Privacy Notice
1. General
1.1. This Notice on the processing of personal data (hereinafter: "Notice") is issued by MANPOWER d.o.o. Zagreb, Ulica grada Vukovara 23, OIB 35539279541, company registered in the Register of Temporary Employment Agencies under number 28/09 based on the decision of the Ministry of Labour, Pension System, Family and Social Policy, Class: 102-02/21-03/28, Reg.No.: 524-04-01-02/1-21-2 (hereinafter: "Company" or "We"). In this sense, the Company has the position of the controller of your personal data.
1.2. This Notice contains information about the processing of your personal data if you are a job candidate, whether you have applied for a specific job posting or registered in our candidate database; if you are our business or other partner or their employee or representative ("you").
1.3. This Notice is published on the date indicated above and replaces the earlier version. Any references to the "privacy rules", "privacy policy" or "privacy statement" shall be considered as references to this Notice.
1.4. In case of any questions or requests regarding the handling or protection of your personal data, please contact us at [email protected] or by post at the company’s registered address: Ulica grada Vukovara 23, Zagreb, with the note "PERSONAL DATA PROTECTION".
2. Personal data
2.1. Personal data mean any data relating to a natural person on the basis of which an individual can be directly or indirectly identified. To identify directly means that it is clear from the data itself to which individual it refers. Indirectly identify means that it is possible to identify an individual based on more information available to us.
2.2. Data relating to legal entities is not considered personal data. Therefore, this Notice is intended exclusively for natural persons whom we can identify based on the information available to us.
3. Applications for a job postings and applications to the candidate database
3.1. This Notice also regulates the issue of the protection of your personal data as well as your privacy if you are looking for a job and/or have applied to our database of candidates.
3.2. Once you have been employed by us, a separate Privacy Policy (Data Processing Notice) for employees will apply to you. In this case, we will request additional data required by employee record regulations, for the execution of the employment contract, or for other purposes.
3.3. Which of your personal data do we process?
We process the personal data that you have provided to us as well as those that we have collected in the process of searching for and assessing candidates, i.e. the following data:
3.3.1. Your basic personal data
Name, last name, address, date and place of birth;
3.3.2. Your contact details
Permanent or temoporary residence (street and house number, town, postal code), mobile phone and/or telephone number, E-mail address; URL profile on social networks;
3.3.3. Additional information relevant to the selection of candidates
Education data (including the name of the educational institution, the title of the diploma, the length of schooling, knowledge of foreign languages, computer work and driving licence); Information about previous work experience (including names/companies of previous
employers, the position you held and the duration of the employment relationship); Information about previous projects (including project name, project URL, project description and project duration);
Test results;
3.3.4. Your photo (if you have attached one).
3.4. For what purpose do we process your personal data?
3.4.1. To determine if you are interested in finding a job or change your existing job and include you in our CV database. For this purpose, we may process your publicly available personal data (e.g. on the portal of the Croatian Employment Service or on other platforms) as well as data that you have provided to us (e.g. in unsolicited applications, job applications, etc.). In this
case, the basis for the processing of your personal data is our legitimate interest (there is our mutual interest in your employment) as a temporary employment agency. To undertake actions necessary to select and hire new employees and make them available to our users (for example, to select candidates for a job interview, to organize interviews, psychological and other testing, and to present potential candidates to our users – companies to which you will be assigned upon employment). In this case, the basis for the processing of your personal data is our legitimate interest as a temporary employment agency;
3.4.2. In order to carry out the recruitment procedure, i.e. the assessment and selection of candidates, as well as if we have your consent for this, for contacting you in case we are looking for candidates for a new position;
3.4.3. To send you our newsletter or perform other marketing activities (such as market research and statistical studies), provided you have given consent for such communication when registering in our CV database. In this case, the basis for the processing of your personal data is your consent;
3.4.4. To comply with our legal obligations (for example, to respond to a data subject's request). In this case, the basis for the processing of your personal data is the fulfillment of our legal obligation;
3.4.5. To protect our legitimate interests (for example, when it is necessary to implement security measures for our network and information systems). In this case, the basis for processing your personal data is our legitimate interest;
3.4.6. In addition, if we have been in contact with you regarding a specific position that you did not accept or was ultimately not offered to you, if you have given your consent, we will continue to process your personal data in the event of future job postings for which you may be a suitable candidate.
