Private policy for the processing of personal data of jobseekers (candidates) and site visitors

The protection of personal data of individuals is of great importance for ANCOR PERSONAL Central Asia LLP (hereinafter referred to as ANCOR, we). The document “Private policy for the processing of personal data of jobseekers (candidates) and site visitors” (hereinafter referred to as the Policy) describes in detail what kind of information we collect to provide our services to jobseekers and to interact with site visitors, and how this information is processed.

ANCOR processes personal data of jobseekers (candidates) and site visitors legally in accordance with Art. 9 of Law of the Republic of Kazakhstan dated May 21, 2013 No. 94-V “On personal data and their protection”, for example, on the basis of consent to the processing of personal data.

As an operator of personal data, we have implemented numerous technical and organizational measures to ensure the fullest possible protection of personal data. However, if you do not wish to transfer your personal data via the Internet, you can choose alternative methods (for example, in person at the ANCOR office).

• Who we are and how to contact us

  ANCOR PERSONAL Central Asia Limited Liability Partnership

  Legal address: 115, Zheltoksan str., Almaty, Republic of Kazakhstan

  Actual address: floor 6, “Kaisar Plaza” BC, 115, Zheltoksan str., Almaty, Republic of Kazakhstan

  Phone: +7 (495) 926-41-00

  E-mail: info@ancor.kz 

  Website: www.ancor.kz 

  Person responsible for the data processing and protection:

  Galina Ostapova

  Address: floor 6, “Kaisar Plaza” BC, 115, Zheltoksan str., Almaty, Republic of Kazakhstan

  E-mail: privacy@ancor.kz

• Principles of personal data processing

  When processing personal data, ANCOR adheres to the following principles:
  

  • processes personal data only on a legal and fair basis; 
    
  • defines specific legitimate purposes before the start of processing (including collection) of personal data;
  • collects only those personal data that are necessary and sufficient for the stated purpose of processing;
  • restricts the processing of personal data, when achieving specific, predetermined and legitimate purposes;
  • destroys personal data, when achieving the purposes of processing or in case of loss of the need to achieve purposes (unless otherwise provided by the contract or other agreement with the data subject, or the legislation of the Republic of Kazakhstan).
• Conditions and methods for the processing of personal data in ANCOR

  The processing of personal data in ANCOR is carried out only, if there is a proper legal basis: with the subject’s consent to process his/her personal data, unless otherwise provided by the legislation of the Republic of Kazakhstan in the field of personal data in effect.

  ANCOR does not process biometric personal data of site visitors and jobseekers (candidates).

  In case of cross-border transfer of personal data to countries that do not ensure the protection of personal data, such transfer is carried out on the basis of the consent of the personal data subject.

  ANCOR does not post personal data in publicly available sources without the separate prior consent of the personal data subject.

  ANCOR does not disclose, transfer to third parties or distribute personal data without a proper legal basis. When transferring the personal data of the personal data subjects, third parties of ANCOR must be warned about the confidentiality of the transferred information.

  Persons, who process personal data on the basis of the contract concluded with ANCOR, undertake to comply with the principles and rules for the processing and protection of personal data provided for by the legislation of the Republic of Kazakhstan. For each third party, the contract establishes the obligation to keep confidentiality and ensure security of personal data during their processing, specifies the requirements for the protection of the processed personal data in accordance with the legislation of the Republic of Kazakhstan.

  In case, if ANCOR entrusts the processing of personal data to another person, ANCOR is responsible to the personal data subject for the actions of this person. The person, who processes the personal data on behalf of ANCOR, as an Operator of Personal Data, is responsible to ANCOR.

