basis for doing so in law. The withdrawal of consent will not affect thelawfulness of processing based on consent prior its withdrawal.
If you want to exercise any of these rights, please contact us at email@example.com. The request response time isone month.
We may need to request specific information from you to help us confirm your identity and ensureyour right to access the information or to exercise any of your other rights. This is anothersecurity measure to ensure that personal information is not disclosed to any person who has norightto receive it.
Please exercise your rights wisely and note that abuse of rights may entail your liability.
7. HOW IS YOUR DATA RETAINED?
We make sure to use appropriate technical and physical security measures to protect yourpersonaldata which is transmitted, stored or otherwise processed by us, from accidental or unlawfuldestruction, loss, alteration, unauthorized disclosure of, or access.
Your personal data is securely stored by Block360 on its servers, and on the servers of thecloud-based database management services that Block360 engages, such as Workable.
We will not retain your data for longer than it is necessary to fulfil the purpose it is beingprocessed for. To determine the appropriate retention period, we consider the amount, nature andsensitivity of the personal data, the purposes for which we process it and whether we canachievethose purposes through other means. We must also consider periods for which we might need toretainpersonal data in order to meet our legal obligations or to deal with complaints, queries and toprotect our legal rights in the event of a claim being made. When we no longer need yourpersonaldata, we will securely delete or destroy it.
We will retain information and documents, including electronic documents, containing personaldata:
to the extent that we are required to do so by law
if the information is relevant to any ongoing or prospective legal proceedings, and
in order to establish, exercise or defend our legal rights, including providinginformationto others for the purposes of fraud prevention and reducing credit risk.
8. WHAT ARE COOKIES AND HOW DO WE USE THEM?
When you visit the Block360 websites, Block360 may place cookies and similar analyticalcodes (collectively, “Cookies”) on your device, browser or the webpage you are viewing, in ordertopersonalize your experience, understand usage patterns and provide, improve, and secure theBlock360 websites. Cookies are simple computer files made of text. Cookies do not typicallycontain any information that personally identifies someone, but personal data that we storeaboutyou may be linked to the information obtained from cookies.
Our websites use different types of Cookies for different reasons, as follows:
Functional cookies - these Cookies areessential toenable you to move around the Block360 websites and use their features. These Cookiesmake sure you can view the websites and use them in a proper way. They also give youaccessto secured parts of the Block360 websites. Examples of functional cookies: SID,PHPSESSID, wp-settings-X, wp-settings-time-X, etc.
Analytical cookies and other cookies - theseCookies help us improve all our websites, collect anonymous information about howvisitorsuse our websites, collect information about the most visited pages and tell us whetherandhow many error messages were displayed. Examples of analytical cookies: 1_P JAR, _ga,_gid,etc.
Third-party cookies - these Cookies help thirdparties to help track and manage the effectiveness of, for example, their websites, ads,number of visitors. More information about these Cookies may be available on therelevantthird party’s website. Examples of third-party cookies: bcookie, sb, fr, spin, wd, xs,etc.
Based on how long they are valid, the Cookies on the Block360 websites may be either persistentcookies or session cookies: a persistent cookie will be stored by a web browser and will remainvalid until its set expiry date, unless deleted by the user before the expiry date; a sessioncookie, on the other hand, will expire at the end of the user session, when the web browser isclosed. If you want to receive more information about the cookies we use, please contact us.
You can adjust your browser settings to delete some of our cookies or cookies set by thirdparties.You may also adjust your browser settings to prevent websites from setting cookies orthird-partycookies altogether. If you prevent us from setting specific cookies, you may find that somefunctions are not available or that certain parts of the website will not load. Find out how toadjust the settings for different browsers: Chrome Firefox InternetExplorer Safari
9. DO YOU HAVE ANY QUESTIONS?