ROVIO RECRUITMENT PRIVACY NOTICE
Last updated: October 7, 2019
This notice explains how Rovio Entertainment Corporation and its subsidiaries identified below (referred to as “we” in this document) collect, store, use, or otherwise process the personal data of job candidates (referred to as “you” in this document) in their recruitment activities, and what rights you have if we are processing your personal data.
In this notice, the phrase “your data” is used when referring to personal data that relates to you as an identified or identifiable person.
It is important that you read this notice before applying for a position at Rovio so that you are aware of how and why we may use data relating to you. Please note, however, that this notice is not a part of any employment or other contract we may offer to you.
1 Data controller
By “data controller”, we mean an entity that determines how and why personal data is processed. With regard to the activities described in this notice, the Rovio group company at which you are considered for a position acts as the data controller.
This means that the data controller is one of the following companies:
- Rovio Entertainment Corporation, address Keilaranta 7, 02150 Espoo, Finland,
- Rovio Sweden AB, address Jakobsbergsgatan 22, 111 44 Stockholm, Sweden,
- Rovio UK Limited, address 10 John Street, London WC1N 2EB, United Kingdom
- Blue Bird Distribution, Inc., address 14724 Ventura Boulevard Suite 350, Sherman Oaks, California 91403, USA, or
- Rovio (Shanghai) Commerce and Trading Co., Ltd, address Room 3108 Lippo Plaza, No. 222 Middle Huaihai Road, Shanghai 2000021, People’s Republic of China.
2 Contact information
Our recruitment team serves as your primary point of contact in matters related to this notice. You can reach them by email at email@example.com.
We have also designated a Data Protection Officer (“DPO”) to oversee matters related to data protection at Rovio. If you have any questions or concerns about the way we use your data, you may contact our DPO at any time by email to firstname.lastname@example.org.
3 Why do we process your data and on what basis?
We may process your data for the following purposes:
- evaluating your qualifications and suitability for an open position,
- communicating with you about the recruitment process or open positions that may interest you, if you have indicated that you wish to hear about our open positions,
- making an employment offer to you and performing other related tasks to facilitate your employment with us,
- performing administrative functions (including record-keeping, internal reporting, and handling payments),
- analyzing and developing our recruitment processes and ability to attract talent,
- establishing, exercising, or defending our legal rights to the extent permitted by applicable laws and regulations, or
- for other purposes where required or permitted by applicable laws and regulations.
Our lawful basis for processing your data depends on the data in question and the context in which we process it. In many situations, we process your data based on our legitimate interest to find and secure talent to work for us. We may also process your data with your consent or as necessary to enter into an employment or other contract with you or to perform a contract we have with you, for example reimbursing you for certain expenses where so agreed. Where processing is required by law, we process your data to comply with our legal obligations.
We do not use your data to make automated decisions which significantly affect you. By an “automated decision”, we mean a decision made by an information system without any human intervention.
4 What data do we process?
Generally, we process your data to the extent necessary to carry out a recruitment process or to communicate with you regarding our open positions. This involves us collecting and using data that, for example, enables us to communicate with you, to evaluate your qualifications and suitability for an open position, and to make an offer to you where appropriate.
More specifically, we may process the following data relating to you:
- personal contact details (including your name, address, telephone number, and email address),
- information included in your curriculum vitae, cover letter, or other similar document,
- links to and contents of online professional profiles or work portfolios (for example LinkedIn),
- other information you submit through our online application system,
- the content and metadata of your communications with us (including emails you exchange with our recruitment team),
- information regarding the types of positions that interest you, if you have indicated that you wish to hear about our open positions,
- notes and other information generated by interviewers and recruiters based on your application or their interactions with you,
- results and other information related to tests or assignments you may complete as part of the recruitment process,
- information supplied to us by a third-party placement firm, recruiter, or staffing company, where applicable,
- recommendations made by others on your behalf, where you have permitted us to ask for recommendations,
- bank details and related information where required (for example for agreed reimbursements), and
- other information we need to make an employment offer to you and to perform other related tasks to facilitate your employment with us (including to offer relocation services to you and your family where applicable).
We neither request you to provide nor expect to collect or otherwise process any special categories of personal data relating to you, unless permitted or required by applicable law or regulation (for example for equal opportunities monitoring purposes). By “special categories of data”, we mean genetic, biometric, or health information or information revealing racial or ethnic origin, sex life or sexual orientation, political opinions, religious or philosophical beliefs, or trade union membership.
Similarly, we do not anticipate a need to process any information about your criminal record. Should we exceptionally need to review your criminal record, we will do so with your express consent and use the information as permitted by applicable laws and regulations.
