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Privacy Notice
for Job Applicants at Amusnet Gaming

 Contents

1. About the Privacy Notice for Job Applicants

2. Job Application Information We Collect & Why?

3. Why Is Your Personal Data Processed?

4. When Do We Delete Your Personal Data?

5. Who May Access Your Recruitment Data?

6. Our Data Protection Measures

7. Your Rights Regarding Personal Data Protection

8. Failure to Provide the Information

9. Data Protection Officer

10. Competent National Supervisory Authority for Personal Data Protection

11. Changes to the Present Privacy Notice

 

  1. About the Privacy Notice for Job Applicants 

    1. AMUSNET GAMING LIMITED, a company incorporated in the Republic of Malta, with company registration number C 58265, and registered address at Quad Central Q2, Floor 6, Central Business District, Triq L-Esportaturi Birkirkara, CBD 1040, Malta, (hereinafter referred to as the “Amusnet Gaming”, “Company”, “We”, “Us”, “Our”) is a data controller and as a data controller complies with the rules and requirements of the Maltese and European legislation on personal data protection as detailed hereunder.
    2. The present privacy notice for job applicants (hereinafter also referred to as the “Privacy Notice”) aims to provide information on the processing of personal data of individuals (hereinafter also referred to as “Data Subjects”, “Job Applicants”, “You”, “Your”) who have submitted an application for employment with Amusnet Gaming, using any method made available by Amusnet Gaming for recruitment and selection purposes, such as via an email address or through a job posting platform maintained by a third party.
    3. This Privacy Notice applies also to personal data provided by Job Applicants for employment at Amusnet Gaming by sending their application in hard copy to the physical address for correspondence with the Company.
    4. This Privacy Notice is in compliance with the relevant data protection and privacy laws, including but not limited to the Regulation (EU) 2016/679 of the European Parliament and of the Council of 27th April 2016 on the protection of natural persons with regard to the processing of personal data and on the free movement of such data, and repealing Directive 95/46/EC (General Data Protection Regulation) (hereinafter referred to as the “GDPR”) and the Data Protection Act (Chapter 586 of the Laws of Malta) and the subsidiary legislation issued thereunder, as may be amended from time to time (hereinafter collectively referred to as the “Data Protection Legislation”).
    5. This Privacy Notice should be read in conjunction with the Privacy Policy, however in the event of conflict, this Privacy Notice shall prevail and apply for job applications with the Company. For the purpose of this Privacy Notice, all capitalised and/ or undefined terms not defined in this Privacy Notice shall have the meaning attributed to them by the GDPR. 
    6. In the capacity of individuals, applicants for employment, whether applying for a specific vacancy advertised by Amusnet Gaming or submitting an unsolicited application without the Company having advertised a current vacancy, You have the right to be informed about how and why Amusnet Gaming, as a Data Controller, collects, processes, stores and protects Your Personal Data which You have provided to the Company in connection with Your job application.
    7. The present Privacy Notice is published and is freely available on the website of Amusnet Gaming. The Privacy Notice may be amended and/or supplemented at any time by Amusnet Gaming, if necessary, and at Amusnet Gaming’s sole discretion.
    8. Please read the Privacy Notice carefully to understand how and why We process Your Personal Data in the context of recruitment, to whom We may disclose Your Personal Data, and what are Your rights in relation to this processing. By submitting Your job application electronically and clicking on the button that may be provided for this purpose, You declare and state that You have read the terms of this Privacy Notice. In case You need any additional information or have any questions regarding the processing of Your Personal Data in the recruitment and selection process, You may contact Amusnet Gaming at the contacts listed below in the Privacy Notice. 
    9. The present Privacy Notice does not restrict Your rights related to the processing of Your Personal Data by Amusnet Gaming in any way. The purpose of this Privacy Notice is to inform You and ensure the transparent and fair processing of Your Personal Data by Amusnet Gaming in the course of the recruitment and selection process. 

