Privacy Policy

INTRODUCTION


The General Data Protection Regulation (hereinafter “GDPR”, Regulation (EU) 2016/679) entered into force in the European Union on 25 May 2018. To read the text of the Regulation, please visit the following URL: https://eur-lex.europa.eu/legal-content/En/TXT/?uri=CELEX:32016R0679. 

This Privacy and Cookies Policy (hereinafter the “Privacy Policy”) concerns the organisation with the registered name LGBT Great Limited and the trade name LGBT Great (hereinafter “LGBT Great” or “us”), seated in Warnford Court, 29 Throgmorton Street, London, England, EC2N 2AT, in regard to the collection, use and disclosure of personal data of users, including representatives of LGBT Great members (or Employers), job applicants and any third parties or visitors (hereinafter “User” or “Users”), visiting the page under the domain name: www.lgbtgreatcareers.com (hereinafter the “Website”) and using the services provided thereon in accordance with the LGBT Great Careers Terms of Use (the “Services”).

This Website may contain links to other websites under the responsibility of third parties (whether natural or legal persons). Additional websites may be added in the future, and LGBT Great shall in no way be held liable for the terms of protection and management of personal data thereof.


1. DEFINITIONS

Under Article 4 of the GDPR:

“Personal Data”: any information through which a natural person (“Data Subject”) is identifiable or can be identified.

“Data Controller”: the natural or legal person, public authority, agency or other body which, alone or jointly with others, determines the purposes and means of the processing of personal data.

“Data Processor”: a natural or legal person, public authority, agency or other body which processes personal data on behalf of the controller.

“Data Subject”: the natural persons whose personal data the controller collects and processes (in this Privacy Policy, the Data Subjects are the Users of the Website as defined above:

“Recipient”: a natural or legal person, public authority, agency or other body, to which the personal data are disclosed, whether a third party or not.


2. COLLECTION OF PERSONAL DATA

When Users visit and interact with the Website, search for a job opening, join the talent community, fill out and submit application forms on the Website, certain information may be collected, such as:

  • General identification and contact information as name, surname, telephone number (work and mobile);
  • Sexual orientation, gender identity, race, religion, social mobility (equality monitoring);
  • IP address and visits on the Website;
  • type of browser and operating system;
  • websites and links clicked on within the webpage;
  • basic server connection information;
  • information collected through software such as HTML cookies, Flash cookies, web beacons and other similar technologies;
  • CV’s, which include name, surname, education, background or employment history, and contact information of job applicants.

The IP address is determined by the connection provider through which Users access the Internet and, subsequently, the Website. The IP address is retained for legal and technical reasons, as well as for the resolution of issues related to the security of webpage systems (server, database, network, etc.).

LGBT Great does not knowingly collect personal information from minors under the age of 18. If LGBT Great ascertains that any personal information has been collected from a minor under the age of 18 without verifiable parental consent, it shall erase the information from its database as soon as possible.


3. PURPOSE OF PROCESSING OF PERSONAL DATA

The Personal Data collected are used solely and exclusively for the purpose of providing the Services as described in the LGBT Great Careers Terms of Use, for communication with the Data Subjects, as well as for statistical reasons and for the improvement of the services.

More specifically, the Personal Data collected from the Users of the Website and the Services are intended to be used by LGBT Great for the purposes set out herein, which include without limitation:

  • to offer the Services as requested via the use of the Website;
  • to personalize the Website for users, in order to provide an optimal user experience and faster access to the services provided;
  • to enable the provision of anonymised statistical data to third parties in a manner whereby they cannot identify the personal data subjects;
  • to enable the management of the Website and all types of communication e.g. respond to any questions submitted by the Users.


4. DATA RECIPIENTS AND PURPOSE OF TRANSFER

The Personal Data of the Users of the Website might be transferred to different service providers used by LGBT Great in order to offer the Services, associates and/or sub-contractors of the Federation (all together “Service Providers”) but always under conditions that fully ensure that the personal data of Data Subjects are lawfully disclosed and do not undergo any unlawful processing.

Those Service Providers act as Data Processors, who are contractually bound under Article 28(3) of the GDPR to take appropriate security measures and to comply with the legislative framework for the protection of personal data.

LGBT Great shares Personal Data with the company under the tradename “Workable Software Single Member Private Company”, (“Workable”) with office located at Kifisias Avenue 95-97, 15125 Marousi, Athens, Greece, which provides website development, maintenance and hosting services for the LGBT Great Careers Job Board. Workable, acting as a Data Processor, will have access and might store, as required, Users data, to facilitate the job postings and application process as part of the Services provided by LGBT Great, in accordance with the LGBT Great Careers Terms of Use, and use those data as necessary to perform its functions and improve the services.

