Recruitment Privacy Policy

WHY DO WE COLLECT YOUR PERSONAL DATA?
 
VICTORY SQUARE PARTNERS collects your personal data as part of the recruitment process to evaluate and select candidates for one or more available positions, the responsibilities and requirements of which are described either in public announcements or communicated directly by the company as part of a proactive recruitment initiative.
 
We collect your personal data when you complete the application form on our platform, at the moment you decide to apply, and/or through the CV you attach to the application form or send to us by email.
 
We may supplement this information by accessing your publicly available professional social media profile (e.g., LinkedIn), if you have one. At this stage of the recruitment process, we do not collect information about you from sources other than those mentioned above and from recommendations offered by third parties (for example, current or former employees, collaborators, or partners), in which case we will contact you and request your consent to continue processing the data.
 
Through the CV or the application form you provide, we collect the following personal data: your first and last name, your photo (if you decide to include it), contact details (phone number, email address), age, nationality, gender, information about your education and employment history, professional skills, foreign language proficiency, professional certificates, and any other information specifically required by law for the available position.
 
The CV you submit to us MUST NOT contain sensitive data related to:
• Racial or ethnic origin;
• Political beliefs;
• Philosophical or religious beliefs;
• Trade union or political party membership;
• Criminal history or any legal proceedings and associated penalties or fines;
• Any illegal or inappropriate behavior and associated sanctions;
• Any national identification number.
 
To ensure that individuals invited to join the VICTORY SQUARE PARTNERS team are qualified and have a strong potential to be productive and successful employees, the company reserves the right to investigate applicants’ work history and employment references. In addition, the company may conduct background checks when employees are considered for promotions or transfers. Background checks will be conducted at the company’s discretion and in accordance with applicable laws.
 
THE LEGAL BASIS FOR THE PROCESSING OF PERSONAL DATA
 
The information is processed lawfully in accordance with:
• EU Regulation No. 679/2016
• Government Decision No. 681/2011
• Government Decision No. 134/2016
 
From the perspective of EU Regulation No. 679/2016, all processing of personal data meets one of the following conditions:
• The data subject has given their consent.
• It is necessary for the legitimate interests of the controller or of a third party.
 
WHAT PERSONAL DATA DO WE COLLECT, AND WHY DO WE COLLECT IT
 
Personal data includes any information that allows for the identification of a person. This data retains its “personal” nature even if the person decides to make it public.
 
We only collect data that is voluntarily provided by visitors through accessing the website, its menus and services, Browse pages, or completing the available forms. Visitors actively contribute by providing their data. By completing any registration forms on the website (https://www.victorysquarepartners.com), visitors consent for the personal data they have communicated to be collected via the website or email and to be processed by VICTORY SQUARE PARTNERS for the declared purposes of this website, as well as for statistical purposes, in accordance with the regulations provided under Law no. 677/2001, as subsequently amended, and the GDPR.
 
Also, if your professional profile is public on platforms such as LinkedIn, we may collect relevant data to evaluate your professional profile, including experience, education, skills, and recommendations. If you are contacted through a recommendation, we will retain only the basic data necessary for contact and evaluation, respecting your consent.
 
For ease of use of the sites and for communication purposes via the Internet, we may collect, in part or in whole, the following data through access to web resources or electronic communication:
• Identification data such as name and address;
• Contact data such as phone number and email address;
• Data related to online activity and social network accounts.
 
When visitors send electronic messages, we collect the data shown in the messages and forms, as well as the visitor’s IP address.
 
This data is retained either temporarily (IP, browser used, etc.) or permanently (electronic messages, personal information sent for various documents and records), but for no longer than 3 years from the date of communication of the personal data, if the person has not been selected for the position for which they applied.
 
VICTORY SQUARE PARTNERS, as the data controller who determines the means and purposes of data processing, may appoint one or more authorized persons to process data on its behalf. All parties involved in this process have legal responsibilities under GDPR rules and are contractually regulated.
 
We are aware of the importance of personal data and make every effort to ensure it is:
• Processed correctly, lawfully, and transparently;
• Used for specified, explicit, and legitimate purposes;
• Used in an adequate, relevant, and limited manner;
• Accurate and up-to-date;
• Retained no longer than necessary;
• Processed in a manner that ensures appropriate data security.
 
