Applicant Privacy Notice
1. INTRODUCTION
When applying for a position within any of the companies in the Evolution group (“Evolution”, “we” or “us”) you have been required to submit information relating to you. Evolution is committed to safeguarding your privacy. This privacy notice will inform you about the processing we undertake with your personal data in connection with your application. The controller of your personal data will be the Evolution company which employ the position you are applying for. The name of the Evolution company is stated in the advert for the position. You can also find a list of the Evolution group companies by emailing to dataprivacy@evolutiongaming.com.
2. DEFINITIONS
Applicable Data Privacy Laws” means data protection laws and regulations implementing the Data Protection Directive 95/46/EC and as of 25 May 2018 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) (the “GDPR“).
“Personal data” is defined as any information relating to an identified or identifiable natural person
“Candidate” means you as an individual who has applied for a position with Evolution.
“Reference person“means you as an individual who has been named as a reference by a Candidate in connection with the recruitment process.
The controller (“Controller“) in regard to job applicants’ Personal data is the Evolution company which employ the position you are applying for.
The Controller is part of the Evolution Gaming Group AB (Sweden), registration nr. 556994-5792. Other companies of the Evolution Gaming Group include SIA Evolution Latvia (Latvia), registration No. 40003815611, EVOGAME ESTONIA OÜ (Estonia) registration No. 14035717, Evolution Belgium (Belgium), registration No. 0638.824.479, Evolution Netherlands BV (Netherlands), registration No. 66682452, Evolution Malta Ltd (Malta), registration No. C 48666, Evolution Gaming Malta Ltd (Malta), registration No., Evolution Malta Ops Ltd (Malta), registration No. C 50583, Evolution Malta Holding Ltd (Malta), registration No. C 48665, Evo Gaming Studios RO S.R.L (Romania), registration No. 36034853, Evolution Core Holding Ltd (Cyprus), registration No. HE 177496 (the “Companies”). An updated list of companies within the Evolution Gaming Group can be found by sending a request to dataprivacy@evolutiongaming.com.
The Evolution Gaming Group has established an Intra Group Data Transfer Agreement which governs any transfer of Personal data within the group of companies.
3. FROM WHOM DO WE RECEIVE DATA
If you choose to apply for a position within Evolution on our career page (https://careers.evolution.com/) we will collect your personal data directly from when you submit your application. We may also collect further information from and about you if we chose to conduct interviews and tests with you as part of the recruitment process.
You may also apply for a position within Evolution by submitting an application through the candidate portal provided by SmartRecruiters. SmartRecruiters is a recruitment agency engaged by Evolution and will, for the purposes of evaluating you for the position you applied for, process your personal data on behalf of us acting as a processor. If you submit an application through the candidate portal SmartRecruiter’s may, in addition to their handling of data under our instructions, process your personal data for their own purposes (for example in order to help you manage you job opportunities within their candidate portal). For such other purposes of processing SmartRecruiters will be responsible for your personal data and act as a controller. You can read more about how SmartRecruiters handles your data here.
We will also collect personal data from other sources such as social networks and LinkedIn where relevant for the specific position.
We will also collect your personal data from Reference person if you have named reference/s in your job application.
4. WHEN AND WHY DO WE PROCESS YOUR PERSONAL DATA
4.1. Handle the recruitment process
We will process your personal data to handle the recruitment process, for example to collect and review documents relating to your application (such as your CV and cover letter), to evaluate the application, making reference checks and to communicate during the recruitment process.
Candidate
Categories of Personal data | Legal basis |
Name Contact details Photo Video (for Game Presenter position) Location data Experience description Education description CV Feedback data from Reference person Other information from connected LinkedIn page and cover letter | Legitimate interest. To the extent you have not requested a specific action the processing is necessary in order fulfil our legitimate interest to handle the recruitment process. The processing of personal number is necessary with regard to the purpose of the processing. We will only process special categories of data, for example health data and information on trade union membership, if you freely have submitted such data to us and if you have given your consent. |
Retention period: Personal data processed for this purpose is retained during the recruitment process and for a period up to 12 months thereafter to fulfil our legitimate interest to establish, exercise and defend any legal claims.
4.2. Future recruitment
If you give your consent we will save your application documents to evaluate you for other positions which may become vacant within the relevant period set out below. It is optional to give your consent to this processing and you may at any time withdraw such consent.
