Raion Technologies Limited Privacy Policy - As of July 2022

Table of contents


I. Identity and contact details of the data controller
II. Contact details of the data protection officer
III. General information on data processing
IV. Rights of the data subject
V. Newsletter
VI. Contact via Email
VII. Corporate web profiles on social networks
VIII. Use of corporate profiles in professionally oriented networks
IX. Hosting
X. Registration
XI. Content delivery networks
XII. Usage of Plugins



This Contract applies to Raion Technologies Limited – branded apps and other sites associated with Raion Technologies Limited. This includes all and any services that state that they are offered under this Contract including the collection of data for Services provided to the User. This includes our ads and the “Share with Raion” options. Registered users of our Services are “Candidates” and unregistered users are “Visitors”.



I. Identity and contact details of the data controller



The data controller responsible in accordance with the purposes of the General Data Protection Regulation (GDPR) of the European Union and other data protection regulations is:



Raion Technologies Limited
Handel House, 95 High Street, Edgware
HA8 7DB, London
United Kingdom
+44 7831 298173
[email protected]
https://raion.io/



II. Contact details of the data protection officer



The designated data protection officer is:
DataCo International UK Limited
c/o One Peak Partners, 41 Great Pulteney Street 2nd floor
London W1F 9NZ
United Kingdom
+44 20 3318 17 18
www.dataguard.co.uk



III. General information on data processing



1. Scope of processing personal data



In general, we only process the personal data of our users to the extent necessary to provide a functioning website with our content and services. The regular processing of personal data only takes place with the consent of the user. Exceptions include cases where prior consent cannot be technically obtained and where the processing of the data is permitted by law.



2. Legal basis for data processing



Where consent is appropriate for processing personal data, Art. 6 (1) (a) UK GDPR serves as the legal basis to obtain the consent of the data subject for the processing of their data. As for the processing of personal data required for the performance of a contract of which the data subject is party, Art. 6 (1) (b) UK GDPR serves as the legal basis. This also applies to processing operations required to carry out pre-contractual activities. When it is necessary to process personal data in order to fulfil a legal obligation to which our company is subject, Art. 6 (1) (c) UK GDPR serves as the legal basis. If vital interests of the data subject or another natural person require the processing of personal data, Art. 6 (1) (d) UK GDPR serves as the legal basis. If the processing of data is necessary to safeguard the legitimate interests of our company or that of a third party, and the fundamental rights and freedoms of the data subject do not outweigh the interest of the former, Art. 6 (1) (f) UK GDPR will serve as the legal basis for the processing of data.



3. Data that we collect from you



If you are a business:

First Name
Last Name
Phone Number
Business Email Address
Company address
Job Title
Company website and social media (and other platform) links
Industry
Number of employees
Type (private / public)
Year found
Logo



If you are a candidate:

First Name
Last Name
Phone Number
Email Address
City
Employment History
Education History
Your Skills
Your social media (and other platforms for developers) profile links
Profile picture
CV



4. Data removal and storage duration



We do not intend to process and store personal data longer than it is necessary for the fulfilment of the intended purposes. If the retention of the data is no longer required for the fulfilment of a contractual or legal obligation, they will be deleted unless we establish a legitimate interest to further retain the personal data (e.g., defend any arising legal claims).



IV. Rights of the data subject



When your personal data is processed, you are a data subject within the meaning of the UK GDPR and have the following rights:



1. Right to information



You may request the data controller to confirm whether your personal data is processed by them.



If such processing occurs, you can request the following information from the data
controller:



The purpose for which the personal data is processed.
The categories of personal data being processed.
The recipients or categories of recipients to whom the personal data have been or will be disclosed.
The planned duration of the storage of your personal data or, if specific information is not available, criteria for determining the duration of storage.
The existence of the right to request from the controller rectification or erasure of personal data or restriction of processing of personal data concerning you or to object to such processing.
The existence of the right to lodge a complaint with a supervisory authority.
Where personal data are not collected from you any available information as to their source
The existence of automated decision-making including profiling under Article 22 (1) and Article 22 (4) UK GDPR and, in certain cases, meaningful information about the data processing system involved, and the scope and intended result of such processing on the data subject.