HOW DO WE PROTECT THE CONFIDENTIAL INFORMATION COLLECTED
 
The information collected about you is stored in written and/or electronic form. We ensure that the information we hold is kept in secure locations, with an appropriate level of security and authorized access for designated personnel.
 
We also ensure that authorized persons are contractually obliged to implement technical and organizational data protection measures in cases where the data they process identifies or could identify a person.
 
LOCATION AND DURATION OF STORAGE
 
The personal data collected is stored exclusively in Recruitee (our recruitment tool).
 
The storage duration for each category of personal data complies with legal requirements, VICTORY SQUARE PARTNERS’ internal regulations, and best practices in the field, but for no longer than 3 years from the date of application, if the person has not been selected for the position.
 
For candidates proactively contacted through social networks or recommendations, the retention period is the same (maximum 3 years from the last interaction), unless the candidate requests the deletion of data beforehand.
 
RIGHTS RELATED TO THE PROCESSING OF PERSONAL DATA
 
According to EU Regulation No. 679/2016, you have the following rights:
 
• WITHDRAWAL OF CONSENT: If the processing is based on your consent, you may withdraw it at any time, without affecting the lawfulness of the processing carried out based on consent before its withdrawal.
 
• DATA RECTIFICATION: If you notice that we hold incorrect personal data about you, you can request the correction of your data at any time. We make reasonable efforts to keep personal data in our possession—which is continuously used—accurate, complete, current, and relevant based on the most recent information available to us.
 
• RESTRICTION OF PROCESSING: In any of the following situations, you may request that we restrict the processing of your data:
    • You contest the accuracy of the personal data while we verify it.
    • The processing is unlawful, and you request restriction rather than erasure.
    • We no longer need your data, but you require it to establish, exercise, or defend a legal claim.
    • You object to processing while we verify whether our legitimate interests override yours.
 
• ACCESS TO YOUR DATA: You may request information about the personal data we hold about you, including the categories of data, the purposes of its use, the source if not collected directly from you, and to whom it was disclosed, if applicable. You can obtain a free copy of the personal data we hold. We reserve the right to charge a reasonable fee for abusive requests.
 
• RIGHT TO DATA PORTABILITY: Upon request, we will transfer your data to another controller, where technically feasible, provided the processing is based on your consent or the performance of a contract and is carried out by automated means.
 
• RIGHT TO ERASURE: You may request the deletion of your data if:
    • The data are no longer necessary for the purposes for which they were collected.
    • You object to further processing (see Right to object below).
    • The personal data was processed unlawfully.
    • You withdraw the consent on which the processing is based.
 
This right does not apply where processing is necessary:
    • To comply with a legal obligation;
    • To comply with legal retention periods;
    • To establish, exercise, or defend a legal claim in court.
 
• RIGHT TO OBJECT: You may object at any time to the processing of your data. In this case, we will stop processing it unless we can demonstrate compelling legitimate grounds for the processing or for establishing, exercising, or defending legal claims. When objecting, please specify whether you request the deletion or restriction of the processing of your data.
 
• RIGHT TO COMPLAIN: In the event of an alleged violation of applicable privacy legislation, you may file a complaint with the National Supervisory Authority for Personal Data Processing by completing the online form available at: dataprotection.ro
 
For candidates who do not apply directly but are contacted by VICTORY SQUARE PARTNERS based on their public professional profile or a recommendation, the company will ensure proper information regarding the purposes and legal basis of data processing as soon as possible from the first contact. You have the right to exercise all the rights mentioned above in the same manner.
 
To request a copy of the data held about you or to update your information, please contact VICTORY SQUARE PARTNERS via the email address contact@vspartners.us.
 
To respond efficiently, you will need to provide your identity (name, surname, phone number, and address). The personal data held by VICTORY SQUARE PARTNERS is subject to the conditions of EU Regulation No. 679/2016, which grants data subjects the right to access all types of information recorded and held by the data controller, subject to certain limitations.
 
VICTORY SQUARE PARTNERS assumes no responsibility for the incorrect registration of personal data. This information notice applies to all data subjects involved in the recruitment process conducted by VICTORY SQUARE PARTNERS, whether they have applied directly via the website or have been contacted by the company through other channels, including social networks or recommendations.
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