Privacy & Cookie Notice

Privacy & Cookie Notice for Talent Loom

Introduction

In Talent Loom (hereinafter referred to as “Talent Loom”, “our Company”, “we”, “us”, “our”) we
respect the privacy of all individuals and we are committed to the security and protection of the
personal information of the visitors to our Website (“Users”).

The present Privacy and Cookie Notice has been prepared based on the provisions of the
applicable data protection legislation, including Art. 13/14 of Regulation (EU) 2016/679 (“General Data
Protection Regulation”) and the Greek Law 4624/2019. It applies to and concerns any personal data that
might be collected and processed by Talent Loom, whenever a User interacts with the website, including
among others when they use the Website Contact form or when they upload their CV. It contains a
description of all personal data processed by Talent Loom, the legal basis for such processes, the
purposes for which we use the personal data collected, to whom we may disclose them and the relevant
rights you have as a data subject under the applicable data protection legislation.
The present Policy forms an integral part of the Terms and Conditions of Use and of any the
other policies adopted by the Company. This Policy relates solely to this Website, if not stated otherwise
within this document and does not apply to your use of any of our other services which may be subject
to different privacy noticies.

We will always keep your personal data safe and comply with all applicable data protection
provisions as each time in force according to the legislative and regulatory framework. We shall not at
any time, receive from you more personal data than those that are necessary for each purpose for
which they are collected and we will not use or share your information with anyone except as described
in this Privacy and Cookie Notice.

Amendments to the present Notice

We may update the present Notice at our discretion, from time to time, for example to comply
with new obligations imposed by the applicable legislation or regulations, and therefore we ask you to
check periodically for the latest version of the Notice, as indicated in the “Last revised” date at the
bottom of the page.  If there will be any significant changes made to the use of your Personal
Information (as defined below) in a manner different from that stated at the time of collection, we will
notify you by posting a notice on our Website or by sending you an e-mail and whenever it is required as
per the data protection legislation we will ask for your consent.

The Data Controller:

The Data Controller for the collection, processing and use of your personal data within the meaning
of the applicable legal and regulatory framework is:
The Company under the trade name: TALENT LOOM L.P., having its registered office in 24A Ipirou
str., Kifisia, Attica Greece, with General Electronic Commercial Registry No. 177698701000 and Tax
Identification Number: 802508388- Tax Office of Kifisia.

Personal Data We May Collect About You:

The term “personal data” used in the present notice has the meaning defined under GDPR and is
any information related to an identified or identifiable natural person ("data subject"); an identifiable
natural person is one who can be identified, directly or indirectly. Such data do not include information
that is anonymous.
We may collect and process various types of personal data about you, when you visit, browse
through and use our website, as described in this Notice. More specifically, we might collect the
following categories of personal data:

• Data collected directly by you:

Personal data such as your name, surname, contact details (e-mail address or phone number) healthcare
profession that you are interested in, any information that you provide in your CV/resume, cover letter
and/or the documents you upload or provide to us by any other means or other personal information
about you that might be contained in communications you send to us (such as email content) for
inquiries, complaints and other requests through our channels of communication (using our website
contact form or by sending us an email).
We use this information in order to offer you job opportunities, including matching and proposing you
to clients, interviews, assessing your suitability for the position you are applying for as part of the
application process assisting you with the hiring or relocation process and provide you with offers for
potential other positions that may be of interest for you. The Users who send us or upload their CV on
our Website, acknowledge that it will be included in our CV database and will be disclosed to potential
employers only having been prior informed about this and the relevant consent has been obtained.
Users are not obligated to share any personal information with us but if they do not, we might not be
able to provide with our services.

• Data collected automatically using cookies and other tracking technologies:

This data includes personal data collected automatically by the Website i.e. usage data relating to User
access to the Website which constitutes information collected as transmitted by the browser on our
server e.g. the IP addresses of your browser software and version, your operating system, the reference
source, the duration of your visit, device information, access data, device ID, time and duration of
connection, frequency of use, means of connection, etc. and other information of this kind. Collecting
this information enables us to better understand the visitors who come to our Website, where they
come from, and what content on our Website is of interest to them.  This data is collected solely for the
purpose of serving the correct and fast operation of the Website provided through it and to improve its
functions as well as to guarantee its stability and security. We use this information for our internal
analytics purposes and to improve the quality and relevance of our Website to our visitors.