You have the right to request information on whether your personal data will be transmitted to a third country or an international organisation. In this context, you can then request for the appropriate guarantees in accordance with Art. 46 UK GDPR in connection with the transfer.



2. Right to rectification



You have a right to rectification and/or modification of the data, if your processed personal data is incorrect or incomplete. The data controller must correct the data without delay



3. Right to the restriction of processing



You may request the restriction of the processing of your personal data under the following conditions:



If you challenge the accuracy of your personal data for a period that enables the data controller to verify the accuracy of your personal data.
The processing is unlawful, and you oppose the erasure of the personal data and instead request the restriction of their use instead.
The data controller or its representative no longer need the personal data for the purpose of processing, but you need it to assert, exercise or defend legal claims; or
If you have objected to the processing pursuant to Art. 21 (1) UK GDPR and it is not yet certain whether the legitimate interests of the data controller override your interests.



If the processing of personal data concerning you has been restricted, this data may with the exception of data storage – only be used with your consent or for the purpose of asserting, exercising or defending legal claims or protecting the rights of another natural or legal person or for reasons of important public interest. If the processing has been restricted according to the aforementioned conditions, you will be informed by the data controller before the restriction is lifted.



4. Right to erasure



a) Obligation to erase



If you request from the data controller to delete your personal data without undue delay, they are required to do so immediately if one of the following applies:



Personal data concerning you is no longer necessary for the purposes for which they were collected or processed.
You withdraw your consent on which the processing is based pursuant to Art. 6 (1) (a) and Art. 9 (2) (a) UK GDPR and where there is no other legal basis for processing the data.
Accordin g to Art. 21 (1) UK GDPR you object to the processing of the data and there are no longer overriding legitimate grounds for processing, or you object pursuant to Art. 21 (2) UK GDPR.
Your personal data has been processed unlawfully.
The personal data must be deleted to comply with a legal obligation to which the data controller is subject.
Your personal data was collected in relation to information society services offered pursuant to Art. 8 (1) UK GDPR.



b) Information to third parties



If the data controller has made your personal data public and must delete the data pursuant to Art. 17 (1) UK GDPR, they shall take appropriate measures, including technical means, to inform data processors who process the personal data, that a request has been made to delete all links to such personal data or copies or replications of the personal data, taking into account available technology and implementation costs to execute the process.



c) Exceptions



The right to deletion does not exist if the processing is necessary



to exercise the right to freedom of speech and information.
to fulfil a legal obligation required by law to which the data controller is subject, or to perform a task of public interest or in the exercise of public authority delegated to the representative.
for reasons of public interest in the field of public health pursuant to Art. 9 (2) (h) and Art. 9 (2) (i) and Art. 9 (3) UK GDPR.
for archival purposes of public interest, scientific or historical research purposes or for statistical purposes pursuant to Art. 89 (1) UK GDPR, to the extent that the law referred to in subparagraph (a) is likely to render impossible or seriously affect the achievement of the objectives of that processing, or
to enforce, exercise or defend legal claims.



5. Right to information



If you have the right of rectification, erasure or restriction of processing over the data controller, they are obliged to notify all recipients to whom your personal data have been disclosed of the correction or erasure of the data or restriction of processing, unless this proves to be impossible or involves a disproportionate effort.



You reserve the right to be informed about the recipients of your data by the data controller.



6. Right to data portability



You have the right to receive your personal data given to the data controller in a structured and machine-readable format. In addition, you have the right to transfer this data to another person without hindrance by the data controller who was initially given the data, if:



In exercising this right, you also have the right to transmit your personal data directly from one person to another, insofar as this is technically feasible. Freedoms and rights of other persons shall not be affected.



The right to data portability does not apply to the processing of personal data necessary for the performance of a task in the public interest or in the exercise of official authority delegated to the data controller.



7. Right to object



For reasons that arise from your particular situation, you have, at any time, the right to object to the processing of your personal data pursuant to Art. 6 (1) (e) or 6 (1) (f) UK GDPR; this also applies to profiling based on these provisions.



The data controller will no longer process the personal data concerning you unless he can demonstrate compelling legitimate grounds for processing that outweigh your interests, rights and freedoms, or the processing is for the purpose of enforcing, exercising or defending legal claims.



