Privacy Policy
Last update: 23 October 2023
Thank you for your interest in this Privacy Policy! At Saffarni we are committed to protecting and respecting your privacy when you use our website at www.saffarni.com and our Services.
In principle, we will only use your personal data in accordance with applicable data protection laws, in particular Austria`s Data Protection Act ("DPA"), the EU`s General Data Protection Regulation (“GDPR”), and only as described in this Privacy Policy.
What is Personal Data?
Personal data is any information relating to personal or material circumstances that relates to an identified or identifiable individual. This includes, for example, your name, date of birth, e-mail address, postal address, or telephone number as well as online identifiers such as your IP address. In contrast, information of a general nature that cannot be used to determine your identity is not personal data. This includes, for example, the number of users of a website.
What is Special Category Data?
Special category data is Personal Data that needs more protection because it is sensitive. This includes Personal Data revealing racial or ethnic origin, political opinions, religious or philosophical beliefs, trade union membership, genetic data, biometric data. As well as, data concerning health, a person’s sex life; and a person’s sexual orientation. In order to lawfully process Special Category Data, it is necessary to consent to the processing.
Responsible for data processing
Responsible for data processing is Saffarni e.U. of Karolinengasse 24/6, 1040 Wien (“Saffarni”, “we”, “us”, or “our”). If you have any questions or if you wish to exercise your rights, please contact us using office@saffarni.com or write to us at the above address.
General information on data processing
a) The legal bases of processing
All personal data that we obtain from you via the website will be processed for the purposes described in more detail below. This is done within the framework of the DPA and the GDPR or with your consent. In particular, we process personal data only when processing is permitted and if:
● you have given your consent,
● the data is necessary for the fulfillment of a contract / pre-contractual measures,
● the data is necessary for the fulfillment of a legal obligation or
● the data is necessary to protect the legitimate interests of our company, provided that your interests are not overridden.
b) Your data subject rights
The following rights are available to you as a data subject:
● the right to information,
● the right to rectification,
● the right to erasure,
● the right to restriction of data processing,
● the right to data portability,
● the right to object to data processing,
● the right to revoke any consent you have given, and
● the right to lodge a complaint with the competent supervisory authority.
Please contact us at any time with questions and suggestions regarding data protection and/or to enforce your rights.
c) Exercising your rights
If you wish to access your personal data or exercise any of the rights listed above, you should apply in writing, providing evidence of your identity. Any communication from us in relation to your rights as detailed above will be provided free of charge. However, in case of requests that are manifestly unfounded or excessive, in particular because of their repetitive character, we may charge a reasonable fee taking into account the administrative costs of providing the information or communication or taking the action requested; or refuse to act on the request.
d) Updating your information
If you believe that the information we hold about you is inaccurate or that we are no longer entitled to use it and want to request its rectification, deletion, or object to its processing, please contact us.
e) The competent supervisory authority
The supervisory authority in Austria is: The Austrian Data Protection Authority, Barichgasse 40 - 42, 1030 Vienna, Austria. (www.dsb.gv.at). If you believe that the processing of your personal data is not lawful, you can lodge a complaint with a data protection supervisory authority. We would, however, appreciate the chance to deal with your concerns before you approach any supervisory authority.
f) Storage and retention of your data
We process and store your personal data using the services of Amazon (AWS Cloud) (410 Terry Ave N, Seattle 98109, WA and Marcel-Breuer-Straße 12, 80807 München, Germany) only for the period of time required to achieve the respective processing purpose or for as long as a legal retention period (in particular commercial and tax law) exists. Once the purpose has been achieved or the retention period has expired, the corresponding data is routinely deleted.
g) Security
We use State-of-the-art internet technologies to ensure the security of your data. For secure storage of your data, the systems are protected by firewalls that prevent unauthorized access from outside. In addition, technical and organizational security measures are used to protect the personal data you have provided against accidental or intentional manipulation, loss, destruction, or access by unauthorized persons.
Processing of Automatically Collected Data
a) Hosting
To provide our website, we use the services of Domainfactory GmbH (Neuturmstrasse 5, 80331 Munich, Germany) who process the below-mentioned data and all data to be processed in connection with the operation of our website on our behalf. The legal basis for the data processing is our legitimate interest in providing our website.
b) Collection of access data and log files
We also collect data on every access to our website. The access data includes the name of the website accessed, file, date and time of access, amount of data transferred, notification of successful access, browser type and version, the user's operating system, referrer URL (the previously visited page), IP address and the requesting provider.