For more details on data collected automatically, through the use of cookies, – or other similar tracking
technologies – by us or third party services used by the Website, please refer to Article 10 below.

• Data collected by third parties

We receive some of the above-mentioned technical data from analytics providers such as Google.

• Aggregated data

We may process aggregated data, such as statistical or demographic data, for any purpose. While
aggregated data may be derived from your personal data, these are not considered personal data as
such data does not directly or indirectly reveal your identity (e.g. we may aggregate your usage data to
calculate the percentage of users accessing a specific website feature); however, if we combine
aggregated data with your personal data so that it can directly or indirectly identify you, we shall treat
the combined data as personal data which will be used in accordance with this notice.
We do not knowingly collect any special categories of personal data about you through our website, e.g.
information about your health, race or ethnicity, religious or philosophical beliefs, sex life, etc.

For what purposes we collect information about you and on what legal basis?

Whenever we process personal data, we always do so on a lawful legal basis for such processing. We
may process Personal Data relating to our Users solely if one of the following applies:

• If processing is necessary for our legitimate interests (or interests of a third party) that are not
  overridden by your interests and fundamental rights, including the operation, maintenance,
  security and the improvement of our Website and of the users’ experience, the performance of
  usage data analysis, the processing of your inquiries or the establishment, exercising or
  defending of legal claims. In these cases, we will look after your information at all times in a way
  that is proportionate and respects your privacy rights and you have a right to object to
  processing as explained in “Your Rights” section below;
• If use of your Personal Information is necessary for the performance of an agreement with the
  User and/or for any pre-contractual obligations thereof;
• If processing is necessary for compliance with a legal or regulatory obligation to which we are
  subject (e.g. the disclosure of information to law enforcement or tax authorities).
• If processing is based on users’ prior explicit consent for one or more specific purposes, e.g.
  allowing Talent Loom to provide you with offers for potential other positions that may be of
  interest for you, to disclose your CV to employers, or sending our Newsletter to Users about
  products, services they may be interested in.

We do not use automated decision-making without human intervention, including profiling, in a way
that produces legal effects concerning you or otherwise significantly affects you.

In any case, we will gladly help to clarify the specific legal basis that applies to the processing, so if you
would like to find out more about the legal basis for which we process Personal Information please
contact us.

Talent Loom Newsletter

When you visit our Website you have the option to register in order to receive our Newsletter. By filling
out our form, you give us your explicit consent to process your e-mail for the purpose of periodically
sending you our newsletter that may contain news, updates, information about the services we provide
as well as information about events, participation in conferences etc.

To protect privacy rights and to ensure you have control over how we manage marketing activities with
you:

• we will take steps to limit marketing to a reasonable and proportionate level and only send you
  communications which we believe may be of interest to you;
• If you no longer wish to receive the Talent Loom Newsletter you can ask us to stop sending
  marketing emails to you, by following the ‘unsubscribe’ link you will find on all the email
  newsletters we send you. Alternatively, you can contact us at info@talent-loom.com. The
  withdrawal of consent does not affect the legality of the personal data processed up until the
  point of revocation.

With whom we might share personal information?

We may share personal data and information we collect about our users, in accordance to the
present Notice, with third parties in the context of the general operation and functioning of our Website
and always in a way that guarantees that your personal data and the information that we collect about
you is not subject to any unlawful processing, i.e. processed for purposes other than the following
purposes:

• With third-party subcontractors and/or our service providers who may provide on behalf of
  Talent Loom technical, operational and marketing services, such as but not limited to hosting,
  technical support, and newsletter delivery services, data analysis or other support services from
  time to time, strictly for the purpose of providing their services to us, appointed, if necessary, as
  our Data Processors. For the same purpose, if you are our service provider we may collect
  contact details and other information about you or your company or organization where you
  provide services to Talent Loom
• Users personal details might be shared with potentional employers for career opportunities
• With our consultants (including financial, legal and other consultants) within the context of our
  Company’s lawful operation.