If the personal data relating to you are processed for direct marketing purposes, you have the right to object at any time to the processing of your personal data in regard to such advertising; this also applies to profiling associated with direct marketing.



If you object to processing for direct marketing purposes, your personal data will no longer be processed for these purposes.



8. Right to withdraw the data protection consent declaration



You have the right to withdraw your consent at any time. The withdrawal of consent does not affect the legality of the processing carried out on the basis of the consent until the withdrawal.



9. Automated decisions on a case-by-case basis, including profiling



You have the right to not be subject to a decision based solely on automated processing – including profiling – that will have a legal effect or substantially affect you in a similar manner. This does not apply if the decision:



However, these decisions must not be based on special categories of personal data under Art. 9 (1) UK GDPR, unless Art. 9 (2) (a) or Art. 9 (2) (b) UK GDPR applies and reasonable measures have been taken to protect your rights and freedoms as well as your legitimate interests.



With regard to the cases referred to in (1) and (3), the data controller shall take appropriate measures to uphold your rights and freedoms as well as your legitimate interests, including the right to obtain assistance from the data controller or their representative, to express your opinion on the matter, and to contest the decision.



10. Right to complain to a supervisory authority



Without prejudice to any other administrative or judicial remedy, you shall have the right to complain to the Information Commissioner’s Office, if you believe that the processing of the personal data concerning you violates the UK GDPR.



The supervisory authority to which the complaint has been submitted shall inform the complainant of the status and results of the complaint, including the possibility of a judicial remedy pursuant to Art. 78 UK GDPR.



V. Newsletter



1. Description and scope of data processing



You can subscribe to a newsletter on our website free of charge. When subscribing for the newsletter, the data from the input mask is transmitted to us. The following data is collected:



Email Address
No data will be passed on to third parties in connection with data processing for the dispatch of newsletters. The data will be used exclusively for sending the newsletter.



2. Purpose of data processing



The user’s email address is collected to deliver the newsletter to the recipient.



Additional personal data as part of the registration process is collected to prevent misuse of the services or email address.



3. Legal basis for data processing



The legal basis for the processing of data provided by the user after registration for the newsletter is Art. 6 (1) (a) UK GDPR if the user has given their consent.



4. Duration of storage



The data will be deleted as soon as it is no longer necessary to achieve the purpose for which it was collected. The user’s email address will therefore be stored as long as the newsletter subscription is active.



The other personal data collected during the registration process is generally deleted after a period of seven days.



5. Objection and removal



The subscription for the newsletter can be cancelled by the data subject at any time. For this purpose, every newsletter contains an opt-out link.



Through this, it is also possible to withdraw the consent to the storage of personal data collected during the registration process.



VI. Contact via Email



1. Description and scope of data processing



You can contact us via the email address provided on our website. In this case the personal data of the user transmitted with the email will be stored.



The data will be used exclusively for the processing of the conversation.



2. Purpose of data processing



If you contact us via email, this also constitutes the necessary legitimate interest in the processing of the data.



3. Legal basis for data processing



If the user has given consent, the legal basis for processing the data is Art. 6 (1)(a) UK GDPR.



The legal basis for the processing of data transmitted while sending an email is Art. 6 (1) (f) UK GDPR. If the purpose of the email contact is to conclude a contract, the additional legal basis for the processing is Art. 6 (1) (b) UK GDPR.



4. Duration of storage



The data will be deleted as soon as it is no longer necessary to achieve the purpose for which it was collected. For personal data sent by email, this is the case when the respective conversation with the user has ended. The conversation ends when it can be concluded from the circumstances that the matter in question has been conclusively resolved.



The additional personal data collected during the sending process will be deleted after a period of seven days at the latest.



5. Objection and removal



The user has the possibility to withdraw consent to the processing of their personal data at any time. If the user contacts us by email, he can object to the storage of their personal data at any time.



Candidates and companies can revoke consent or object to their data being stored by sending us an email. The rest of the process will then be carried on an individual basis for each candidate and company.



In this case, all personal data stored while establishing contact will be deleted.



