Adatkezelési tájékoztató

1. Introduction

This Privacy Policy explains what we do with your personal data, whether we are in the process of helping you find a job, continuing our relationship with you, using your data to inform you of our latest job offers or you are visiting our website. This Privacy Policy can be changed from time to time. It can be the case if the range of our services expands or if it is required by legislation. Information on the changes will be published 10 days in advance in the form of a message on the website www.gmedrecruit.com. Data subjects will accept the amendments to this Privacy Policy by continuing the use of our services upon such amendments have entered into force. Please just visit this page if you want to stay up to date, as we will post any changes here.

The collection, storing and processing of any form of personal data by AM Vitality Kft. (headquarters: Horvát u. 14-24., 1027 Budapest, Hungary, registration number: 01-09-180889) is in compliance with the applicable provisions of data protection laws, in particular the provisions of the Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 on the protection of natural persons with regard to the processing of personal data and on the free movement of such data, and repealing Directive 95/46/EC (General Data Protection Regulation, hereafter: “GDPR”) and the Hungarian Act No. CXII of 2011 on the right of self-determination and freedom of information (hereafter: „Infotv.”)

By submitting your CV you expressly accept that AM Vitality Kft. may process your personal data as provided by you in accordance with the objectives set out in this Privacy Policy for the time period and to the extent required to realize these objectives.

Controller of personal data: AM Vitality Kft.

Place of processing data: Horvát u. 14-24., 1027 Budapest, Hungary

Contact details of the controller of personal data:

Telephone: + 36-70-60-88390; + 36-70-60-88391;

E-mail:info[at]gmedrecruit.com and cv[at]gmedrecruit.com

These e-mail addresses are being protected from spambots. JavaScript has to be enabled to view them.

2. Objective of processing of personal data:

Personal data of candidates, clients, suppliers and referees are collected, processed and used only in the context of recruitment and other related services. We collect your personal data as follows:

• if you are a candidate, directly from you or from third persons;
• if you are a client, directly from you or from third persons;
• if you are a supplier, during the course of our work with you;
• if you are a referee, from our candidates who mention you as a referee;
• if you are a visitor of our website, automatically via cookies, in line with cookie settings in your browser.

All personal data shall be processed in accordance with the legal bases specified in Clause 3. The objective of processing personal data is:

1. Collecting your data from you and other sources, such as LinkedIn;
2. Storing your details (and updating them when necessary) on our database, so that we can contact you in relation to recruitment;
3. Assessing data about you against vacancies which we think may be suitable for you;
4. Contacting you for the purpose of shortlisting via skype and telephone interviews;
5. Sending you information on potential job offers we think may be of interest to you;
6. Sending information from you to Clients in order to apply for jobs or to assess your eligibility for jobs;
7. Forwarding your personal data to our partner companies in EEA Member States so that you can apply for further vacancies;
8. Carrying out our obligations arising from any contracts entered into between us and third parties in relation to your recruitment;
9. Complying with our reporting obligation in accordance with the Hungarian Government Decree No. 118/2001 (VI.30.) on the provisions for registration and performance of activities of personnel services;
10. Facilitating our payroll and invoicing processes;
11. Improving your experience of using our website via cookies (e.g. by analysing search criteria of your job searches).

The collected personal data – without any direct link to any specific data subject – may be used to compile statistics and publications.

3. Legal bases for the processing of your data
   
   A) YOUR CONSENT

Pursuant to Article 6 (1) (a) of the GDPR we may process your data if you have given consent hereto. We make explicit reference to the content of this Privacy Policy on our website at the contact form in a way that you may not submit your CV via this contact form without giving your consent to the processing of your personal data in accordance with the provisions of this Privacy Policy. Furthermore, we explicitly indicate in all our job offers published on external websites that you shall read this Privacy Policy prior to submitting your application and that by submitting your application you confirm that you have read and understood this Privacy Policy and give consent to the processing of your personal data. The processing of your data pursuant to Clause 2 paragraphs a) to e) above is based on your explicit consent.

B) LEGITIMATE INTEREST

Pursuant to Article 6 (1) (f) of the GDPR we may process your data where it is necessary for the purposes of the legitimate interests pursued by us or by a third party, except where such interests are overridden by the interests or fundamental rights or freedoms of you which require protection of personal data.