  2. Job Application Information We Collect & Why

    1. Amusnet Gaming processes the Personal Data provided by You in its capacity as a Data Controller. The Company collects and processes only those categories of Personal Data that have been provided to the Company voluntarily and directly by the applicants, or such Personal Data that were additionally provided by the applicants during the recruitment procedure and/or requested by Amusnet Gaming within the procedure for evaluating Your application.
    2. In certain cases, the Personal Data processed by Amusnet Gaming in connection with Your application is not collected or received directly from You, but from third parties such as recruitment agencies, for example, when You apply through such agencies.
    3. Amusnet Gaming processes the following categories of Personal Data related to Your job application, which You have provided voluntarily as part of Your application and recruitment process:
      • Identification data about You (which includes information such as Your full name, contact details such as address [current and/or permanent address), telephone number, e-mail address], date of birth, photograph (but only if You have voluntarily provided one as part of Your job application);
      • Information on education and acquired professional qualifications, which includes and may not be limited to Your completed education, acquired professional qualifications, scientific degree; completed educational courses, trainings, seminars, and/or other information related to acquired education and qualifications; knowledge of foreign languages and previous professional experience, as well as other information related to Your skills and qualifications;
      • Information on current and/or previous employment, which includes and may not be limited to Your details of employment; work experience; posts/positions held; roles and responsibilities performed; current and/or previous employers; length of service/experience; references and references from employer(s) where these have been volunteered by You;
      • Information concerning the possession of a driving license or other certificates of acquired competence (where and to the extent that such competence is necessary and required for the performance of the duties included in the scope of the position for which You are applying or when You have voluntarily provided such information);
      • Information on remuneration, including expected remuneration for the position You are applying for;
      • Information that You have voluntarily provided on Your initiative in the process of Your job application and that is not included in the above (for example, information provided through a CV, cover letter, and/or another document that You have provided or has been additionally requested from Amusnet Gaming within the recruitment procedure); and
      • Information collected and prepared by recruitment agencies and employment intermediaries to whom Amusnet Gaming has assigned recruitment activities, including collecting, reviewing, and evaluating applications, conducting interviews, and preparing reports and recommendations.
    4. The Personal Data contained in Article 3.3 may vary depending on the individual applicant and the requirements of the specific vacancy.
    5. Amusnet Gaming does not process special categories of Personal Data (such as health, racial or ethnic origin, political opinions) as part of the recruitment process, unless they are voluntarily provided by You. 

  3. Why Is Your Personal Data Processed?

    1. As part of the recruitment and selection procedure, Amusnet Gaming, as a potential employer processes Your Personal Data only insofar as it is necessary for the Company to evaluate and select potential employees, make a decision on Your potential employment, prepare a job offer and/or prepare a draft employment contract (as applicable). In particular, Amusnet Gaming processes the Personal Data which You provide for the following purposes:
      • Administration and management of Your job application with Amusnet Gaming, including identification of applicants, and written and oral communication with job applicants during the selection procedure;
      • Assessment of Your suitability for the relevant position, carrying out of evaluations, and reaching decisions regarding the extension of an offer of employment; and/or
      • In the event that You are selected for employment, the draft and preparation of an employment contract, and compilation of any other documentation required to complete the onboarding and recruitment process.
    2. Amusnet Gaming may process Your Personal Data solely in accordance with one or more of the following legal bases for lawful processed as laid down in the GDPR:
      • Consent: where You have provided Your explicit, freely given, informed, and unambiguous consent for the processing of Your Personal Data for one or more specified purposes, including but not limited to consideration for future employment opportunities;
      • Contractual Necessity: Where processing is necessary in order to take steps to enter into an employment contract with Amusnet Gaming, and, if applicable, for the performance of such a contract in the event Your application is successful and You accept an offer of employment;
      • Legitimate Interests: Where processing is necessary for the purposes of the legitimate interests pursued by Amusnet Gaming, including but not limited to evaluating the suitability of potential employees, ensuring alignment with the Company's recruitment needs and organizational goals, and maintaining an efficient recruitment process, except where such interests are overridden by Your interests or fundamental rights and freedoms which require the protection of Personal Data; and/or
      • Compliance with Legal Obligations: Where processing is required for compliance with legal obligations to which the Company is subject, including but not limited to obligations arising under the Data Protection Legislation, such as responding to data subject access requests, or to establish, exercise, or defend legal claims.

