Candidate Data Privacy Notice (Serbia)

The purpose of this Privacy Notice is to inform you how Mily Technologies (which in particular means the company within the Mily Technologies group with which you are in communication) will process your personal data or information (within the scope of applicable data protection regulation) when you apply for a job or participate in the recruitment process ("Candidate Privacy data ").

1. The purpose for which we process your personal data

Mily Technologies will process your Candidate Privacy data for the following purposes:

  • To comply with legal obligations regarding Mily Technologies (such as creating and submitting reports under applicable laws or regulations or confirming that you meet legal requirements to work in a certain jurisdiction); and
  • For legitimate interests of Mily Technologies or third parties - We process your Candidate Privacy data  based on the following legitimate interests:
  • Conducting job application and recruitment process (identifying and evaluating a candidate, including assessment of skills, qualifications, and interests to determine suitability and fulfillment of the requirements for the position you have applied for; verifying your information and conducting employment background and reference checks, when applicable, with your consent when required;
  • Taking the necessary steps to establish an employment or other contractual relationship with you;
  • Keeping records related to our recruitment processes for as long as required by law or other internal requirements of record retention;
  • Compliance with our legal, regulatory, and other corporate governance requirements;
  • Analyzing and improving our application and recruitment processes, including determining how candidates found our job postings;
  • Preventing fraud in connection with our recruitment or employment processes;
  • Ensuring network and information security, including preventing unauthorized access to our computer and electronic communications systems and preventing the distribution of malicious software. Despite implementation of adequate security measures on our behalf, the publication or transmission of personal data over the Internet, including through recruitment systems, email, or other electronic means, is only partially secure. Mily Technologies cannot guarantee that personal data transmitted to us, especially electronically, will be completely safe. It may occur that third persons illegally intercept or access such data; and
  • In other cases where it is required or permitted by applicable law.

Apart for the aforementioned, if you would like to be considered by Mily Technologies for positions other than the one for which you have applied, you may instruct us to do so, and we will store and use your Candidate Privacy data.

2. Categories of processed data and legal basis for processing

Mily Technologies may, under applicable regulations, process the following types of your Candidate Privacy data based on our prevailing legitimate interest to conduct an efficient job application process and ensure the hiring of an adequate job candidate for a vacant position:

  • Contact information, such as full name, home address, telephone number, and email address;
  • All written and/or electronic communication you have exchanged with Mily Technologies;
  • Personal information, such as gender, date and place of birth, signature, photograph (if provided), race, ethnicity, current and previous citizenship, marital status, disabilities, veteran or military status, driver's license; should you choose to provide this information;
  • Educational and professional experience - work experience, academic and professional qualifications, educational records, references, job interview notes, and criminal records;
  • Employment data, such as information about your current employment, including job title, position, dates of employment, salary expectations, visa sponsorship requirements, work permit status, and specified information regarding your previous employment; job interview notes; evaluation and assessment data during the job application process;
  • Social networks and website profiles; should you choose to provide this information, and other information about you that are publicly available on the Internet.

There is no legal obligation to provide us with your personal data. However, part of the above-mentioned Candidate Privacy data is mandatory for our recruitment activities. If the candidate does not provide or allow Mily Technologies to process this particular Candidate Privacy data, it may affect our ability to make contact with you and consider you for employment.

Mily Technologies may collect Candidate Privacy data  1) directly from you as a candidate (including when you provide us with your personal data, cover letter and/or curriculum vitae via e-mail or submit an online or paper job application ); 2) from third parties, with your consent, when it is required, for example through employment background or reference checks; from an employment agency or other appropriate entity; or public sources; 3) during subsequent communication and/or job interviews upon submitting your job application.

3. Transfer of personal data

If necessary for the aforementioned purposes, Mily Technologies shall transfer part of your personal data to the following recipients:

  • Recruitment agencies we hire;
  • IT service providers we use; and
  • Companies that are part of the Mily Technologies group.

Candidate Privacy data may be transferred or stored internationally, including in countries that do not have personal data protection laws equivalent to those of the country in which you reside or in which your Candidate Privacy data is collected. Mily Technologies transfers Candidate Privacy data to countries which the Government of Republic of Serbia and EU Commission have evaluated as such that they have an adequate level of personal data protection; or Mily Technologies takes prescribed security measures to guarantee that all recipients provide an adequate level of personal data protection.

4. Storage period

Mily Technologies may store your personal data for two years from the application's submission date, or in case you give us your consent to keep your application for future recruitments, until you withdraw your consent. In any case, Mily Technologies will retain your personal data for as long as there are outstanding legal retention obligations or potential legal claims are still under the timeframe set by statute of limitations; or when it is necessary for other accounting or reporting purposes.

We may anonymize or de-identify your Candidate Privacy data  under certain circumstances, so that it can no longer be linked to you or used to identify you. We reserve the right to use such anonymized and de-identified data for any legitimate business purpose without additional notice or your consent unless required by law.

If Mily Technologies offers employment and you accept it, your Candidate Privacy data that we collected during the application and recruitment process will become part of your employment records and their use is subject to Mily Technologies' internal employer bylaws or the contract by which your employment is regulated. If you do not become our employee, or when you cease to be our employee, we will store and securely destroy your personal data in accordance with then applicable Mily Technologies' record retention policies and laws and regulations in force at the time.

5. Your rights regarding your personal data

Under applicable regulation, you may have, among other, the right (subject to the conditions set out in the applicable laws) to:

  • Check whether and what types of your personal data we hold and request copies of that data;
  • Request the correction, addition, or deletion of your personal data that is incorrect or processed in violation of applicable regulation. Please note that in certain circumstances, it may not be possible for us to accept your request for erasure, for example, when the processing is necessary to comply with a legal obligation or if the processing is necessary for the performance of a contract;
  • Request us to restrict the processing of your personal data. Please note that in certain circumstances, it may not be possible for us to accept your request, for example, when the processing is necessary to comply with a legal obligation or if there are other legitimate reasons that Mily Technologies can justify;
  • In certain circumstances, for legitimate reasons, you object to the processing of your personal data or withdraw the consent to the processing that was previously given;
  • Require data portability;
  • Know the identity of third parties to whom your personal data is transferred; and
  • File a complaint with the competent authority.

Withdrawal of your consent does not affect the lawfulness of processing based on your consent prior to your withdrawal. Please note that changing or withdrawing your consent may affect our ability to communicate with you.

You are responsible for the accuracy and up-to-dateness of your Candidate Privacy data. If your Candidate Privacy data changes during the recruitment process, you are obliged to inform us about it.

6. Our contact details

Please direct your request and any other questions regarding this notice to any of the following:

Mily Technologies will respond to the request/complaint without delay, but in any case no later than in 30 days as of the date of receipt of the complete and accurate request. This term may be extended by another 60 days if necessary, considering the complexity and number of requests. Mily Technologies will inform the candidate about the extension of the term and the reasons for that extension within 30 days from the day of receipt of the request. If Mily Technologies has reasonable doubts about the identity of the person who has submitted a request for the exercise of rights or when it cannot reliably identify the person who is contacting via electronic means, Mily Technologies will request the submission of additional information necessary to confirm the identity of this person. In cases where it cannot reliably identify the person requesting the exercise of its rights, Mily Technologies may refuse to act on the person's request only if it presents that it is unable to identify them.

Last updated on 02.06.2023.

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