We think it’s reasonable to expect that if you are looking for employment or have posted your professional CV information on a job board or professional networking site, you are happy for us to collect and otherwise use your personal data to offer or provide our recruitment services to you, share that information with prospective employers and assess your skills against our bank of vacancies. Once it’s looking like you may get the job, your prospective employer may also want to double check any information you’ve given us or to confirm your references and qualifications to the extent that this is appropriate and in accordance with local laws. We need to do these things so that we can function as a profit-making business, and to help you and other Candidates get the jobs you deserve.

We want to provide you with tailored job recommendations to help you on your job hunt. We therefore think it’s reasonable for us to process your data to make sure that we send you the most appropriate content.

We have to make sure our business runs smoothly, so that we can carry on providing services to Candidates like you. We therefore also need to use your data for our internal administrative activities, like payroll and invoicing where relevant.

The processing of your personal data pursuant to Clause 2 f) to h) and j) to k) is based on our legitimate interests. We don’t think that any of the following activities prejudice individuals in any way – in fact, they help us to offer you a more tailored, efficient service, so everyone’s a winner! However, you do have the right to object to us processing your personal data on this basis.

C) COMPLIANCE WITH LEGAL OBLIGATIONS

We shall comply with our own obligations under the law and it is a legitimate interest of ours to insist on meeting these obligations. If we believe in good faith that it is necessary, we may therefore share your data in connection with crime detection, tax collection or actual or anticipated litigation.

As a provider of personnel services, we shall comply with a reporting obligation specified in Article 13 of the Hungarian Government Decree No. 118/2001 (VI. 30.) pursuant to which we shall deliver statistical data to the relevant local government office about the number of successful and failed placements sorted by sex, age, education, profession, citizenship and country of destination.

The processing of your personal data in accordance with Clause 2 i) and the forwarding of your data in connection with crime detection, tax collection or actual or anticipated litigation is aimed to comply with a legal obligation and is based on Article 6 (1) (c) of the GDPR.

D) ESTABLISHING, EXERCISING OR DEFENDING LEGAL CLAIMS

Sometimes it may be necessary for us to process personal data and, where appropriate and in accordance with local laws and requirements, sensitive personal data in connection with exercising or defending legal claims. Article 9(2)(f) of the GDPR allows this where the processing “is necessary for the establishment, exercise or defence of legal claims or whenever courts are acting in their judicial capacity”.

This may arise for example where we need to take legal advice in relation to legal proceedings or are required by law to preserve or disclose certain information as part of the legal process.

Scope of the processed personal data

The following personal data are collected from the candidates: name; age/date of birth; place of birth; sex; citizenship; photograph; marital status; contact data; education details; language skills; employment history (experience); payment expectations; contact information regarding the contact person for your referees; certificates; information on your interests, objectives of employment and motivation; copy of your identity card or passport; IP address; the dates, times and frequency with which you access our website and additional information that you choose to tell us in your CV.

From our clients and suppliers we collect the contact details of individual contacts within the organisation (such as their names, telephone numbers and email addresses) to enable us to ensure that our relationship runs smoothly.

From the persons who our candidates indicate in their applications as referees we collect their contact details (such as their names, telephone numbers and email addresses)

From the visitors of our website we collect your browser type, the location you view our website from, the language you choose to view it in and the times that our website is most popular as well as information on how you use our website and the frequency with which you access it.  If you contact us via the website we will collect any information that you provide to us, for example your name and contact details.

Who do we share your personal data with?

We may share your personal data with the following categories of people:

• Third party service providers who perform functions on our behalf (including external consultants, business associates and professional advisers such as lawyers, auditors and accountants, technical support functions and IT consultants carrying out testing and development work on our business technology systems);
• Tax, audit, or other authorities, when we believe in good faith that the law or other regulation requires us to share this data;
• in the case of candidates: potential employers in EEA Member States, in particular hospitals, medical practices, nursing homes and other healthcare institutions;
• in the case of candidates: HR consultant companies and HR service providers in EEA Member States.

To protect your identity and legitimate interests, we disclose your profile to potential employers at first only in anonym form and we request our business HR consultant companies and HR service providers partners (HR consultant companies and HR service providers) to whom we forward your data to increase your chances to find the right job to do so as well. When a potential employer expresses his interest for your profile, we inform you hereof under specification of the name of the employer and we ask you for your consent to disclose your name and contact details to the potential employer.

