Privacy Policy
Last updated: January 31, 2022.
This is our – the SCOBO app (hereinafter referred to as the “App”) team’s – privacy policy, which applies to the processing of personal data of SCOBO registered users (hereinafter referred to as “You”).
The core of the SCOBO team consists of employees of the public institution Diversity Development Group (registration code 302877111, address Lukiškių str. 5-527, Vilnius), which is considered the controller of the data processed for the purposes of the App (hereinafter referred to as “We”). The aim of the App is to find the employer or employee who best meets Your expectations and criteria. In order to achieve this goal, we must process the personal data You provide when registering.
When processing Your personal data, we comply with the requirements of the General Data Protection Regulation (hereinafter referred to as the “GDPR”), the Law on Legal Protection of Personal Data of the Republic of Lithuania, as well as other legislative acts concerning personal data handling.
If You are job searching, in order to provide You with quality services, we:
1. Allow You to create an account (profile) in the App in which You indicate Your work experience and expectations for finding a new job;
2. Save Your needs and the system provides the job offers that best meet Your expectations and criteria;
3. Give You the opportunity to apply for relevant jobs and contact employers who meet Your criteria directly.
If You are an employer in order to provide You with quality services, we:
1. Allow You to create an account (profile) in the app where You post job offers (ads);
2. Save Your needs and show them to the employees who meet Your criteria the most;
3. Give You the opportunity to contact the candidates of interest directly. We purposefully show to the suitable candidates Your proposed positions when inviting them to apply.
In order to provide the above services, You provide and We store the following information:
| Data category | If You are job searching | If You are an employer |
| Mandatory registration data (necessary to complete registration in the App) |
Name;
|
Information about Your company; Information about the employees You are looking for; Information on the vacancy; Email address. |
| Optional registration data (may be provided if You so choose) | Telephone number; Education; Field of study; Languages that You know; City in which You are job searching. |
|
| Access data | Your unique login key, which is generated when You first sign up for the App. This login key is required in order to send messages to Your devices. | Your unique login key, which is generated when You first sign up for the App. This login key is required in order to send messages to Your devices. |
| Technical data (automatically generated data from Your device and the App) | Time and duration of the app sign-in session. |
Time and duration of the app sign-in session. |
| Correspondence or communication data (if You submit inquiries to us by email) | Email address; Information about email sender, e.g., name and surname; Content of the message. |
Email address; Information about email sender, e.g., name and surname; Content of the message. |
When You create an account in the SCOBO app, You choose a login password. The National Cyber Security Center recommends using strong passwords that are at least 12 characters long and consist of uppercase letters, lowercase letters, numbers, and special characters. It is recommended to use a unique password that is not used anywhere else.
Do not disclose Your account password to third parties. If You disclose Your password or any other account information to other persons, You will be responsible for all actions taken while using Your account.
Your password is the key to signing in to Your account. We do not accumulate Your passwords. By logging in to Your account, You can change and update Your data at any time. If You forget Your password, You can create a new one.
| Purpose and circumstances of the data processing | Categories of data processed | Legal basis for data processing | Data retention period |
| To create Your profile and provide basic SCOBO App services | Mandatory and optional registration data Login key | Legitimate interest (Art. 6(1) (f) GDPR) to provide and receive services | Data is processed as long as Your account is active, i.e. until You delete it |
| Data analysis to improve App performance and user experience | Aggregated and anonymized technical data Aggregated and anonymised mandatory and optional registration data | Legitimate interest (Art. 6(1) (f) GDPR) to improve the services offered in the App and Your interest in receiving quality services |
Anonymized (which does not allow to identify you as a person) personal data may be stored for an unlimited period of time |
| Identify and address technical vulnerabilities in the App and ensure compliance with security controls | Technical data Other categories of data, depending on the nature of the incidents | Legitimate interest (Art. 6(1) (f) GDPR) to ensure security and prevent unfair practices by third parties | The data shall be processed until the technical problem or security incident is resolved and stored for 1 year after the resolution of the incident |
| Respond to inquiries and requests from App users | Correspondence or communications data | Legitimate interest (Art. 6(1) (f) GDPR) to ensure continuity and quality of services Legal obligation (Art. 6(1) (c) GDPR) to facilitate the exercise the rights of data subjects under the GDPR | Data is stored for 6 months after the last response to Your request |
Upon expiry of the specified data retention period, we will delete Your data, unless it is necessary for the fulfillment of legal obligations (e.g. to respond to legal claims) and regulatory requirements (e.g. to provide data to competent authorities on legal grounds).
We will not transfer Your personal data to third parties unless it is necessary to ensure the services we provide or required by law. For these reasons, Your personal data may be transferred to the following groups of recipients:
• Companies providing technical support and technical infrastructure services (e.g. data hosting and storage services) for the App;
• Facebook and Google, which provide sign-in plugin services. These companies may process Your data in third countries, therefore we recommend that You familiarize Yourself with the information provided by the following companies and Standard Contractual Clauses put in place by them:
• Competent public authorities, but only if required by law or court decisions;
• We may share aggregated and anonymized (which does not allow us to identify You as a person) information with sponsors specified in this App and a wider audience by informing them about the services provided in the App.
When processing personal data, we respect and facilitate Your rights under the GDPR and the Law on Legal Protection of Personal Data of the Republic of Lithuania. You have the following rights:
a. correct or supplement, rectify incorrect or inaccurate personal data about You. You can do this in the “Profile” section of the App;
b. delete Your account and erase Your personal data. If You delete Your account, Your personal data will be deleted from the system, we will no longer have it and we will not be able to recover it. In this case, You will no longer be able to use the App and we will not be able to help You find potential employers or employees;
c. get access to Your data that we have collected, in other words, to receive a copy of the data we hold about You. You can see Your registration details in the “Profile” section of the App;
d. request restriction of data processing – if You believe that we are processing Your data unlawfully or the data we hold about You is incorrect, You can request that we temporarily pause processing of Your data. In such a case, until lawfulness of processing is verified, we can only store the data, while other actions with it would require Your consent;
e. request to object to the processing – if You believe that there are specific reasons why we should not process Your data, You can also contact us outlining these reasons and request that Your data not be processed;
f. file a complaint with a supervisory authority – if You believe that we are processing Your data unlawfully, You can also file a complaint with the data protection authority. In Lithuania, this is – State Data Protection Inspectorate
You can submit a request for the exercise of Your rights and contact us by e-mail diversity@diversity.lt
We may change this Privacy Policy from time to time to reflect the current situation. Once we will make changes, we will specify an update date at the top of this page. We recommend that You periodically review our privacy policy so that You know how we protect and process Your personal data.