Privacy Policy

MindDig Privacy Policy

Introduction

Minddig cares about privacy and protecting the Personal Data handled by us. This means that we care about your personal integrity and actively work to protect it.

In this Policy we overall describe how and the purposes for which we use your Personal Data as well as what lawful basis we use and what measures we take to protect Personal Data.

MindDig AB Reg. No. 559339-4249 ("Minddig", "we", "us", "our") is the Controller of all Personal Data listed in this Privacy Policy (the "Policy").
This Policy provides information on how we handle Personal Data when you communicate with us, use the Services or visit our website www.minddig.com (together the "Functions").

The intended recipient of the information provided in this Policy is:

  • Users of the Services
  • Potential customers
  • Customers
  • Employees of potential customers
  • Employees of existing customers
  • Visitors of our website

Definitions

"Applicable Law" refers to the legislation applicable to the Processing of Personal Data, including the GDPR, supplementary national legislation, as well as practices, guidelines and recommendations issued by a national or EU supervisory authority.
"Controller" is the company/organisation that decides for what purposes and in what way personal data is to be Processed and is responsible for the Processing of Personal Data in accordance with Applicable Law.
"Data Subject" is the living, natural person whose Personal Data is being Processed.
"Personal Data" is all information relating, directly or indirectly, to an identifiable natural person.
"Processing" means any operation or set of operations which is performed on Personal data, e.g. storage, modification, reading, handover and similar.
"Processor" is the company/organisation that Processes Personal Data on behalf of the Controller and can therefore only Process the Personal Data according to the instructions of the Controller and the Applicable Law.
"The Services" the Services we provide to connect job seekers with growing companies who wish to hire new employees.

The definitions above shall apply in the Policy regardless if they are capitalised or not.

Minddig's role as a Controller

The information in this Policy covers Personal Data Processing for which Minddig is the Controller. As a Controller we are responsible for the Processing activities for which we decide the purpose of and the means for the Processing (for example why we Process data, what methods we use for Processing, what Personal Data and for how long it is stored). The Policy does not describe how we Process Personal Data in the role of a Processor - i.e. when we Process Personal Data on behalf of our customers.

MindDig's Processing of Personal Data

We have a responsibility to describe and demonstrate how we fulfill the requirements that are imposed on us when we Process your Personal Data. This policy aims to give you an understanding of what type of Personal Data we Process and on what reasons.

Processing of Personal Data that MindDig receive from you

The information that you provide to us is being Processed for the following purposes: 
- to provide our Service to you, which includes storing the talent profile you create in our system and making it visible to companies using our Services to look for new talents; 
-to respond to your contact request when you have used the contact form on our website;
-to identify you and to contact you with relevant information about the Services;
- to inform you of relevant job offers, communicate about career services and to inform you about updates and new functionalities in our Services; 
- to match your profile with job listings and provide personalized recommendations and listings;
- to provide functionalities (including the QR-functionality described below) to our Customers which allow them to organize and make certain lists of candidate profiles based on certain parameters; 

- to provide a functionality in the Service where our customers may create recommendations together with a comment about you to other customers of the Services;
- to match your profile with talent profiles provided by our Customers in order to provide Customers with relevant talent suggestions;
- to match your Personal Data towards job ads in the Services by using a matching algorithm with the purpose to create recommendations about you to our Customers; 

- to match your Personal Data towards job ads in the Services by using a matching algorithm with the purpose to create recommendations about available jobs to you;
- to offer personal development and career advise; 
- to describe our Services in general;  
- to comply with the legal requirements imposed on us, and to be able to provide information requested by authorities.

Processing of Personal Data that MindDig collects about you 

By socialmedia e.g. Facebook or other media
Through third-party analysis technology ex. cookies
Through our logs
Through information created from data analysis

Lawful basis

In order for us to be able to Process your Personal Data, it is required that we have so-called legal basis for each Process. In our business, we Process your personal data mainly on the following grounds:

Processing is necessary for the performance of a contract with you

For the Processing of the talent profile that you have chosen to register in our Services, this is the main legal basis that we rely upon. This is also the legal basis we apply for the Processing activities where we match talent profiles with job listings (for example by using the matching algorithm referred to above) and when we inform you about job offers. We also rely on this legal basis when responding to contact requests from our website.

