TBF Finance, UAB (hereafter “the Company”) is the company that is recruiting for the job vacancy you have applied for.
Personal data: means any information relating to an identifiable natural person (i.e. using information and data in order to directly or indirectly identify a specific person).
Processing: means any operation(s) which is performed on personal data (or on sets of personal data) whether or not by automated means such as collection, recording, organization, structuring, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, alignment, combination, restriction, erasure or destruction.
The Company respects your privacy and will treat your personal information as confidential. Accordingly, we are committed to taking all reasonable steps in order to protect and safeguard the privacy, confidentiality, security and integrity of your personal data. Moreover, any personal data that we collect about you will only be used for the purposes we have collected it for, or as allowed under the GDPR and applicable legislation.
This Policy is applicable to the processing of personal data regardless of the form/environment that the personal data is provided (e.g. via email, on paper, electronically, by phone or otherwise) and whether or not the Company process it by automated means of manually.
Data Protection Principles
We will comply with data protection law and principles, which means that your data will be:
Personal information we collect about you
When you apply for a job at the Company, we will ask you to provide us with certain personal information about yourself so we can evaluate your application. We will process that information & data to decide whether you meet the requirements for the advertised job position and if you do, we will invite you for an interview. During the interview we will use the personal information & data you have provided us to decide whether to offer you the position.
If this information is not provided, our ability to consider you as a candidate may be limited and we may not be able to process your application further. You may also provide us with your personal information that we have not specifically requested (for example, your CV may contain information about your hobbies and social preferences). All information is provided on a voluntarily basis and you determine the extent of information that you provide to the Company.
During your job application and/or the recruitment process we will collect, use and store the following categories of personal data about you:
Any personal data derived or contained in the supporting documents which are part of the application / recruitment process, including but not limited to
Sensitive Personal Information
The Company does usually not request or require sensitive personal information regarding religion, health, sexual orientation or political affiliation in connection with your application. If you have a disability and would like for us to consider an accommodation, you may provide that information during the recruitment process in order to enable us to make appropriate adjustments.
For some countries, the Company may also ask for information such as race, ethnicity or gender for the purposes of monitoring equal opportunity and to help the Company assess whether a work permit and/or visa will be required in order to be employed. However, for the purposes of your application this information is voluntary. If you provide us with this information, it will not be considered in the hiring or selection process.
Information from other third parties
How does the Company use and processes your personal information?
The Company will use and process your personal information based on one or more of the following legal bases and purposes:
Profiling and automated decision making
The Company may also process your personal data in relation to your application for data and statistical analysis. We may deploy specific technologies for the purposes of enabling certain global-level recruiting analysis and diversity monitoring with your consent (where permitted by applicable law) to comply with legal requirements or in the Company’s legitimate interests. The Company does not make any automated decisions in relation to your application without human involvement.
Who does the Company share your personal information with?
Any personal data or other confidential information that you provide to the Company will be treated as confidential and it will not be disclosed to any third parties, unless such a disclosure is necessary for the purposes described herein.
Below are the cases under which we will disclose your personal data and why:
(i) Other group companies
Your personal information may be shared for the purposes described herein with other companies of the Group (i.e. mother company, subsidiaries, sister companies, branches, representative companies and its respective employees in order to contact you for the outcome of your job application, to inform you of future job opportunities, to complete the recruitment process, to evaluate your suitability for the advertised position, conduct background checks and fulfil our contractual obligations as per the terms of your employment agreement etc.). It should be noted that all the group entities and our employees are required to follow our privacy and security protocols when handling personal data;
(ii) Third party service providers
We may also share your personal information with third parties who provide services to us such as recruitment agencies, consultants, background services, fraud prevention agencies, identity verification providers, banks or other financial institutions, internal auditors, external auditors, legal advisors and attorneys; or any other service providers which are necessary to fulfil our contractual obligations under your employment agreement or ancillary to it (i.e. accounting systems to process salary payments, insurance companies for our medical insurance schemes, external training providers, event organizers, travel agencies, car rentals etc.).
If your personal information is shared in this way, the Company do so only on a “need-to-know” basis and we will seek to ensure it is only used in connection with the functions or services these parties will be performing for the Company and that your personal information is treated by them in a confidential manner. We do not allow our third-party service providers to use your personal data for any other purposes or for their own purposes, apart from the ones we they have been contracted for and we instructed them for.
These service providers that the Company uses may change depending on the group entity that employs you and may change over time but we will always seek to ensure that any third parties who handle your personal information will do so in a manner consistent with this Privacy Statement and in accordance with applicable law. Moreover, all our third-party service providers are required to take appropriate security measures to protect your personal data and prevent any data breach.
(iii) Other third parties
The Company may also disclose your personal information to other third parties including but not limited to:
Legal basis under which the Company processes your personal information
If you are an individual in the European Economic Area and Cyprus (“EEA”), our legal basis for our collecting and processing of your personal information is as follows:
Data Security, Confidentiality and Safeguards
In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a business need-to-know. They will only process your personal data on our specific instructions and they are subject to a duty of confidentiality.
We have put in place procedures to deal with any suspected data security breach and will notify you and any applicable regulator of a suspected breach where we are legally required to do so. If you have any questions on the security measures that we use you may contact us at [email protected]
(a) For job applicants: If your job application is unsuccessful, we shall retain your personal data only for 6 months following the outcome of your application, or for a period of 2 years with your explicit consent in order to consider you for future job openings.
(b) For successful candidates: we will retain your personal data for a period of 3 years after your application date.
(c) For employees leaving the company: we will retain your personal data for a period of 2 years following the last day of your employment. However, your personal data may be retained for a longer period in case for example a dispute or legal claim arises between us, or due to legislative or regulatory reasons requiring us to do so. In any case, we will not keep your personal data for any longer than it is required.
As soon as the purpose has been fulfilled or at the end of the retention period, the Company will securely erase or destroy your personal data in accordance with our data retention policy.
Monitoring and Recordings
Moreover, we hereby inform you that we have security measures in place both for the whole building and at our offices, including CCTV and building access controls. There are signs notifying you that CCTV is in operation. Accordingly, if you visit the Company’s premises for an interview or for any other reason, we may have CCTV footage which will record your image. However, these images are securely stored and only accessed by authorized personnel on a need-to-know basis (i.e. to look into an incident). CCTV recordings are typically erased after a short period of time unless an issue arises which requires us to maintain the recording for a longer period of time (i.e. to investigate a case of theft).
In addition, visitors to our offices may be requested to sign in at reception and we shall keep a record of visitors for a short period of time. Our visitor records are securely stored and are accessible only on a need-to-know basis. All the above-mentioned types of recordings will be the sole property of the Company and will constitute evidence of the communications between us, any business dealings and agreements made. The Company reserves the right to use these recordings in a court of law in case of a dispute or otherwise.
In the European Economic Area and some other countries, you may have certain rights available to you under applicable data protection laws which may include the right to:
If you wish to exercise any of your rights or if you have any questions about these rights, please contact our DPO at [email protected]
Data Protection Officer (DPO)
If you have any questions regarding this Policy, have any privacy concerns, wish to make a complaint or exercise any of your rights in relation to your personal data you may contact our DPO as follows:
Via email at: [email protected]
Via telephone: +370 672 277 61
With registered post at: Konstitucijos pr. 21C, 5th Floor, Vilnius, LT-08130, Lithuania
If you are still not satisfied after having spoken to us, or you are unhappy with the outcome of the complaint, you also have the right to lodge a complaint to the Data Protection Commissioner (which is the supervisory authority/regulator for personal data protection issues in Lithuania) by visiting this page https://vdai.lrv.lt/en/