Privacy Policy

Last updated March 2023

Whitespectre SLU L-711068-C Camí del Solà 25, La Cortinada, Ordino, AD300 ANDORRA (hereinafter referred to as “We”, “Us”, “Our”) is committed to protecting the privacy of its users. This Privacy Policy outlines the types of personal information that we collect, how we use and safeguard that information, and your rights in relation to that information.

We undertake to provide the best level of protection to your personal and non-personal information when using our website, our services, or interact with us, in accordance with our legal responsibilities as the ‘Data Controller’ under applicable data protection laws such as the US Data Protection Act (‘DPA’) and the EU General Data Protection Regulation (the ‘GDPR’).

We encourage you to read the present statement before using our website or applying for a job position. Your use of this website signifies that you understand and agree with all terms of this policy including, but not limited, to the way we may collect, use and share your personal and non-personal information.

This policy addresses data subjects whose data we may receive from our users in our websites located at https://www.whitespectre.com, https://www.paragoncommerce.com (the “Website(s)”) and from third parties sites that you may use to apply for a job opening via the application function on a job site or similar online service provider (“Partner”). You should note that the relevant Partner may retain your personal data and may also collect data from Us in respect of the progress of your application. Any use by the Partner of your data will be in accordance with the Partner’s Privacy notice.

2. Information We Collect

Personal information is information that can be used to identify you, such as your name, email address, phone number, and job application data. Non-personal information includes information that cannot be used to identify you, such as your browser type and IP address.

    We may collect personal information from you in the following ways:

    • When you apply for a job through our website or ATS (Applicant Tracking System) Workable, an online application provided by Workable Software Limited, to assist with Our recruitment process. We use Workable to process personal information as a data processor on Our behalf. Workable is only entitled to process your personal data in accordance with Our instructions.
    • When you subscribe to our newsletter.
    • When you fill out a form on our website.
    • When you contact us via email or other means of communication.

    Information we collect from other sources via our ATS Workable

    Workable provides Us with the facility to link the data you provide to Us, with other publicly available information about you that you have published on the Internet – this may include sources such as LinkedIn and other social media profiles.

    Workable’s technology allows Us to search various databases – some publicly available and others not, which may include your personal data (including your CV or Resumé), to find possible candidates to fill Our job openings. Where We find you in this way We will obtain your personal data from these sources.

    We may receive your personal data from a third party who recommends you as a candidate for a specific job opening or for Our business more generally.

    3. Use of Information

    We use the information that we collect for the following purposes:

    • To provide you with the services that you have requested.
    • To respond to your inquiries and customer service requests.

    • To send you marketing communications, such as newsletters and promotional emails. Note that we will only send them to you if you have opted-in to receive them, and you can unsubscribe/opt-out at any time.

    • To improve the functionality of our website and ATS system.
    • To evaluate your job application and communicate with you during the recruitment process in respect of a role for which you have applied or of other roles.
    • To help Our service providers (such as, but not limited to, Workable and its processors and data providers) and Partners (such as, but not limited to, the job sites through which you may have applied) improve their services.
    • To comply with applicable laws and regulations, including the GDPR (General Data Protection Regulation) for EU candidates.

    Automated decision making/profiling

    We may use Workable’s technology to select appropriate candidates for Us to consider based on criteria expressly identified by us, or typical in relation to the role for which you have applied. The process of finding suitable candidates is automatic, however, any decision as to who We will engage to fill the job opening will be made by Our staff.

    4. Sharing of Information

    We may share your personal information with third parties in the following circumstances:

    • With our service providers that help us to operate our website and ATS system.
    • With our affiliates and subsidiaries.
    • With law enforcement agencies, government authorities, or other third parties as required by law.
    • With third parties as necessary to protect our legal rights or the legal rights of others.

    Sharing your information with third parties

    We may share your personal data with our subsidiaries and affiliates, as well as with our service providers (collectively, “Third Parties”), who process Personal Data on behalf of Whitespectre, and who agree to use the personal data only to assist us in providing our services or as required by law. Our service providers include those providing:

    • application hosting services.
    • project management and content collaboration services.
    • team communication services.
    • software development services.
    • e-mail software.
    • customer relationship management (CRM) software.
    • application tracking system (ATS) software - Workable.

    Such Third Parties may be located outside the European Union or the European Economic Area. In any case, we are responsible for ensuring that these Third Party companies have an ‘adequate level of protection’ under the GDPR and have put in place a strict data protection policy and contractual clauses to protect any Personal Data we share with them.

    We require all Third Party services to respect the security of your personal data and to treat it in accordance with the law. We do not allow our Third Party services to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our instructions.

    Disclosure of candidate’s information when you apply for a job position

    As set out above, We pass your information to Our third party service providers, including Workable, who use it only in accordance with Our instructions and as otherwise required by law.

    Where you have applied for a job opening through the Indeed Apply functionality, and where you have consented to this disclosure, We will disclose to Indeed certain personal data that We hold, including but not limited to a unique identifier used by Indeed to identify you, and information about your progress through Our hiring process for the applicable job opening, as well as tangible, intangible, visual, electronic, present, or future information that We hold about you, such as your name, contact details and other information involving analysis of data relating to you as an applicant for employment (collectively “Disposition Data”). Indeed’s Privacy Notice in respect of Indeed’s use of the Disposition Data is available on Indeed’s website.