Legitimate interest 

MindDig may Process Personal Data if we have assessed that a legitimate interest overrides the interest of fundamental rights and freedoms of the Data Subject, and if the Processing is necessary for the purpose in question. We rely upon this legal basis when we are communicating with users about our Services, for our marketing activities (including newsletters), when recommending talent profiles to our Customers.

When we process your personal data for the purposes of matching your talent profile and other Personal Data that we have about you with the purpose to recommend you to our customers, we rely upon our legitimate interests and our customers interests to provide this functionality within our Services.

When we analyze the usage our services, use cookies and similar, we do this based on our legitimate interest to develop and market our Services and to analyze the result of our marketing activities.  

For how long do we store your Personal Data?

We will keep your Personal Data as long as it is necessary for the purpose for which it was collected. In the list below, we indicate, where possible, the period during which the Personal Data will be stored and the criteria used to determine the storage period.

We never Process your Personal Data longer than necessary and we delete Personal Data regularly. MindDig also takes reasonable actions to keep the Personal Data being Processed updated and to delete outdated and otherwise incorrect or redundant Personal Data.

The talent profile you have created is retained in the system for as long as you are actively interacting with the system. If you have not been using the system for twenty-four months, you will be contacted and asked to confirm if you wish your talent profile to remain in the system. If such confirmation is not obtained the talent profile will automatically be deleted.

You may at any time choose to delete your talent profile and the information contained therein, partly or the entire profile, from our Service. This can be managed by you when you are logged in to our Service.  

The cookies we use in our Services store Personal Data and the retention periods vary depending on what cookie is being used. Please refer to our Cookie Policy for more information.

QR-functionality

Talents that sign up to our Services by using a QR-code from one of our Customers will create a talent profile which is stored in the Service according to this Privacy Policy.

The QR-functionality allow our Customers to categorize and make certain list of talent profiles after certain parameters that the company chooses.

If you are new to MindDig and register your talent profile by being redirected from one our Customer’s QR-code you will be visible only to that Customer for twenty days. After this time period, you will be visible to every company using the Service.

It is always optional for you if you want to be exclusively shown to one of our Customer as described above and you have the right to withdraw yourself form this Company list at any time. This can be managed from your own talent page.  

Recommendations about you and about available positions

In our Services, we provide a functionality that creates job recommendations to the Users that have created a talent profile in our Services. In addition to this, we provide similar functionality to our customers that for example creates recommendations about talents that matches a certain job-posting of the customer. 

The matching of a talent profile towards job ads are made by a matching algorithm. The matching algorithm analyses tag-data from your MindDig profile and all job-postings, to cross reference potential matches between your MindDig profile and new job-postings. This means that the recommendations are created automatically from this technology and without the interaction by a human being. 

Your rights

You are the one in control of your Personal Data and we always strive to ensure that you can exercise your rights as efficiently and smoothly as possible.
Access - You always have the right to receive information about the Processing of data that concerns you. We only provide information if we have been able to verify that it is you that are requesting the information.
Rectification - If you find that the Personal Data we Process about you is incorrect, let us know and we will fix it!
Erasure - Do you want us to completely forget about you? You have the right to be forgotten and request deletion of your Personal Data when the Processing is no longer necessary for the purpose for which it was collected. If we are required to retain your information under applicable law or a contract that we have entered with you, we will ensure that it is Processed only for the specific purpose set forth in such applicable law or contract. We will thereafter erase the information as soon as possible.
Objections - Do you disagree with our assessment that a legitimate interest for Processing your Personal Data overrides your interest in protecting your privacy? Don’t worry - in such case, we will review our legitimate interest assessment. Of course, we add your objection to the balance and make a new assessment to see if we can still justify our Processing of your Personal Data. If you object to direct marketing, we will immediately delete your personal information without making an assessment.
Restriction - You can also ask us to restrict our Processing of your Personal Data
Whilst we are Processing a request from you for any of your other rights;
If, instead of requesting erasure, you want us to limit the Processing of Personal Data for a specific purpose. For example, if you do not want us to send advertising to you in the future, we still need to save your name in order to know that we should not contact you; or
In cases where we no longer need the information in relation to the purpose for which it was collected, provided that you do not have an interest in retaining it to make a legal claim.
Data portability - We may provide you with the data that you have submitted to us or that we have received from you in connection with a contract that we have entered with you. You will receive your information in a commonly used and machine-readable format that you can transfer to another personal data manager.
Withdraw consent - If you have given consent to one or several specific Processing(s) of your Personal Data, you have the right to withdraw your consent at any time and thus ask us to terminate the Processing immediately. Please note that you can only withdraw your consent for future Processing of Personal Data and not for Processing that has already taken place.

