Privacy Policy
This Privacy Policy explains how we handle your personal data. It covers what data we
collect, why we collect it, how we use it, who we share it with, and your rights regarding
your data.
We prioritize your privacy and ensure that all personal data is used
in compliance with our obligations and your rights under national and international laws.
Specifically, our data processing practices comply with:
• The Cypriot Law
on the Protection of Natural Persons with Regard to the Processing of Personal Data and the
Free Movement of Such Data of 2018 (Law 125(I)/2018), including any amendments or related
legislation.
• The General Data Protection Regulation (EU) 2016/679 (GDPR).
This
Privacy Notice applies to personal data collected through your interactions with our
Website. This includes data gathered when you apply for a job, use our 'Contact
Us' page, or simply visit our site. For detailed information specifically related to
candidate data and job applications, please refer to our
Candidate Privacy Notice.
This Website is operated by BrainRocket Limited, a Cypriot company with its registered
address at 4 Promitheos St., 1st floor, 1065, Nicosia, Cyprus.
BrainRocket
Limited determines the means and purposes of processing your personal data and, therefore,
acts as the "Data Controller" in terms of the applicable Data Protection Laws.
Our Data Protection Officer can be contacted by email at
dpo@brainrocket.com or by post at 4
Promitheos St., 1st floor, 1065, Nicosia, Cyprus.
Category of Personal Data
Purpose of Processing
Legal Basis for Processing
Contact Information and Identifiers (such as name, email address, phone number, and device identifiers)
To provide information on offers, respond to your queries, and update on vacancies.
Concent
Employment and Qualifications Data
To evaluate your candidacy for employment.
Consent
Legitimate Interest
Other Information You Provide
Depends on the nature of the data; to provide accessible contact channels if no other purpose or legal basis
Consent
Legitimate Interest (initial evaluation for further processing)
Internet or other electronic network activity information (such as your browsing history, search history, device information, and other relevant information), geolocation information
To evaluate the outreach and performance of our Website
To prevent fraud
Consent
Legitimate Interest (website optimization, service development, security)
• Information you provide to us directly, including when you communicate with us through our
Website or participate in our events, marketing, and outreach activities.
• Information
automatically collected including technical information about your interactions with our
Website such as IP address, browsing preferences.
• Information from public sources,
including information from public records and information you share in public forums, such
as social media.
• Information from other third parties, including third-party service
and content providers, entities we partner with to sell or promote products and services,
and social media networks.
We may combine information that we receive from the
various sources described in this Policy, including third-party sources and public sources,
and use or disclose it for the purposes identified above.
At BrainRocket, we are committed to protecting your privacy and ensuring you have full
control over your personal data. Below is an overview of your rights under the GDPR, which
we fully uphold. If you have any questions or wish to exercise any of these rights, please
contact our Data Protection Officer at
dpo@brainrocket.com.
• Right
to be Informed: You have the right to receive clear, transparent, and easily understandable
information about how we use your personal data. This right is fulfilled through the
provision of this Privacy Notice, which details the specifics of our data processing
activities.
• Right of Access: You can request access to your personal data to verify
the lawfulness of the processing.
• Right to Rectification: If the personal data we
hold about you is inaccurate or incomplete, you have the right to correct it.
• Right
to Erasure (Right to be Forgotten): You can ask us to delete or remove your personal data
when there is no compelling reason to continue processing it.
• Right to Restrict
Processing: You can block or suppress further use of your personal data under certain
conditions.
• Right to Object: You have the right to object to our use of your personal
data for particular purposes, such as direct marketing.
• Right to Data Portability:
You can move, copy, or transfer your personal data from our database to another. We will
facilitate this transfer in a secure, machine-readable format.
• Rights Related to
Automated Decision Making Including Profiling: You have the right not to be subject to
decisions based solely on automated processing, including profiling, which has legal effects
concerning you or similarly significantly affects you. You can request human intervention,
express your point of view, and contest the decision. However, we do not perform automated
decision-making or profiling using your personal data.
• Right to Lodge a Complaint: If
you believe that we have infringed your rights, you have the right to complain to the
Cypriot Data Protection Authority, which can be contacted at:
Office of the
Commissioner for Personal Data Protection
Kypranoros 15, Nicosia 1061, Cyprus
Tel:
+357 22818456
Fax: +357 22304565
Email: commissioner@dataprotection.gov.cy
We
encourage you to contact us first to seek a resolution before you lodge a complaint.
Our commitment to protecting your personal data involves implementing the highest industry
standard security processes and systems. We use secured HTTPS protocol for communication
between the Website and your browser, ensuring that all data transmitted is securely
encrypted. In addition, our secure servers are safeguarded with advanced firewall
technology. We store your personal data within the European Union, on encrypted servers
and/or with certified data centers compliant with the "ISO/IEC 27001 - Information
security management" standard.
Despite these precautions, the security of
data transmitted over the Internet can never be guaranteed. Data may be transmitted across
international borders even when the sender and receiver are in the same country. We cannot
be held responsible for any compromise of data before it reaches our system.
