Terms & Privacy

Privacy Notice

(Current update January 28, 2019. Please note, in case if terms described in this Privacy Notice are changed, Ciklum will take all reasonable measures in order to inform you prior to implementation of such changes)

1. Contact information for privacy matters

If you have any questions regarding your personal data, feel free to contact our Data Protection Officer via data.privacy@ciklum.com.

2. Sources of your personal data

Ciklum may collect and process information that

  1. you personally provide, for example, in hard copies, via emails or by sending personal messages directly to our representatives,
  2. collected during performance of a contract between you and Ciklum,
  3. you provide during interaction with our web sites, for example, through cookies (please see Cookie policy for details) and web forms,
  4. obtained from third parties, for example, recruitment agencies, your representatives, and
  5. obtained from open sources, for example, social media profiles, public web sites, press releases.

Ciklum will not process your personal data if such is prohibited by applicable law.

3. Purposes of processing

Ciklum may process your personal data linked to particular purposes and corresponding legal bases outlined below:

  • purposes to which you agree in a consent form or purposes that are genuinely compatible with them, taking into account your expectations as a data subject when consenting to processing;
  • for the fulfilment of the contract as further specified in that contract;
  • in order to comply with legal obligations specified in a particular law or regulation;
  • legitimate interests pursued by Ciklum group members, except where such interests are overridden by your interests or fundamental rights and freedoms.

If you belong to one of the categories identified below, please expand the relevant section for further information. Please consider that you may belong to more than one category. If you need further assistance, please contact our Data Protection Officer via data.privacy@ciklum.com.

In case Ciklum is planning to change the purpose of processing to such that is incompatible with the original one, we will contact you to provide you with further information on purposes for processing prior to it taking place, at all times ensuring appropriate legal basis for processing, which may include asking for your additional consent.

Ciklum does not process your personal data for automated decision-making, including profiling. For cases where automatic processing is performed, Ciklum will inform you additionally in the relevant section of this notice.

4. Recipients of personal data

All your personal data will be kept strictly confidential and will not be disclosed to unauthorized third parties or made public without your prior notification by this notice or in person.

We may share your personal data with our technical partners that support Ciklum in day-to-day operations and in provision of more convenient services to you. Our technical partners are located all over the globe, including countries with different data protection and privacy laws, including outside of the European Union legal system. In all cases, Ciklum will not transfer your personal data internationally without reasonably ensuring that the rights and freedoms of you as the data subject are protected.

We never sell your data or share it with other third parties in order to obtain direct or indirect financial gains.

To obtain information about third-party recipients of your personal data, please expand the relevant section below. Please consider that you may belong to more than one category. If you need further assistance, please contact our Data Protection Officer via data.privacy@ciklum.com.

5. Where Ciklum stores your personal data

The data collected by Ciklum is stored within the information systems, owned and operated by Ciklum, and in the cloud systems. All information you provide to Ciklum is stored (including backups) within secure environment certified in accordance with world-leading security standards (currently, ISO/IEC 27001:2013 “Information Security Management System”). Once Ciklum receives personal data from you, a third party or a public source, it will use all reasonable procedures and security measures to avoid unauthorised access, loss, disclosure or amendment of the personal data.

Please mind that, unfortunately, transmission of information via the Internet (including by email) is not completely secure, and, although Ciklum will do its best to protect your personal data, we cannot guarantee the security of your data in transfer. Accordingly, please proceed with any such transmission at your own risk.

6. Storage period

We store your personal data for the limited period of time, which varies depending on type of data, the purposes of processing, legal requirements and duration of contractual relationship with Ciklum.

To obtain information about storage period of your personal data, please expand the relevant section below. Please consider that you may belong to more than one category. If you need further assistance, please contact our Data Protection Officer via data.privacy@ciklum.com.