Candidates and companies can revoke consent or object to their data being stored by sending us an email. The rest of the process will then be carried on an individual basis for each candidate and company.



VII. Corporate web profiles on social networks



Use of corporate profiles on social networks



Instagram:



Instagram, Part of Facebook Ireland Ltd., 4 Grand Canal Square Grand Canal Harbour, Dublin 2 Ireland



On our company profile we provide information and offer Instagram users the possibility of communication. If you carry out an action on our Instagram company profile (e.g. comments, contributions, likes etc.), you may make personal data (e.g. clear name or photo of your user profile) public. However, as we generally or to a large extent have no influence on the processing of your personal data by Instagram, we cannot make any binding statements regarding the purpose and scope of the processing of your data.



Our corporate profile in social networks is used for communication and information exchange with (potential) customers. We use the company’s profile for:



We use our website for informational purposes only.



Publications on the company profile can contain the following content:



Every user is free to publish personal data.



The legal basis for data processing is Art. 6 (1) (a) UK GDPR.



The data generated on the company profile are not stored in our own systems.



You can object at any time to the processing of your personal data that we collect within the framework of your use of our Instagram corporate web profile and assert your rights as a data subject mentioned under IV. of this privacy policy. Please send us an informal email to [email protected] For further information on the processing of your personal data by Instagram and the corresponding objection options, please click here:



Instagram: https://help.instagram.com/519522125107875



Twitter:



Twitter International Company, One Cumberland Place, Fenian Street, Dublin 2, Ireland



On our company profile we provide information and offer Instagram users the possibility of communication. If you carry out an action on our Instagram company profile (e.g. comments, contributions, likes etc.), you may make personal data (e.g. clear name or photo of your user profile) public. However, as we generally or to a large extent have no influence on the processing of your personal data by Instagram, we cannot make any binding statements regarding the purpose and scope of the processing of your data.



Our corporate profile in social networks is used for communication and information exchange with (potential) customers. We use the company’s profile for:



We use our website for informational purposes only.



Publications on the company profile can contain the following content:



Information about services
Every user is free to publish personal data.



The legal basis for data processing is Art. 6 (1) (a) UK GDPR.



The data generated on the company profile are not stored in our own systems.



You can object at any time to the processing of your personal data that we collect within the framework of your use of our Twitter corporate web profile and assert your rights as a data subject mentioned under IV. of this privacy policy. Please send us an informal email to [email protected] For further information on the processing of your personal data by Twitter and the corresponding objection options, please click here:



Twitter: https://twitter.com/de/privacy



YouTube:



YouTube LLC, 901 Cherry Ave., San Bruno, CA 94066, United States



On our company profile we provide information and offer Instagram users the possibility of communication. If you carry out an action on our Instagram company profile (e.g. comments, contributions, likes etc.), you may make personal data (e.g. clear name or photo of your user profile) public. However, as we generally or to a large extent have no influence on the processing of your personal data by Instagram, we cannot make any binding statements regarding the purpose and scope of the processing of your data.



Our corporate profile in social networks is used for communication and information exchange with (potential) customers. We use the company’s profile for:



We use our website for informational purposes only.



Publications on the company profile can contain the following content:



Information about services
Every user is free to publish personal data.



The legal basis for data processing is Art. 6 (1) (a) UK GDPR.



The data generated on the company profile are not stored in our own systems.



You can object at any time to the processing of your personal data that we collect within the framework of your use of our YouTube corporate web profile and assert your rights as a data subject mentioned under IV. of this privacy policy. Please send us an informal email to [email protected] For further information on the processing of your personal data by YouTube and the corresponding objection options, please click here:



YouTube: https://policies.google.com/privacy?gl=DE&hl=en



VIII. Use of corporate profiles in professionally oriented networks



1. Scope of data processing



We use corporate profiles on professionally oriented networks. We maintain a corporate presence on the following professionally oriented networks:



LinkedIn:



LinkedIn, Unlimited Company Wilton Place, Dublin 2, Ireland



XING:



XING SE, Dammtorstrasse 30, 20354 Hamburg, Germany



On our site we provide information and offer users the possibility of communication.



The corporate profile is used for job applications, information, public relations, and active sourcing.