Data Retention
We only process your personal data for as long as is necessary for the purposes for which
it was first collected. Your personal data will be retained for as long as we have a
relationship with you (for example, evaluating employment opportunities or answering your
queries) and up to one (1) year after that. Data used to provide you with information on our
offers, industry events, and other news and products of ours and our affiliates will be
processed until you indicate that you no longer wish to receive such information.
When we have no ongoing legitimate business need or lawful legal ground to
process your personal data, we will delete, anonymize, or aggregate it. If this is not
possible (for example, because your personal data has been stored in backup archives), we
will securely store your personal data and isolate it from any further processing until
deletion is possible. If you want to know more about retention periods applicable to your
particular circumstance, please contact us using the details provided in the contact section
below.
Sharing Your Personal Data
We may share your personal data with competent authorities having jurisdiction over
us. Such disclosures will only be made when permitted or required pursuant to the Data
Protection Laws and/or other legislation applicable to us.
We may share your
personal data with other companies in our corporate group – parent companies, subsidiaries,
and sister companies. As our processors, these companies will process your personal data on
our behalf on the grounds and for the purposes listed in this Privacy Policy.
We
may share your personal data with other selected third parties including but not limited
to:
• IT and related service providers and their sub-processors engaged in operating
our Website, such as service providers contracted to store your personal data (such as
Amazon Web Services);
Analytics, business intelligence partners and search engine
providers and their sub-processors, such as Google Analytics;
• Our lawyers, advisors,
auditors, and consultants, whom we may engage to advise on any matter which requires them to
gain access to personal data.
Your personal data will only be transferred
outside of the EEA when such transfers meet the requirements of the Data Protection Laws.
Your Personal Data will never be shared with third parties for marketing purposes (unless
you consent to it).
In the event of a sale, merger, or any other change in
ownership or control of our company, your personal data may be disclosed as part of the
transaction or during the preparation for such an event. The new owner or controlling entity
will be permitted to use your personal data, but only in accordance with the terms outlined
in this Privacy Notice, unless you provide explicit consent for other uses.
Children's Privacy
Our Website is not intended for individuals under 18, and we do not knowingly
collect any information from children. If we learn that we have collected or received
personal data from an individual under 18, we will delete that information upon awareness or
request.
Our Use of Cookies
Our Website may place and access certain cookies on your computer or device. A
cookie is a very small text file that is placed on an internet user's hard drive. It is
generated by a web page server, which is basically the computer that operates a website. The
information the cookie contains is set by the server, and it can be used by that server
whenever the user visits the site.
We use cookies and similar tracking technologies to
ensure the basic functionality of our Website, remember user preferences (including your
preferences regarding tracking technologies), improve the provision of our Services to you,
maximize the performance of our Sites, provide you with offers that may be of interest to
you, measure the effectiveness of our Website, marketing campaigns, and email
communications, and personalize online content.
We use various categories of cookies on
our site to enhance functionality and improve user experience:
• Essential Cookies:
These are necessary for basic site operations and cannot be turned off without affecting our
site's functions. Although you can set your browser to block these cookies, doing so
may impair website performance.
• Functional Cookies: These cookies provide enhanced
functionality and personalization, set either by us or third-party providers whose services
we've incorporated into our site.
• Analytics Cookies: These are used to gather
data on site visits and traffic sources, helping us to measure and enhance our
Website's performance. They enable us to identify the most and least popular pages and
observe visitor navigation on the site.
• Targeting Cookies: Set by advertising
partners, these cookies track your online activity to deliver targeted advertising on other
websites. They include cookies from third-party advertisers and social media platforms.
You
can manage non-essential cookies directly through your browser settings. For broader control
over cookies, most web browsers offer built-in functionality to block or manage settings.
You can find specific instructions for managing cookies in browsers like
Firefox,
Chrome,
Internet Explorer, and
Safari
through the provided links. Additionally, to manage Flash cookies and more detailed
information on cookies, visiting educational resources online can be helpful.
To
opt out of interest-based advertising, visit the
Digital Advertising Alliance (DAA),
Network Advertising Initiative (NAI),
and the
European Interactive Digital Advertising Alliance (EDAA)
websites. Mobile users can set device-based opt-out preferences that limit ad tracking,
which must be configured on each device used. Remember, changing devices or browsers or
clearing cookies requires resetting these preferences.
Contact Us
If you have questions about the Website or this Privacy Policy, please email our
Data Protection Officer at
dpo@brainrocket.com or by post at 4
Promitheos St., 1st floor, 1065, Nicosia, Cyprus.
Changes to Our Privacy Policy
We may change this Privacy Policy from time to time. Changes will be immediately
posted on the Website and deemed accepted on your first use of the Website following the
alterations in the Privacy Policy. Please check this page regularly to remain up to date
with any changes. Where appropriate, we will also notify you by email. If you do not agree
with any changes, you must stop using the Website.
Version 1.1
Effective Date: October 2024