5 Where do we collect your data from?
We may collect data relating to you from the following sources:
- directly from you, for example when you submit information through our online application system, during the recruitment process, in other interactions with us (including at recruitment or industry events), or by other means,
- online services used for sharing work portfolios, networking, or other professional purposes (for example LinkedIn), or
- third-party placement firms, recruiters, or staffing companies, if you are introduced to Rovio through them.
Where permitted by applicable laws and regulations, we may also collect information from a third party who we have perform a background check on you. A background check will only be performed with your express consent, and its scope and manner will be determined by applicable laws and regulations. We do not expect to perform background checks routinely.
During the recruitment process, we will only collect information about you from third parties with your permission. You are not required to give us your permission for any such collection.
Providing data to us is not mandatory. However, we may be unable to complete a recruitment process or to choose you for a position if we have inadequate information about you. If you do decide to provide data to us, please make sure that the data is complete and accurate.
6 Who do we share your data with?
We may share your data with third parties to achieve the purposes outlined in this document. This includes the following types of recipients:
- companies in the Rovio group other than the company at which you are considered for an open position (for example, when personnel from a group company participate in a recruitment process as interviewers),
- companies or individuals outside the Rovio group that provide services to us (including the operator of our online application system or others that assist us in handling recruitment related activities or events),
- competent governmental authorities, courts of law, or other similar entities where we believe disclosure is required by applicable laws and regulations or to exercise, establish, or defend our legal rights,
- with a prospective or actual buyer (and their agents or advisors) in the context of a planned or actual acquisition, merger, or other business restructuring, or
- with any other person or entity with your consent.
In connection with the activities described in this document, your data may be transferred to or processed in countries outside of the European Union (“EU”) and the European Economic Area (“EEA”). In particular, this takes place when you are a candidate for a position at a Rovio company based outside of the EU and the EEA. These countries may have data protection laws that differ from the laws of your country. In these cases, we will ensure that appropriate safeguards are in place to protect your data. These safeguards may include compliance with the European Commission’s standard contractual clauses for transfers of personal data or reliance on the EU-US Privacy Shield framework. Upon request, we can provide you a copy of the European Commission’s standard contractual clauses and further details on the applicable safeguards.
7 How long do we keep your data?
We will keep your data for as long as necessary to achieve the purpose(s) for which it was collected, including compliance with any legal, accounting, or reporting requirements.
Generally, where you were considered but not selected for an open position, we will retain your applicant data for two years from the date you were informed of the decision. If you have indicated that you wish to hear about or be considered for other open positions, we may keep your data as long as you inform us otherwise. If you are selected for a position, we will transfer some or all of your data to our employee records and retain it according to the policies we apply to those records.
In some cases, the retention times we apply may deviate from the guidelines described above.
After the end of the applicable retention period, we may keep and continue to use data that is not identifiable to you (including aggregate data), for example for statistical purposes.
8 How do we keep your data secure?
We have adopted measures to provide your data a level of security appropriate for the degree of risk involved with the processing activities outlined in this notice. These measures are designed to protect your data against accidental or unlawful destruction, loss, or alteration as well as unauthorized disclosure or access. The specific measures we employ vary from one service or system to another, but typically include, for example, controls to limit access to services or systems that contain personal data, contractual safeguards with third parties who process your data, and maintaining procedures to handle any suspected security incidents.
9 Your rights
If we are processing your data, you have the right to:
- access, correct, or request the deletion of your data,
- request us to restrict our processing of your data,
- object to our processing of your data to the extent our processing is based on the legitimate interests of Rovio or a third party, or
- where technically feasible, request a copy of the personal data you have provided to us in machine-readable format.
Where our processing of your data is based on your consent, you also have the right to withdraw your consent at any time. Please be aware that we may continue processing your data despite your withdrawal of consent, if we have a lawful basis for doing so.
To exercise any of these rights, please contact our recruitment team at email@example.com. To fulfill your request, we need to confirm your identity to verify your right to make the request, which may involve requesting additional information from you. While we will usually not do so, we reserve the right to charge an appropriate fee from you for the exercise of your rights where permitted by applicable law or regulation.
Finally, you always have the right to lodge a complaint with your local data protection authority regarding our processing of your data. For more information, please contact your local data protection authority (for example, the Office of the Data Protection Ombudsman in Finland or the Swedish Data Protection Authority in Sweden).
We may update this notice from time to time, for example due to changes in our operations or the legal obligations that apply to us. We will inform you of any changes made by means that are appropriate considering the significance of the changes.