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Portal (Clients) Privacy Policy

Please read the following carefully to understand how and why this Website uses your data in order to access and browse our website <https://www.castilleresources.com/> (“the Website”) and register an account in order to use our services.


Castille Resources Limited (C 36907) located at Case Leone, Pjazza Robert Sammut, Floriana, FRN 1200, (herein “we”, “us”, “our” or “Castille”)  are committed to protecting and respecting your privacy.


The purpose of this Privacy Policy (“the Policy”) is to set out the basis on which any personal data is processed by us and make you aware of how we will handle your personal data, our obligations in regard to processing your personal data responsibly as well as your data protection rights. It should be read in conjunction with Our Portal Terms and Conditions https://www.castilleresources.com/resources/client-portal-terms-and-conditions and Cookie Policy https://www.castilleresources.com/resources/ip-address-and-cookies-policy-for-clients


Please read the following carefully to understand our views and practices regarding your personal data and how we will treat it. These practices are relevant for when you:


  1. access, browse and use our Website, accessible at https://www.castilleresources.com
  2. avail yourself of the services which we have made available and provide (as updated from time to time) via the Website.

We process your data in an appropriate and lawful manner, in accordance with The Data Protection Act (Chapter 440 of the Laws of Malta) and the General Data Protection Regulation (Regulation (EU) 2016/679, herein “GDPR”) which will come into force on 25th May 2018.


For the purposes of these data protection laws, Castille Resources Limited is the data controller.


This Privacy Policy was last updated 29th May 2018


DATA PROTECTION CONTACT POINT


We have appointed a Data Protection Contact Point who can be contacted via the following address data@castilleresources.com You can address any comments, queries or complaints to this address with words ‘Data Protection Matter’ in the subject line.


INFORMATION WE COLLECT FROM YOU

We will collect and process the following data about you:


  1. Information You Give Us


  1. Account Information: In order to be able to use the Services offered on our Website, in particular to post job vacancies on our Website, you are required to login with your email address and password.


  1. Contact information: In order to be able to carry out the services which you have engaged us to provide to you, we need to process your personal data. This shall include details relating to a contact person within your organisation, such as your Human Resources manager, in order to be able to notify you of any potential prospective candidates for the vacancy which you have posted on our Website. Such contact information shall include name, surname, capacity within the organisation, work email and telephone number.


INFORMATION WE COLLECT ABOUT YOU


Whenever you visit our Website we will automatically collect the following information which is necessary in order for the Website to function properly and to allow you to login and make use of the services offered on our Website:


  1. Technical information: This includes the IP address used to connect your computer to the Internet, your login information, browser type and version, the full Uniform Resource Locators (URL), clickstream to, through and from our Site (including date and time) as well as other information regarding your experience on our Website such as page response times, download errors, length of visits to certain pages, page interaction information (such as scrolling, clicks, and mouse-overs) and methods used to browse away from the page.
  2. Location Information: We may receive information about your location. We may determine your location through your IP address and, when accessing the Website through a mobile device, by using the data that we collect from this device. This includes precise location information from GPS or information about the wireless networks or cell towers near your mobile device at the time of access.


  1. Visit and Search Information: With regards to your visits to the Website, we collect and process information about any postings which you may make on our website and the duration of any session during which you may be logged in to your account.


HOW WE USE YOUR INFORMATION


  1. Information you give to us. We shall use this information:


  1. To provide you with listing space on our Website in order for you to directly receive CVs for potential candidates;


  1. To inform you of any potential candidates who have applied for a vacancy which you may have posted on the Website;


  1. To forward the relevant details of potential candidates using the contact information you provide;


  1. To assist in setting up job interviews following the selection of potential candidates;


  1. To resolve any issues which you may have and provide support;


  1. Information we collect about you. We shall use this information:


  1. to ensure Website functionality allowing you to submit the details necessary for us to provide the Services you request;


  1. as part of our efforts to keep our site safe and secure; and


  1. to ensure that content displayed on the Website is presented in the most effective and user-friendly manner.
  1. Information We Receive from Other Sources


We will combine the information obtained from other sources with information you give to us and information which we collect from you. We will use this information and the combined information for the purposes described above.


LEGAL BASIS FOR PROCESSING


We shall only process your data insofar as this is necessary for us to be able to provide the services indicated above.


We may also process your personal data in order to comply with any legal obligation. This may include the exercise or defence of legal claims or in order to comply with an order of any court, tribunal or authority.


DISCLOSURE OF YOUR INFORMATION


In order for us to carry out the recruitment services provided on our Website we need to share any personal data which we may have in relation to the contact person within your organisation to the potential candidate.

We shall only provide the information which is necessary in order to provide this recruitment service.


We may also share your data with service providers and processors who are necessary for us to provide the services you request. These processors store and process your data on the basis of strict confidentiality and subject to the appropriate security measures and safeguards as described below.


