PRIVACY NOTICE FOR JOB APPLICANTS

This privacy notice (hereinafter: “Privacy Notice”) describes how Freeway CAM Besloten Vennotschap’s Hungarian Branch (registered seat: H- 1052 Budapest, Piarista köz 2., 6. floor; registration number: 01-17-001357) and Independent CAM Collection Account Management Services Limited Liability Company (registered seat: H- 1052 Budapest, Piarista köz 2., 6. floor; registration number: Cg. 01-09-703374) as data controllers (together “we” or “us”) process the job applicants’ (“job applicant” or “you”) personal data and confirms our commitment to protecting your privacy.

In this Privacy Notice, the expression Freeway Entertainment Group shall cover Freeway Entertainment  Group B.V. (registered seat: NL-1101 Amsterdam Zuidoost, Luna Arena, Herikerbergweg 238.; registration number: 34163521) as a whole and its direct and indirect affiliates (hereinafter: “Group”).

This Privacy Notice applies to the processing of the personal data of individuals we are in contact with us regarding job opportunities, whether it is about opportunities with us, or the Group. Please refer to our  Privacy Statement available at Privacy Statement to learn more about the processing of your personal data related to the visiting of our website.

This Privacy Notice explains:

• What personal data and processing means
• How we collect your personal data 
• The legal grounds for processing your personal data
• What types of personal data we process and the purposes of the processing
• Who gets to see your personal data
• Context of the transfer of personal data
• How long we process your personal data
• How to access to your personal data and what your rights are
• How to contact us and what your rights to remedy are

Please read this Privacy Notice carefully to understand your rights before submitting your personal data to us. By applying for a specific vacancy or submitting a general application, you acknowledge that you have read and understood the content of this Privacy Notice and accept the terms and conditions under which we will be processing your personal data.

1. What do we mean by personal data and processing?

Data protection laws are the applicable data protection laws including in particular Regulation (EU) 2016/679 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” or “GDPR”) and Act CXII of 2011 on information self-determination and freedom of information (“Infotv.”) 

“Personal data” is information relating to you (or from which you may be identified) which is processed by automatic means or which is (or is intended to be) part of a structured manual filing system. It includes not only facts about you such as your name, identification number, location data, online identifier or one or more factors specific to your physical, physiological, genetic, mental, economic, cultural or social identity, but also intentions and opinions about you.

“Sensitive personal data” includes personal data relating to racial or ethnic origin, political opinions, religious or philosophical beliefs, trade-union membership, genetic or biometric data are subject of special protection.

"Processing" means any operation or set of operations performed on personal data,  or on sets of personal data, whether or not by automated means, such as collection, recording, organization, structuring, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, alignment or combination, restriction, erasure and/or destruction.

2. How do we collect your personal data?

We may receive personal data about you from several sources:

• When you apply for job opportunities at the Group, the initial personal data about you is likely to come from you (e.g.: your name, contact details, CV, and general information about you).
• When you apply through our career page at https://www.freeway-entertainment.com/career, we will need you to provide us with a minimal amount of personal data (at least your name, your e-mail address and CV) to allow us to process your application.
• You may submit additional information you deem relevant for your application. It is also likely that we receive the initial personal data about you from a recruitment agency we engaged.
• In the course of the application process, we may receive personal data relating to you from others, through references from previous employers for example.
• We may also require references and information to carry out background checks, and criminal records’ checks if it is necessary in case of the position you applied for

3. The legal basis for processing your personal data

Under applicable data protection laws, there are various grounds we can rely on when processing your personal data. In some situations, more than one applies, we have summarized these as consent, contract, legal obligation and legitimate interests. We may only process your personal data based on one or more of the following:

Processing sensitive personal data

Please note that we do not process sensitive personal data in general. If we process sensitive personal data about you, we also ensure that at least one or more of the legal grounds for processing sensitive personal data applies. These include the following:

• You have given explicit consent to the processing of those personal data for one or more specified purpose, in so far as authorized by law.
• The processing is necessary for the purposes of carrying out our obligations and exercising our specific rights or yours in the field of employment and social security and social protection law in so far as it is authorized by law; or where the processing is required under a specific legal obligation.
• The processing relates to personal data which you manifestly made public.
• The processing is necessary for the purpose of establishing, making or defending legal claims.
• The processing is necessary for the provision of healthcare or treatment, medical diagnosis, and the assessment of your working capacity

4. The personal data we process, purposes and legal basis

Purpose: Recruitment - Specific job

Details of the purpose: Managing and processing your application including contacting you; evaluating your skills and suitability for the role you may have applied for; the conduct of reference checks to validate your qualifications, experience, and suitability for a role. For certain roles, we may also conduct background checks in so far as authorized by law.   If relevant, we may also process information concerning your health, any disability and in connection with any adjustments to working arrangements in so far as authorized by law. 