  ANCOR processes personal data in the following ways:

  • using automation tools, including using information technology and technical means, including computer technology, information technology complexes and networks, means and systems for transmitting, receiving and processing personal data, software tools (operating systems, database management systems etc.), information protection tools used in information systems;
    
  • not using automation tools.
• Personal data processed by ANCOR, grounds for processing, purposes of processing and processing deadlines

  Processing purpose	Processed data	Legal basis	Deadlines for storage
  Assistance in employment or organization of other type of cooperation with a potential employer, informing about emerging career opportunities, conducting a preliminary interview for a job or other type of employment, providing services/performing works on the basis of a civil law contract, as well as for the purpose of ANCOR to carry out activities related to human resource management and labor market analytics	Jobseekers (candidates): surname, name and patronymic; sex; photo; contact telephone number; e-mail address; date of birth; nationality; city and district of residence address of the personal Internet page on social networks; readiness for relocation and business trips; marital status; work experience; information about education; information about previous jobs; level of computer skills; level of proficiency in foreign languages; salary expectations; estimated characteristics inserted by the employee of the Company; other personal data that you include in your CV by yourself; references from previous employers	Consent of a jobseeker (candidate) to the data processing	Until the withdrawal of consent to the data processing
  Emailing marketing materials and conducting social surveys	Job seekers: e-mail address; IP-Adress; sex; age category; level of education; information on the existence of the employment relationship at the moment of the survey; sphere of activities; professional specialization; region of residence; other data collected as part of the specific social surveys	Consent of a jobseeker to the data processing	Until the withdrawal of consent to the data processing
  Familiarization of an unlimited circle of persons with the information about ANCOR's activities	Site visitors: cookies; IP addresses; other automatically collected data, and specifically: URL pages;  referer pages; page title; browser and its version; operating system and its version; device model; screen height and width; information about whether the visitor has cookies and JavaScript enabled (ECMAScript); JavaScript events (accounting for the visitor's interactions with the site, including the use of JavaScript API methods on the site, for example, submitting a form, scrolling the page); time zone; browser language; screen color depth; width and height of the client side of the browser window; sex, age and interests of site visitors; geographic data; page loading parameters (for example, time to rendering and server response time); data about viewed pages and visit, clicks on external links, downloading files, withdrawals, time spent on the site and visit depth	Consent of a site visitor to the data processing	Cookie-files – in accordance with The Cookie Policy; Other data – until the withdrawal of consent to the data processing
  Feedback of site visitors  (including the publication of a review)	Site visitors (including jobseekers and representatives of the clients): surname and name; place of work (company name); contact telephone number; e-mail address; other PD that you will include in your review by yourself	Consent of a site visitor to the data processing	Until the withdrawal of consent to the data processing
  (Job, newsletter) subscription	Site visitors: name; e-mail address	Consent of a site visitor to the data processing	Until the withdrawal of consent to the data processing

• Source of personal data

  Personal data of jobseekers (candidates) can be obtained by ANCOR directly from you personally, from your representative, who acts in your interests, or from job sites, where you posted your CV in accordance with the terms of use of the sites.

  Personal data of site visitors can be obtained by ANCOR directly from you personally, from your representative, who acts in your interests, or from your devices that you use to access the site.

• Recipients of personal data to whom the ANCOR may transmit the data of applicants (candidates) and website visitors
  • Clients of ANCOR - potential employers, Group of persons ANCOR (in the meaning of the definition of the group of persons specified by Article 7 of Law of the Republic of Kazakhstan No. 112-IV dated 25.12.2008).

  The purpose of the transfer: assistance to a jobseeker in employment or in organizing other type of cooperation with a potential employer.

  • TimService LLC (building 2, 21, Entuziastov highway, 111024, Moscow), Geliosoft LLC (19, Leninskaya Sloboda st., 115280, Moscow).

  The purpose of the transfer: support of ANCOR information systems.

• Personal data protection

  ANCOR has implemented a set of measures aimed at ensuring the security of personal data in the process of management and production activities of ANCOR.