How you use your rights

By contacting us through info@minddig.com you will get the help required.

Transfer of Personal Data outside EU/EES

All data that is added to our Services and any data generated therein will be stored within the EU/EES. 

In order to run our business, we may need help from others who will Process Personal Data on our behalf, so-called Processors.

In cases where our Processors are located outside of EU/EEA, we have ensured that the level of protection is adequate, and in compliance with applicable law, by controlling that either of the following requirements are fulfilled:
the EU Commission has determined that the level of protection is adequate in the third country where the data is Processed;
the Processor has signed up to the EU Commission's standard contract clauses (SCCs) for data transfer to non-EU/EEA countries; or
the Processor has taken other appropriate safeguards prior to the transfer and that such safeguards comply with Applicable law.

Our Processors and other recipients

Minddig does not sell your Personal Data to third parties and of course we do not share your Personal Data with just anyone. However, in some cases we may need to share your Personal Data with selected third parties. If so, we make sure that the transfer happens in a secure way that protects your privacy. The following are categories of recipients with whom we may share your data.

- Suppliers of various HR systems or HR services ex. CLM systems or for the payment of salaries. 
- IT suppliers for e.g. business systems and case management. In order to be able to carry out our assignments and services, we store your Personal Data in our business systems (a system that administers our customers and contacts)
- Statistics to contribute to industry statistics and to improve the customer experience.
- MindDig’s customers or partners which are searching for talents by using the MindDig system.

We have entered into Data Processing Agreements (DPA) with all our Processors. The DPA sets out, among other things, how the Processor may Process the Personal Data and what security measures are required for the Processing.

We may also need to disclose your personal information to certain designated authorities in order to fulfill obligations under applicable law or legally binding judgements.

Security measures

Minddig has taken technical and organisational measures to ensure that your Personal Data is Processed securely and protected from loss, abuse and unauthorised access.

Organisational

The following security measures are measures that are implemented in work methods and routines within the organisation.
- Internal governance documents (policys/instructions)
- Login and password management
- Information security policy
- Physical security (premises etc.)

Technical Security Measures 

The following technical security measures are implemented through technical solutions.
- Encryption
- Access control level
- Access log
- Secure network
- Back-up

Cookies

Minddig uses cookies and similar tracking techniques to analyse the use of the Functions so that we can give you the best user experience. For more information on how we use cookies, see our Cookie Policy (www.minddig.com/cookies).

If we don’t keep our promise
If you think that we are not Processing your Personal Data correctly, even after you have notified us of this, you are always entitled to submit your complaint to the Swedish Authority for Privacy Protection.
More information about our obligations and your rights can be found at www.imy.se

You can contact the authority via e-mail at: imy@imy.se

Changes to this policy

We reserve the rights to make changes to this Policy. In the event that the change affects our obligations or your rights, we will inform you about the changes in advance so that you are given the opportunity to take a position on the updated policy.

Contact

We have appointed a Data Protection Officer who can answer questions about your rights and other questions about how we Process your personal information.
Contact information for
Markus Gustafsson
markus.gustafsson@minddig.com

This policy was updated 2023-09-19