We are MoveMyTalent OÜ, an Estonian company with registry code 12637702 (MoveMyTalent, MMT, we, us and our). We operate an online platform at movemytalent.com, (the Website) to provide certain services relating to relocation of employees (the Employee) from one country to the place of employment in another country (the Services).
The term “Client” or “you” refers to a natural person who has accepted our Terms of Service (the Terms).
The EU General Data Protection Regulation (GDPR) aims at protecting individuals from violations of their personal privacy in connection with the processing of their personal data. MoveMyTalent is committed to protect your privacy when processing your personal data.
The purpose of this privacy notice (the Privacy Notice) is to provide information on how MoveMyTalent processes your personal data in connection with the Services as data controller. The terms used in the Privacy Notice are used in the meaning given to them in Article 4 of the General Data Protection Regulation (EU) 2016/679 of the European Parliament and of the Council (GDPR).
1) WHY WE PROCESS PERSONAL DATA AND WHAT PERSONAL DATA DO WE PROCESS?
We process personal data to enable Services to you (Employee) provided via our Website and/or to enable Services to your Employer to whom you have granted a consent to process your personal data in relation to the Services (the Employer).
We process personal data that is submitted to us directly by you or by your Employer via email or forms provided on the Website.
Personal data we process may include following data about you:
general personal information: name, nationality, personal identity number, gender, marital status, educational qualifications
contact details: address, phone number, email address, bank details;
employment data: resumé, date of employment, position, salary information, information regarding bonus, benefits, other employment documentation, rehabilitation matters, information on entry and exit at the workplace;
family data: data about family members who are subject to Services;
other: any other information that you, your Employer and any other person, as applicable, submit to us.
You can request to see all data that we process about you and that we have collected about you by contacting us.
2) WHAT IS THE LEGAL BASIS FOR PROCESSING YOUR PERSONAL DATA?
We process your personal data to fulfil our duties under the Agreement concluded between us and your Employer and under the Agreement concluded between you and us (please read Terms of Services for using our Website and the Services) (legal basis: GDPR Article 6-1-(c)).
In certain specific situations we might also process your personal data where processing your personal data is necessary for the purpose of our legitimate interests pursued by us (legal basis: GDPR Article 6-1-(f)). In such a case we shall ensure that processing is proportionate and that we have carried out legitimate interest impact assessment.
In certain specific situations we may also process your personal data based on your consent (GDPR Article 6-1-(a)). In those situations, we process your personal data on the terms as provided in the consent that you have granted to us.
3) WHEN DO WE SHARE YOUR PERSONAL DATA?
To the extent the action is necessary for the provision of our Services, we may share your personal data with certain authorities, agencies or other third parties. For example, we may share your personal data with following parties in following situations:
with police (in Estonia Police and Border Guard Board) when it is necessary for applying for documents, such as residence permit to work in a country of your destination or for applying for other required documentation;
embassies in the country of your residence, in your home country or in your destination country;
state registers such as population registry;
state authorities, such as tax authority;
banks, for example to help creating a bank account;
family doctor or other health care providers, for example to find a suitable service provider for you;
Kindergartens and schools, for example if part of the Services includes relocation services concerning your family;
your Employer.
You can ask for the overview of specific third parties with whom your data has been shared and what personal data has been shared with each party from your MoveMyTalent agent, from your Employer or by contacting MoveMyTalent on the contact details indicated in clause 9 below.
We may also share your personal data with third party suppliers providing services to us, e.g. IT suppliers. At the moment of adopting this Privacy Notice, we use the following service providers:
We use Google Cloud Storage provided by Google Commerce Limited (“GCL”), a company incorporated under the laws of Ireland, with offices at Gordon House, Barrow Street, Dublin 4, Ireland. Please visit https://cloud.google.com/terms/ for Google Cloud Storage terms and https://cloud.google.com/terms/data-processing-terms for data processing terms.
We may also transfer your personal data to third countries, i.e. countries outside the EU/EEA area, for the purposes explained above in clause 3. When transferring your personal data to third countries, we will ensure that the transfer is subject to appropriate safeguards and that your rights are protected.
4) HOW LONG IS YOUR PERSONAL DATA RETAINED?
Personal data related to contracts can be retained during the term of the contract and based on our legitimate interest pursuant to Article 6 (1) (f) of the GDPR until the end of the statutory limitation periods under applicable law. Accordingly, MoveMyTalent processes your personal data as long as it is necessary for the provision of the Services.
5) HOW DO WE PROTECT YOUR PERSONAL DATA?
To protect your personal data from unauthorized access, unlawful processing or disclosure, accidental loss, modification or destruction, we use appropriate technical and organisational measures that comply with applicable laws.
These measures include but are not limited to the implementation of appropriate computer security systems, protection of paper and electronic format files by technical and logical means, controlling and limiting access to documents and buildings.
All third party IT suppliers and their servers we use to store your data, have successfully completed the ISO 27001, ISO 27017 and ISO 27018 certification processes, and SOC 1, SOC 2, and SOC 3 evaluation processes.
6) COOKIES
Our Website uses cookies to authenticate you, and provide you the service. This section incorporates our cookie policy (the Cookie Policy) that applies when you use the Website.
Cookies are small data files stored on your hard drive by a website.
We use session cookies on our website that are temporary cookies, which only exist during the time you use the website (or more strictly, until you close the browser after using the website). Session cookies help our websites remember what you chose on the previous page, avoiding the need to re-enter information.
You can delete or block cookies on the Website through your browser settings at any time. However, some cookies might be necessary for the functionality of the Website. Therefore, you understand that when blocking or deleting the cookies some features of the Website might not function correctly. For more general information about cookies including the difference between session and persistent cookies please see http://www.allaboutcookies.org.
Your continuing use of the Website stipulates your acceptance to using cookies.
In case you have any questions concerning Cookie Policy, you may contact us via contact details provided below.
7) YOUR RIGHTS
MoveMyTalent is dedicated to ensuring that all data subject rights arising under applicable law are always guaranteed to you. In particular, any data subject has:
the right to access the personal data that MoveMyTalent processes about you;
the right to request that MoveMyTalent rectifies any inaccurate personal data about you;
the right to request MoveMyTalent to erase your personal data and/or restrict processing your personal data if we do not have valid legal basis for processing;
the right to receive your processed personal data in a structured, commonly used and machine-readable format and have the right to transmit your personal data to another controller;
the right to object to the processing of your personal data.
If you believe that your rights have been infringed by MoveMyTalent or by your Employer, providing MoveMyTalent with your personal data on behalf of you, you may contact and lodge a complaint to the supervisory authority applicable for your jurisdiction (Data Protection Inspectorate in Estonia address Tatari 39, Tallinn 10134, http://www.aki.ee, info@aki.ee or other competent authority in your jurisdiction).
8) GOVERNING LAW AND JURISDICTION
This Privacy Policy shall be governed by the laws of the Republic of Estonia. Any disputes arising from these Privacy Policy shall be settled in the Harju County Court in the Republic of Estonia, unless you have a right to turn to the court of your residence pursuant to statutory law.
9) CONTACT DETAILS AND NOTICES
If you have any questions about this Privacy Policy or concerns about how we use your personal or if you want to exercise your rights as described above, you may contact us via e-mail or in writing using the following contact information: info@MoveMyTalent.com