4. Contact form
4.1. Which of your personal data do we process?
4.1.1. If you have contacted us via one of the forms on our website (contact form), we process your following data (depending on which data you have entered): Name and last name, E-mail address and phone number, country, your job title, your employer's company name, reason for contact, message;
4.2. For what purpose do we process your personal data?
4.2.1. For the purpose of responding to your message. In this case, the basis for the processing of your personal data is our legitimate interest, based on your message.
5. Newsletter
5.1. Which of your personal data do we process?
5.1.1. If you have signed up to receive our newsletter, we process the following personal data that you have provided to us when subscribing to the newsletter:
Your e-mail address.
5.2. For what purpose do we process your personal data?
5.2.1. To deliver our newsletter to you. In this case, the basis for the processing of your personal data is our legitimate interest because you have expressed your interest by subscribing to our newsletter.
6. Visitors to our social media websites
6.1. If you are a Facebook user and you have visited our Facebook page, Meta Platforms Ireland Limited (4 Grand Canal Square, Grand Canal Harbour, Dublin 2 Ireland, hereinafter referred to as "Meta") and we are jointly controllers of your personal data.
6.2. Meta processes your personal data as a visitor to our Facebook page in accordance with its rules (more on this Meta Privacy Policy – How Meta collects and uses user data | Privacy Centre | Manage your privacy on Facebook, Instagram and Messenger | Facebook Privacy), while we influence this processing only by specifying which groups of Facebook users (for example, by age, gender, etc.) are of business interest to us.
6.3. We are responsible for all our posts and messages via Facebook independently. Meta was not involved in this process or consulted prior to the individual post/message. Meta does not necessarily share our views, vision, etc., stemming from our posts/messages.
6.4. We receive user data from Meta exclusively on a statistical, for us anonymized, basis. If you have left a comment, inquiry or similar on our Facebook page, we will not store or process your data separately.
6.5. This also applies to our other social media websites, such as LinkedIn
(https://www.linkedin.com/legal/privacy/eu) or YouTube
(https://www.youtube.com/howyoutubeworks/our-commitments/protecting-user-data/).
7. Our business partners
7.1. Which of your personal data do we process?
7.1.1. We process the personal data that you have provided to us as well as those that we have collected when establishing and maintaining our business relationship. These are the following data (data of the authorized person and contact person):
Name, last name, connection to the legal entity (owner, director, employee or similar); Phone, E-mail address.
7.2. For what purpose do we process your personal data?
7.2.1. To fulfil our contractual obligations to you and to take other necessary actions related to the conclusion and performance of a contract (e.g. issuing invoices) or prior actions (e.g. sending offers). In this case, the basis for the processing of your personal data is the performance of our contract or taking actions at your request before concluding the contract. If you are an employee or representative of our business partner, the legal basis is our legitimate interest due to our business relationship with your employer;
7.2.2. For other purposes where we have a legitimate interest as your business partner (for example, when it is necessary to assess your satisfaction with our services, etc.);
7.2.3. To fulfill our legal obligations.
8. Who has access to your personal data?
8.1. We consider your personal data to be a business secret and protect it in accordance with applicable legal regulations and best practices.
8.2. Third parties have the right to access and process your personal data only in the situations described below:
8.2.1. Our users (employers to whom you will be referred if we hire you) have the right to access your personal data if you are a candidate who meets their requirements. For instance, if you have applied for a job posting for a certain position, after which we have contacted you to access the selection process, introduced you to the employer's identity and you met the required criteria during the process, we share your data with the user who ordered that posting;
8.2.2. Affiliated companies that also perform activities of temporary employment agencies or related activities, if we determine that they have open job postings for which you may be a suitable candidate;
8.2.3. Third party service providers who provide us with services necessary for our operational activities, such as accounting services, postal services, archiving, etc. In this case, they process your personal data exclusively in accordance with our instructions;
8.2.4. Third party service providers whose services we use to comply with a legal obligation or when we have a legitimate interest, and who process your personal data in accordance with the legal authorizations granted to them. In this case, they process your personal data on the basis of and in accordance with legal authorizations. For example, these includes various consultants, auditors and similar professionals;
8.2.5. Competent authorities conducting supervision over the legality of business operations and actions. In such cases, they process your personal data in accordance with their legal authority.
