Lorka's Candidates Privacy Policy

This Privacy Policy describes how personal information is collected, processed and protected for candidates and applicants during the application and recruitment process.

We may update this Privacy Policy according to new legislative or jurisprudential requirements and/or business needs, among other reasons. The new version of this Privacy Policy will be applicable from the moment of its publication on the Website. It is important that Candidates read and retain this Privacy Policy so that you are aware of how and why we are using your data.

Who is the personal data controller?

Palatine Global Capital LLC (hereinafter, "the Company", "We", "Us" and the like) is the controller of the Candidate's personal data. We are firmly committed to regulatory compliance and the privacy and protection of personal data of Users. Accordingly, in the present Privacy Policy, the Candidate (hereinafter "the Candidate", "Candidates", "you", "your") will find all the relevant information to better understand what We do with your personal data.

Where you have applied to a job opening through any third party service provider (such as, but not limited to: LinkedIn, Indeed, Workable), said service provider shall be the data controller of this data and shall therefore be responsible for complying with all applicable law in respect of the use of that data. Candidates can find more information about the Privacy Policy applicable to these third party service providers on each provider's respective website.

What does this Policy apply to?

This Privacy Policy applies to the personal data that We collect and process from you as a Candidate or Applicant, and/or from our third party providers through which you have applied, during application and recruitment processes for employment at our Company.

What does personal data mean and which data do We collect and process?

For the purposes of this Policy, "personal data" refers to all data that identifies you or that could be used to identify you, such as:

Information that you provide when you apply for a role. This includes information provided through an online job site, via email, in person at interviews and/or by any other method.
In particular, We process personal details such as name, email address, address, telephone number, date of birth, qualifications, experience, information relating to your employment history, skills and experience that you provide to Us, as well as your video in case you conduct your interview using the Video Interview feature.
Communication data: If you contact Us, We may keep a record of that correspondence.
A record of your progress through any hiring process that We may conduct.
Online profiles: information available on your LinkedIn profile or other professional platforms you choose to share with us.
Application-related information: such as cover letters, job preferences, salary expectations, and availability.
Technical data: such as IP address, browser type, and usage data when you interact with our application systems (if applicable).
Optional data: any additional information you voluntarily provide during the recruitment process.

We ask that you do not include any special categories of personal data (such as information relating to health, racial or ethnic origin, political opinions, religious or philosophical beliefs, genetic or biometric data, or data concerning your sexual orientation) in your application.

If such data is nevertheless provided, it will not be used for recruitment purposes and, where identified and if applicable, will be promptly deleted in accordance with applicable data protection laws.

What do We use your personal data for?

We use information held about you in the following ways:

To consider your application in respect of a role for which you have applied.
To consider your application in respect of other roles.
To communicate with you in respect of the recruitment process.
To enhance any information that We receive from you with information obtained from third party data providers.
To find appropriate candidates to fill our job openings.
To help our service providers and Partners (such as the job sites through which you may have applied) improve and develop their services.

Use of AI technologies

During our interviews, We may use Artificial Intelligence (AI) powered technologies to transcript conversations and help our recruiters take notes on the information you provide. If so, you will be duly informed prior to the interview and you will have the right to opt-out of this specific use of your data. For further information on your rights in relation to this use of your data and how to exercise them, please refer to the section "What rights do you have and how can you exercise them?" of this Candidate's Privacy Policy.

Automated decision making/profiling

We may use Third Party Providers and/or our own technology to select appropriate candidates for Us to consider based on criteria expressly identified by us, or typical in relation to the role for which you have applied. The process of finding suitable candidates is automatic, however, any decision as to who We will engage to fill the job opening will be made by our staff.

In accordance with applicable data protection laws, you have the right not to be subject to a decision based solely on automated processing that produces legal or similarly significant effects concerning you. You also have the right to request human intervention, to express your point of view, and to contest any such decision. For further information on your rights and how to exercise them, please refer to the section "What rights do you have and how can you exercise them?" of this Candidate's Privacy Policy.

What is the legal basis for processing your personal data?

We only process your personal data when there is a legal basis for doing so. The legal basis will depend on the reason(s) why We collect and process your personal data. In almost all cases the legal basis will be:

To perform the necessary actions and take the required steps, according to your application and requests, during the recruitment process and prior to potentially entering into an employment contract with you.
When applicable, we may request your consent for specific circumstances and uses of your data, such as, but not limited to: the processing of your data by using AI technologies during the recruitment process; the use of your data to provide you with information about other job opportunities.
To comply with our legal obligations and/or to attend administrative, judicial, police, or the corresponding authorities' official requirements.
Our legitimate interest in ensuring we recruit the best possible candidates.
When we process special categories of personal data, we will only do so in accordance with legal requirements.

How long do we keep your personal data for?

