Privacy Notice

Effective as of 19 April 2023

1. Introduction

This Privacy Notice contains information how Tripod companies manage the information obtained from candidates, our clients, cooperation partners, website (www.tripod.ee, the Website) and/or from third parties to provide various services and functionalities.

Tripod companies in Estonia, Latvia, Lithuania are the data controllers of your personal data unless explicitly stated otherwise. Depending on the location where our services are provided, one of the following companies is the data controller in relation to your personal data (hereinafter all together referred as “Tripod“, “we“, “us” or “our“):

• Tripod Grupp OÜ, registry code 10736400, Lõõtsa 1a, 11415 Tallinn, Estonia,
• Tripod SIA, Audēju iela 15, Centra rajons, Rīga, LV-1050, Latvia
• People Link UAB, Konstitucijos pr. 7, LT-09308 Vilnius, Lithuania.

We process your personal data under this Privacy Notice and in accordance with our Terms and Conditions and applicable laws, including the General Data Protection Regulation.

If you have any questions or concerns about this Privacy Notice or our practices with regard to your personal data, please contact us at .

2. Scope

Personal data is any information that relates to an identified or identifiable living individual. Different pieces of information, which in collection can lead to identification of particular individual, also constitutes as personal data.

Information about you will be collected, if provided by you through certain facilities on our website, for example, the job advertisement. The purpose of these facilities is apparent at the point where you provide your personal information and Tripod only uses your information for those specific purposes, unless further processing is allowed.

Your data may also be collected from third parties such as your current employer and social media platforms (e.g. Facebook, LinkedIn) that may share information about how you interact with our social media content (e.g. likes, comments). Also, if you are a potential client or a client (or its representative) we will collect personal data that is needed to provide you our services.

3. Personal data collected, its purposes and legal grounds

3.1 Recruitment

Tripod is a market leader with 16 years of experience in the recruitment industry with a reputation for excellence in finding and placing top talent in key positions across various industries. Due to our long-standing experience, our clients expect us to have a broad overview of the labour market and its active professionals.

Consequently, we have come to the conclusion that active members of the labour market expect that recruiters/recruitment firms may process their personal data in connection to potentially offer them new job opportunities. Under this section Tripod provides potential candidates an overview of how we may your personal data. We will also do our best to keep you actively informed about how we process your personal data.

3.1.1       Open job advertisements

Our customers may turn to us to help them find a suitable candidate via public job advertisement. Tripod may then collect personal data directly from job applicants or contact suitable candidates to invite them to apply. The personal data collected may include name, contact details (such as phone number and email address), cover letter, education and employment history (CV), and other information relevant to the position.

We help the company to assess the qualifications and suitability of the candidates for the position, this assessment may involve also conducting background checks and reference checks using the personal data provided by the applicant.

Tripod processes the personal data in the course of fulfilling the relevant vacancy based on Tripods and its customer’s legitimate interest or based on candidate’s consent (e.g. to contact previous employers). If the personal data processing is based on candidate’s consent, then he/she has the right to withdraw the consent at any time. The information how to withdraw the consent is provided in the relevant consent collection process (e.g. on the consent form).

Tripod allows all persons whose personal data are processed by Tripods to access, correct and request the deletion of their data. The rights of the individuals and their exercise are described in more detail in Section 7 of this Privacy Notice.

3.1.2       Headhunting

Headhunting is a recruitment strategy where Tripod actively seeks out highly skilled and experienced professionals who are currently employed at another company, with the goal of convincing them to leave their current job and to join our client’s company instead. This is typically done for executive-level positions or highly specialized roles where it can be difficult to find suitable candidates through traditional recruiting methods. For example in our labour market, it has become tendency that candidates in the technology sector do not actively search for offers at all, but are matched mainly on the basis of their professional communities and LinkedIn profiles.

During the headhunting process, a company contacts Tripod and provides its description of the open vacancy and lists the necessary skill and expertise of a suitable candidate, which is followed by Tripods search for the suitable candidate. Tripod collects personal data through various means, such as online job boards, social media platforms, professional networks and referrals. We may also collect personal data directly from candidates through phone or email conversations, interviews, or application forms, unless our client requests confidentiality in the early phase of the recruitment.

If our client requests confidentiality, then we will look for candidates, who possess the necessary skills and expertise, and present the list of candidates to our client. Our client will then decide which candidates will be approached to share the information about the vacancy and to find out potential candidate’s interest of the role.

We process candidate’s personal data based on the shared legitimate interest of Tripod and its customers. The personal data is also processed within the interests of the individuals to help them find new fulfilling job opportunities.

In the course of headhunting, the personal data processed may include the name, contact details (such as phone number and email address), education and employment history (CV), and other information relevant to the position to determine suitable candidates and their skills, or expertise in a particular field.