  4. When Do We Delete Your Personal Data?

    1. Amusnet Gaming will retain and process Your Personal Data only for as long as necessary to fulfil the purposes for which it was collected as set out above. In the event that Your application is unsuccessful, Your Personal Data will be retained for a period of 6 (six) months following the final decision on Your application, unless there is a legitimate interest for a longer retention period. This retention period is necessary to enable the Company to exercise or defend potential legal claims before any competent court and/ or any other public or regulatory authority based on its legitimate interests.
    2. Subject to Your explicit and informed written consent, Amusnet Gaming may retain Your Personal Data beyond the aforementioned six (6)-month period for the sole purpose of considering Your application for other current or future employment opportunities within the Company. We will retain Your Personal Data for this purpose indefinitely, unless You ask the Company to delete it sooner. You retain the right to withdraw Your consent at any time, without affecting the lawfulness of processing based on consent before its withdrawal, by submitting a written notice to the Company.
    3. In the event that Your application is successful and You enter into an employment contract with Amusnet Gaming, the Personal Data provided by You (or part thereof, as the case may be) will continue to be processed by Amusnet Gaming and will be incorporated into Your employment file, which the employer is obliged to compile and maintain. Additional documentation and Personal Data may be required to finalize the employment contract, subject to the relevant legal and regulatory obligations, and the internal rules and procedures of Amusnet Gaming. 
    4. Should You submit Your job application through a third-party online recruitment platform, please be advised that the privacy and data retention policies of the respective platform shall also apply. Amusnet Gaming bears no responsibility for the processing activities, data retention periods, or data protection practices of such third parties. You are therefore encouraged to review their applicable privacy documentation prior to submission.

  5. Who May Access Your Recruitment Data?

    1. As part of the recruitment procedure, the Personal Data which You provided will not be disclosed by Amusnet Gaming to third parties, outside the Amusnet Gaming corporate group, unless required by law or with your prior explicit consent. 
    2. Access to your Personal Data is strictly limited to the employees of Amusnet Gaming and/ or entities forming part of the Amusnet Gaming corporate group, who have a legitimate need and interest to process such data for the purposes set out in this Privacy Notice. Specifically, Your Personal Data may be made available only to employees of the relevant departments which are directly involved in the administration, management, assessment, and decision-making process regarding Your job application. All such employees are bound by confidentiality obligations and are required to process Your Personal Data in compliance with the Data Protection Legislation and internal Company policies.

  6. Our Data Protection Measures

    1. In accordance with the Data Protection Legislation, in addition to any other applicable laws, Amusnet Gaming implements all necessary technical and organizational measures to protect Personal Data from accidental loss and unauthorized access, use, alteration, or disclosure. The Company has adopted and ensured the implementation of internal policies and procedures designed to protect information from loss, misuse, and improper disclosure.
    2. In addition, Amusnet Gaming implements information security measures, including, but not limited to, access control, strict physical protection, and robust practices for collecting, storing, and processing information, such as encryption, pseudonymization, and anonymization of the collected personal data.

  7. Your Rights Regarding Personal Data Protection

    1. As the Data Controller, Amusnet Gaming is committed to ensuring that the Personal Data it processes is accurate, complete, and up to date, in accordance with its obligations under the Data Protection Legislation. To this end, it is important that You inform the Company of any changes to Your Personal Data during or upon conclusion of the recruitment process. As detailed hereunder, You have the right to request the rectification, updating, and/or supplementation of Personal Data if it is inaccurate, outdated, or incomplete. To exercise this right, You must submit a written request to Amusnet Gaming in accordance with the procedures and requirements set out under the applicable Data Protection Legislation. 