7. Your rights

As a data subject you have the following rights:

  • right to obtain information in relation to your personal data;
  • right to access your personal data;
  • right to data portability;
  • right to withdraw the consent;
  • right to correct mistakes in your personal data;
  • right to stop the unwarranted processing;
  • right to be forgotten (erase your personal data);
  • right to be aware of the existence of the automated individual decision-making and to object in this regard;
  • right to lodge a complaint to a supervisory authority.

Sources of your personal data

Ciklum may collect and process the information originated as follows:

  • Information that you personally provide, e.g. by filling in questionnaires or orally to HR department specialists, entering into IT systems to which you have been granted access with, provided on paper or sent in corporate emails.
  • Information collected directly from you, including fingerprints for your unique identification for provision of access to Ciklum premises (if you consented for it).
  • We may obtain access to information that you store at company-owned computer provided to you, but only if this information is connected with business purposes, or if it is needed to control compliance with labour or statutory obligations, or if we need to guarantee the appropriate operation of devices;
  • Data provided by third parties, e.g., information collected and provided to us by third parties for execution of a contract and maintenance of contractual relationship between you and Ciklum. This data may include feedbacks from clients that have experience of working with you, background check results, compliance check results, whistle-blower reports, and areas for improvements that may have been highlighted by your supervisors, peers, Ciklum`s clients etc.
  • Data which is generated internally, e.g., information for and from your login in the systems, logs of performed actions in the internal systems and while using corporate network, CCTV footage, videos created during interview with you, corporate structure data, collaboration history, data obtained from your supervisors and peers.

Types of information

Ciklum collects and processes the following types of information:

  • For the purpose of maintenance of employment records or records for individual contractors/entrepreneurs (depending on your status):
    name, surname, date of birth, gender, citizenship, marital status, division, department, position, passport details, passport scan, tax id scan copy, marriage certificate, birth certificate, social security number, driving licenses, relatives’ passport, email, phone number, skype, registration address, residence address, country, town, education, diplomas, certificates, employment history, work experience, CV, references, individual entrepreneur documents scans, individual entrepreneur reports, information about remuneration, contracts and amendments to the contracts, start date, end of probation date, information about criminal convictions, background check results, evaluation (after interview), link to social profiles, Djinni profile, job satisfaction rate, overtimes, dates of unavailability due to sickness or other reasons (no sensitive health information), reasons for termination of relationship.
  • For the purpose of workplace administration:
    name, surname, position, passport number, email, phone, address.
  • For the purpose of provision of physical security, parking spaces, and theft prevention:
    name, surname, photo, email, phone, passport number, project, license plate, car model, fingerprints, CCTV footage.
  • For the purpose of business trip management and related financial accounting:
    name, surname, date of birth, phone, email, itinerary, project, department, budget holder name, budget holder surname, travel dates, destination, passport scan copy, passport issuing date, passport expiration date, passport number, citizenship, tax id scan copy, ERM profile, booked hotel, travel documents, travel costs.
  • For the purpose of internal and external communication:
    name, surname, date of birth, gender, citizenship, marital status, division, department, position, technology, names of the clients which worked with you, email, phone, location, photo, video interviews, name and surname (of a child), date of birth (of a child), t-shirt size.
  • For the purpose of background and compliance check:
    name, surname, information about criminal convictions in certain locations, where such type of screening is allowed.
  • For the purpose of support during relocation:
    name, surname, previous surname, date of birth, place of birth, nationality, nationality at birth, current address, passport number, phone, email, registration address, marital status, number of children, countries of legal residency in the last 5 years, relocation country, native country, education, travel passport number, date of issue, date of expiry, issuing authority, national passport number, tax number, address, email, phone, countries where person lived, current occupation, Schengen/national visa information, parents’ information, personal data of the family member who is an EEA citizen, scan copies of travel passport, scan copies of previous travel passport, scan copy of tax id, scan copies of national passport, scan copies of diplomas, CV, education, employment history, information about criminal convictions, salary, position, scan copy of international passport, scan copy of spouse and children’s passports, scan copy of marriage certificate, scan copy of birth certificates, payroll information, home address, date of birth, gender, us social security number, non-immigrant status, visa status, date of last us entry, us home address, immigration court proceeding information, criminal convictions, job position, us worksite location, us position, bank statement, individual entrepreneur registration documents, visa issue date, visa expiry date; residence permit number and expiry date

Please review our corporate policies and procedures to obtain more information about personal data processing practices in Ciklum.

