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CANDIDATES PERSONAL DATA PROCESSING POLICY

1. GENERAL TERMS

1.1. SIA “IT Camp”, registration no. 40103908693, legal address: Kaivas street 50, k-2, dz. 24C, Riga, LV-1021 (hereinafter – the Company).

1.2. The purpose of this Clients Personal Data Processing Policy (hereinafter – the Policy) is to provide the data subject (identified or identifiable natural person, representatives, employees or contact persons of legal entities) as a client (hereinafter – the Client) with information about the processing of the Client’s personal data in connection with recruitment and related services, including the purposes of processing, categories of personal data, storage periods, data protection measures, and the Client’s rights in relation to such processing.

1.3. The Client’s personal data is processed in accordance with 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) (hereinafter – the Regulation), the applicable laws of the Republic of Latvia in the field of privacy and personal data protection, and this Policy.

1.4. Processing means any operation or set of operations performed on personal data, whether or not by automated means, such as collection, recording, organisation, structuring, storage, adaptation, alteration, use, disclosure, transmission, restriction, erasure or destruction.

1.5. The Company processes the Client’s personal data in order to provide recruitment and HR-related services, to communicate with the Client, to organise and manage the recruitment process, to fulfil contractual obligations and, where applicable, to facilitate the establishment of employment or commercial cooperation between the selected candidate and the Client, as the Company provides recruitment services in the course of its commercial activities.

1.6. The processing of the Client’s personal data is necessary to respect the legitimate interests of the Controller (the Company), which include communication with Clients, managing recruitment assignments, organising interviews between Clients and candidates and, where necessary, establishing, exercising or defending legal claims related to the recruitment process.

1.7. The Company undertakes to ensure the confidentiality of the Client’s personal data and to protect such data by using appropriate secure modern technology options, including secure data transmission technologies (such as SSL encryption) and other safeguards intended to prevent unauthorised access, disclosure, alteration, loss or other unlawful processing of personal data. Such measures are regularly reviewed and improved in accordance with applicable legal requirements.

1.8. The Company does not disclose or transfer the Client’s personal data to third parties except where such disclosure is necessary for the purposes set out in this Policy, is required for the provision of recruitment services, is based on the Client’s consent, is necessary for compliance with applicable legal obligations, or is otherwise permitted under applicable law.

1.9. As a general rule, the Client’s personal data is processed within the territory of the European Union and the European Economic Area. If, in exceptional cases, the Company transfers personal data outside the European Union or the European Economic Area, such transfer shall be carried out in accordance with the requirements of applicable data protection laws and subject to appropriate safeguards.

1.10. This Policy applies to the processing of personal data regardless of the form and/or medium in which the Client provides such data to the Company, including in person, by e-mail, via the Company’s website, in paper form, by telephone or otherwise.

2. CONTROLLER AND CONTROLLER CONTACT INFORMATION

2.1. The controller of personal data processing is the Company.

2.2. For matters related to the processing of personal data or possible personal data protection violations, the Client may contact the Company by telephone at +371 26884088 or by e-mail at info@itcamp.lv

3. WHAT DATA DOES THE COMPANY PROCESS AND FOR WHAT PURPOSE

3.1. Submission of service requests via website:Purpose: receiving and processing Client inquiries submitted via the Company’s website (e.g. contact form, request for recruitment services), initial communication with potential clients, preparation of offers and proposals.Legal basis: taking steps at the request of the data subject prior to entering into a contract and legitimate interest in responding to business inquiries. Important note: The provision of personal data is necessary to process the request. If the Client does not provide the required information, the Company may be unable to respond or provide the requested services.

3.2. Provision of recruitment services: Purpose: identifying Client needs, searching and selecting candidates, organising interviews, facilitating the hiring process. Legal basis: performance of a contract or taking steps prior to entering into a contract, legitimate interests (e.g. communication, service management, legal protection). Processed data: name, surname, position, contact details (email, phone), company information, communication records.

3.3. Business communication and relationship management: Purpose: maintaining cooperation, responding to inquiries, providing updates. Legal basis: legitimate interest (e.g. communication, service management, legal protection).

3.4. Compliance with legal obligations: Purpose: accounting, tax compliance, responding to authorities. Legal basis: legal obligation.

3.5. Marketing and future cooperation: Purpose: informing about services, maintaining client databases. Legal basis: consent, legitimate interest (e.g. communication, service management, legal protection).

4. DATA CATEGORIES

The Company may process identification data, contact information, company-related data, communication content (emails, calls), contractual information, billing and payment data.

Processed data may include: name and surname, company name, position, email address, telephone number, content of the inquiry (including hiring needs, budgets, etc.), any other information voluntarily provided.

Additional data collected automatically: IP address, date and time of submission, browser and device information.

5. DATA SOURCES

Personal data may be obtained via the Company’s website (contact forms, service request forms, or other online submission tools), directly from the Client, during communication, from publicly available sources (e.g., LinkedIn), from third parties (within legal limits).

6. DATA SHARING

Personal data of the Client (e.g. contact details, company information) may be shared with candidates where necessary for the recruitment process, IT service providers, legal and financial advisors, public authorities when required by law. The Company ensures that only necessary data is shared.

7. DATA RETENTION

Personal data obtained via website inquiries is stored until the request is processed, and up to 1 year thereafter, unless further cooperation is established.