    Where you have applied to a job opening through another service provider, We may disclose data similar to the Disposition Data defined above to such service provider. The service provider shall be the data controller of this data and shall therefore be responsible for complying with all applicable law in respect of the use of that data following its transfer by Us.

    5. Security

    We take appropriate measures to ensure that all personal data is kept secure including security measures to prevent personal data from being accidentally lost, or used or accessed in an unauthorized way. We limit access to your personal data to those who have a genuine business need to know it. Those processing your information will do so only in an authorized manner and are subject to a duty of confidentiality.

    We also have procedures in place to deal with any suspected data security breach. We will notify you and any applicable regulator of a suspected data security breach where We are legally required to do so.

    Unfortunately, the transmission of information via the internet is not completely secure. Although We will do Our best to protect your personal data, We cannot guarantee the security of your data transmitted through any online means, therefore any transmission remains at your own risk.

    6. Were We store your personal data

    Where We store your personal data in Our own systems, it is stored Andorra.

    The data that We collect from you and process using our third party services may be transferred to, and stored at, a destination outside the European Economic Area ("EEA"). It may also be processed by staff operating outside the EEA who work for Us or for one of Our suppliers. Such staff may be engaged in, among other things, the fulfillment of your requests and the provision of support services. By submitting your personal data, you agree to this transfer, storing or processing.

    In particular, if you apply for a job position, your data may be accessible to i) Workable’s staff in the USA or ii) may be stored by Workable’s hosting service provider on servers in the USA as well as in the EU. The USA does not have the same data protection laws as the United Kingdom and EEA. A Data Processor Agreement has been signed between Workable Software Limited and its overseas group companies, and between Workable Software Limited and each of its data processors. These data processor agreements are designed to help safeguard your privacy rights and give you remedies in the unlikely event of a misuse of your personal data.

    If you would like further information please contact Us (see ‘Contact’ below). We will not otherwise transfer your personal data outside of the United Kingdom OR EEA or to any organization (or subordinate bodies) governed by public international law or which is set up under any agreement between two or more countries.

    7. Your Rights

    Under the General Data Protection Regulation you have a number of important rights free of charge. In summary, those include rights to:

    • access to your personal data and to certain other supplementary information that this Privacy Notice is already designed to address
    • require Us to correct any mistakes in your information which We hold
    • require the erasure of personal data concerning you in certain situations
    • receive the personal data concerning you which you have provided to Us, in a structured, commonly used and machine-readable format and have the right to transmit those data to a third party in certain situations
    • object at any time to processing of personal data concerning you for direct marketing
    • object to decisions being taken by automated means which produce legal effects concerning you or similarly significantly affect you
    • object in certain other situations to Our continued processing of your personal data
    • otherwise restrict Our processing of your personal data in certain circumstances
    • claim compensation for damages caused by Our breach of any data protection laws.

    For further information on each of those rights, including the circumstances in which they apply, see the Guidance from the UK Information Commissioner’s Office (ICO) on individuals rights under the General Data Protection Regulation.

    If you would like to exercise any of those rights, please:

    • contact Us using Our Contact details below,
    • let Us have enough information to identify you,
    • let Us have proof of your identity and address, and
    • let Us know the information to which your request relates.
    8. How to complain

    We hope that We can resolve any query or concern you raise about Our use of your information.

    The General Data Protection Regulation also gives you the right to lodge a complaint with a supervisory authority, in particular in the European Union (or European Economic Area) state where you work, normally live or where any alleged infringement of data protection laws occurred. The supervisory authority in the UK is the Information Commissioner who may be contacted at http://ico.org.uk/concerns/ or telephone: +44303-123-1113.

    9. Cookies

    Cookies are small text files that can be used by Websites to make a user’s experience more efficient. Cookies help us to provide you with a good experience when you browse this Website and allow you to make full use of the features available on this Website. 

    We use cookies on our Website for one purpose, and that is to collect statistical information about how visitors use our website, so we can improve the way this website works and measure our success. By recording such statistics as browser usage, visitor location, operating system etc. we can measure and improve on how we manage and maintain our site, in order to give you an ultimately better visitor experience.

    Most web browsers automatically accept cookies. Unless you have adjusted your browser settings so that it will refuse cookies, cookies will be set when you access our Website. By continuing to use and browse this Website, you agree and consent to our use of cookies. If you do not consent, please understand that certain features of our Website may not function as intended.

    If you would like to manage your use of cookies then you can find out how to do so by visiting www.allaboutcookies.org

    10. Changes to this Privacy Policy

    We may update this Privacy Policy from time to time. The updated Privacy Policy will be posted on our website with the updated date. Your continued use of our website after the updated Privacy Policy has been posted indicates your acceptance of the updated terms.

    11. Contact Us

    If you have any questions or concerns about this Privacy Policy or our use of your personal information. As We are based in ANDORRA, We have appointed Andrés Guillot to be Our representative within the EEA. Their contact details are [email protected].

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