6. Term of data processing

If we have not had meaningful contact with you (or, where appropriate, the company you are working for or with) for a period of three years, we will delete your personal data from our systems. When we refer to “meaningful contact”, we mean, for example, communication between us (either verbal or written), or where you submit your updated CV onto our website. We will also consider it meaningful contact if you communicate with us about potential roles, either by verbal or written communication or click through from any of our marketing communications.

7. Rights of the data subject
8. A) RIGHT OF ACCESS

We provide access to your personal data, i.e. you may anytime request a confirmation from us about what kind of your personal data are processed by us and you may request the following information pertaining to these data:

(a) the purposes of the processing;

(b) the categories of personal data concerned;

(c) the recipients or categories of recipient to whom the personal data have been or will be disclosed;

(d) where possible, the envisaged period for which the personal data will be stored, or, if not possible, the criteria used to determine that period;

(e) the existence of the right to request from the controller rectification or erasure of personal data or restriction of processing of personal data concerning the data subject or to object to such processing;

(f) the right to lodge a complaint with a supervisory authority; and

(g) where the personal data are not collected from the data subject, any available information as to their source.

If we provide you with access to the information we hold about you, we will not charge you for this unless your request is “manifestly unfounded or excessive”. If you request further copies of this information from us, we may charge you a reasonable administrative cost where legally permissible.

B) right to object

This right enables you to object to us processing your personal data where we do so for one of the following four reasons: (i) our legitimate interests; (ii) to enable us to perform a task in the public interest or exercise official authority; (iii) to send you direct marketing materials; and (iv) for scientific, historical, research, or statistical purposes.

The “legitimate interests” category above is the one most likely to apply to our website users, candidates, clients and suppliers by ceasing the activity in question unless:

• we can show that we have compelling legitimate grounds for processing which overrides your interests; or
• we are processing your data for the establishment, exercise or defence of a legal claim.
C) RIGHT TO WITHDRAW CONSENT

Where we have obtained your consent to process your personal data for certain activities, you may withdraw this consent at any time and we will cease to carry out the particular activity that you previously consented to unless we consider that there is an alternative reason to justify our continued processing of your data for this purpose in which case we will inform you of this condition.

D) right to erasure

You have the right to request that we erase your personal data in certain circumstances. Normally, the information must meet one of the following criteria:

• the data are no longer necessary for the purpose for which we originally collected and/or processed them;
• where previously given, you have withdrawn your consent to us processing your data, and there is no other valid reason for us to continue processing;
• the data has been processed unlawfully (i.e. in a manner which does not comply with the GDPR);
• it is necessary for the data to be erased in order for us to comply with our legal obligations as a data controller; or
• if we process the data because we believe it necessary to do so for our legitimate interests, you object to the processing and we are unable to demonstrate overriding legitimate grounds for our continued processing.
E) RIGHT TO RESTRICT PROCESSING

You have the right to request that we restrict our processing of your personal data in certain circumstances. This means that we can only continue to store your data and will not be able to carry out any further processing activities with it until either: (i) one of the circumstances listed below is resolved; (ii) you consent; or (iii) further processing is necessary for either the establishment, exercise or defence of legal claims, the protection of the rights of another individual, or reasons of important EU or Member State public interest.

The circumstances in which you are entitled to request that we restrict the processing of your personal data are:

• where you dispute the accuracy of the personal data that we are processing about you. In this case, our processing of your personal data will be restricted for the period during which the accuracy of the data is verified;
• where you object to our processing of your personal data for our legitimate interests. Here, you can request that the data be restricted while we verify our grounds for processing your personal data;
• where our processing of your data is unlawful, but you would prefer us to restrict our processing of it rather than erasing it; and
• where we have no further need to process your personal data but you require the data to establish, exercise, or defend legal claims.

If we have shared your personal data with third parties, we will notify them about the restricted processing unless this is impossible or involves disproportionate effort. We will, of course, notify you before lifting any restriction on processing your personal data.

F) right to rectification

You also have the right to request that we rectify any inaccurate or incomplete personal data that we hold about you. If we have shared this personal data with third parties, we will notify them about the rectification unless this is impossible or involves disproportionate effort. Where appropriate, we will also tell you which third parties we have disclosed the inaccurate or incomplete personal data to. Where we think that it is reasonable for us not to comply with your request, we will explain our reasons for this decision.