We do not have any information on the processing of your personal data by the companies jointly responsible for the corporate profile. Further information can be found in the privacy policy of:



LinkedIn:


https://www.linkedin.com/legal/privacy-policy

XING:


https://privacy.xing.com/en

If you carry out an action on our company profile (e.g. comments, contributions, likes etc.), you may make personal data (e.g. clear name or photo of your user profile) public.



2. Legal basis for data processing



The legal basis for the processing of your data in connection with the use of our corporate web profile is Art. 6 (1) (f) UK GDPR.



3. Purpose of the data processing



Our corporate web profile serves to inform users about our services. Every user is free to publish personal data.



4. Duration of storage



We store your activities and personal data published via our corporate web profile until you withdraw your consent. In addition, we comply with the statutory retention periods.



5. Objection and removal



You can object at any time to the processing of your personal data which we collect within the scope of your use of our corporate web profile and assert your rights as a data subject mentioned under IV. of this privacy policy. Please send us an informal email to the email address stated in this privacy policy.



You can find further information on objection and removal options here:



LinkedIn:


https://www.linkedin.com/legal/privacy-policy

XING:


https://privacy.xing.com/en

IX. Hosting



The website is hosted on servers of a service provider commissioned by us.



Our service provider is:



Google Cloud Platform



The servers automatically collect and store information in so-called server log files, which your browser automatically transmits when you visit the website. The stored information is:



Browser type and version
Used operating system
Referrer URL
Hostname of the accessing computer
Time and date of the server request
IP address of the user’s device



This data will not be merged with other data sources. The data is collected on the basis of Art. 6 (1) (f) UK GDPR. The website operator has a legitimate interest in the technically error-free presentation and optimisation of their website – and server log files are therefore recorded.



The server of the website is geographically located in the United Kingdom.



X. Registration



1. Description and scope of data processing



We offer users the opportunity to register by providing personal data. The data is entered into an input mask and transmitted to us and stored. The data will not be passed on to third parties. The following data is collected as part of the registration process:



If you are a business:



First Name
Last Name
Phone Number
Business Email Address
Company address
Job Title
Company website and social media (and other platform) links
Industry
Number of employees
Type (private / public)
Year found
Logo
What roles you are hiring for
What markets you are hiring in



If you are a candidate:



First Name
Last Name
Phone Number
Email Address
City
Employment History



As part of the registration process, the user’s consent to the processing of this data is obtained.



2. Purpose of data processing



A registration of the user is necessary for the fulfilment of a contract with the user or for the execution of pre-contractual measures.



Its to provide the core service of the platform which is to find appropriate jobs for candidates and appropriate candidates for each job of each company.



3. Legal basis for data processing



The legal basis for the processing of the data is Art. 6 (1) (1) (a) GDPR if the candidate has given their consent.



If the registration serves the fulfilment of a contract to which the candidate is a party or the execution of pre-contractual measures, the additional legal basis for the processing of the data is Art. 6 (1) (1) (b) GDPR.



4. Duration of storage



The data will be deleted as soon as it is no longer necessary to achieve the purpose for which it was collected.



This is the case for the data collected during the registration process for the execution of a contract or for the implementation of pre-contractual measures if the data is no longer required for the execution of the contract. Even after the conclusion of the contract, it may be necessary to store personal data of the contractual partner in order to comply with contractual or legal obligations.



5. Objection and removal



As a user you have the possibility to cancel the registration at any time. You can request a change to the data stored about you at any time.



Candidates can manually delete their account in their profile settings. Companies can send a request via email for their profile and all their jobs posted to be deleted.



If the data is necessary for the fulfilment of a contract or for the implementation of pre-contractual measures, a premature deletion of the data is only possible insofar as contractual or legal obligations do not stand in the way of a deletion.