Log file information is stored for security reasons (e.g., for the clarification of abuse or fraud) for a maximum of 7 days and then deleted. Data whose further storage is necessary for evidentiary purposes is exempt from deletion until the respective incident is finally clarified. The legal basis for the data processing is our legitimate interest in providing an appealing website.
c) Content Management System
We also use the Content Management System (CMS) of Duda, Inc. (577 College Ave, Palo Alto, California, 94306, United States) to publish and maintain the created and edited content and texts on our website. This means that all content and texts submitted to our website are transferred to Wix .The legal basis for this processing is our legitimate interest.
d) Use of cookies
We use so-called cookies on our web site. Cookies are small text files that are stored on your respective device (PC, smartphone, tablet, etc.) and saved by your browser. For further information please refer to our Cookie Policy. The legal basis for the use of cookies is your consent as well as our legitimate interest.
Data processing when you submit it to our website and when you use our services
When you contact us through our website or use our services, some data is collected and processed by us or on our behalf by our selected third-party providers.
a) Contacting us
If you contact us, we process the following data from you for the purpose of processing and handling your request: first name, last name, e-mail address, and, if applicable, other information if you have provided it, and your message. The legal basis for the data processing is our obligation to fulfill the contract and/or to fulfill our pre-contractual obligations and/or our overriding legitimate interest in processing your request.
We also offer to contact us via the messaging services of WhatsApp (Meta Platforms Ireland Limited, 4 Grand Canal Square, Grand Canal Harbour, Dublin 2, Ireland). If you contact us via WhatsApp we store and use the mobile phone number, you use and - if provided - your first and last name in accordance with the provision of a contractual or pre-contractual measure to process and respond to your request.
b) Data management and support
For optimal support, we use first name, last name, e-mail address, and the data related to your contract with us. Your data will be stored on our website and or our customer relationship management and applicant tracking system provided by Ankaadia GmbH (Clara-Schumann-Str. 3, 61440 Oberursel, Germany). This data processing is based on our legitimate interest in providing our service.
c) Contract processing when using our services
i) Candidate Data
We need to process certain information about you in order to provide you with optimal, tailored employment opportunities. We only ask for information that we believe will actually help us to serve you better, such as your name, age, contact details, education details, employment history, emergency contacts, residency status, financial information, salary information. Where appropriate and permitted by laws and regulations, we will also collect information about your health, diversity information or details of any criminal record.
ii) Potential Candidate Data
If we believe that you may be interested in our services or that they may be of benefit to you, we will collect and use this information about you to evaluate how we might help you and contact you. We also collect certain information about you when you access our website or click on a link in an email we send.
iii) Client Data
If you are a client, we may need to collect and use information about you or individuals within your organization in order to provide or offer services to you, such as:
● search for candidates who are a good match for you or
● providing a managed service provider programme to you (or assisting another organization to do so),
● providing recruitment process outsourcing services to you (or assisting another organization to do so),
● providing services to your employees such as training, and/or
● notifying you of content published by us that is likely to be important and useful to you.
In all cases, the legal basis for the data processing is the fulfillment of our contractual obligations and, in individual cases, the fulfillment of our legal obligations as well as your Consent.
Some of the Personal Data you provide may be considered “special” or “sensitive”, for example your racial or ethnic origins, sexual orientation, and religious beliefs. By choosing to provide this data, you consent to our processing of that data.
Where any Personal Data relates to a third party, you represent and warrant that the Personal Data is up-to-date, complete, and accurate and that you have obtained the third party’s prior consent for our collection, use and disclosure of their Personal Data for the Purposes. You agree that you shall promptly provide us with written evidence of such consent upon demand by us.
You may withdraw your consent and request us to stop using and/or disclosing your Personal Data for any or all of the Purposes by submitting your request to us.
d) Application Form
If you apply for a role using our application form, we process the information we receive from you as part of the application process, e.g., through your letter of application, CV, references, correspondence, telephone, or verbal details. In addition to your contact details, information about your education, qualifications, work experience and skills is particularly relevant to us. The legal basis for processing data during the application process is the initiation of a contract and, if you have given your consent, for example by sending us information that is not necessary for the application process, it is your consent. The legal basis for data processing after a rejection is our legitimate interest.
e) Administration, financial accounting, office organization, contact management
We process data in the context of administrative tasks as well as organization of our operations, financial accounting and compliance with legal obligations, such as archiving. In this regard, we process the same data that we process in the course of providing our contractual services (point c) and b) above). The purpose and our interest in the processing lies in the administration, financial accounting, office organization, archiving of data, i.e., tasks that serve the maintenance of our business activities, performance of our tasks and provision of our services.
Furthermore, based on our business interests, we store information on suppliers, and other business partners, e.g., for the purpose of contacting them at a later date. This data, most of which is company-related, is generally stored permanently.
