1. Introduction
This Privacy Policy is related to Backfills Limited having its registered address at
(‘BACKFILLS’, ‘Company’, ‘we’, ‘us’,
‘our’). We are committed to safeguarding the privacy of our clients
using our services (‘user’, or ‘you’, ‘your’).
This Privacy Policy explains how we collect, use, disclose, safeguard and treat your
personal information when you are enrolling as a candidate with us, for us to seek
employment for you with our clients.
By utilising or receiving, our services, you agree with the terms of this Privacy
Policy. By providing us with your personal information, you acknowledge to the
Company’s processing your personal data/personal information in accordance
with this Policy and the applicable EU laws and regulations.
2. Personal Information – Collection &
Processing
We may collect, store and use the following types of personal information:
-
Personal details including your name, surname, address, identification
details, date of birth, citizenship, nationality, CV, email address and
contact number.
-
Copy of your communication with us, such as emails and messages through the
website, in line with our legal obligations or due to a legitimate interest.
-
We may hold CCTV recordings of you should you visit our offices. These are
kept for the purpose of preventing crime and protecting our staff and
clients.
We shall process your personal information if the scope therefor falls within at
least one of the following categories:
-
Contractual obligation or necessity;
-
Legal obligation;
-
Member-state law;
-
Vital interest of the data subject;
-
When processing the data is in the best interest of the public; and
-
Legitimate interest.
It is the nature of our business to process your data mostly due to a legitimate
interest.
3. Non-personally identifiable information and traffic analysis
BACKFILLS strives to make its website as user friendly as possible and easy to
find
on the internet. BACKFILLS collects data on how you use the site, which
does
not identify you personally. When you access the website, our servers keep an
activity log unique to you that collects certain administrative and traffic
information including: source IP address, time of access, date of access, web
page(s) visited, and type of browser used.
4. Consent
We shall need your consent in the following circumstances:
-
When sending you direct marketing material or promotions regarding our
services;
-
When sharing your personal information outside the Company, and outside the
scope of Section 2;
-
When processing your personal information without having any legal basis in
terms of the General Data Protection Regulation (“GDPR”).
You can withdraw your consent at any time, unless there is another legal basis that
allows us to process your data as per the below section.
5. Cookies
Once you accept the cookies on our website, then you may be targeted for marketing in
line with our cookie policy which may be found on the website. If you do not wish to
be targeted, then you should not accept the cookies on our website.
6. Non-Marketing Material
From time to time we may send you non-marketing material such as general information
about matters that may concern you. Such material is usually sent by email. This is
performed after ensuring that our legitimate interest to send you such non-marketing
material would not affect your privacy in a negative manner. We shall always provide
you with an option to unsubscribe from such informative material. Should you
unsubscribe, we shall not send you further non-marketing material. The same would
apply if you have requested or shall request that no material whatsoever is sent to
you.
7. Disclosure
Whilst we perceive it a legitimate interest that we use your personal information to
source employment for you, including by the disclosure to third parties, if you do
not consent to disclosure of your data to our clients when there is a vacancy that
suits your profile, pursuant to your selection at registration, we shall contact you
to authorise disclosure on a case-by-case basis. Should you wish to change your
selection, please contact us on +356 2703 0133.
IN addition to disclosure based on your consent, we may disclose your personal
information:
-
To the extent that we are required to do so by law;
-
In connection with any ongoing or prospective legal proceedings;
-
In order to establish, exercise or defend our legal rights (including
providing information to others for the purposes of fraud prevention and
reducing credit risk);
-
To any person who we reasonably believe may apply to a court or other
competent authority for disclosure of that personal information where, in
our reasonable opinion, such court or authority would be reasonably likely
to order disclosure of that personal information;
-
To any of our employees, officers, insurers, professional advisers, bankers,
agents, suppliers, IT service providers or subcontractors insofar as
reasonably necessary for the purposes set out in this notice (also known as
Processors and sub-processors);
-
To any member of our group of companies (this means our subsidiaries, our
ultimate holding company and all its subsidiaries) insofar as reasonably
necessary for the purposes set out in this notice. If the Company is merged,
acquired, or sold, or in the event of a transfer of some, or all, of our
assets or equity, we may disclose or transfer Personal Information and usage
data in connection with such transaction;
-
In all other circumstances where you would have given your consent.