  To protect personal data, ANCOR has implemented the following measures:

  • appointment of a person responsible for organizing the processing of personal data;
  • development and approval of by-laws on the processing and protection of personal data;
  • application of the information security facilities;
  • accounting of material carriers of personal data;
  • detection of facts of unauthorized access to personal data and taking measures to prevent similar incidents in the future;
  • recovery of personal data modified or destroyed due to the unauthorized access to them;
  • establishment of the rules for access to personal data processed in the information systems, as well as ensuring registration and accounting of all actions performed with the personal data in the information systems;
  • control over the measures taken to ensure the security of personal data and the level of security of the information systems;
  • compliance with the conditions excluding unauthorized access to material carriers of personal data and ensuring the safety of personal data;
  • familiarization of ANCOR employees, who directly process personal data, with the provisions of the legislation on personal data, including the requirements for the protection of personal data, by-laws on the processing and protection of personal data;
  • organization of the procedure for the destruction of information containing personal data;
  • explanatory work with ANCOR employees to prevent threats or danger of personal data loss;
  • organization of access control in ANCOR;
  • organization of the procedure for the protection of the territory, buildings, premises of ANCOR.
• Rights and obligations of ANCOR as an operator of personal data

  ANCOR has a right to:
  

  • provide personal data to state and other authorized bodies, if provided by the legislation of the Republic of Kazakhstan (tax, law enforcement agencies, etc.);
  • refuse to provide personal data in the cases specified by the legislation of the Republic of Kazakhstan;
  • process personal data of a subject without his/her consent, in the cases provided for by the legislation of the Republic of Kazakhstan.
  • ANCOR must:
  • provide the personal data subjects with the information regarding the processing of their personal data, upon their request;
  • in case of receiving personal data not from the personal data subject, at the request of the personal data subject, the following information:
    1. confirmation of the collection and processing of personal data;
    2. list of personal data;
    3. terms for the processing of personal data (including the terms of their retention);
  • ensure the storage of personal data, as well as by a third party in the database, which is stored in the territory of the Republic of Kazakhstan.
• Rights of the personal data subject

  If ANCOR processes your data based on your consent¹ to processing of personal data, you can revoke such consent at any time.

  You have the right to receive information² regarding the processing of your personal data, their validation or deletion³ the right to appeal against the actions performed by ANCOR⁴ and the right to compensation and reimbursement.⁵

  To exercise your rights, please contact us.

• Changes in this Policy
  The Policy may be amended from time to time to reflect possible changes in our processes of the personal data processing. We will notify you of any material changes in this Policy. The appropriate notifications may be displayed on the site (for example, via a pop-up window or banner) before such changes take effect, or may be sent to you via other communication channels (for example, by email, if you have provided us with your contact details).
  The date of the last change and the current version is indicated at the beginning of the Policy.
• Appendix 1 Form for revoking consent to the processing of personal data

  I,
  _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ ,
  

  (Full name)

  
  

  _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _,

  ((data of the identity document of the jobseeker, or other information that allows identifying the jobseeker, for example, date of birth, email, mobile phone)

  
  

  _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _

  
  

  withdraw my consent from ANCOR PERSONAL Central Asia LLP (legal address: 115, Zheltoksan street, Almalinskiy district, Almaty city) and its group of persons  to the processing of my personal data provided by me for (highlight the required):
  

  • assistance in employment or organization of other type of cooperation with a potential employer, informing about emerging career opportunities, conducting a preliminary interview for a job or other type of employment, providing services/performing works on the basis of a civil law contract, as well as for the purpose of ANCOR to carry out activities, related to human resource management and labor market analytics;
  • emailing marketing materials and conducting social surveys;
  • providing feedback to ANCOR on the website (including publishing a review);
  • (job, newsletter) subscription;
  • other:

  I ask you to stop processing my personal data.
  

  
  

  signature: _ _ _ _ _ _ _ _ _ /

  Full name: _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ __ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ /

  Date: _ _ _ _ _ _ _ _ _ /