    2. You have certain rights related to the processing of Your personal data provided in the GDPR, including:

      • Right of access: You have the right to obtain information about the processing of Your Personal Data, and to access the Personal Data that we hold about You. You may also request a copy of such data.
      • Right to rectification: You have the right to request the correction of inaccurate, outdated, or incomplete Personal Data. We may verify the accuracy of the data before making any corrections.
      • Right to restriction of processing: You have the right to request the restriction of processing of Your Personal Data in the following circumstances:
        • if You contest the accuracy of the data, for a period enabling Us to verify its accuracy;
        • if the processing is unlawful, but You oppose the erasure of the data and request restriction instead;
        • if We no longer need the Personal Data for the purposes for which it was collected, but You require it for the establishment, exercise, or defense of legal claims; or
        • if You have objected to processing, pending the verification of whether Our legitimate grounds override Your rights.
      • Right to erasure: In certain circumstances, You may request the deletion of Your Personal Data. However, We may not be legally obligated to comply with such requests where processing is necessary for compliance with a legal or regulatory obligation to which We are subject (including, but not limited to, data retention obligations), or for the establishment, exercise, or defense of legal claims.
      • Right to data portability: You have the right to receive the Personal Data You have provided to Us in a structured, commonly used, and machine-readable format, and, where technically feasible, to request the transmission of that data to another data controller. This right applies only to Personal Data processed by automated means, based on Your consent or on the performance of a contract.
      • Right to object and rights related to automated decision-making: You have the right to object, on grounds relating to Your particular situation, to the processing of Your personal data. We will assess such objections and cease processing unless We can demonstrate compelling legitimate grounds that override Your interests, rights, and freedoms.
      • Right to withdraw consent: Where We rely on Your consent to process Your Personal Data, You have the right to withdraw that consent at any time. Withdrawal will not affect the lawfulness of any processing carried out before the withdrawal. Processing based on other legal grounds will remain unaffected.
      • Right to lodge a complaint: If You believe Your Personal Data is not being processed lawfully, You have the right to lodge a complaint with the relevant data protection authority as listed below in this Privacy Notice.

      The above rights are not absolute and may be subject to limitations or exemptions under applicable law. In certain cases, we may be unable to fulfill Your request if We are legally prevented from doing so.

    3. Please note that Amusnet Gaming does not use Your Personal Data for profiling or automated decision making. 
    4. All Personal Data requests mentioned herein shall be made in writing, signed by the data subject and submitted to Amusnet Gaming on [email protected].
    5. The Company will respond to such requests by no later than 30 (thirty) calendar days (with the possibility to extend this period for particularly complex requests in accordance with applicable law), implements them if there are grounds for doing so, or makes a reasoned refusal if there are reasons for doing so, indicating the right of the data subject to follow.

  8. Failure to Provide the Information 

    1. You are under no statutory or contractual obligation to provide Your Personal Data to the Company during the recruitment process. However, the provision of certain Personal Data may be necessary in order for the Company to assess Your job application and to take the requisite steps prior to potentially entering into an employment contract. 
    2. If You opt not to provide Us with the required information, the Company may be unable to process Your job application in whole or in part, which may affect its ability to evaluate Your eligibility and proceed with the recruitment process.

  9. Data Protection Officer

    1. If You wish to receive additional information on how Amusnet Gaming processes Your Personal Data and/ or if You have any questions about this Privacy Notice, you can contact the Data Protection Officer on [email protected].
    2. You can also forward any matters or queries relating to the recruitment process to [email protected] or by sending Your questions to the registered address of the Company, indicated at the beginning of this Privacy Notice.

  10. Competent National Supervisory Authority for Personal Data Protection 

    Office of the Information and Data Protection Commissioner 
    Address:  Floor 2, Airways House, Triq Il-Kbira, Tas-Sliema SLM 1549, Malta 
    Phone number: +356 2328 7100 
    E-mail:  [email protected] 
    Website: https://idpc.org.mt/ 

  11. Changes to the Present Privacy Notice

    1. This Privacy Notice may be amended over time by the Company at its sole discretion without any prior notice to You, and the changes made to it shall become effective promptly after being announced on the Company’s website. We therefore encourage You to check our Privacy Notice on a regular basis.