YOUR OBLIGATIONS


In order to be able to provide the recruitment services offered via our Website, we shall need to transfer personal details relating to potential candidates for the job vacancy which you have posted on our Website. Upon receiving such personal data, you shall become the data controller and your own policies and data protection practices shall become applicable.


We shall not be responsible for ensuring that your data protection practices are compliance in accordance with applicable law. Once the personal data relating to candidates is transferred to you, you shall act as a data controller in your own right and you shall be fully responsible to ensure compliance with all applicable data protection legislation.


In cases where you receive personal details relating to potential candidates yourself, you are solely and exclusively responsible for ensuring that such personal data is processed in accordance with applicable law and your own privacy policies and practices shall apply. In cases where Castille solely provides space for you to post your listings on our Website and our recruiters are not engaged to pass CVs on to you, Castille shall not have access to personal data relating to candidates who send you their CVs and you shall be the sole data controller in such a scenario, to the exclusion of Castille.



 THIRD PARTY ACCESS TO YOUR PERSONAL DATA

We work closely with third parties in order to provide you the services you request on our Website. These third parties include recruitment software providers, cloud storage providers, analytics providers and search engine information providers.


We have processing agreements in place to ensure that these companies handle your personal data responsibly. Our software providers may also be located outside the EU, namely the United States. In this regard, our software providers have subscribed to the EU-U.S Privacy Shield policy. This joined initiative between the European Commission and the United States authorities ensures that companies which adhere to this policy ensure an adequate level of protection for data subjects’ right and freedoms. More information on how the Privacy Shield works can be accessed on : <http://ec.europa.eu/justice/data-protection/files/eu-us_privacy_shield_guide_en.pdf>


In order to remit payment pursuant to our Portal Terms and Conditions, the banking institution of your choice may access your personal data for payment processing and remittance of funds.


We may also disclose your data if we are under a duty to disclose or share your personal data to comply with any legal obligation, judgment or under an order from a court, tribunal or authority. We may also disclose your data to enforce our Terms of Use or to protect our rights, property or safety, that of our partners or other users of our website. This includes exchanging information with other companies and organisations for the purposes of fraud protection.


TRANSFERS OF DATA BETWEEN CASTILLE ENTITIES


Castille Resources Limited, Castille Staffing Limited Company Registration Number C46062)  having its registered address at Casa Leone, Pjazza Robert Sammut, Floriana) Sp. Z o.o. having its registered office in S.p.z.oo Business Link Lublin ul. Lipowa 4a 20-027 Lublin, entered into register of business entities of the National Court Register run by the District Court for the Capital City of Warsaw, XII Commercial Division of national Court Register under KRS number 0000654040, NIP 525689567, Regon 366128080 and Castille Mauritius office, 2nd Floor, NG Tower, Ebene Cyber City, Mauritius act as joint controllers of your data. All these Castille entities may process your personal data for the purposes indicated in this Privacy Policy, namely to provide you with the recruitment services you request and assist you in finding potential candidates. Any processing carried out by any of these entities is subject to the terms of this Privacy Policy and only the data which is necessary to provide the services you request is processed by these entities.

Castille Mauritius is located in the Mauritius and as such is outside the European Union. Any transfers of your personal data to Castille Mauritius  are carried out on the basis of standard contractual clauses which ensure that your data is transferred securely and in compliance with data protection legislation.

Castille Resources acts as a data representative of Castille Mauritius

You may address any issues, queries or concerns which you may have to Castille Resources by sending an email with ‘Data Protection’ in the subject line on the following address data@castilleresources.com


DATA SECURITY


We will ensure that appropriate security measures are taken against unlawful or unauthorised processing of personal data, and against the accidental loss of, or damage to, personal data. When the Website is accessed using Microsoft Internet Explorer versions 5.0 or higher, Secure Socket Layer (SSL) technology protects information using both server authentication and data encryption to ensure that personal information is safe and secure while in transit.


All data is stored in a secure server environment that uses a firewall and other advanced technology to protect against interference or unauthorised access. Usernames and passwords are issued to persons authorised to access the data who are bound by confidentiality not to disclose any data.


[Additional measures for transfers to Castille Mauritius]


No method of transmission of data is one hundred percent (100%) secure and absolute security cannot be guaranteed.


DATA STORAGE


We shall only store your data for as long as this is strictly necessary for the purposes for which it was collected. In any case, retention of data shall not exceed 5 years from the date of termination of your account on our Website, saving your rights to request erasure, rectification and restriction (as established in greater detail below). This period of retention enables us to use the data for the defence of possible future legal claims (taking into account the applicable prescription period at law). 


DATA MINIMISATION


Whenever and to the extent possible, we anonymise the data which we hold about you when it is no longer necessary to identify you from the data which we hold about you.