Candidate
Categories of Personal data | Legal basis |
Name Contact details Photo Location data Experience description Education description CV Feedback data from Reference person Other information from connected LinkedIn page and cover letter | Consent. The processing is based on your given consent. The processing of personal number is necessary with regard to the purpose of the processing. We will only process special categories of data, for example health data and information on trade union membership, if you freely have submitted such data to us and if you have given your consent. |
Retention period: Personal data is retained during a period of 12 months from the time of the recruitment process for the position you have applied for has ended. Provided that you give your consent in each case, personal data will be retained for additional 12 months’ periods.
4.3. Carry out background checks
As part of the recruitment process we may, depending on the position you have applied for, perform background checks on you in order to further evaluate and validate your application. Such background checks may include criminal records, public social media checks etc.
Candidate
Categories of Personal data | Legal basis |
Name Personal ID number Educational/professional background Other information of relevance in public social media profiles | Legitimate interest. The processing is necessary in order to fulfil our legitimate interest to further evaluate and validate your application. The processing of personal number is necessary with regard to the purpose of the processing. Data from criminal records will only be processed if necessary to fulfil a legal and/or regulatory obligation to which Evolution is subject. |
Retention period: Personal data processed for this purpose is only checked and not stored.
4.4. Conduct personality and ability tests
Depending on the position you have applied for we may conduct personality and ability tests as part of the recruitment process. If such tests are relevant for your applied position we will, before conducting the tests, ask for your consent.
Candidate
Categories of Personal data | Legal basis |
Name Personal ID number Test data Video (for Game Presenter position) | Legitimate interest. The processing is necessary in order to fulfil our legitimate interest to further evaluate and validate your application. The processing of personal number is necessary with regard to the purpose of the processing. The processing of video is necessary to evaluate your behaving and performance of tasks related to job position in front of camera. |
Retention period: Personal data processed for this purpose is retained during the recruitment process and for a period up to 26 months thereafter to fulfil our legitimate interest to establish, exercise and defend any legal claims.
4.5. Evaluate recruitment process and follow-ups
We process Personal data to evaluate and follow-up the recruitment process, for example in order to create reports and statistics of the number of applications per position.
Candidate
Categories of Personal data | Legal basis |
Name Contact details Location data Experience description Education description CV Feedback data from Reference person Other information from connected LinkedIn page and cover letter | Legitimate interest. The processing is necessary to fulfil our legitimate interest in following up and evaluating the recruitment process. |
Retention period: Reports and statistics on aggregated level which do not contain personal data will be saved until further notice.
4.6. Establish, exercise and defend legal claims
For the purpose of establish, exercise and defend legal claims (for example in connection with a dispute or legal process) we will process your personal data.
Candidate and Reference person
Categories of Personal data | Legal basis |
All data collected that is necessary to establish, exercise or defend the legal claim. | Legitimate interest. The processing is necessary in order to fulfil our legitimate interest to establish, exercise or defend the legal claim, for example in connection with a dispute or legal process. The processing of personal number is necessary with regard to the purpose of the processing. We will only process special categories of data, for example health data and information on trade union membership, to fulfil our legitimate interest to establish, exercise or defend legal claims. Personal data relating to criminal offences or convictions will be processed only if necessary to fulfil our legitimate interest to establish, exercise or defend legal claims. |
Retention period: Your personal data is retained for the period required in order for us to establish, exercise or defend the legal claim.
4.7. Fulfil legal obligations
We will process your personal data to fulfil legal obligations which apply to Evolution.
Candidate and Reference person
Categories of Personal data | Legal basis |
All data collected that is necessary to fulfil each legal obligation. | Legal obligation. The processing is necessary in order to fulfil Evolution’s legal obligations, for example within the area of book-keeping and taxation. |
Retention period: Personal data is retained for the period as necessary to fulfil the legal obligations which apply to Evolution.
5. Whom we share your data with
Processors acting on behalf of Evolution
Evolution will, if necessary, transfer your personal data to external parties such as vendors and service providers which process personal data under the instructions of Evolution (for example IT-service providers, third party recruitment agencies (such as SmartRecruiters, Inc), etc.).