Processed personal data:

• Contact data (phone number, e-mail address, etc.)
• Standard personal data related to the job applicant’s identity (surname, name(s), date and place of birth, nationality, gender, etc.)
• The job applicant’s picture (e.g.: included in the CV) if he/she voluntarily provided it
• Personal data regarding the job applicant’s professional experience (profile, data on previous employers, participation in special projects, references, etc.),
• Personal data regarding the job applicant’s education (diplomas, certificates, internships, special trainings, etc.) and language skills
• Hobbies and interests
• Sensitive personal data of the job applicants if shared with us, in so far as authorized by law
• Any other personal data that the job applicant presents us with as part of the job applicant’s application, related to the exercise of the role 

Legal basis:

• Consent
• Legitimate interests
• Carrying out obligations and exercising rights regarding the employment

Purpose: Recruitment – Future job opportunities

Details of the purpose: Managing employee headcount. Identifying future positions that may become available, and providing you with more suitable career opportunities at the Group

Processed personal data: Same as the personal data processed for the purposes of application for a specific job

Legal basis:

• Consent
• Legitimate interests
• Carrying out obligations and exercising rights regarding the employment.

Purpose: Employment contract

Details of the purpose: Processing related to the preparation and entering into an employment contract with you in case of a successful application. Compliance with all legal, regulatory and administrative obligations and application of employment and tax regulations

Processed personal data: Information on your terms of employment, including your salary and benefits, such as your participation in pension arrangements, or your bank account number) and other personal data to be processed by virtue of the law

Legal basis:

• Legal obligation
• Contract
• Consent
• Legitimate interests

Purpose: Diversity and equal opportunities

Details of the purpose: Personal data processing for equality and diversity purposes

Processed personal data: Information on your ethnic origin, gender, sexual orientation, religion, and disability

Legal basis:

• Explicit consent
• Legitimate interests
• Legal obligation

Purpose: Disputes and legal proceedings

Details of the purpose: Dealing with a legal dispute and to establish, exercise and defend (potential) legal claims related to your recruitment procedure

Processed personal data: Any information relevant or potentially relevant to a dispute or legal proceeding affecting us

Legal basis:

• Legitimate interests
• Legal obligation

Purpose: Security

Details of the purpose: When visiting our office, monitoring or temporary recording of your access to office areas in CCTV for security purposes

Processed personal data: Videos recorded or monitored by security cameras

Legal basis:

• Consent
• Legitimate interests
• Protection of human life and health, and  security of property

5. Who gets to see your personal data?

We store your personal data and application documents either electronically or on paper in your personal file designated specifically for recruitment and selection purposes.

Internal use
Your application can be maintained and released at different levels:

• If you are applying for a specific job, your personal data may be disclosed to our HR colleagues and other persons taking part in the selection process (e.g.: your future manager). Only the persons involved in the selection process can view your data.
• You release your application for future job opportunities at the Group. We may also disclose your personal data within the Group to HR colleagues and the persons taking part in the selection process, under adequate protection. This allows us to identify positions that may be interesting for you. It may occur that we contact you by telephone, in writing or by other electronic means to inform you regarding relevant job offerings. Your data may only be used to contact you regarding job opportunities other than a specific job you applied for when you allow us to do this by giving your consent at the time of the application.

External use
Other than related to job opportunities:

• Disclosure to other data controllers: We may only disclose your personal data to third parties (within or outside the Group) if the disclosure is consistent with a legal basis for processing on which we rely and doing so is lawful and fair to you, and if an adequate written contract has been concluded between us and the third party, including sufficient data protection provisions. We may disclose your personal data if it is necessary based on our legal obligations, or for our legitimate interests as an organization or the legitimate interests of a third party, excluding if these legitimate interests are over-ridden by your legitimate interests and rights, in particular your privacy rights. We may also disclose your personal data based on your consent.

• Disclosure to other data processors: Entities that process personal data on our behalf, these are such as companies, which carry out system administrator or other IT services, in particular GBL IT GROUP Korlátolt Felelősségű Társaság (HU-1041 Budapest, Árpád út 39-43. registration number: 01-09-724111)

6. Transfers of personal data outside the European Economic Area (EEA)

Due to the international nature of our jobs and positions, we may transfer your personal data to one or more employees of the members of the Group outside the EEA and/ or one or more employees of other data controllers or of our processors outside the EEA, always subject to adequate safeguards.

7. How long do we process your personal data?

Although there is no specific period for which we will keep your personal data, we will not keep it for longer than it is necessary and permitted by applicable law. We erase your personal data in a secure way, when they are no longer necessary for the mentioned purposes.

Personal data relating to job applicants will be deleted after the end of the job application procedure, unless

• You withdrew your application by sending an e-mail to hr@freeway-entertainment.com, in which case the personal data will be erased within reasonable time but not later than 25 days in line with applicable data protection laws.

• You explicitly consented in writing to the processing of your personal data for a period of one (1) year following the end of the job application procedure (or, if you are nor applying for a specific job, for a period of one (1) year following the submission of your general application). In such case, we will retain the relevant personal data for future employment-related opportunities.

• Your job application was successful. In case of successful applications, the personal data may be stored and processed to the extent and for the duration necessary for the fulfilment of the purposes of the processing, related to your employment. Thereafter, data shall be erased within reasonable time.

• Regulations provide otherwise.

