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Privacy Policy

Privacy Policy for recruitment

The service for handling recruitments and simplifying the hiring process (the "Service") is managed and controlled by Smilegate Barcelona S.L.("Controller" “we” “us” etc.). We are a controller of the information that is collected during the recruitment process, and Career site and the associated application related to our Service are provided by Teamtailor AB on our behalf.

It is important that the persons using the Service ("Users” “applicant” “you”) feel safe with, and are informed about, how we handle User's personal data in the recruitment process. We respect your privacy and are committed to protecting your personal data. We process, manage, use, and protect User's Personal Data in accordance with this Privacy Policy ("Privacy Policy").


< Basic information about the processing of Users’ personal data >

Identity of the Controller

Smilegate Barcelona, S.L. Avenida Diagonal 409, Planta 4ª, Modulo A y B, 08008 Barcelona (Spain),


Managing and facilitating recruitment of employees to our business

Legal basis for the processing

Compliance with a legal obligation, Necessary for the purposes of legitimate interest

Categories of processed data

Only data that is relevant for the recruitment process is collected and processed (see Section 2 below).

Sources of data subject to processing

You, other employees, third-party websites such as Facebook or LinkedIn, Recruitment agencies and Personnel service providers.


Right of access, of rectification, to erase, to object, to restrict processing, to data portability and to complain to the supervisory authority.


For further information, please see below.


1. General

We are the controller in accordance with current privacy legislations. The Users’ personal data is processed with the purpose of managing and facilitating recruitment of employees to our business.


2. Collection of personal data

We are responsible for the processing of the personal data that the Users contribute to the Service, or for the personal data that we in other ways collect with regards to the Service.

When and how we collect personal data

•      to make an application through the Service or otherwise, adding personal data about themselves either personally or by using a third-party source such as Facebook or LinkedIn; and

•      to use the Service to connect with our staff, adding personal data about themselves either personally or by using a third-party source such as Facebook or LinkedIn.

•      to provide identifiable data in the chat (provided through the website that uses the Service) and such data is of relevance to the application procedure;

We collect data from third parties, such as Facebook, Linkedin and through other public sources. This is referred to as “Sourcing” and is manually performed by our employees or automatically in the Service.

In some cases, existing employees can make recommendations about potential applicants. Such employees will add personal data about such potential applicants. In the cases where this is made, the potential applicant is considered a User in the context of this Privacy Policy and will be informed about the processing.

We may also recruit employees via recruiting agencies or by receiving direct application from applicants, such as by email. In case we recruit employees via recruiting agencies, the recruiting agencies provide us with your personal data you include in the application form to help us to evaluate your suitability for the applicable job position.

To the extent necessary for the job you apply for, we may perform (where applicable) a background check at the end of the application process, via personnel service providers.

The types of personal data collected and processed

We may collect the following types of information relating to you through the Service:

•      names, e-mails, pictures and videos, information from Facebook and LinkedIn-accounts, answers to questions asked through the recruiting, titles, education, information on work experience, CV, cover letter, (where applicable) information required by applicable law and other information that the User or others have provided through the Service. Only data that is relevant for the recruitment process is collected and processed.

We may also collect the following information automatically when you visit our website:

•      connection record (IP address, dates, device type etc.)

Purpose and lawfulness of processing

The purpose of the collecting and processing of personal data is to manage recruiting. The lawfulness of the processing of personal data is our legitimate interest to simplify and facilitate recruitment. We also process your personal data for compliance with legal obligations that apply to us and to establish, exercise or defend legal claims.

Personal data that is processed with the purpose of aggregated analysis or market research is always made unidentifiable. Such personal data cannot be used to identify a certain User. Thus, such data is not considered personal data.

The consent of the data subject

The User consents to the processing of personal data for the purpose of Controller’s handling recruiting. The User consents that personal data is collected through the Service, when Users;

a)     make an application through the Service, adding personal data about themselves either personally or by using a third-party source as Facebook or LinkedIn, and that Controller may use external sourcing-tools to add additional information; and

b)     when they use the Service to connect to Controller’s recruitment department, adding personal data about themselves either personally or by using a third-party source such as Facebook or LinkedIn.

The User also consents to the Controller collecting publicly available information about the User and compiling them for use in handling recruitment.

The User consents to the processing of personal data according to the below sections Storage and transfer and How long the personal data will be processed.

The User has the right to withdraw his or her consent at any time, by contacting Controller using the contact details listed under section 9. Exercising this right may however, mean that the User can not apply for a specific job or otherwise use the Service.

If you agree to email notification for job opportunities, you may withdraw your consent at any time by signing in to Career site and clicking the unsubscribe button. Alternatively, you can request unsubscribe using the contact details in section 9.

Storage and transfers

Your data will be stored in Spain where our servers are located. Your data may also be processed in the Republic of Korea where Smilegate headquarters is located, or in other locations where our third party service providers are located.