• With special successors: In the event that Talent Loom undergoes a business transition such as a
  merger, joint venture, acquisition by another company or sale of the whole or part of the
  Company assets, including personal information may be transferred to the successor entity/ in case of such change. If material changes to Talent Loom privacy practices will occur as a result of
  the business transition, we will notify you and other users of the business transition.

• With anyone else only with the prior written consent of our Users unless other legal basis is
  provided by the applicable data protection legislation.

Furthermore, we will also respond to requests for personal data where required to do so by law, or
when we believe that disclosure is necessary to protect our rights and/or comply with a judicial
proceeding, court order, request from a regulator or any other legal process served on us.

Transfer of data outside of the European Economic Area (E.E.A.)

We process your personal data at our operating offices and in any other place where the parties
involved in the processing, such as our subcontractors, are located. As a result, depending on the User's
location, data transfers may involve transferring of User's Data to a country other than their own. If such
transfer takes place to a third-country outside of the EU/EEA area in the context of and for the needs of
the above-mentioned purposes, and the third country does not provide an adequate level of security of
the personal data, the personal data will be transferred to that country only if the protection of data is
guaranteed by a data transfer agreement based on Standard Contractual Clauses or by any other
condition explicitly provided by European or local law.

Retention time (How long do we keep your data?)

We will store your personal Information for as long as is reasonably necessary for the purposes for
which it was collected, as explained in this Privacy and Cookie Notice, or until a consent given by you
gets revoked and you request its deletion (if this happens earlier), unless we are required to retain data
for longer period of time for the performance of a legal regulatory, tax or accounting obligation or upon
order of an authority. If you provide consent allowing Talent Loom to provide you with offers for
potential other positions that may be of interest for you, your personal data will be stored for 24
months or until you withdraw your consent. Notwithstanding the previous sentence:

• personal data collected for purposes related to the performance of a contract between us and
  the User shall be retained until such contract has been fully performed or there are no pending
  related claims and legal.
• personal data collected for the purposes of our legitimate interests shall be retained as long as
  needed to fulfill such purposes.

Once the retention period expires, Personal Data shall be deleted. Therefore, the right to access, the
right to erasure, the right to rectification and the right to data portability cannot be enforced after
expiration of the retention period. Talent Loom may keep anonymized data – i.e. data that does not
allow you to be identified – for internal statistics purposes and for purposes to improve our recruitment
process.

Cookies

Our Website uses cookies. A cookie is a small amount of data file that is sent to a user’s browser from a
web server and stored on the user’s computer’s hard drive, in order to allow a website to recognize the
user when he returns to the website using the same computer and web browser, either for the duration
of his visit (a “session cookie”) or for repeat visits (a “persistent cookie”). The session cookies are stored
in the user’s device until log out, until the user leaves a webpage or until the software (web browser) is
disabled while the persistent cookies remain on the user’s device until deleted or once they reach a
defined expiration date. Other similar files (or tracking technologies and services) work in the same way
and we use the word ‘Cookie’ in this Policy to refer to all files that collect information in this way.

Cookies set by the owner of a website are called “first party cookies”. Cookies set by other parties are
called “third party cookies”. Third-Party Cookies, such as Google Analytics enable us to monitor and
analyze web traffic and can be used to keep track of User behavior and gain insights on the quality,
performance and/or effectiveness of our Website.
Strictly necessary cookies: are essential for the proper operation of the website, are used to help make
our website work efficiently and enable you to browse around our website and use its features;
Analytical/performance cookies used to analyze the way our website works and how we can improve
and optimize it e.g. for statistical audience measuring to estimate the number of unique visitors, to
detect the most preeminent search engine keywords that lead to a webpage or to track down website
navigation issues.
When certain types of cookies require your prior consent in order to be installed and used, you are
asked through a relevant banner displayed on the front page of the website. If you choose not to enable
or delete certain cookies, you will still be able to browse our website, but it will restrict some of the
functionality of our website.
We do not use automated decision-making without human intervention, including profiling in a way that
produces legal effects concerning you or otherwise significantly affects you.
Please see below the list of the First-Party and Third-Party Cookies we use and where you can find more
information about them or the options to disable them:

Source