• We store your personal data in accordance with the applicable data protection laws until it is necessary for the given purposes, we may however retain your personal data for the performance of our legal or contractual obligations and rights.

Irrelevant personal data, such as videos recorded by security cameras shall be erased within the shortest time upon the time of recording, unless the recorded video or other personal data is used as evidence in the procedures of courts or authorities. Of course, the job applicants can always exercise their rights to erase or object to the personal data processing (see below for more information).

8. Access to your personal data and your rights   Right to information

Any person whose personal data we process has the right to be provided with information as to the nature of the personal data processed or stored about him or her. We give this information to job applicants through this Privacy Notice, by asking them to acknowledge and consent to the terms of the Privacy Notice. Based on your request, we will also provide you with information on the personal data we process, or on the personal data processed by any data processor acting on behalf or appointed by us, this including the source of the personal data and the purposes of data processing, the legal basis for the processing, the period of data processing,  the identity and contact details, for example name and address of the data processor(s) and information regarding data processing activity of the data processor(s) involved. In case you submit a data subject access request, and your identity is questionable, we may request you to provide additional information necessary to confirm your identity. We shall provide you with information in writing to your request relating to processing your personal data without undue delay, but within 1 (one) month at the latest as from receipt of the request. Where necessary, taking into account the complexity of your request and the number of the requests, this period may be legally extended by 2 (two) further months. We do not impose any fees or costs for the information. We shall have the right to refuse access to information in thencases stipulated within GDPR and Infotv. In case we refuse to provide you with information, we will inform you in writing without undue delay about the relevant terms of the GDPR and Infotv. that constitute a legal ground for our refusal and will inform you about the possibility of lodging a complaint with the National Authority for Data Protection and Freedom of Information and to seek judicial remedy in court.

Right to rectification

If the personal data is inaccurate or incorrect, and the relevant personal data is available to us or if you request it from us, we will correct it.

Right to erasure

Provided that the deletion is not excluded by the law, we delete your personal data if its processing is unlawful, you request the deletion of the processed personal data, the processed personal data is incomplete or  incorrect (and this status is not remedied lawfully), the purpose of the personal data processing has ceased or the period of the  personal data processing has expired, or the deletion of the personal data is required by court or the National Authority for Data Protection and Freedom of Information.

Right to block the personal data

We will block your personal data if you request us to do so, or we will also block your personal data instead of the deletion if our assessment is that the deletion would be against your legitimate interest.

Right to object to the personal data processing

You have the right to object to the processing of your personal data in cases determined by law. We will examine your request without undue delay, but within 1 (one) month at the latest as from the receipt of your request and decide if your request is well-founded or not and will inform you in writing about the decision. Where necessary, taking into account the complexity of your request and the number of the requests, this period may be legally extended by 2 (two) further months. In case we establish that your request is well-founded, the personal data processing – including the collection of further personal data and the personal data transfer as well – will be ended and the personal data will be blocked, furthermore we will inform the relevant person to whom the personal data was transferred and who is required to take measures in order to ensure the right to object.

Profiling and right to object to the automated decision

You have the right to request information regarding the substantial value and the method used for a profiling and the automated data processing, furthermore the importance and consequences of the data processing for you.

Right to data portability

If the personal data processing is made automatically and we process your personal data based on your consent or on a contract, you have the right to receive your relevant personal data in a structured, commonly used, and machine-readable format and transfer it to another data controller. You also have the right to require the direct transfer of the relevant personal data to another data controller – if technically possible, excluding public interest data processing and data processing as official authority.

9. Contact us!

Should you have any questions or complaints relating to the processing of your personal data throughout the application process, please feel free to reach out to us.

Our contact details:

Freeway CAM Besloten Vennotschap’s Hungarian Branch
Registered seat: H-1052 Budapest, Piarista köz 2. 6. floor

Registration number: 01-17-001357

Telephone: +36 1 473 4300

E-mail address: info@freeway-entertainment.com

You may also reach out to our data protection point of contact at the following e-mail address: datapolicy@freeway-entertainment.com

10. Right to remedy

Before you exercise your right to remedy in court or with the relevant authorities, please contact us first.

In the event of an infringement to your data privacy rights, you have the right to notify the data protection supervisory authority, i.e., the National Authority for Data Protection and Freedom of Information:

Nemzeti Adatvédelmi és Információszabadság Hatóság

Postal address:  1363 Budapest, Pf.: 9.

Address:             1055 Budapest, Falk Miksa utca 9-11.

Telephone:          +36 (1) 391-1400

Fax:                     +36 (1) 391-1410

E-mail:                 ugyfelszolgalat@naih.hu

Website:              www.naih.hu

In case of infringement of your data privacy rights, or if you do not agree with our decision regarding your objection to the personal data processing, you also have the right seek judicial remedy in court. The examination of the application shall be the competence of general courts, therefore you have to submit your application at the general court of your place of residence or your place of stay.

11. Closing provisions

This Privacy Notice entered into force on 2 February, 2022.

This Privacy Notice’s primary purpose is to provide information in order to exercise your rights. It may be amended by us at any time, we will inform you regarding any changes that may affect your rights, or our obligations described herunder.