9. Profiling and automated decision-making
9.1. We do not carry out automated decision-making based on your personal data, nor do we create data subject profiles for such purposes.
10. Are my personal data transferred to third countries?
10.1. Your personal data are only exceptionally transferred to third countries, when they are processed by our affiliated companies in those countries for the purposes of your employment. We ensure that all transfers of your personal data comply with applicable data protection laws and that we have appropriate safeguards in place to ensure the protection of your data. For example, we enter into contracts with our affiliates that include standard contract clauses approved by the European Commission.
11. How do we protect your personal data?
11.1. The protection of your personal data is extremely important to us. Some of the protection measures we implement are the following:
11.1.1. Implementation database pseudonymization whenever possible;
11.1.2. Minimization of personal data processing (handling only the necessary data set for a particular process);
11.1.3. Ensuring confidentiality in the handling of personal data both internally and externally;
11.1.4. Application of modern methods of data protection and control of access to data resources containing personal data;
11.1.5. Continuous monitoring of all resources used for personal data processing.
12. Retention period of your personal data
12.1. For personal data for which there is a statutory retention period (for example in accordance with accounting regulations), we retain your personal data during that mandatory period. We delete them after the expiration of the mandatory period, in an additional period of one year.
12.2. For personal data for which there is no legally defined mandatory retention period, we proceed as follows:
12.2.1. We store personal data that we process on the basis of your consent for the duration of the consent and delete it after the expiration of the consent. In the case of withdrawal of consent, we delete them as soon as possible;
12.2.2. Personal data that we process based on our legitimate interest, we store as long as our legitimate interest exists - we delete them within a period of one year from the termination of our legitimate interest. In case of a job application, if you have not been selected for the job and have not given a consent for a future processing, your application and related data will be deleted after the end of recruitment process.
13. Your rights
13.1. In the event that you decide to exercise one or more of our rights listed below, we have the right to verify your identity, all for the purpose of protecting your personal data.
13.2. You exercise your rights free of charge. However, if you frequently (for example, if less than 6 months have passed since your last request) or excessively (for example, if you request all your personal data in writing) request access to or transfer of your personal data, we have the right to ask you to pay our costs before carrying out such action.
13.3. You can exercise your rights by (1) sending your request to the adress [email protected], (2) stating "Data subject request" as the subject of the message, (3) explaining in the message itself which right you wish to exercise, and (4) providing
13.3. You can exercise your rights by (1) sending your request to the adress [email protected], (2) stating "Data subject request" as the subject of the message, (3) explaining in the message itself which right you wish to exercise, and (4) providing
information by which we can identify you. Upon receipt of the message, we will send you a confirmation of receipt. Please note that you can only exercise your rights in relation to your own personal data. You can also send your request by post to the address MANPOWER d.o.o., Ulica grada Vukovara 23, 10 000 Zagreb.
13.4. Access to personal data
You have the right to request confirmation from us as to whether we are processing your
personal data, access to your personal data and obtain information on how we process it.
13.5. Correction of inaccurate personal data
You have the right to request the correction of your inaccurate personal data, as well as the right to complete your personal data.
13.6. Restriction of processing of personal data
If you dispute the accuracy of your personal data or in other situations provided for by the General Data Protection Regulation, you have the right to request the restriction of the processing of your personal data until such situation is resolved.
13.7. Deletion of personal data
If you withdraw your consent to the processing of your personal data, or when the legal basis for the processing of your personal data ceases to exist, or in other cases provided for by the General Data Protection Regulation, you have the right to request the deletion of your personal data.
13.8. Portability of personal data
You have the right to request the transfer and obtain your personal data.
13.9. Objection to the processing of personal data
You have the right to object to the processing of your personal data as well as to our general handling of your personal data.
13.10. Withdrawal of consent
You have the right to withdraw your consent to further processing of your personal data at any time. The withdrawal of consent does not affect the processing carried out on the basis of consent prior to its withdrawal.
13.11. Complaint to the Croatian Personal Data Protection Agency
At any time, you have the right to file a complaint with the competent authority for personal data protection – the Croatian Personal Data Protection Agency (www.azop.hr), regarding the processing and protection of your personal data.
14. Final Remarks
14.1. We may unilaterally amend this Notice at any time to ensure it aligns with our current