How will your personal data be used?
a) Candidate Data
The main reason we use your personal data is to help you find employment or other suitable employment. The more information we have about you, your skills, and your goals, the better we can tailor our service to you. Where appropriate and permitted by laws and regulations, we will also use your personal data to advertise our services to you, profiling, and diversity monitoring, etc. We may ask you to provide us with more information about yourself. Where appropriate, we will ask for your consent to do some of these things.
b) Potential Candidates
We use information about potential candidates to determine whether you are interested in or may benefit from our services. If this is the case, we will assess whether and how we could help you. If we think we can help you, we will use your information to contact you about our services.
c) Client Data
The main reason we use information about clients is to be able to introduce ourselves to you and to ensure that the contractual arrangements between us can be properly implemented to ensure a smooth business relationship. This will include:
● identifying candidates that we believe are a good fit for you or your organization,
● providing services to you (or supporting another organization in doing so),
● providing services to your staff.
The more information we have, the better we can tailor our service to you.
Sharing of personal data
We will not disclose or otherwise distribute your personal data to third parties unless this:
● is necessary for the performance of our services,
● you have consented to the disclosure,
● or the disclosure of data is permitted by relevant legal provisions.
a) Candidate Data
We will share your personal data with different recipients in different ways and for different reasons. First and foremost, we will share your information with potential employers to increase your chances of getting the job you want.
b) Potential Candidate Data
If you have been identified as a potential candidate, we may share your information with all group companies and related third parties, such as service providers we use, in order to contact you about our services.
c) Client Data
We share your data for the following purposes:
● primarily to ensure that we can provide you with access to an appropriate pool for candidates,
● to provide (or assist another organization to provide) services to you and/or
● to provide services to your employees.
Unless you have indicated otherwise, we will share your information with any of our group companies as well as related third parties, such as service providers we use, in order to better achieve these objectives.
However, we are entitled to outsource the processing of your personal data in whole or in part to external service providers acting as processors within the framework of the DPA and GDPR. External service providers support us, for example, in the technical operation and support of the website, data management, the provision and performance of services, marketing, as well as the implementation and fulfillment of reporting obligations.
The service providers commissioned by us however will process your data exclusively in accordance with our instructions and we remain in accordance with the DPA and GDPR responsible for the protection of your data. Doing so we always make sure that service providers commissioned by us are carefully selected, follow strict contractual regulations, technical and organizational measures, and additional controls by us.
We may also disclose Personal Data to third parties if we are legally obliged to do so e.g., by court order or if this is necessary to support criminal or legal investigations or other legal investigations or proceedings at home or abroad or to fulfill our legitimate interests.
Social Media
General
We are present on social media on the basis of our legitimate interest (currently, Facebook, and Instagram (Meta Platforms, Inc., 1601 Willow Road Menlo Park California 94025 und 4 Grand Canal Square Grand Canal Harbour Dublin 2 Ireland)). If you contact or connect with us via social media, we and the relevant social media website are jointly responsible for the processing of your data and enter into a so-called joint controller agreement. The Personal Data collected when contacting us is to handle your request and the bases are both your consent and our legitimate interest.
Market research and advertising
In addition, your data may be processed for market research and advertising purposes. For example, usage profiles can be created from your usage behavior and the resulting interests. This allows, for example, advertisements to be placed within and outside the websites that presumably correspond to your interests. The legal basis is our legitimate interest and you can find more information in our Cookie Policy.
When you visit our profiles and interact with us and others
When you visit our social media profiles, we, as the operator of the profile, process your actions and interactions with our profile (e.g., the content of your messages, enquiries, posts or comments that you send to us or leave on our profile or when you like or share our posts) as well as your publicly viewable profile data (e.g., your name and profile picture). Which Personal Data from your profile is publicly viewable depends on your profile settings, which you can adjust yourself in the settings of your social media account. The legal basis is our legitimate interest and your consent.
Analytics
For business reasons, we analyze the data we have on business transactions, contracts, enquiries, browsing behavior etc. The analyses serve us alone and are not disclosed externally and processed using anonymous analyses with summarized and or anonymized values. For this purpose we use Google Analytics by Google (1600 Amphitheatre Parkway Mountain View, CA 94043, USA and Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland) and Snowpolw Analytics by Snowplow Analytics Limited (17 Bevis Marks, Floor 6, London, EC3A 7LN, United Kingdom) and you can find more information in our Cookie Policy. The legal basis is our legitimate interest and your consent.
Automated decision-making
Automated decision-making including profiling does not take place.
Direct marketing in the context of a customer relationship
Insofar as you have also given us your separate consent to process your data for consulting, marketing, and advertising purposes, we are entitled to contact you for these purposes via the communication channels you have given your consent to.
Personal data and children
Our services are aimed at people aged 18 and over. We will not knowingly collect, use, or disclose personal data from minors under the age of 18 without first obtaining consent from a legal guardian through direct offline contact.
Does this policy change?
We may update our Privacy Policy from time to time. This might be for a number of reasons, such as to reflect a change in the law or to accommodate a change in our business practices and the way we use cookies. We recommend that you check here periodically for any changes to our Privacy Policy. This Privacy Policy was last updated on 23. October 2023.
Who should I contact for more information?
If you have any questions about this policy or about our data protection practices in general, you can reach us via email using office@saffarni.com, or write to us at the above address.