YOUR RIGHTS AS A DATA SUBJECT


You are entitled to exercise the following rights:


  1. Right to Access Information: You have the right to request information as to whether or not your personal data is being processed by us as well as information as to how and why it is processed. You may send an email to data@castilleresources.com requesting information as the personal data which we process. You shall receive one copy free of charge via email of the personal data which is undergoing processing. Any further copies of the information processed may incur a charge;


  1. Right to object: You may ask us not to process your personal data for marketing purposes and your data will no longer be processed for such purposes.
  2. Right to withdraw consent: You have the right to withdraw your consent to this Policy, and the processing practices described herein, at any time by sending an email to data@castilleresources.com .This will not however affect the lawfulness of processing which we carried out on the basis of such consent before its withdrawal.
  3. Right to rectification: You have the right to obtain rectification of any inaccurate personal data about you that we have processed, update any data which is out-of-date and the right to have incomplete personal data completed, including by means of a supplementary statement.
  4. Right to erasure: You have the right to obtain the erasure of personal data we have concerning you when your personal data is no longer required, where:
  • You withdraw your consent to us processing your personal data;
  • Your personal data no longer needs to be processed;
  • Your personal data has been unlawfully processed;


  1. Right to Restriction of Processing: You have the right to restrict our processing activities where:
  • you contest the accuracy of this personal data, for a period enabling Us to verify the accuracy of the same personal data;
  • Our processing is deemed unlawful, and you oppose the erasure of your personal data and request restriction of its use instead;
  • We no longer need your personal data for the purposes stated in this Policy, but you require it for the establishment, exercise or defence of legal claims;
  • You have objected to our processing pending the verification whether the legitimate grounds of our processing activities overrode those pertaining to you;


  1. Right of Data Portability: As from 25th May 2018, you shall have the right to receive your personal data in a structured and machine-readable format and transmit this data to another controller.


COOKIES


Our Website uses cookies to distinguish you from other users of our Website. This helps ensure that we provide you with a good experience when you browse our Website and also allows us to improve our Website. For detailed information on the cookies we use and the purposes for which we use them see our Cookie Policy accessible at: https://www.castilleresources.com/resources/ip-address-and-cookies-policy-for-clients


In order for us to be able to provide you with the best possible experience and ensure that we provide our services in the most efficient and effective way possible, we would need to process your data for additional purposes for which we require your consent.


You may tick the box next to any, all or none of the purposes listed in this section. If you choose not to consent to any one of the purposes listed here or none at all, we will still be able to provide recruitment services however, we may not be able to provide you the full range of services which we offer and it may affect the efficiency with which we provide you possible job opportunities.


ADDITIONAL PURPOSES FOR PROCESSING


1. Information you give to us

  • To provide you with information about the additional services that we offer. When you have registered an account we shall contract you by email with information about such services.


  • To notify you about any changes to the Website, and/or the services we provide;


  • To generate reports for statistical purposes;


  •  To inform you of lectures and courses which we offer that may be of interest to you.


2. Information we collect from you


  • To administer our Website and for internal operations, including troubleshooting, data analysis, testing, research, statistical and survey purposes;



  • To measure or understand the effectiveness of advertising we serve to you and others, and to deliver relevant advertising to you;



TRANSFERS OF DATA TO THIRD PARTIES


In order to process the data pursuant to the consent which you have provided above we shall share your personal data with the following service providers:


  1. advertising and advertising networks that require the data to select and serve relevant adverts to you and others. We do not disclose information about identifiable individuals to our advertisers, but we will provide them with aggregate information about our users. We may also use such aggregate information to help advertisers reached the kind of audience that they want to target;
  2. web analytics and search engine providers that assist us in the improvement and optimization of our Site (including in respect of e-mail delivery).


So as to improve the quality and overall user experience of the Website, we are using Google Analytics .



So as to improve the quality and overall user experience of the Website, we are using Google Analytics.

There is a Google Analytics Opt-Out browser add-on that you can download at https://tools.google.com/dlpage/gaoptout.

You may withdraw your consent given for any of the purposes listed above at any time. This does not affect the lawfulness of your personal data for these purposes prior to your withdrawal. You may send us an email on data@castilleresources.com indicating the purpose/s for processing in relation to which you are withdrawing your consent for us to process.



COMPLAINTS


We welcome any comments, complaints and queries in relation to data protection. As indicated above you may contact our Data Protection Contact Point at data@castilleresources.com and we shall try our best to deal with any issue or concern you may have.


If we fail to address your concerns you have the right to lodge a complaint with the Information and Data Protection Commissioner (“IDPC”) as the relevant national supervisory authority on data protection matters.


CHANGES TO THIS PRIVACY POLICY


Any changes we make to this Policy in the future will be posted on this page and if appropriate, notified to you via email.


Please check back frequently to see any updates or changed to this Policy.