Date of drafting: 07.11.2023


(1) Personal data operator: Seatbelt Consulting SRL, headquartered in Bucharest, Muniției Street, no. 5, Sector 6, registered with the Trade Registry under no. J40/7094/2011, Unique Identification Code RO28607739.

(2) Processed personal data: data referring to candidates, including: candidate's contact details; email address; address; current employer; work history; education; licenses/certifications; information related to studies as well as other information included in the curriculum vitae;

(3) Source of Personal Data:
Personal Data can be obtained from the following sources: directly from you by providing or entering your data into our human resources systems, through the application process or through other forms or information you provide us in connection with your employment (curriculum vitae) or from third parties, including references and other background checks, from former employers and/or labor force recruitment agencies, subject to applicable legal requirements.

(4) Purpose of processing Personal Data:
The Company wishes to store your personal data related to the candidacy process in order to obtain a job, as defined in (2) for the purpose of contacting you to offer a job. The Company mentions that there is no automated decision-making process (including profiling) based on your Personal Data.

(5) Disclosure of Personal Data:
Your Personal Data will be disclosed within the Company only to management and other persons who need access to Your Personal Data (“need to know basis”) in order to fulfill their specific duties for the purposes listed in Section (4) above or when this is necessary or permitted by applicable legislation.
The Company may also present Your Personal Data to third parties providing recruitment or archiving services for the mentioned purpose (strictly within the EU). Your Personal Data will be disclosed to such third parties only to the extent necessary in connection with the execution of the purpose described in Section (4) above, as permitted by the candidate's consent or otherwise authorized, required or permitted by law.

(7) Legal basis for processing Personal Data:
The legal basis for processing Personal Data for the purpose described in section (4) is the legitimate interest of the Company. In addition to the legal basis presented in this section, the Company may use your data to comply with requirements from authorities (investigations, inquiries, court order or other legal requests).

(8) Data security:
The Company maintains physical, technical and organizational security measures to protect Personal Data against destruction, loss, alteration, disclosure, restriction or accidental, illegal or unauthorized access, regardless of where they are processed (stored).

(9) Duration of processing/storing Personal Data:
If you are a candidate for a position offered by the Company (without having formalized any relationship with the Company), your Personal Data provided to the Company will be stored for a duration of 1 year. The recruitment process is defined as a complex stage of expanding organizational capacity that occurs following elements such as business analysis, analysis of the socio-economic context of activity, department development plans, budget analyses, business forecast and others. Consequently, it may result from the analysis the need to initiate recruitment processes in advance of the implementation of projects (and making hires), as a fundamental stage of project management. This fact results in the company's need, in some cases, based on legitimate interests, to carry out recruitment processes that can have a maximum duration of 12 months.

(10) Your rights regarding Personal Data:
In accordance with the applicable provisions regarding Personal Data, we inform you that you have the following rights, which can be exercised by addressing a request in this regard using the contact details indicated in Section (13) below:
(a) The right of access to the processed Personal Data, meaning your right to obtain from the Company confirmation whether or not personal data concerning you are being processed and, if so, access to such data and the conditions in which they are processed (including the purpose of processing, categories of processed data, recipients of the data);
(b) The right to request rectification or deletion of Personal Data, meaning your right to ask us to rectify inaccurate personal data or complete incomplete data.
Also, the right to delete your Personal Data can be exercised under certain circumstances provided by applicable law, including: the situation where Personal Data are no longer necessary in relation to the purposes of processing, the situation where the data subject opposes processing and there are no other legitimate interests prevailing for processing, the situation where Personal Data have been illegally processed.
(c) The right to request the restriction of processing, meaning your right to obtain from the Company the restriction of processing in the following cases: (i) you contest the accuracy of the data (restriction will apply as long as it is necessary for the Company to verify the accuracy of the Personal Data); (ii) the processing is illegal and you oppose the deletion of the data requesting instead the restriction of their use; (iii) the Company no longer needs the Personal Data for the purposes mentioned above, but you request the Personal Data for the establishment, exercise or defense of a right in court; or (iv) you have opposed processing, for the interval of time in which the Company verifies whether the legitimate rights of the Company prevail over your rights;
(d) The right to oppose processing, meaning your right to oppose processing for reasons related to your particular situation when processing (i) is based on the legitimate interests of the Company or a third party, including in the case of profiling activities based on this ground or (ii) to the extent applicable, is carried out for direct marketing communications, involving profiling;
(e) The right not to be subject to an automated decision, including profiling;
(f) The right to data portability, meaning your right to request the movement, copying or transfer of your existing data in the Company's database to another database, in a structured, commonly used and machine-readable format, where processing is based on a contract and is carried out by automated means;
(g) The right to file a complaint with the National Supervisory Authority for Personal Data Processing and to address the competent courts.

(11) Modifications to the Notification:
If we substantially change our practices regarding Personal Data or this Notification, we will issue a revised Notification and/or take other measures to notify you of the changes, in accordance with applicable legislation.

(12) Data Protection Officer:
In consideration of applicable legal provisions, the Company has designated a Data Protection Officer (also known as DPO or Data Protection Officer).
Their contact details are as follows:
Address: Bucharest, Muniției Street no. 5, Sector 6

(13) Questions or requests:
If you have questions regarding this Notification or wish to (i) access or review Your Personal Data or learn more about them or (ii) make another type of request related to Your Personal Data, please contact us using the previously mentioned details.