This Privacy Statement describes our practices with respect to Personal Data collected via the Website at www.olxgroup.com (“Website”) and in the course of recruiting for the OLX Group (please refer to section 1 below to find out more about who exactly the OLX Group is). This Privacy Statement further provides information on your rights under applicable data protection and other laws, including the European Union’s General Data Protection Regulation (“GDPR”). For the purposes of this Privacy Statement, ‘Personal Data’ is any data under Art. 4 No. 1 GDPR, i.e. data which relates to an individual who may be identified from that data, or from a combination of a set of data.
1. Who is the data controller?
OLX Global B.V., Gustav Mahlerplein 5, 1082 MS Amsterdam, the Netherlands (“OLX”) is the data controller responsible for the processing of your Personal Data on the Website. OLX has subsidiaries and affiliated companies all over the world forming the global “OLX Group” (OLX Group is also meant when the words “we” or ”us” are used below). When you not only use the Website as a visitor but also apply for a job with the OLX Group, please be aware that OLX and the respective OLX Group company which you seek employment with will both be responsible for processing your data (the GDPR calls this joint controllership). This means you can assert your rights both against OLX as well as against the recruiting company of the OLX Group. To find out which OLX Group company is recruiting in which country, you can check the “Brands” section of the Website.
You can reach OLX Group’s data protection officer for any questions or feedback by mailing to [email protected]. Please understand that any inquiries not related to privacy or data protection issues can neither be answered nor forwarded internally. We invite you to address all customer relation inquiries to the respective customer service responsible for the OLX Services your inquiry relates to.
2. What type of personal data do we process and how do we collect it?
Information you actively provide to us when you apply for a job (“Application Data”):
We primarily receive information when you use the contact form, subscribe to job alerts or apply for a job on the Website. When you use our contact form, apply for a job or subscribe to our job alerts (“Services”) on the Website we may require you to provide us with certain Personal Data such as name, email address, phone number in order to contact you or to answer your queries. While applying for a job you may also be required to provide your resume/CV and cover letter which may contain additional Personal Data to process your corresponding request.
We usually do not require special categories of personal data for the application process. Please do not include such data in your application documents if that is possible. Where such data are relevant in exceptional circumstances, we will process them together with other applicant data. This may include information on job restrictions based on pregnancy or health issues or information on disabilities in view of our special legal obligations vis-á-vis the disabled. In these cases we process your data for carrying out obligations and exercising specific rights in the field of employment and social security and social protection law. Our legal basis for processing is Art. 9 no. 2 (b) GDPR and/or for the assessment of your working capacity Art. 9 no. 2 (h).
During the recruitment process we may ask you to provide additional information concerning your experience, qualifications and job expectations. In particular, you may be invited to the online/traditional interview and asked to answer some questions and/or solve dedicated tests confirming your qualifications for the position.
We need your Application Data for the solicitation, evaluation, and selection of applicants for employment with OLX Group. Thus, your Application Data will be processed for the purposes of managing our recruitment related activities, which include setting up and conducting interviews, and as is otherwise needed in the recruitment and hiring processes. Our legal basis for processing your Application Data is Art. 6(1)(b) GDPR.
Please note that by submitting your application you acknowledge the privacy practices explained in this notice. We will process your Application Data in the manner and for the duration explained in this notice.
Information collected during cognitive assessments in the course of the application process (“Assessment Data”):
Please be aware that we might conduct so-called behavioral and cognitive tests to assess your suitability for employment with OLX Group. We also do tests to assess the coding skills of candidates we would like to hire as developers (which might include live-coding experiences). These tests will be conducted through an online assessment platform operated by one of our third-party providers. To invite you to do these online assessments, we will send you a direct link once you have applied for a position with OLX Group. You will learn more about the identity of our service provider before you start the assessment. We will process Assessment Data for the sole purpose of assisting our recruiters in determining if you will be successful in the role for which you have applied and evaluating and assessing the results of your test. We will not use the assessment result for any automated decision-making. Our legal basis for processing Assessment Data are Artt. 6(1)(b), 88 GDPR and its respective EU Member State implementations.
Information collected during online interviews:
Due to the latest changes to modern economy as well as the way we work today, we would like to offer unique experience and opportunity to take part in a modern recruitment process that allows candidates to fully present all their skills and strengths that are important to the OLX Group.
We realize that in the age of remote working, taking part in a recruitment interview may involve some difficulties. These difficulties can be caused by travel restrictions, lack of suitable conditions for an online interview during the day, problems with computer equipment, video applications or internet connection.