Purposes of processing

All personal data collected and processed for the purposes, which include:

  • Maintenance of employment records or records for individual contractors/entrepreneurs (as applicable): Ciklumers’ accounting and performance of contractual obligations, official employment documents processing, resourcing, team management, establishment of contractual relationship, employment, employment & performance of a contract, recruitment of candidates, retention of candidate information.
  • Workplace administration: workplace location, office administration, procurement of services / equipment, user access management, postal services, business cards creation, provision of information for a client, measurement of your job satisfaction rating (may be performed automatically, but final decision is made with human interaction).
  • Provision of benefits and payments to Ciklumers: payments to Ciklumers, medical insurance, pension fund reporting.
  • Financial accounting and operations: financial accounting, reimbursement, payment of taxes, bank account opening, financial audit, financial reporting, payments for services, obligatory payments.
  • Provision of access to information resources and hardware: provision access to information resources, software accounting, hardware accounting.
  • Internal and external communication: communications, promo actions and marketing, event organisation.
  • Performance of services: software development, project delivery, management of the projects.
  • Business trips management: business trips organization, business trips accountancy, taxi booking.
  • Support during relocation to different office of Ciklum and client sites: relocation, obtaining a work permit and visa opening, support during immigration, monitoring of visas and initiation of work and residence permit extension, related consulting.
  • Operational support and maintenance: service request management, business continuity management, infrastructure support, system testing.
  • Protection of Ciklum`s assets: Information security monitoring and troubleshooting.
  • Provision of physical access to premises and parking.
  • Education, knowledge and performance management.
  • Whistleblowing.
  • Background and compliance check.

Recipients

Your personal data may be wholly or partially disclosed to the following third parties:

  • companies of the Ciklum Group;
  • client, whom you are working with, for performance of a contract;
  • external accounting service providers in your country, for provision ofaccounting and payment services;
  • external tutors, knowledge management providers or other service providers that assess your performance and may suggests for you points for improvement;
  • external providers of benefits;
  • external providers that provide services of transportations, accommodation or other service providers that may support during business trip;
  • external auditors;
  • service providers supplying and servicing our internal system;
  • attorneys and legal councils;
    banks and other financial service providers for transfer of remuneration for your services;
  • governmental entities where required by law or mandatory order;
  • third parties that issues visas and work permits, including embassies, immigration offices, etc., if you requested relocation;
  • landlords and other providers of physical security services in your office and offices which you visit
  • security operation centres and other service providers;
  • printing service providers.

Retention period

Based on type of processed personal data, it may be stored different period of time from 1 month (CCTV video records and some logs) up to period of time that is required by applicable law. If you need more information, please, contact our Data Protection Officer via data.privacy@ciklum.com.

Types of information

Ciklum may collect and process any information that was provided by you directly to us or by the companies acting as recruitment agencies or your referees. In this case, Ciklum processes your personal data including your name, email, phone, skype, links for social media profiles, work experience, technologies, education, location, feedbacks from interviewers and client representatives etc. We do not collect any kind of sensitive personal data for recruitment purposes. Please note that in case if you provide sensitive data voluntarily, for example by inclusion into your CV, Ciklum may store this personal data in files that you provided, which become attached to your profile in our internal systems, but will never process or use the data in any other way.