G) RIGHT OF DATA PORTABILITY

If you wish, you have the right to transfer your personal data between data controllers (e.g. HR agencies, employers, employment bureau). To allow you to do so, we will provide you with your data in a commonly used machine-readable format that is password-protected so that you can transfer the data to another online platform. Alternatively, we may directly transfer the data for you. This right of data portability applies to: (i) personal data that we process automatically (i.e. without any human intervention); (ii) personal data provided by you; and (iii) personal data that we process based on your consent or in order to fulfil a contract.

H) RIGHT TO LODGE A COMPLAINT WITH A SUPERVISORY AUTHORITY

You have the right to submit a complaint pertaining to the processing of your personal data directly to us. We will do our best to eliminate and remedy eventual violations of your privacy as soon as possible.

Pursuant to Article 52 (1) of Infotv. you also have the right to lodge a complaint with the Hungarian supervisory authority at the following contact details:

Name of the authority: Nemzeti Adatvédelmi és Információszabadság Hatóság

Address of the authority: H-1125 Budapest, Szilágyi Erzsébet fasor 22/c

Telephone: +36 1 391 1400

Fax: +36 1 391 1410

E-mail: ugyfelszolgalat@naih.hu

You can submit your request as per Clause 7 from Section A) to H) via an e-mail to info@gmedrecruit.com or cv@gmedrecruit.com or via a letter by post sent to the following address of our office: Horvát u. 14.-24., Budapest 1027, Hungary. These e-mail addresses are being protected agains spambots. JavaScript has to be enabled to view them. We may ask you to verify your identity and for more information about your request. We will not charge you for processing your request unless your request is manifestly unfounded or (in particular in case of frequent repetition) excessive.

We are obliged to provide the requested information within one month upon the receipt of your request in a comprehensive and written form. This period may be extended by two further months where necessary, taking into account the complexity and number of the requests. Where we are legally permitted to do so, we may refuse your request. If we refuse your request we will always tell you the reasons for doing so.

8. Data security

The storage and processing of your personal data is managed at the registered seat of AM Vitality Kft. via the database on the website www.gmedrecruit.com. We will take all administrative, IT and physical security measures to protect your personal data and the contact form containing such data from unauthorized access, modifications, transmission, erasure, destruction, damages or loss.

This website uses SSL or TLS encryption for security reasons and to protect the transmission of confidential content, e.g. orders and requests that you send us as the operator of the website. You may recognize an encrypted connection when the address line of your browser changes from “http://” to “https://” and an icon of a lock appears. When the SSL or TLS encryption is active, third parties may not spy out data transmitted from you to us.

If you suspect any misuse or loss of or unauthorised access to your personal information please let us know immediately.

9. Cookies Policy

A “cookie” is a piece of information that is stored on your computer’s hard drive and which records your navigation of a website so that, when you revisit that website, it can present tailored options based on the information stored about your last visit. Cookies can also be used to analyse traffic and for advertising and marketing purposes. Cookies are used by nearly all websites and do not harm your system. If you want to check or change what types of cookies you accept, this can usually be altered within your browser settings. Upon deactivating cookies, the functionality of this website may be impaired.

Most of the cookies we use are so-called „session cookies“. These are automatically deleted when you close your browser. Other cookies are stored on your end device until you delete these. Such cookies enable for us to recognize your browser upon your next visit to our website.

We use cookies to do two things:

• to track your use of our website. This enables us to understand how you use the site and track any patterns that emerge individually or from larger groups. This helps us to develop and improve our website and services in response to what our visitors want and need; and
• to help us advertise jobs to you that we think you’ll be interested in. Hopefully this means less time for you trawling through endless pages and will get you into the employment you want more quickly.

The analysis of your browsing conduct is carried out generally anonymously; your surfing conduct cannot be tracked back. You can object to this analysis pursuant to Clause 7 Section B) above.

Cookies that are necessary for the performance of communication processes or providing certain functions upon your request will be stored on the legal basis under Article 6 (1) (f) of the GDPR. The operator of the website has a legitimate interest to store cookies to provide his services in an optimal and faultless way.