In the event that we transfer your personal data to another country and where the country or territory in question does not maintain adequate data protection standards, we want to make sure that your data are stored and transferred in a way which is secure. We will therefore only transfer data outside of the European Economic Area or EEA (i.e. the Member States of the European Union, together with Norway, Iceland and Liechtenstein) where it is compliant with data protection legislation and the means of transfer provides adequate safeguards in relation to your data.

How long the personal data will be processed

If a User does not object, in writing, to the processing of their personal data, the personal data will be stored and processed by us as long as we deem it necessary with regards to the purposes stated above.

In general, we will retain your personal data for a one (1) year period if not converted into an employment relationship. Once we have determined that we no longer need to hold your personal data, we will delete it from our systems within 30 days.

Note that an applicant (User) may be considered for potential future recruitment and for this purpose we may store Users’ personal data until they are no longer needed for potential recruitment. If you as a User wish not to have your personal data processed for this purpose (future recruitment) please contact us using the contact details in section 9.


3. Users’ rights

You have various rights in relation to the data which we hold about you. To get in touch with us about any of your rights under applicable data protection laws, please use the contact details set out below. We will seek to deal with your request without undue delay, and in any event within any time limits provided for in applicable data protection law (subject to any extensions to which we are lawfully entitled). Please note that we may keep a record of your communications to help us resolve any issues which you raise.

Users have the right to request(access) information about the personal data that is processed by us, by notifying us in writing, using the contact details in section 9 below.

Users have the right to, if necessary, rectification of inaccurate personal data concerning that User, via a written request, using the contact details in section 9 below.

The User has the right to demand deletion(erase) or restriction of processing, and the right to object to processing based on legitimate interest under certain circumstances.

The User has the right to revoke any consent to processing that has been given by the User to Controller. Exercising this right may however, mean that the User can not apply for a specific job or otherwise use the Service.

The User has under certain circumstances a right to data portability, which means a right to get the personal data and transfer these to another controller as long as this does not negatively affect the rights and freedoms of others.

User has the right to lodge a complaint to the supervisory authority (i.e. the Spanish Data Protection Agency (AEPD), regarding the processing of personal data relating to him or her, if the User considers that the processing of personal data infringes the legal framework of privacy law.


4. Security

We prioritize personal data integrity and therefore work actively to ensure to ensure that User’s personal data are processed with the utmost care. We take measures that can be reasonably expected to make sure that the personal data of Users and others are processed safely and in accordance with this Privacy Policy and the GDPR.

However, transfers of information over the internet and mobile networks may involve some risks, so all transfers are made at the own risk of the person transferring the data. It is important that Users also take responsibility to ensure that their data is protected. It is the responsibility of the User to keep their login information secret.


5. Transfer of personal data to third party

We will not sell or otherwise transfer Users’ personal data to third parties.

We may transfer Users’ personal data to;

•      Smilegate group entities

•      our contractors and sub-contractors, acting as our Processors and Sub-Processors in accordance with our instructions, for the provision of the Service;

•      authorities or legal advisors in case criminal or improper behaviour is suspected; and

•      authorities, legal advisors or other actors, if required by us according to law or authority’s injunction.

We will only transfer Users’ personal data to third parties that we have confidence in. We carefully choose partners to ensure that the User’s personal data is processed in accordance to current privacy legislations. We cooperate with the following categories of processors of personal data; Teamtailor, who supplies the Service, server and hosting companies, e-mail reference companies, video processing companies, information-sourcing companies, analytical service companies, personnel service providers and other companies with regards to supplying the Service.


6. Aggregated data (non-identifiable personal data)

We may share aggregated data to third parties. The aggregated data has in such instances been compiled from information that has been collected through the Service and may, for example, consist of statistics of internet traffic or geographical location relating to the use of the Service. The aggregated data does not contain any information that can be used to identify individual persons and is thus not personal data.


7. Cookies

When Users use the Service, information about their usage may be stored as cookies. Cookies are passive text files that are stored in the internet browser on the User’s device, such as computer, mobile phone or tablet, when using the Service. We use cookies to improve the User’s usage of the Service and to gather information, such as statistics about the usage of the Service. This is done to secure, maintain and improve the Service. The information that is collected through the cookies may in some instances be personal data and is, in such instances, regulated by our Cookie Policy.

Users can at any time disable the use of cookies by changing the local settings of their devices. Disabling the use of cookies can affect the experience of the Service, for example disabling some functions in the Service.


8. Changes

We will review this Privacy Policy periodically, and reserve the right to modify and update it at any time. You acknowledge that we may make changes to this Privacy Policy and it is your responsibility to check back to this page( from time to time to review the Privacy Policy. We will also notify you of any relevant changes of this Privacy Policy in case it directly affects and applies to you. Changes to this Privacy Policy will come into effect immediately upon such changes being uploaded.


9. Contact

For questions, further information about our handling of personal data or for contact with us in other matters, please use the below stated contact details:

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