When a User applies for a job opening on the Website, LGBT Great will collect and share Users personal data, CV details, equality monitoring and contact information, directly with the Employer who posted the Job on the Website. This Employer acts as a Data Controller of the User’s data and is responsible for the collection and use of such Personal Data, including the storage of Personal Data on its databases or any direct communication with the User, in accordance with its Privacy Policy. Any data subject rights under GDPR and as described in this Privacy Policy shall be exercised directly and separately toward the Employer as well. LGBT Great has no control and no responsibility over the collection, storage and processing of such data by the Employer.

LGBT Great shall not sell or otherwise transfer or make public the Personal Data of Users to third parties, excluding the foregoing recipients, without the consent of Users, with the exception of the application of legal requirements and solely to the competent Authorities.

The Personal Data kept may be disclosed to the competent judicial, police and other administrative Authorities, following a lawful request on their part and in compliance with currently applicable legal provisions. Furthermore, in the event of a legal provision, service order or official preliminary investigation, LGBT Great has the right to make the relevant data immediately available to the corresponding service.

LGBT Great may transfer personal data of Users to a third country outside the UK and European Union, provided there are sufficient guarantees in place according to the requirements of data protection laws.

In particular Personal Data might be shared with Service Providers in the US, provided there is a valid data transfer mechanism in place, which is recognised by the relevant Data Protection authorities to provide an adequate level of protection to data subjects.

By using the Website and the Services, the Users confirm their consent to the processing of their Personal Data outside the European Union, in accordance with this Privacy Policy.


5. RETENTION

Any information of the Users including their Personal Data will be collected and stored by LGBT Great only for so long it is required to provide the Services, in accordance with the LGBT Great Careers Terms of Use, or until a User asks specifically for the deletion of their data, or as long as required in order for LGBT Great to comply with any legal obligations.


6. RIGHTS OF DATA SUBJECTS

As the Controller, for the purposes described in this Privacy Policy and in full compliance with the provisions of the GDPR, LGBT Great satisfies and facilitates the satisfaction of the following rights of the Data Subjects:


a) Right to access

The Data Subjects shall have the right to be notified at any time, by the Controller, of whether it processes their personal data and, if so, to request information on the purpose of the processing, the type of Data processed, to whom they are transferred, how long they are stored and whether there is automated decision-making. Furthermore, Subjects shall be granted access to these personal data without undue delay.


b) Right to rectification

The Data Subject shall have the right to obtain, from the Controller, the rectification of inaccurate or outdated personal data concerning him or her. Furthermore, they shall have the right to demand that incomplete personal data be supplemented with a supplementary statement, among other things. Additionally, LGBT Great shall communicate any rectification of personal data to each recipient to whom the personal data have been disclosed, unless this proves impossible or involves disproportionate effort. LGBT Great shall notify the Data Subject of the recipients in question, upon request.


c) Right to erasure

The Data Subject shall have the right to request, from the Controller, the erasure of personal data concerning him or her if they are no longer necessary in relation to the foregoing processing purposes and under the conditions of Article 17 of the GDPR.


d) Right to restriction of processing

The Data Subject shall have the right to request, from the Controller, restriction of processing of the personal data concerning him or her. If the processing of personal data has been restricted, such personal data shall, with the exception of storage, be processed solely and exclusively if specific exceptions apply.


e) Right to data portability

The Data Subject shall have the right to receive the personal data concerning him or her, which he or she has provided to a Controller, in a structured, commonly used and machine-readable format.


f) Right to object

The Data Subject shall have the right to object, on grounds relating their particular situation, at any time, to processing of personal data concerning them when it is required for the performance of a task carried out in the public interest or in the exercise of official authority vested in the Controller, or when the processing is necessary for the purposes of the legitimate interests pursued by the Controller. Once the right to object has been exercised, the personal data shall no longer be processed unless it can be demonstrated that there are compelling, legitimate grounds for the processing which override the interests, rights and freedoms of the Data Subject or for the establishment, exercise or defence of legal claims. LGBT Great guarantees that if the Data Subject objects to the processing of data concerning them, it shall no longer process these data unless it demonstrates compelling legitimate grounds for the processing which override the interests, rights and freedoms of the Data Subject.


g) Automated individual decision-making, including profiling

The Data Subject shall have the right to object to a decision based solely on automated processing, including profiling, as the case produces legal effects concerning him or her, or similarly significantly affects him or her. At this time, LGBT Great does not carry out automated individual decision-making. In any event, should it decide to proceed with automated individual decision-making in the future, LGBT Great shall satisfy this right.


Overall, LGBT Great ensures that:

  • There are procedures allowing the Data Subjects to easily exercise their rights in order for all the actions required to be taken immediately.
  • The Controller shall respond to a request submitted by the Data Subject without undue delay and within a maximum of thirty (30) calendar days. Should it be unable to satisfy a right exercised by the Data Subject, LGBT Great shall ensure that specific, sufficient and comprehensive reasoning is provided.
  • Save in exceptional circumstances, all actions concerning issues relating to the satisfaction of the rights of Data Subjects shall be taken at no cost to the Subjects.