Tripod allows all persons whose personal data is processed by Tripods to access, correct and request the deletion of their data. The rights of the individuals and their exercise are described in more detail in Section 7 of this Privacy Notice.

3.1.3       Talent database

Tripod’s talent database is a collection of information about people who have potential or proven talent, skills, or expertise in a particular field. The database can contain various types of information, such as the name, contact details, work experience, educational qualifications, skills, and other relevant information. This is information may be obtained about you from other sources such as LinkedIn, corporate websites, job board websites, online CV libraries, your business card, personal recommendations.

The purpose of our talent database is to have an expert level overview of active talents in the labour market and to enable Tripod to help our customers quickly and easily search for suitable candidates for a job opening. Our Talent database also helps us to provide the active talents of the labour market the information about open vacancies that is not publicly available but may be of interest and benefit to the individual’s career. Talent database system potentially saves time and effort in the recruitment process, allowing employers to focus on the candidates most likely to meet their requirements, and vice versa, on the talent, helping them to reach vacancies that may be of interest to them.

Tripod processes individuals’ personal data respective in storing a Talent database:

• on the basis of the individual’s consent: during the active application process, the person has expressed his/her wish for Tripod to store his/her personal data for the purposes of future job opportunities.
• on the basis of Tripod’s and its customer’s and potential job seekers’ legitimate interest: Tripod has weighed up the rights and interests of the various parties involved in the provision of the recruitment service incl. creating a Talent database and concluded that it does not unduly infringe the rights and freedoms of the individual. The data processing activity is carried out bearing in mind the interest of the individual and is likely to be of benefit to the individual both economically and in terms of personal development.

Tripod allows all persons whose personal data are processed in the Talent database to access, correct and request the deletion of their data. The rights of the data subject and their exercise are described in more detail in Section 7 of this Privacy Notice.

3.2 Assessment services

Assessment services are an essential part of the recruitment process that help organizations to evaluate the suitability of candidates for specific roles. These services include a range of activities and tools that are designed to measure the skills, abilities, personality, and potential of job candidates.

Tripod performs such assessments on behalf of our clients e.g., Tripod is the data processor and respective company is the data controller.

The data processed depends on the respective test used, but in most cases involve processing demographic information (such as age, gender, or occupation), contact information (such as name, email address, or phone number), and responses to survey questions:

• Aptitude tests: These tests are used to measure a candidate’s cognitive abilities, such as verbal and numerical reasoning, logical thinking, and problem-solving.
• Personality assessments: These assessments measure a candidate’s personality traits, such as extroversion, conscientiousness, and emotional stability.
• Job simulations: These are assessments that simulate real-life work situations and allow candidates to demonstrate their skills and abilities in a realistic setting.
• Work sample tests: These are assessments that require candidates to complete a specific task or project that is relevant to the job they are applying for.
• Behavioural interviews: These interviews are designed to assess a candidate’s past behaviour and how it relates to the job they are applying for.
• Reference checks: These are assessments that involve contacting a candidate’s former employers or colleagues to verify their work experience, performance, and other relevant information.

Overall, the results of assessment services provide a more objective and reliable basis for making hiring decisions than relying solely on a candidate’s resume, cover letter, or interview performance. By using assessment services, organizations can identify the most qualified candidates and reduce the risk of making costly hiring mistakes.

3.3 Surveys

Surveys are quantitative assessments of different situations or processes. During surveys, personal data may be collected through various methods such as questionnaires, interviews, or online forms. The data collected may include demographic information (such as age, gender, or occupation), contact information (such as name, email address, or phone number), and responses to survey questions. Once the data is collected, it may be processed in various ways depending on the purpose of the survey. For example, the data may be analysed to identify trends, patterns, or insights related to the research question.

In most cases when performing surveys Tripod acts on behalf of another company e.g., Tripod is the data processor and respective company is the data controller. The surveys which may require the processing of personal data are designed to help to analyse organisational health, including employee satisfactory, customer satisfactory, feedback and so on.

The personal data will be processed based on the survey respondents consent and based on the organisation’s legitimate interest. When Tripod acts as a data processor then this Privacy Notice should be read together with the privacy notice of the company on who’s behalf the survey is performed. Respective information is provided in the beginning of each survey.

3.4           Training and Development

Tripod offers variety of additional services to help individuals evolve and succeed in their career, such as trainings, supervision, coaching and outplacement. To efficiently provide these services, we need to process personal data.

Every service is different and the amount of personal data that is required and processed differs in every situation and is dependant on the outcome pursued. In most cases the individuals have full control of what personal data will be processed.

Overall, the types of information that may be processed are the name, contact details, work experience, educational qualifications, skills. Personal data processing will be based on the fulfilment of the service agreement and/or based on individuals consent. When the data processing is based on consent, it is most likely provided during the conversation e.g., during the physical/virtual meeting between the coach and coachee.