For this reason we decided to offer you a new way of recruitment interviews. During the recruitment process you may be asked to record a short video which will supplement your CV. We call these recordings “Virtual CVs” or “VCV”. During the recording session we gather your data in the form of image, email address, user ID and system logs. Access to the recording is strictly limited to the people responsible for the recruitment process and we do not share your data with any third parties except for service providers of a recording system. Your participation in this form of recruitment is entirely voluntary and takes place with your consent. If you decline to do so we will offer you the alternative option of a classic recruitment interview in the form of an online video interview or a phone call. Accordingly, our legal basis for processing your Virtual CV is Art. 6(1)(a) GDPR.
Depending on the job position, we may request a showcase of your soft skills after the initial part of the recruitment interview on Zoom. In such cases, we may ask you to act out a short scene according to a prepared script and ask you whether you agree to video recording. The video recording will help us to share the scene with the relevant hiring managers and to streamline the recruitment process. As recording this part of the interview is absolutely voluntary, we assure you that if you do not agree to the recording, you will not experience any negative effects as a result. In particular, your refusal will not decrease your chances of employment with our Group. To make sure your consent is provided on a voluntary basis, we would like to ask you to consider, prior to the interview, whether you give your consent to the recording of the scene. Accordingly, our legal basis for processing your Zoom interview is Art. 6(1)(a) GDPR.
Information gathered from third parties (“Third-Party Candidate Data”):
To evaluate your application, we may process data collected not directly from yourself but also from third parties. If this is the case, we will send you a notification without undue delay after adding your data to our systems (unless you have already received such a notification from the third party who transmitted the data to us). Your Personal Data will either be obtained from publicly available sources (e.g. career networks such as LinkedIn, Glassdoor, Indeed or others; we do not collect data from social media) or provided to us by someone who referred you for potential employment, such as an OLX Group employee, a recruitment agency or a headhunter. Your Personal Data will be processed solely for the purpose of managing our recruitment related activities, which include setting up and conducting interviews and tests for applicants, evaluating and assessing the results thereto, and as is otherwise needed in the recruitment and hiring processes. Such processing is legally permissible under Art. 6(1)(f) GDPR as well as EU Member State implementations of Art. 88(1) GDPR as it is necessary for the purposes of the legitimate interests pursued by OLX Group which are the solicitation, evaluation, and selection of applicants for employment.
Information gathered automatically on the Website (“Website Access Data”):
When you visit the Website, OLX collects in log-files your information such as Internet Protocol (“IP”) address, demographics, details of your computer’s operating system, browser type, and your Internet service provider in order to provide better usability, troubleshooting, site maintenance, and to understand which parts of the Website are visited and how frequently. The legal basis for this processing is Art. 6(1)(f) GDPR as OLX needs to process this data to guarantee the functionality and security of the Website. OLX also processes certain further Personal Data through cookies, web beacons and other technologies (“Website Usage Data”). To learn more about this, please refer to the Information on The Processing of Website Usage Data by Cookies and Tracking Tools at the very end of this Privacy Statement.
3. How is your personal data shared?
3.1 The Website is powered by our database provider, the online recruiting service Greenhouse and Lever. Your Personal Data will be processed on behalf of OLX Group by Greenhouse Software, Inc. and/or Lever, Inc., both cloud services providers located in the USA and engaged by OLX Group to help manage its recruitment and hiring process on our behalf. Nonetheless, you can rest assured that we store all candidate data on servers in the EU. The transfer of Personal Data to third countries or the access to Personal Data from third countries will only take place if the conditions laid down in Art. 44 et.ceq. GDPR are met. Further, Greenhouse Software, Inc. will ensure an adequate level of protection for Personal Data at any point in time.
3.2 OLX Group is an organization with a global footprint. Therefore, we share information between OLX Group companies located in different countries if the role at stake requires such sharing. OLX Group companies use Application Data or Third-Party Candidate Data only for the sole purpose of assisting the respective hiring company with their recruiting. For example, this is the case when an OLX Group company recruits for another OLX Group company. All OLX Group companies must honor this Privacy Statement as well as strict intra-group data transfer agreements, which ensure an adequate level of protection for Personal Data within the scope of the GDPR also where Personal Data is shared with an OLX Group company located outside the European Economic Area (EEA). As a general rule, if you apply for a job in the EEA and the recruitment process requires an OLX Group company to share your Personal Data with other OLX Group companies outside the EEA, we will process your Personal Data on the legal basis of Art. 6(1)(b) GDPR.
3.3 If your Personal Data is transferred outside the EEA, we guarantee that the appropriate level of protection is assured by the introduction of one of the following safeguards:
- We will transfer your Personal Data to those third countries outside the EU that have been certified by the EU Commission as those who assure the adequate level of protection. Further information is available here: European Commission: Adequacy of the protection of personal data in non-EU countries
- While contracting with external service providers outside the EEA we will apply standard contractual clauses certified by the EU Commission to provide an adequate level of data protection for any transfers outside the EU. Further information is available here: European Commission: Model contracts for the transfer of personal data to third countries
3.4 We may share Personal Data with government authorities as requested by applicable law. Personal Data may also be shared with private or public authorities that will enable us to fight fraud and abuse on our network, to investigate suspected violations of law, or to fight any other suspected breach of our terms of service.
