Purpose and scope of the Policy
The purpose of present privacy policy (hereinafter referred to as: „Policy”) is to define the lawful order of the use of the records/databases maintained by the RespAct GmbH (hereinafter referred to as: „Controller”) on the website under hlth-global.com (hereinafter referred to as: „Website”) and to ensure that the constitutional principles of data protection, the informational self-determination and data security are met, and that everyone has the right to manage their personal data within the framework of the relevant laws and getting known the circumstances of the processing of the data; as well as to prevent the unauthorized access, alteration and disclosure. Furthermore, present Policy shall inform the data subject about the data processing practice of the Controller.
The scope of the Policy covers the data processing of all personal and special data carried out by any units of the Controller.
Relevant laws
- 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) (general data protection regulation; hereinafter referred to as: „GDPR”)
Data of the Controller
Applicable data of the Controller are the followings:
- Name: HLTH-GLOBAL PTE. LTD.
- Seat: 30 Cecil Street, #19-08 Prudential Tower, Singapore (049712)
- Company Reg. No.: 202429758Z
- Registering Authority: Accounting And Corporate Regulatory Authority (ACRA)
- E-mail: zoltan@hlth-global.com
Scope, purpose, duration and title of the processed data
The data processing operation of Controller are based on the consent of the data subject or on legal provision. In case of voluntary consent, the data subject may request information about the scope of the processed data at any time and also about how they are used, and may withdraw the consent, except in certain cases where the data processing is continued on the basis of a legal obligation (in such cases, the Controller shall provide information to the data subject regarding the further processing of the data).
Data providers shall submit their data correctly.
If the informant does not provide his/her personal data, the information provider is obliged to obtain the consent of the data subject.
If the Controller transmits data to data processors or other third parties, the Controller keeps records of these. The data transfer note shall contain the addressee, the method, the date and the range of data transmitted.
Data processing of each activities of Controller are the followings:
Registration on the Website
Legal title of the data processing: consent of data subject by registering on the Website
Scope of processed data:
- Scope of mandatory data:
- Scope of optional data:
- address
- phone number
- date of birth
- gender
- professional CV
- foreign languages
- relevant professional qualification
- driving skills
- IT knowledge
- LinkedIn account
- facebook account
- results of the soft skill tests, quizzes done on the platform
- data generated during the use of the system (e.g. which jobs and trainings the users are interested in, or which job advertisers they contact etc.)
Purpose of data processing: use of the recruit services of Controller and the other services provided by the Website
Legal basis for data processing: consent, contract and the legitimate interest of the data controller
Data transfer: due to the nature of the service, employers registering on the Website may have access to shared data in a special case
Deadline of deletion of data: After deleting the registration from the Website, the provided data shall be deleted within 10 business days
Deadline for data deletion from backups: 90 days after the user deletes its account. During this time, only data storage exists; no data of the user will be processed.
Possible consequence of failure to deliver data: Unavailability of recruit services and other Website features
Invoicing
Legal title of the data processing: complying with legal provisions
Scope of processed data: name, address
Purpose of data processing: complying with legal provisions
Data processor: Treuhandbüro FIDEMEDIA GmbH
Deadline of deletion of data: 9 years after issuing the invoice
Possible consequence of failure to deliver data: the data providing may not be denied due to legal obligation of Controller, it would cause the failure of providing any services of the Controller
Facebook page
Legal title of the data processing: consent of data subject (by liking the Facebook page of Controller)
Scope of processed data: data provided via messages; data used by Facebook cookies
Purpose of data processing: to provide more information about open vacancies, e-learning materials and other news about the Controller
Data processor: Meta Platform Ireland Limited (in respect of the Facebook cookies)
Deadline for deletion of data: unilaterally by the Controller, if the message has a content that creates a legal obligation to the Controller, or if it considers that it may be necessary in the future to enforce or protect the rights of its own or third parties interest the data will be deleted after 5 years, otherwise within 30 days of receipt of the message; cookies are used and deleted in accordance with the current Facebook information page (https://www.facebook.com/policies/cookies/), the Data Processor does not have access to these data
Possible consequence of failure to deliver data: inability to access information
Google Analytics Cookies of the Website
Legal title of the data processing: consent of data subject
Applied cookies: Google Analytics cookies – sends anonymous IP address to Google Inc. containing only the tracking ID of the visitor
Scope of processed data: Google Analytics cookies: IP address of the visitor
Purpose of data processing: Google Analytics cookies: Improving the operation of a data management website
Data processor: Google Inc. (Mountain View, California, USA)
Deadline for deletion of data and further information: https://developers.google.com/analytics/devguides/collection/analyticsjs/cookie-usage
Possible consequence of failure to deliver data: endangering the proper functioning of the Website
Scope and activity of data processors
The Controller employs data processors for certain data processing operations. The data processors can not take a substantive decision regarding the data processing, they can only process the data obtained according to the Controller's instructions, they cannot use it for their own purposes and must store and retain personal data according to Controller’s instructions.
The Controller may use the following data processors:
- Treuhandbüro FIDEMEDIA GmbH
Rights of data subject
The data subject may request information about the processing of his or her personal data, as well as request the rectification, deletion, revocation, restriction and may object to the processing of such personal data, as well as has the right to data portability and to lodge a complaint with the supervisory authority:
- Right to request access to personal data: the right to know and to access the personal data processed about him or her
- Right to rectification: the right to request the rectification of inaccurate personal data
- Right to erasure ("right to be forgotten"): the right to request the deletion of personal data if certain conditions are met
- Right to restriction of processing: the right to request the restriction of data processing
- Right to data portability: the right to receive the personal data concerning him or her in a structured, commonly used and machine-readable format and to transmit those data to another controller without hindrance from the Controller
- Right to object: the right to object to the processing of personal data in certain cases
Supervisory authority
In case of violation of his or her rights, the data subject may lodge a complaint with the supervisory authority:
Modification of the Policy
The Controller reserves the right to unilaterally amend this Policy at any time. The amended Policy shall be disclosed to the data subject on the Website.
Miscellaneous
The data subject can find the detailed rules for data processing of the Controller and more information about data protection in this Policy.
In case of any questions related to the processing of data, the data subject may contact the Controller at the above contact details.