3.5 Marketing Activities

Tripod may periodically send you information that we think you may find interesting, or to ask for your help with connecting other candidates with jobs. In particular, we may process your data to market our full range of recruitment services to you or to send you details of reports, offers, networking and client events, and general information about the industry sectors which we think might be of interest to you.

We process your data mostly on the basis of your consent and you have the right to withdraw your consent at any time by contacting us.

3.6 Social networks

For the purpose of managing and administering Tripod’s social network (i.e. “Facebook” and “LinkedIn” accounts) Tripod collects the following personal data you have provided voluntarily: your social network profile name, profile picture, public comments made on the Tripod’s account, subject matter and text of your queries, if any.

Tripod processes named personal data on the basis of your consent (on your request to provide you with an answer or your choice to comment) and Tripod’s legitimate interests to communicate with our followers. Such personal data will be stored until the account of Tripod is actively used by Tripod unless you by yourself at any time delete your personal data earlier on.

Tripod may delete your activity from Tripod’s accounts at its own discretion if the content you have provided infringes the social media platform’s terms and conditions or Tripod’s rights or interests. Respective to personal data processed within the social networks, the individuals should also review the privacy notice of the respective social network platform.

3.7  Cookies

Cookies are text files containing small amounts of information which are sent to your browser and stored on your computer, mobile phone or other device when you visit a website. The cookies send information back to the website each time you return. You can accept/reject, manage and / or delete cookies according to your preferences.

In any case, the processing of your personal data with the help of cookies is based on your consent provided on Website’s cookie banner which you can change at any time or based on Tripod’s legitimate interest respective to the use of necessary cookies which allow our Website to function correctly.

Tripod informs that you can delete all cookies stored on your computer, and in most browsers, you can set cookies not to be saved. Please be aware that if cookies are disabled, you may lose the ability to use the many features necessary to make the website work as well. If you need more information about cookies, visit aboutcookies.org. On this website you may find detailed, independent information on how to disable cookies through your browser preferences and how to remove cookies that are already on your computer. In order to remove cookies from your mobile phone, you should find this information in the user guide for your phone.

More information can be found on our Cookie Policy.

3.8           Fulfilling our legal obligation

Tripod may be obliged to process personal data when it is necessary to comply with our legal obligations which arise from the law or from the industry practice. Such data processing may be in connection with the collection of taxes or duties, bookkeeping and responding to supervisory authorities.

3.9           Service improvement and analysis

Tripod may also process personal data respective to test and improve our services. To the extent possible we use anonymised data to fulfil named purpose, however there are instances where personal data processing may be required. If personal data processing is required, we have implemented appropriate organisational and technical measures to mitigate the risks that may affect individuals’ rights and freedoms e.g., personal data is pseudonymised and we have implemented access management procedure to limit the number of employees who will have access to personal data.

4. Retention of your personal data

Tripod will only retain your personal data for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting or reporting requirements. We view our relationship with you as being one which is to support your career through numerous roles and assignments. Accordingly, we may retain your data for a period of time which is materially greater than simply one placement if we reasonably believe that we will continue to have an ongoing relationship with you.

We will appropriately and securely dispose of your personal data when it is no longer required.  To determine the appropriate retention period for personal data, we will consider the following factors:

• amount and nature of the personal data;
• its sensitivity;
• the potential risk of harm from unauthorised use or disclosure of the personal data;
• the purposes for which we handle your personal data;
• whether we can achieve those purposes through other means; and
• applicable legal requirements.

When technically possible your personal data will be automatically anonymised after certain period of time e.g., respective to assessment services, the personal data is automatically anonymised in two years after the commencement of the test.

When we act as a data processor to our clients, the data controllers, we will retain your personal data in accordance with the retention periods prescribed by our clients.

5. Data sharing and transfer

Any information that you provide or collected by us, including any data collected by using cookies, may be processed by each Tripod company and shared with third parties (data processors) which provide us services and act on our behalf (e.g. companies providing marketing/advertising services, companies providing data centre services, IT service providers, accounting service providers, etc.). Tripod ensures that processing of personal data by such third parties will be based on legal ground and will be performed in accordance with lawful instructions and in compliance with the applicable laws.

The personal data may also be transmitted to the relevant personal data recipients. Specifically, we may share personal data with the following categories of third parties (data processors, data recipients or separate data controllers) as necessary:

• Tripod group companies and our affiliate companies,
• the companies for which we provide our services,
• police, law enforcement authorities, tax authorities, other government institutions when required by law,
• our professional advisers such as lawyers, accountants,
• service providers who provide information technology and system administration services, translation, marketing, accounting, postal or courier, event management and coordination or other services,
• legal directories or other persons or entities for the purposes of obtaining feedback or references in relation to client services provided to you (if needed, we will check with you that you are willing to be contacted),
• other persons or entities if needed to provide you our services as effectively as possible.