3.5 As a matter of policy, we do not rent or sell Personal Data about our users or candidates with non-affiliated third parties unless we have specific permission to do so. In the event that our business or a division of our business is reorganized or sold and we transfer all or substantially all of our assets to a new owner, your Personal Data may be transferred to the buyer to enable continuity of service.
4. For how long do we retain your data?
Unless you are starting your employment with us after your application, with your consent, we will store and process the Application Data to maintain our talent pool and to contact you in the future with job offers for a period of 12 months after you have completed the application process. Accordingly, our legal basis for this is Art. 6(1)(a) GDPR. Before the end of this retention period we will contact you via email to ask you if you want to remain in our talent pool and extend your consent or if you would rather be deleted upon expiration of the initial retention period.
If you do not grant us your consent for a longer retention period, we will store your Application Data for a period of 6 months after you have completed the application process.
We keep all other Personal Data no longer than necessary for the purpose for which we obtained them and for any other permitted compatible purposes, including compliance with legal obligations in the field of employment law. Group records management schedules document the applicable minimum retention periods required by local laws.
5. What legal rights do you have?
As a data subject under the GDPR, you have the following rights:
- SUBJECT ACCESS: You have the right to access your Personal Data in many circumstances, generally within 1 month of your request;
- RECTIFICATION: You can ask us to have inaccurate Personal Data amended;
- ERASURE: You can ask us to erase Personal Data in certain circumstances, recognising that OLX Group must in any case respect its data retention legal obligations in the field of employment;
- WITHDRAWAL OF CONSENT: You can withdraw at any time any declaration of consent that you have given us and prevent further processing if there is no other legitimate ground upon which OLX Group can process your Personal Data;
- RESTRICTION: You can require certain Personal Data to be marked as restricted for processing in certain circumstances as defined in Art. 18 of the GDPR;
- PORTABILITY: You can ask us to provide you with a copy of your Personal Data in a such a form that you can send it to a third party;
- RAISE A COMPLAINT: You can raise a complaint about our processing with the data protection regulator in the EU Member State of your habitual residence, place of work or place of where you think a violation of the GDPR has occurred.,
- OBJECTION: You have the right, for reasons arising from your particular situation, to object at any time to the processing of your Personal Data, which is processed on the basis of Art. 6(1)(f) GDPR (data processing on the basis of a balance of interests); this also applies to any profiling for the purposes of Art. 4(4) GDPR based on this processing. If you object, we will no longer process your Personal Data in the future unless we can prove compelling grounds for the processing that outweigh your interests, rights and freedoms or the processing serves to assert, exercise, or defend legal claims.
If you would like to exercise any of the above rights, please contact your dedicated OLX recruiter.
6. How will we notify you of changes to this privacy statement?
This Privacy Statement was last updated on 17 December 2021. We may update this Privacy Statement from time to time. If we make any substantial changes in the way we use your Personal Data we will notify you by posting a prominent announcement on the Website.
7. Information on the processing of website usage data by cookies and tracking tools:
Cookies are used whether you apply for a job with OLX Group or not. “Cookies” are small text files transferred by a web server to your hard drive and thereafter stored on your computer. With the help of cookies, the web server can save, for instance, preferences and settings on the user’s computer, mobile phone or other device which are then automatically restored on the next visit. Additionally, on the Website, we use web beacons, which are small graphic elements (also known as ‘tracking pixels’). They are used together with cookies to identify our users and their behavior.
We use both persistent cookies and session cookies. Whereas persistent cookies remain on your computer for a longer period of time, session cookies are automatically deleted when the browser window is closed.
- Necessary cookies: These cookies are installed to provide you with access to the Website and its basic functions, and therefore do not require your consent.
- Functional cookies: allow the Website to remember your preferences or choices (such as username, language, text size or other elements that you can adjust) and provide you with personalized content on the Website. If you do not agree to the use of these cookies, some of our services may not function properly.
- Performance cookies – allow us to check the number of visits and traffic sources on the Website. They help us recognise the level of popularity of a given site and understand how users move around the site. This allows us to improve the performance of our Website.
- Advertising cookies – these are used to provide you with advertisements relevant to you and in line with your interests.
You can manage cookies through:
- your web browser which should allow you to change your settings to reject, delete or block cookies. Following these links you will find relevant information for the most popular browsers: Google Chrome, Mozilla Firefox, Internet Edge, Safari.
- the Consent Management Platform which will appear in the form of a cookie banner during your first visit to the OLX Website. During subsequent visits, you can change the selected settings using the Cookie settings button at the bottom of the Website.