Personal Data Processing Policy
The definitions used in this Personal Data Processing Policy have the meaning given below:
1.1 Personal Data – any information about a natural person whose identity has been determined or whose identity can be directly or indirectly determined (data subject), e.g. by name and surname, date of birth, postal or email address, or by physical, physiological, genetic, psychological etc. features.
1.2 Person – any natural person, whose Personal Data is processed (data subject), e.g. a candidate, an employee, or any other natural person.
1.3 Controller – the controller of Personal Data is Tribe Payments Ltd.
1.4 Candidate – a natural person, whom the Controller has already contacted and who has agreed to collaborate with the Controller, has filled out the necessary forms and has provided their Personal Data required for the Controller to provide potential job offers, invite them to recruitment sessions and offer an employment contract if selected.
1.5 Data processing – any action related to Personal Data, e.g. collecting, recording, sorting, structuring, storing, adapting or altering, viewing, using, disclosing, restricting, deleting or destroying etc.
1.6 Supervisory Authority – an independent government authority responsible for the supervision of compliance with the Data Processing requirements, which also has other General Data Protection Regulation -defined rights and functions.
2 PERSONAL DATA PROCESSING PRINCIPLES
In processing Personal Data, Tribe Payments Ltd adheres to the following principles:
2.1 Compliance with the General Data Protection Regulation (hereinafter referred to as GDPR)
2.2 Personal Data shall be managed in a legitimate, honest and transparent manner;
2.3 Personal Data shall be collected for fixed, clearly defined and legitimate purposes;
2.4 All reasonable means shall be taken to ensure that Personal Data that is not accurate or comprehensive, considering the purpose for which it is being processed, shall be immediately corrected, appended, or shall cease to be processed or shall be destroyed;
2.5 Personal Data is stored in a form that allows determining the Person’s identity for a time period that is only as long as necessary for the purposes for which the Personal Data is being processed;
2.6 Personal Data shall not be supplied to third persons or published, excluding cases stipulated in the Personal Data processing policy or cases stipulated by legislation.
2.7 It shall be ensured that Personal Data is processed in a way that, by applying appropriate technical or organisational means, ensures the proper safety of Personal Data, including protection from unauthorised or illegal data processing and from accidental loss, destruction or damage.
3 PURPOSES OF THE COLLECTION AND PROCESSING OF PERSONAL DATA
Tribe Payments Ltd processes data in the following ways:
3.1 When a Person submits it to our company themselves. A Person submits their Personal Data to us when they send in CVs and covering letters or when they register on our website, communicate with us on the phone, by email or during meetings, fill out our questionnaires, perform tasks or tests. When a Person contacts us by writing or email, Tribe Payments Ltd store the correspondence data.
3.2 When a Person uses our website. When a Person uses the Tribe Payments Ltd website, Tribe Payments Ltd will receive certain information (e.g. the internet protocol (IP) address, the type of internet browser used, the number of visits, website pages viewed, time spent on the website etc.).
Tribe Payments Ltd processes data for the following purposes:
3.3 For the purpose of administrating the work and activities of the staff. The Personal Data of the employees of the company Tribe Payments Ltd is processed under the procedure stipulated by the Employee Personal Data Protection Policy. For this purpose, the employee data is only stored for as long as is stipulated by legislation.
3.4 For the purpose of selecting candidates for jobs available at the company, the data is processed in order to find candidates that meet the necessary requirements to work at the company, select the best ones and determine whether the candidates are suitable for the job offered.
For that purpose, Tribe Payments Ltd processes the data provided by the candidates themselves (e.g. data provided in CVs, data collected through communication etc.) or collected while using our website and (or) social media, means of public information etc.
For that purpose, the Personal Data is stored for 12 months from the day when the Person provided their data to us for the first time or renewed it unless a separate permission has been received from the person to keep the data longer.
3.5 For the purpose of administrating the database of candidates for job positions at the company. After a specific recruitment in our company ends, for which the Person had provided their data, the Personal Data is processed in order for the company to be able to offer the candidate jobs and career opportunities in the future, find candidates that meet the needs of the company, as well as select them and determine whether or not they are suitable for the job offered.