Where you have applied to a job opening through any third party service provider (such as us but not limited to LinkedIn, Indeed, Workable), said service provider shall be the data controller of this data and shall therefore be responsible for complying with all applicable law in respect of the use of that data, including regulations relating to the definition of the conservation period.

When We store your personal data, We will hold all the data for 12 months. Beyond that, your personal data will be retained, securely blocked, for the necessary retention period to fulfil our legal obligations and/or for our legitimate reasons (i.e to address claims in connection with the recruitment process; to finish the investigation of detected fraudulent or illicit activity).

Your personal information will be deleted on one of the following occurrences:

deletion of your personal information by you (or by another person engaged by you); or
receipt of a written request by you (or another person engaged by you) to us; or
elapse of the necessary retention period to fulfill our legal obligations and legitimate reasons.

Who do We share your personal data with?

We may share your personal data with third parties, when required as part of the recruitment process and when necessary for the fulfillment of our legal obligations and the protection of our rights and legitimate interests. These third parties may use your data only in accordance with our instructions and as otherwise required by law.

Where you have applied to a job opening through any third party service provider (such as, but not limited to: LinkedIn, Indeed, Workable), the service provider shall be the data controller of this data and shall therefore be responsible for complying with all applicable law in respect of the use of that data. Candidates can find more information about the Privacy Policy applicable to these third party service providers on each provider's respective website.

The third parties mentioned above may have their headquarters outside the European Economic Area (EEA), therefore, your personal data will be the object of international transfers. In any event, if a personal data international transfer is deemed appropriate, We inform you that We will only transfer personal data to recipients located in countries that ensure an adequate level of data protection or, failing that, offer the appropriate safeguards required by the current applicable law and regulations on the protection of personal data, to ensure that your personal data is properly protected and that your individual rights and freedoms are guaranteed. In this regard, please be informed that the third parties mentioned above are committed to standard contractual clauses approved by the EU Commission certification in case of transfers to the USA.

How do We protect your personal data?

When We store your personal data, We take appropriate measures to ensure that all personal data is kept secure including security measures to prevent personal data from being accidentally lost, or used or accessed in an unauthorised way. We limit access to your personal data to those who have a genuine business need to know it. Those processing your information will do so only in an authorised manner and are subject to a duty of confidentiality.

We also have procedures in place to deal with any suspected data security breach. We will notify you and any applicable regulator of a suspected data security breach where We are legally required to do so.

Unfortunately, the transmission of information via the internet is not completely secure. Although We will do our best to protect your personal data, We cannot guarantee the security of your data transmitted through any online means, therefore any transmission remains at your own risk.

Where you have applied to a job opening through any third party service provider (such as, but not limited to: LinkedIn, Indeed, Workable), said service provider may store your personal data according to its applicable Privacy Policy, which Candidates can find on the third party service providers' respective websites.

What rights do you have and how can you exercise them?

Subject to local data protection laws and in particular under the GDPR and the UK GDPR, you have a number of important rights you can exercise free of charge. In summary, those include rights to:

access to your personal data and to certain other supplementary information that this Privacy Policy is already designed to address
require Us to correct any mistakes in your information which We hold
require the erasure of personal data concerning you in certain situations
receive the personal data concerning you which you have provided to Us, in a structured, commonly used and machine-readable format and have the right to transmit those data to a third party in certain situations
object at any time to processing of personal data concerning you for direct marketing
object to decisions being taken by automated means which produce legal effects concerning you or similarly significantly affect you
object in certain other situations to our continued processing of your personal data
otherwise restrict our processing of your personal data in certain circumstances
claim compensation for damages caused by our breach of any data protection laws.

If you would like to exercise any of those rights, please:

contact Us using our contact details below,
let Us have enough information to identify you,
let Us have proof of your identity and address, and
let Us know the information to which your request relates.

As a general rule, We will respond to data protection rights requests within one (1) month. Occasionally, this period may be extended by two (2) further months where necessary, taking into account whether your request is particularly complex or you have made several requests. In this case, We will notify you of this event and explain the reasons for the delay to you.

Please, bear in mind that, where you have applied to a job opening through any third party service provider (such as, but not limited to: LinkedIn, Indeed, Workable), said service provider shall be the data controller of this data and, therefore, any request in relation to the exercise of the above-indicated rights shall be directed to the specific third party service provider. Please note that We cannot delete or modify information which is not stored in our databases and any such action must be handled directly by the applicable data controller according to their own policies. In these cases, Candidates can find more information on their rights and how to exercise them in the Privacy Policy included in the respective third party service provider's website.

Finally, We inform you that should you consider it appropriate, you have the right to lodge a complaint before the corresponding Supervisory Authority, especially if you consider that your data protection rights have not been adequately addressed.

Contact Us

All questions, comments and requests regarding this Privacy Policy should be addressed via email to info@lorka.ai.