Purposes of processing

All personal data is collected and processed only for the following purpose(s):

  • entering of your information into Ciklum’s internal systems in order to provide additional offers about open vacancies that may be interesting for you;
  • establishment of contractual relationship between you and Ciklum, including possibility of performance of general compliance check based on information, which were provided by you in CV’s or during interviews, and open sources;
  • technical maintenance of our internal systems, including data back-up, data migration without any modification of your personal data.

Recipients

Your personal data may be wholly or partially disclosed to the following third parties:

  • companies of the Ciklum Group;
  • email service provider if the data is transferred to us via Internet;
  • our client if you are considered for open positions;
  • service providers supplying and servicing our internal system for candidates relations management.

Retention period

Retention period of your data may vary based on options chosen in your consent form and current legislative requirements. Generally, Ciklum does not store your personal data for a period longer than 3 years from the last contact with you, if you provide your consent for personal data processing, or 3 month, if you did not provide such consent.

Types of information

Ciklum processes personal data like your contact details and full name, email, date and time of visit, signature, and video records created during your visit.

Purposes of processing

All personal data is collected and processed only for the following purposes:

  • to ensure the physical and information security of the premises;
  • to protect your safety during the visit of the premises;
  • to provide you with other administrative services (taxi, catering services, etc.) to ensure that your visit of Ciklum`s premises will be pleasant and convenient.

Recipients

Your personal data may be wholly or partially disclosed to the following third parties:

  • companies of the Ciklum Group
  • service providers suppling and servicing maintenance of the visitor management system;
  • service providers of physical security guard services;
  • email service providers if data is transferred via email;
  • business centre owners and other administrative service providers (taxi service, catering service) which ensure that your visit of Ciklum`s premises will be pleasant and convenient.

Retention period

Based on the type of information your personal data may be stored for in our internal systems for up to 3 years, however, video records created during your visit is stored for no longer than 1 month. If you would like to obtain more details, please contact our Data Protection Officer via data.privacy@ciklum.com.

Types of information

During visiting our web-site Ciklum may collect information directly entered by you in contact us forms or through cookies, beacons and other trackers. In this case, Ciklum may process your personal data which include your IP, location, visited web pages on our web-site, and, if you filled contact us form, your name, email, phone and country and data in the message.

All personal data is collected and processed only for the following purposes:

  • to ensure stable operation of Ciklum web site;
  • to monitor popularity of our publication and web-pages;
  • to provide relevant information on our web site and web sites of our partners.

Recipients

Your personal data may be wholly or partially disclosed to the following third parties:

  • companies of the Ciklum Group;
  • our partners which may deliver relevant information to you through advertisement, publications and other materials;
  • email service provider if the data is transferred to us via email or “contact us” form;
  • service providers suppling and servicing our internal system for customer relation management;

Retention period

Information collected through cookies, beacons and other trackers retained no longer than 6 months, however, based on collected information impersonalised and aggregated statistics can be created and processed.

Information entered by you in “contact us” form can be stored and retained for 12 months from the last contact date (please see section for representatives of potential clients for additional information).

Types of information

Ciklum may collect and process any information that was provided by you directly to us or via intermediaries when registering or participating in an event. In this case, Ciklum processes your personal data like full names, contact details, your professional experience and technologies in which you are proficient / industry, current job position, photo and video records created during the event.

Purposes of processing

Depending on your role in the event, your personal data may be processed for one or several of the following purposes:

  • to organise current public events and prepare materials that will suit your professional experience and may be relevant for your current job position or industry;
  • to share information about current public events in social media platforms and on other public websites;
  • to invite you to an event that might be interesting for you and might promote your technical skills or boost your company performance;
  • to provide you with information about job positions / service offerings that may be interesting for you;
  • to publish information (photo and / or video that may contain your image) on the external websites to invite participants for the event;
  • to publish information (photo and / or video that may contain your image) on the external Ciklum websites.

Recipients

Your personal data may be wholly or partially disclosed to third parties in the following cases:

  • companies of the Ciklum Group
  • email service provider if the data is transferred to us via Internet;
  • providers of external services that are used for collection of your personal data, in particular when registering for the event;
  • external speakers that will present during the event;
  • external web resources on which photos and videos from the events will be published.