For that purpose, the Personal Data is stored for 24 months from the day when the person provided their data to us for the first time or renewed it unless a separate permission has been received from the person to keep the data longer.
Tribe Payments Ltd does not process personal data for any other purposes that would be incompatible with those listed above.
4.1 Cookies are small files temporarily saved onto the hard drive of the user’s device that allow recognising the user during later visits to websites, storing the person’s browsing history and options, tailoring content, making searches within the websites faster, creating a convenient and friendly website environment that can be offered more effectively and reliably. Cookies are a common practice when browsing websites and make them easier to use.
4.2 The information received through cookies is used to ensure the functionality of websites.
5 PERSONAL DATA PROTECTION
5.1 Tribe Payments Ltd guarantees that Personal Data will not be sold, supplied or otherwise transferred to third persons without legal grounds, or used for any purpose other than what they had been collected for. Tribe Payments Ltd does not disclose Personal Data in any way other than in accordance with this personal data processing policy and legislation.
5.2 However, Tribe Payments Ltd reserves the right to disclose information about a person if it is required to do so by law or if it were requested by legitimately acting institutions or institutions conducting criminal persecution.
5.3 Tribe Payments Ltd stores Personal Data for no longer than is required for the purposes for which the data is processed or is stipulated by legislation if the latter specifies a longer data storage duration.
5.4 Data collected from Persons by Tribe Payments Ltd will be located within the territory of the European Union but may be transferred or stored outside the EU. It may also be processed by the staff of Tribe Payments Ltd or its suppliers working from outside the EU. When transferring Personal Data outside the EU, all the necessary precautions will be taken to ensure that the Personal Data is processed securely and in compliance with this Personal Data processing policy.
5.5 Upon learning about a violation of Personal Data security that could pose a threat to personal rights or freedoms, Tribe Payments will inform you immediately upon receiving such knowledge and determining that access had been gained to such information.
6 RIGHTS OF THE DATA SUBJECT
When processing your Personal Data, Tribe Payments Ltd ensures your rights under GDPR.
The personal data subject has the following rights:
6.1 to know (be informed) about the processing of their Personal Data;
6.2 to review and have access to their Personal Data processed by the company;
6.3 to demand to correct, append, or specify incorrect, inaccurate, incomplete Personal Data;
6.4 to demand to destroy Personal Data it is no longer required for the purposes for which it had been collected;
6.5 to demand to destroy Personal Data when it is being processed illegally or when the person cancels their permission to process Personal Data or does not give such a permission that is necessary;
6.6 to not agree with the processing of their Personal Data or to cancel a prior permission;
6.7 to demand to stop the actions of Personal Data processing (excluding storage) if disputes are underway or the legitimacy of data processing has to be reviewed, as well as in cases when the company no longer needs Personal Data but the person does not want it to be destroyed.
6.8 to understand if Personal Data is being used in automated decision making and profiling
7 Demands pertaining to the implementation of the rights of a Personal Data subject may be posed to the company by email at email@example.com
After receiving your request, the company may request documents proving your identity and additional necessary information related to the request.
7.1 After receiving a demand from the personal data subject, Tribe Payments Ltd shall respond to it no later than over 30 calendar days from receiving the demand and the day of receiving all the documents necessary for providing a response.
7.2 If the Personal Data subject legitimately cancels their prior permission to process Personal Data, Tribe Payments Ltd shall no later than within 3 business days cease the actions of processing such Personal Data, excluding cases when it is obligated to continue processing personal data under the applicable legislation, legal obligations, court rulings or mandatory orders received by the company from authorities.
7.3 If a person would like to submit a complaint regarding the processing of data carried out by Tribe Payments Ltd, they shall submit it by email to firstname.lastname@example.org providing as much information as possible. Tribe Payments Ltd collaborates with Personal Data subjects and strives to immediately resolve all issues.
Tribe Payments Ltd will provide you with information on any issues covered by this Personal Data Processing Policy by email at email@example.com