If the Data Subjects consider that the processing of their Personal Data infringes the regulatory framework in force, they shall have the right to lodge a complaint with the: 

Information Commissioner (postal address: Wycliffe House Water Lane Wilmslow Cheshire SK9 5AF, tel,: +44 0303 123 1113, website: https://ico.org.uk/concerns/).

LGBT Great Limited (postal address: Warnford Court, 29 Throgmorton Street, London, EC2N 2AT, tel.: +44 203 909 8640, e-mail address: [email protected]).


7. UPDATES

LGBT Great reserves the right, when deemed expedient, to amend this Privacy Policy, whether in part or in whole, at its absolute discretion, and to post this amendment on the Website. Any amendment hereto shall enter into force as soon as the amended Privacy Policy is posted on the Website. In any event, continued use of the Websites by the User following amendments shall mean acceptance of these amendments. Otherwise, the User must cease using the Website, or notify LGBT Great of any objections. Users must regularly consult the Privacy Policy in order to ensure that they are aware of the most recent version.


8. CONTACT

For any question concerning this Privacy Policy, users can contact LGBT Great at [email protected]

This Privacy Policy will be renewed and updated from time to time, based on the national and European legislation in force.


COOKIES POLICY

LGBT Great uses cookies and log files to improve the services of the Website and to better understand how Users use it. Log files are server files that are created automatically when a user visits a website. Cookies are small plain text files that websites place on the hard drive of the website user’s computer. Each of the cookies has a unique code, which is used to recognize the computer every time a user visits the same website again.


1. Which ‘Cookies’ LGBT Great uses

The Website uses cookies in order to improve the user's experience on the Website. In particular the categories of cookies used are outlined below:

A) Session and persistent

‘Session Cookies’ Session cookies are stored on a User’s computer or electronic device during their visit to the Website and are deleted upon leaving the Website.

‘Persistent Cookies’ remain on a User’s computer or electronic device for a longer period of time, until the Users themselves delete them.


B) Strictly necessary, functionality and performance cookies

Strictly necessary ‘Cookies’ are critical for the proper functioning of the Websites. These ‘Cookies’ allow users to access and use the functions of the website, such as access to secure areas or filling out of website forms. These ‘cookies’ do not identify users, and the smooth operation of the Website would be impossible without them.

‘Functionality Cookies’ allow the Website to remember a user’s choices, in order to provide improved and personalized functions. They can also be used to provide services that have been requested by the User, such as viewing videos or using social media. If a User does not accept these cookies, the performance and functionality of the LGBT Great website may be affected and the User’s access to website content restricted.

‘Performance – Analytics Cookies’ those Cookies are used to collect information on how visitors use the Website in order to satisfy most users' needs, to improve the content of its websites and facilitate its use by visitors. These cookies utilize the way visitors use the Website and are used for statistical purposes and for monitoring and improving the performance of the Website.

‘Advertising cookies’ are used to display advertisements that will be relevant to the User or are used by third parties in order to provide Users with relevant advertising.


C) ‘Third-Party Cookies’ and embedded content

LGBT Great allows, Workable, Google and other third companies with which it cooperates to install the ‘Cookies’ it uses. Should Users enter third-party websites or connect to social networking media (Twitter, Facebook, YouTube) through the Website, they must be aware that these third websites or media may install ‘Cookies’ upon their visit to the link in question. These ‘Cookies’ are beyond the control of LGBT Great and are governed by the Cookies Policy of each third-party installing them. In order to know how to manage them, users must consult the corresponding policies of the websites in question.

Additionally, the Website uses the below third-party analytics cookies. You can find more information on how to opt out from those on website’s:

  • Google services: Google tag manager, Google Analytics etc
  • Leadfeeder
  • HubSpot
  • AdRoll
  • HotJar
  • Facebook
  • Bing


2. Managing and Deleting Cookies

Most browser menus contain options on managing ‘Cookies’. Depending on the choices provided to users by the browser, users may allow the installation of ‘Cookies’, disable/delete existing ‘Cookies’ or be alerted each time ‘Cookies’ are received. Instructions on managing and deleting Cookies can usually be found in the ‘Help’, ‘Tools’ or ‘Edit’ menu of each browser. Users can also find more detailed guidance at www.youronlinechoices.com/gr, explaining in detail how to control and delete ‘Cookies’ in most browsers.

Users must be aware that if they reject or disable Cookies on the website of LGBT Great, the functionality of the websites may be partially impaired. Furthermore, disabling a ‘Cookie’ or category of ‘Cookies’ does not delete the corresponding file from the browser. This action must be taken by users themselves by changing the internal settings of their browser.


3. Changes to the use of Cookies by LGBT Great

LGBT Great reserves the right, when deemed expedient, to amend this Cookies Policy, whether in part or in whole, at its absolute discretion, and to post this amendment on its websites. Any amendment hereto shall enter into force as soon as the amended Cookies Policy is posted on the website. In any event, if users continue to use the Website following amendments, LGBT Great shall bear no liability whatsoever. Users must regularly consult the Cookies Policy in order to ensure that they are aware of the most recent version.