XI. Content delivery networks



CloudFlare



1. Description and scope of data processing


On our website we use functions of the content delivery network CloudFlare of CloudFlare Germany GmbH, Rosental 7, 80331 Munich, Germany (Hereinafter referred to as CloudFlare). A Content Delivery Network (CDN) is a network of regionally distributed servers connected via the Internet to deliver content, especially large media files such as videos. CloudFlare offers web optimisation and security services that we use to improve the load times of our website and to protect it from misuse. When you visit our website you will be connected to the servers of CloudFlare, e.g. to retrieve content. This allows personal data to be stored and evaluated in server log files, the user’s activity (e.g. which pages have been visited) and device and browser information (e.g. IP address and operating system). Further information on the collection and storage of data by CloudFlare can be found here:

https://www.cloudflare.com/en-gb/privacypolicy/

2. Purpose of data processing



The use of CloudFlare’s features serves to deliver and accelerate online applications and content.



3. Legal basis for data processing



The data is collected on the basis of Art. 6 (1) (f) UK GDPR. The website operator has a legitimate interest in the technically error-free presentation and optimisation of their website -and the server log files are therefore recorded.



4. Duration of storage



Your personal information will be retained for as long as necessary to fulfil the purposes described in this Privacy Policy or as required by law.



5. Objection and removal


Information about objection and removal options regarding CloudFlare can be found at:

https://www.cloudflare.com/en-gb/privacypolicy/

XII. Usage of Plugins



We use plugins for various purposes. The plugins used are listed below:



Use of Google Analytics



1. Scope of processing of personal data


We use Google Analytics, a web analysis service provided by Google LLC, 1600 Amphitheatre Parkway, Mountain View, CA 94043, USA and its representative in the Union Google Ireland Ltd., Gordon House, Barrow Street, D04 E5W5, Dublin, Ireland (Hereinafter referred to as Google). Google Analytics examines, among other things, the origin of visitors, their length of stay on individual pages and the use of search engines, thus allowing better monitoring of the success of advertising campaigns. Google places a cookie on your computer. This allows personal data to be stored and evaluated, in particular the user’s activity (in particular which pages have been visited and which elements have been clicked on), device and browser information (in particular the IP address and the operating system), data on the advertisements displayed (in particular which advertisements have been displayed and whether the user has clicked on them) and also data on advertising partners (in particular pseudonymised user IDs). The information generated by the cookie about your use of this website will be transmitted to and stored by Google on servers in the United States. However, if IP anonymisation is enabled on this online presence, Google will previously truncate your IP address within member states of the European Union or other signatory states to the Agreement on the European Economic Area. Only in exceptional cases is the full IP address transmitted to a Google server in the USA and shortened there.

On behalf of the operator of this online presence, Google will use this information to evaluate your use of the online presence, to compile reports on the activities of the online presence and to provide further services associated with the use of the online presence and the Internet use to the operator of the online presence. The IP address transmitted by your browser as part of Google Analytics is not combined with other data from Google. You may refuse the use of cookies by selecting the appropriate settings on your browser, however please note that if you do this you may not be able to use the full functionality of our website.\Further information on the collection and storage of data by Google can be found here:

https://policies.google.com/privacy?hl=en-GB

2. Purpose of data processing



The purpose of processing personal data is to specifically address a target group that has already expressed an initial interest by visiting the site.



3. Legal basis for the processing of personal data



The legal basis for the processing of personal data is the user’s given consent in accordance with Art. 6 (1) (a) UK GDPR.



4. Duration of storage



Your personal information will be stored for as long as is necessary to fulfill the purposes described in this Privacy Policy or as required by law. Advertising data in server logs is anonymised by Google’s own statements to delete parts of the IP address and cookie information after 9 and 18 months respectively.



5. Possibility of revocation of consent and removal



You have the right to revoke your declaration of consent under data protection law at any time. The revocation of the consent does not affect the lawfulness of the processing carried out on the basis of the consent up to the revocation.
You may prevent the collection and processing of your personal data by Google by preventing the storage of cookies by third parties on your computer, by using the “Do Not Track” function of a supporting browser, by deactivating the execution of script code in your browser or by installing a script blocker such as NoScript (https://noscript.net/) or Ghostery (https://www.ghostery.com) in your browser. your IP address) to Google and to prevent the processing of this data by Google by downloading and installing the browser plug-in available under the following link:

https://tools.google.com/dlpage/gaoptout?hl=en

With the following link you can deactivate the use of your personal data by Google:

https://adssettings.google.com

Further information on objection and removal options against Google can be found at:

https://policies.google.com/privacy?gl=EN&hl=en