We will not, without your express consent, supply your personal information to any
third party for the purpose of their, or any other third party's direct
marketing.
8. Storage & Protection
Your data may be stored in one or more of the following locations:
-
Physical files in our office;
-
A server located at our registered office;
-
A back-up server located in Dubai; and
-
On Cloud which is located within the European Union.
We take reasonable technical and organisational precautions to prevent the loss,
misuse or alteration of your personal information. We maintain physical, electronic,
and procedural safeguards to protect the confidentiality and security of personal
information and other information transmitted to us.
You acknowledge that the transmission of information over the internet is inherently
insecure and while we strive to protect information transmitted on or through the
website, we cannot, and do not, guarantee the security of any information you
transmit on, or through, the website, and you do so at your own risk.
We shall take the necessary steps to protect such information.
9. Your Rights
If you would like a copy of the personal information we hold about you, you should
request it by emailing dpo@ceek.com.mt
To ensure the security of your personal information, we may ask you for valid proof
of identity and once we’ve received it we will provide our response within a
reasonable timeframe.
You can obtain information regarding the processing of your personal information and
access to the personal information which we hold about you by contacting us on +356
2703 0133.
For any information that cannot be updated through your account on the website, you
may request rectification by sending an e-mail to jobs@ceek.com.mt
You have the right to request that we erase your personal information if it is
inaccurate or incomplete. There may be circumstances where you ask us to erase your
personal information, but we are legally obliged to retain it.
You may object to the processing of your personal information however there might be
circumstances where you object to, or ask us to restrict our processing of your
personal information but we would be legally entitled to refuse that request.
You may instruct us at any time not to process your personal information for
marketing purposes.
10. Retention
Personal data will be retained for as long as it is necessary for the purposes of
processing such data. Thus, the Company will keep data for as long as it is obliged
to by law, or need to keep a record of, a relationship with a client.
Following the lapse of the applicable retention period we shall destroy your data in
a safe and reliable manner. Physical files shall be destroyed by means of shredding
and data stored in digital format shall be permanently deleted, including any
backups held on servers and/or cloud. Correspondence records shall also be deleted.
Should the Company dispose or replace any hardware on which data is stored, we shall
ensure disposal is done in a professional manner and in a way that data cannot be
retrieved from it in the future.
11. Complaints
We value your comments and we are committed to ensure that all your data is
safeguarded and in line with regulation and our internal policies. Should you feel
the need to complain about, or raise your objections, to how we are handling your
personal data, then you may contact us using either/all of the following:
-
By post to DPO, Backfills, 88B, Triq Salvu Psaila, B’Kara BKR 9073
Dubai
-
By telephone on +356 2703 0133
-
By sending an email on dpo@ceek.com.mt
We will do our utmost to ensure that complaints are handled and settled internally in
an efficient and professional manner.
You may also contact the Office of the Data Commissioner as follows:
-
You may file a complaint with the Maltese Data Protection Commissioner
through the following link: https://idpc.org.mt/en/pages/contact/complaints.aspx
-
Alternatively, you may contact the office of the Maltese Data Commissioner by
phone on +356 23287100 or by post addressed to The Commissioner, Level 2,
Airways House, High Street, Sliema, SLM 1549
12. Approval of the Policy
If you do not agree with any statements contained within this Privacy Policy, please
do not proceed any further on our website.
You have the right to cease using the website at any time, however we may still be
legally required to retain some of your personal information.
We may periodically make changes to this Privacy Policy and will notify you of these
changes by posting the modified terms. We recommend that you revisit this Privacy
Policy regularly.