At Catena Media (“Catena Media", "we", "us"), we process personal data about you ("you"). We make efforts to handle your personal data with care, keep it secure and comply with data protection laws.
Catena Media is engaged in performance marketing and lead generation online, with headquarters in Malta and subsidiaries in a number of other countries.
How this Policy Works
The purpose of this Policy is to explain when, why and how we process information which may relate to you ("personal data"). It also provides important information on your statutory rights. This Policy is not intended to override the terms of any contract you have with us, nor rights you might have under data protection laws.
• Depending on the purpose for which we use your personal data, the legal basis can be consent, legitimate interest or legal grounds.
• We keep your personal data for 24 months from latest active contact. To learn more, see section 7.
• You have the right to request at any time that we no longer keep your profile. Please see Section 7 and 8 on how to exercise that right.
1. Who is responsible for looking after your personal data?
Catena Operations Ltd having its registered address Quantum Place, Triq ix-Xatt, Ta´Xbiex, Gzira, Malta GZR 1052, is principally responsible for looking after your personal data (your Data Controller). Data Controller means the company that determines the means and purposes of processing of personal data.
You should be aware that although we are principally responsible for looking after your personal data, information may be held in databases which can be accessed by other companies. When accessing your personal data, all companies will comply with the standards set out in this Policy.
Catena Media is a group of companies with subsidiaries in several countries, for example in the European Union, Australia, Japan and the USA.
2. What personal data do we process?
We may process the following personal data about you when you submit in Lever or give information in other communication with us:
• Data of birth
• Nationality/citizenship/place of birth
• Email address
• Contact details
• Education details
• Employment history
• Marital status/children
• IP address
• Location data
• Website usage
• Referee and reference details
• Information on your interests and needs regarding future employment
• Personal preferences and opinions
• Information that you choose to tell us
Considering the sensitive nature of certain information, we kindly ask you not to provide us with sensitive personal data here, such as racial or ethnic origin, religious or other similar beliefs, and physical or mental health or details of any criminal convictions. If you decide to provide sensitive personal data, we need to obtain your explicit consent before we can use it. Explicit consent means that you have to explicitly and clearly tell us that you agree to us collecting and using this information.
3. What do we use your personal data for and when do we process your personal data?
Catena Media will collect information directly from you when you use our services.
We use your personal data to:
• contact you regarding vacancies, recruitment, networking, our own and partners´ events or training related to recruitment and employment with Catena Media.
• send you emails relating to recruitment and more generally, employment with Catena Media.
• assess you, create scorecards and similar evaluations about you to see if vacancies we have may be suitable for you.
• allow you to apply online for jobs and as available, subscribe to alerts about jobs.
• carrying out obligations arising from contracts made with Lever and other third parties who provide support and storage functions.
• analyse information in our systems and databases to improve the way we run our business and websites according to user preferences, to provide a better service and user experience.
• meet or exercise any of our legal obligations or rights
We will only process your personal data for the purposes set out in this Section 3 and where we are satisfied that:
• you have provided your consent to us using the data in that way, or
• our use of your personal data is necessary to support 'legitimate interests' that we have as a business (for example, to improve our products, or to carry out analytics across our datasets), in a way that is proportionate and respects your privacy.
4. Who do we share your personal data with?
We work with third parties, to help manage our business and deliver services. These third parties may from time to time need to have access to your personal data:
• Service providers or data processors that handle your personal data on our instructions, for example Lever, marketing technology and service providers and cloud services.
• Individuals and organisations who hold information related to your reference or application to work with us, such as current or past employers, education bodies and examining bodies.
• Our subsidiaries in the Catena Media group, located inside or outside the EU/EEA. Transfers of personal data will be subject to Catena Media intra group data transfer agreements.
• If we are under a duty to disclose to comply with a legal obligation or protect our interests or security.
• In the event we sell, buy or re-organise any business or assets, or if our assets are acquired by a third party, including prospective sellers or buyers.
5. International Transfers
International Transfers mean that personal data is transferred to a country outside the European Union.
As set out in Section 4 above, we may allow access to your personal data to third parties who may be located outside the European Union.
We may also disclose your personal data if we receive a legal or regulatory request from a foreign law enforcement body outside the European Union.
We will always take steps to ensure that any international transfer of information is managed to protect your rights and interests. Any requests for information that we receive from law enforcement or regulators will be carefully checked before personal data is disclosed.
You have the right to ask us for more information about the safeguards we have put in place as mentioned above. Contact us (see Section 8) if you wish further information.
6. Direct Marketing
We will use your personal data to send you direct communications regarding recruitment, recruitment events and training that we and our partners may offer.
You always have a right to say no to further direct marketing, at any time. You can use the opt-out link that you find in all direct marketing communications, or by contacting us (see Section 8).
We take steps to limit direct marketing to a reasonable and proportionate level, and to send you communications that we believe may be of interest or relevance to you, based on the information we have about you.
7. How long do we keep your personal data?
If we have not had active contact with you for a period of 24 months we will delete your personal data from our systems.
In some circumstances we keep your personal data for a longer period than as set out above, to meet for example legal, tax or accounting requirements. We will retain your personal data for as long as reasonably necessary for the purposes listed in Section 3 of this Policy.
We maintain a data retention policy for personal data in our care. Where your personal data is no longer required we will ensure it is either securely deleted or made anonymous.
8. What are your rights?
You have a number of rights in relation to your personal data. More information about each of these rights can be found by referring to the table set out further below.
To exercise your rights you may contact us as by sending an email to email@example.com or in writing to Catena Media at the address set out in Section 1 above.
Please note the following if you wish to exercise your rights:
|Right||What this means|
You can ask us to:
You can ask us to rectify inaccurate personal data.We may seek to verify the accuracy of the data before rectifying it.
You can ask us to erase your personal data, but only where:
We are not required to comply with your request to erase your personal data if the processing of your personal data is necessary:
There are certain other circumstances in which we are not required to comply with your erasure request, although these two are the most likely circumstances in which we would deny that request
You can ask us to restrict (i.e. keep but not use) your personal data, but only where:
• its accuracy is contested (see Rectification), to allow us to verify its accuracy; or
We can continue to use your personal data following a request for restriction, where:
You can ask us to provide your personal data to you in a structured, commonly used, machine-readable format, or you can ask to have it 'ported' directly to another Data Controller, but in each case only where:
You can object to any processing of your personal data which has our 'legitimate interests' as its legal basis, if you believe your fundamental rights and freedoms outweigh our legitimate interests.We have an opportunity to demonstrate that we have compelling legitimate interests which override your rights and freedoms.
You can ask to obtain a copy of, or reference to, the safeguards under which your personal data is transferred outside of the European Economic Area.We may redact data transfer agreements or related documents (i.e. obscure certain information contained within these documents) for reasons of commercial sensitivity.
You have a right to lodge a complaint with the responsible local supervisory authority about our processing of your personal data.We ask that you please attempt to resolve any issues with us first, although you have a right to contact your supervisory authority at any time.
Version 1.0, 24 May 2018