Retention period

Your personal data is stored no longer than 3 years from the date of the event. Please mind that you may be included into other category described in this notice (including “Candidate” or “Office Visitor”) category during the event and if so, please read the corresponding section of this notice.

Types of information

Ciklum may collect and process information that is provided by you. In this case, Ciklum processes personal data like your name, email, photo, professional experience.

Purposes of processing

Your personal data is collected and processed based solely on your consent (unless we pay you for the event, in which case please refer to section about representatives of vendors and service providers) only in order to publish information at certain external web sites to invite participants to the event or to publish event report or other materials.

Recipients

  • companies of the Ciklum Group;
  • email service provider if the data is transferred to us via email;
  • external web resources on which information about event and photos and videos from the event will be published.

Retention period

Retention period of personal data at the external resources is defined by the resource where personal data will be published. If you request deletion of your personal data Ciklum will take all reasonable efforts to delete such published information.

Types of information

Ciklum may collect and process information that is provided by you or other individuals on your behalf or which is available in other public and open sources. In this case, Ciklum processes personal data related to the company or business you represent, including your name, email, job position, etc.

Purposes of processing

All personal data is collected and processed only for the following purposes:

  • to enter your information into internal IT systems in order to contact you with information related to our service offerings;
  • to establish contractual relationship between your company and Ciklum.

Recipients

Your personal data may be wholly or partially disclosed to the following third parties:

  • companies of the Ciklum Group
  • email service provider if the data is transferred to us via email;
  • service providers suppling and servicing our internal system for customer relation management.

Retention period

Personal data is retained for 12 month from the last contact date or 12 months after finalization of contracting procedures.

Types of information

Ciklum may collect and process information that is provided by you, other individuals from your company and entered into written contracts between your company and Ciklum. In this case, Ciklum processes personal data related to the company or business you represent like your name, email, company name and address, job position, phone number, social profile reference, Skype, emails sent from you to Ciklum etc.

If you require to obtain access to Ciklum premises and consented to use Ciklum`s fingerprint access system, Ciklum will collect and process your sensitive personal data, namely fingerprints. This is purely for your convenience and you may opt for using access badge instead without any detriment.

Purposes of processing

All personal data is collected and processed only for the following purposes:

  • to enter your information into internal IT systems in order to contact you with information related to our service offerings;
  • to establish contractual relationship between your company and Ciklum;
  • to execute the contract with your company and to maintain a good relationship with your company and its representatives;
  • to prepare business cases and marketing materials with mentioning your company representatives in order to promote image of your company`s and Ciklum`s business (where permitted by contract);
  • to invite your company`s representatives to participate in the events organised and hosted by Ciklum;
  • to inform about changes in performance of the services and additional arrangements, if required;
  • to provide information requested by your company or its representatives.

Recipients

Your personal data may be wholly or partially disclosed to the following third parties:

  • companies of the Ciklum Group;
  • email service provider if the data is transferred to us via email;
  • service providers suppling and servicing our internal system for customer relation management;
  • phone helpline service provider if you requested any kind of support via helpline;
  • electronic signature service provider if contract with you was signed in electronic format;
  • satisfaction survey organiser if you participate in customer satisfaction survey.

Retention period

Client and Client representative personal data is stored for 6 years after end of contractual relationship with the Client. Contractual data may be stored by Ciklum longer, if it required by law.

If personal data belongs to individual who is no longer represent a Client personal data may be deleted immediately (except email correspondence which may be used in order to execute contract with the Client) after provision of information to consideration of Ciklum’s Data Privacy Team via data.privacy@ciklum.com.

Types of information

Ciklum may collect and process information that is provided by you, other individuals from your company or is entered into written contracts between your company and Ciklum. In this case, Ciklum processes personal data like your name, email, company name and address, job position, phone number, social profile reference, Skype etc.