Please note that if it is expressly required by relevant laws, personal data about you can also be shared with competent public authorities.

Third countries. Tripod will not transfer your personal data to third countries (countries outside the EU/EEA), unless this is assessed as necessary. When such transfer is necessary Tripod will implement all the necessary measures required by law.

6. Data protection measures

Tripod implements appropriate and compliant technical and organizational measures to protect your information against accidental or unlawful destruction or accidental loss, alteration, unauthorized disclosure or access, and against all other unlawful forms of processing.

We may hold your personal data in a combination of secure computer storage facilities and paper-based files. We limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know. They must only process your personal data on our instructions. They are also subject to a duty of confidentiality.

We have also put in place procedures to deal with any suspected personal data breach and will notify you and any applicable supervisory authority where we are legally required to do so.

7. Your rights as a data subject

You may, at any time, exercise the following rights with respect to processing of your personal data:

• Right to access: You have the right to request access to any data that can be considered your personal data. This includes the right to be informed on whether we process your personal data, what personal data categories we process, the purpose and the legal ground that we rely on when processing your data.
• Right to rectification: You have the right to request that we correct any of your personal data if it is inaccurate or incomplete.
• Right to object: You are entitled to object to processing of personal data, if the processing of your personal data is based on legitimate interest.
• Right to erasure: You may also request that your personal data be erased subject to certain statutory exceptions if the personal data is no longer necessary for the purposes for which it was collected, or if you consider that the processing is unlawful.
• Right to data portability: If we process your personal data based on your consent or on the basis of a mutual contractual relationship, you may request that we provide you with that personal data in a structured, commonly used and machine-readable format. Moreover, you may also request that the personal data is transmitted to another controller. Bear in mind that the latter can only be done if that is technically feasible.
• Right to restriction of processing. In some cases you may have a right to request restriction of processing of your personal data or to object to processing of your personal data.
• Right to withdraw your consent: In cases where the processing is based on your consent, you have the right to withdraw your consent to such processing at any time.

Please note that some of the rights listed above may be limited where our legitimate interests or legal obligations override your interests and rights (particularly, in connection with exercising and defending our legal rights or meeting our legal and regulatory obligations).

We assure you that our processes are built in a way that you will not be subject to any decision based solely on automated processing, including profiling, which would produce legal effects concerning or similarly significantly affects concerning you. If to some extent automated processing takes place, we will provide you an option to request human intervention.

If you have complaints on how we process your personal data, or you would simply like to know more about our data processing activities, feel free to contact our Data Protection Officer at any time on the contact details: ; Tripod Grupp OÜ, Lõõtsa 1a, II korrus, 11415 Tallinn with a reference “Data Protection Officer”.

You have the right to lodge a complaint to a Data Protection Authority if you think that your personal data is being processed incorrectly or your data subject’s rights have been violated by us. You can find contact details of the Estonian Data Protection Inspectorate here: www.aki.ee.

8. Changes

Tripod may, at its sole discretion, change, modify, add or remove any portion of the Website, the Website content and / or this Privacy Notice, in part or in its entirety, at any time based on new functions or regulations. Any changes to this Privacy Notice are effective from the date of their publication. You undertake to review this Privacy Notice periodically to become aware of any changes.

This Privacy Notice is drafted in Estonian and translated into English. In the event of disputes, arguments or claims of linguistic nature or concerning the interpretation, the version of the Privacy Notice in Estonian is legally binding.

9. Details of the Website and ownership

The Website, content of the Website, code of the Website, design, domain name, all copyrights, trademarks, databases, corporate names and other intellectual property or other property related to the Website and / or its contents are fully owned by Tripod and / or licensors and / or content providers, and are protected by national and international intellectual property laws and other legislation.

Unless expressly permitted by Tripod, you have no right, in any form and by any means, to copy, capture, reproduce in any form or manner, launch, publish, transfer, sell, translate, reprocess, submit, licence, modify, create derivative works from or based upon, republish, edit, transmit, retransmit or otherwise make public, publicly perform or display, frame, distribute or use, in part or in its entirety, the Website, the Website content or Website code.

10. Contact

For any information regarding the Website, Tripod and your personal data please contact us by e-mail: .

Full contacts of Tripod legal entities:

Tripod Grupp OÜ

Address: Lõõtsa 1a, 1st floor, 11415 Tallinn, Estonia

E-mail:

Phone: +372 618 1570

Tripod SIA

Audēju iela 15, Centra rajons, Rīga, LV-1050, Latvia

E-mail:

Phone: +371 279 98 661

People Link UAB

Konstitucijos pr. 7, Vilnius, Lithuania

Email:

Phone: +370 5 248 7265