Other recipients
Recipient | Purpose of transfer | Legal basis |
Courts and outside counsels | In order to exercise, establish or defend legal claims | Our legitimate interest in having disputes settled by competent courts |
External auditors | To fulfil legal obligations (such as accounting and auditing obligations) | To fulfil legal obligations |
Authorities | To fulfil legal obligations (for example due to requests from competent authorities) | To fulfil legal obligations |
Group companies of Evolution | To administer and handle the recruitment process | Our legitimate interest to internally administer and handle the recruitment process/ Intra Group Transfer Agreement |
Trade unions | To fulfil legal obligations within the field of employment, e.g. consultation obligations | To fulfil legal obligations within the field of employment |
Appropriate safeguards for transfers outside the EU/EEA-area
Where a disclosure as mentioned above entails transfers of personal data outside the EU/EEA, Evolution will ensure that the EU Commission’s standard contractual clauses have been entered into between the transferring Evolution entity and the receiving external party. Alternatively, other safeguards will be put in place prior to such transfers (for example ensuring that the recipient of data is certified under EU/US Privacy Shield).
You are entitled to receive a copy of any documentation demonstrating that appropriate safeguards have been taken in order to protect your personal data during a transfer outside the EU/EEA.
If you would like to know more about the processing of your personal data and whether your personal data is transferred outside the EU/EEA, please contact us on the contact details as set out below.
6. What are your rights
Under the GDPR you may be entitled to:
- Access
You may request confirmation whether or not personal data is processed and if that is the case have access to your personal data and additional information such as the purposes of the processing. You are also entitled to receive a copy of the personal data undergoing processing. If the request is made by electronic means the information will be provided in a commonly used electronic format if you do not request otherwise.
- Rectification
Evolution will take steps to keep your personal data accurate, complete and up-to-date. If you identify that any personal data related to you is inadequate, incomplete or incorrect, you are entitled to have the personal data corrected.
- Object to certain processing
You may object to the processing of your personal data processed on the basis of a legitimate interest, on grounds relating to your particular situation and to processing for direct marketing purposes.
- Erasure
You may have your personal data erased under certain circumstances such as when your personal data it is no longer needed for the purposes for which it was collected.
- Restriction of processing
Under certain circumstances, you may ask us to restrict the processing of your personal data to only comprise storage, if you do not want your personal data erased.
- Withdrawal of consent
You have the right to at any time withdraw your consent to processing of personal data to the extent the processing is based on your consent, for example if your personal data is kept for the purpose of evaluating you for other open positions.
- Data portability
As regards personal data that you have provided to Evolution, you may ask to receive a machine-readable copy of the data, in so far the data is processed on the basis of your consent or on the basis that the processing is necessary in order to perform an agreement with you. You also have the right to ask for such data to be transferred to another controller (where possible).
Complaints to the supervisory authority
You acknowledge that you always have the right to lodge complaints pertaining to the processing of your personal data to the competent data protection authority.
Data collected from SmartRecruiters including recommendations
When you share your personal data with us through SmartRecruiter’s candidate portal, you are deemed to have read this privacy notice. We are not responsible for the processing activities that SmartRecruiters undertake for its own purposes regarding your personal data. Hence for these activities, we will ask you to check SmartRecruiter’s privacy notice.
If you choose an option to refer a friend for a vacant job position in Evolution, it is your responsibility to make sure that the person you refer has given the consent to be referred and his/her data submitted.
7. Security
We will ensure that the access to your data is accurately secured by applying appropriate safeguards, depending on the circumstances taking into account the state of the art, the costs of implementation and the nature, scope, context and purposes of processing as well as the risk. In support of this commitment, we have implemented appropriate technical, physical and organizational measures to protect your personal data against unauthorized or accidental destruction, alteration or disclosure and misuse, damage, theft or accidental loss or unauthorized access.
8. Contact Information
If you have any questions or concerns regarding the processing of your personal data or if you wish to exercise any of your rights as set out below, please contact Evolution on e-mail:
9. Other Notices
We reserve the right to update this privacy notice, if necessary, for example to comply with legislative changes, regulatory changes, new practices and procedures, or requirements imposed by any authority. The most recent version is always available on this link https://www.evolution.com/privacy-policy/ and the revisions will apply from the date of their publication or via the position page on the website. The date on which this text was last changed can be found in the header of the document.
Additional information can be found here:
- Evolution Privacy Policy: https://www.evolution.com/privacy-policy
- Evolution Cookie policy: https://careers.evolution.com/cookie-policy/
- Smart Recruiter Privacy Policy: https://www.smartrecruiters.com/legal/candidate-privacy-policy/march-27-2020/