If you require to obtain access to Ciklum premises and consented to use Ciklum`s fingerprint access system, Ciklum will collect and process your sensitive personal data, namely fingerprints. This is purely for your convenience and you may opt for using access badge instead without any detriment.

Purposes of processing

All personal data is collected and processed only for the following purposes:

  • to enter your information into internal IT systems in order to contact you with information related to services that is provided by your company and / or you;
  • to establish contractual relationship between your company and Ciklum;
  • to execute the contract with your company and to maintain a good relationship with your company and its representatives;
  • to inform about changes in performance of the services and additional arrangements, if required;
  • to provide information requested by your company or its representatives.

Recipients

Your personal data may be wholly or partially disclosed to the following third parties:

  • companies of the Ciklum Group;
  • email service provider if the data is transferred to us via email;
  • service providers suppling and servicing our internal system for customer relation management;
  • electronic signature service provider if contract with you was signed in electronic format.

Retention period

Personal data is retained during performance of a contract with a Vendor or service provider plus amount of time that is defined by law in your country.

If personal data belongs to individual who is no longer represent a Vendor or service provider, personal data may be deleted immediately after provision of information to consideration of Ciklum’s Data Privacy Team via data.privacy@ciklum.com.

Types of information

Ciklum may collect and process the following information:

  • Information about an individual applying for relocation to one of Ciklum`s offices: name, surname, maiden name (if applicable), date of birth, place of birth, nationality, current address, passport number, phone, email, registration address, marital status, countries of legal residency in the last 5 years, parents’ names, education, scan copy of travel passport, scan copy of previous travel passport, scan copy of national passport, photo, scan copies of diplomas, certificates, labour book, bank statement, individual entrepreneur registration documents, relocation country, native country, marital status, number of children, visa issue date, visa expiry date; residence permit number and expiry date, parents’ information (including name, surname, maiden name, data of birth), personal data of the family member who is an EEA citizen (including name, surname, maiden name, date of birth, social security number, if applicable).
  • Information about adult dependents of the individual: name, surname, maiden name (if applicable), citizenship, relationship with the individual being relocated, phone, email, registration address, nationality, full names of parents, photo, passport number, date of birth, nationality at birth, place of birth, marital status, scan copy of travel passport, scan copy of previous travel passport, scan copy of national passport, travel passport number, date of issue, date of expiry, issuing authority, national passport number, tax number, US social security number (if applicable), address, email, phone, countries where the person lived, current occupation, Schengen and national visa information, parents’ information (including name, surname, maiden name, data of birth), personal data of the family member who is an EEA citizen (including name, surname, maiden name, date of birth, social security number, if applicable), scan copy of tax ID, scan copies of diplomas, certificates, labour book, relocation country, native country, number of children, visa issue date, visa expiry date; residence permit number and expiry date.
  • Information about children participating in relocation: name, surname, gender, citizenship, place of birth, date of birth, passport number, US social security number (if applicable).

Purposes of processing

All personal data is processed in order to support your approved relocation (including that of your dependents and children, if applicable) to one of Ciklum`s offices of your choice or to our client`s location. Please note that you may always refuse collection and processing of your data and obtain work permit and visa without assistance by Ciklum.

Recipients

Your personal data may be wholly or partially disclosed to the following third parties:

  • companies of the Ciklum Group;
  • email service provider if the data is transferred to us via email;
  • attorneys supporting visa opening process;
  • embassies and immigration offices of the destination country;
    a client sponsoring of your relocation;
  • service providers used for exchange of information between you, Ciklum and the above third parties.

Retention period

Personal data is retained during performance of contractual relationship with relocated individual plus 1 year.

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By submitting completed “Contact Us” form, your personal data will be processed by Ciklum Group and its subsidiary entities worldwide. Please read our Privacy Notice for more information. If you have any questions regarding your rights or would subsequently decide to withdraw your consent, please send your request to us.

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