Global Privacy Notice for Recruitment

This Recruitment Privacy Notice (hereinafter “Privacy Notice”) explains how Bolt Technology OÜ and its group companies (hereinafter “Bolt” or “We”) processes your (hereinafter “You” or Data Subject”) personal data during the application and recruitment process.

1. Personal data we process

We only process the following personal data we need for the activities related to the application and recruitment process:

  • Contact details: such as name and surname, phone number, email address. Sources of collection of data: we get this data from you when applying for a position in Bolt. We may also get this data from a third party who refers you for a position.
  • Information included in your CV and/or cover letter: such as employment history, academic background, skills and experience, languages spoken and written, recommendations and referees and any other information submitted by you. Sources of collection of data: we get this data from you when applying for a position in Bolt. We may also get this data from the referees that you provide.
  • Information related to assessing your suitability: such as information given in interviews, test results undertaken during the recruitment process, personality assessment questionnaires. Sources of collection of data: we get this data from you when applying for a position in Bolt. Some data is generated during the recruitment process.
  • Copy of identification document: such as ID or passport copy. Sources of collection of data: we get this data from you prior to entering into the employment contract.
  • Compensation and payment or benefits related information: such as salary, bank account details. Sources of collection of data: we get this data from you prior to entering into the contract. Some data is generated during the process of preparing the agreement.
  • Criminal record checks if required by the law. Source of collection of data: we get this data from you when applying for a position which requires such background checks.
  • General communications: such as recruitment process related e-mails or other communications. Sources of collection of data: this data is generated during the recruitment process.

We may also get the data from external recruiters and agencies who carry out the recruitment process on behalf of Bolt as a partner.

2. The purposes and the legal grounds for the processing of personal data

We only process personal data when we have defined a relevant purpose and legal ground for the processing. The purposes and the legal grounds for the processing of personal data are the following:

2.1 Legitimate interest

Purposes of processing Categories of data
Evaluate your application and suitability for a position Contact details
Information included in your CV and/or cover letter
Copies of relevant documents
General communications
Information related to assessing your suitability
Contact you about your application and recruitment process Contact details
Evaluate referred candidates Contact details
Information provided by the person referring you for a position

2.2 Processing is necessary to take steps prior to entering into a contract

Purposes of processing Categories of data
Preparing the agreement Contact details
Copy of identification document
Compensation and payment or benefits related information

2.3 Processing is necessary for compliance with a legal obligation

Purposes of processing Categories of data
Evaluate your suitability for a position Criminal record checks

3. Recipients

  • In some circumstances we are legally obliged to share information with external recipients. For example, under a Court Order or where we cooperate with a data protection supervisory authority in handling complaints or investigations. We can also respond to requests, such as those from law enforcement agencies, when we have a good-faith belief that the response is required by law in that jurisdiction or furthers a public interest task, affects users in that jurisdiction, and is consistent with internationally recognised standards. In any scenario, we’ll always satisfy ourselves that we have a lawful basis on which to share the information, and we’ll make sure that we document our decision.
  • Depending on the location of the applicant, the personal data may be disclosed to the Bolt Technology OÜ group companies and partners (local subsidiaries, representatives, affiliates, agents etc). Processing of personal data by Bolt Technology OÜ group companies and partners will occur under the same strict conditions as established in this privacy notice.
  • We generally do not transfer your personal data outside of the European Union (EU) or the European Economic Area (EEA), nor to such third country or international organization, the level of data protection of which the European Commission has not considered adequate. If your personal data is transferred outside of the EU or EEA, such transfer of personal data will take place only upon appropriate legal basis, and we will take appropriate protective measures. You have the right to obtain additional information about the transfer of your personal data by sending the relevant request at privacy@bolt.eu.

4. Your rights

Your right of access

  • you have the right to know, whether personal data concerning you are being processed or not, what is the purpose of processing and what are the categories of personal data. Besides, to whom the personal data is disclosed (especially the recipients in third countries), for how long the personal data is retained and what are your rights concerning rectification, erasure and restriction of the processing.

Your right to rectification

  • you have the right to demand rectification of the personal data concerning you if the data are inaccurate or incomplete.

Your right to erasure

  • in some cases, you have the right to demand erasure of the personal data concerning you, for example in case when you withdraw your consent and there are no other legal grounds for the processing of the personal data.

Your right to restriction of processing

  • You have the right to ask us to restrict the processing of your information in certain circumstances. This means that your data can only be used for certain things, such as legal claims or to exercise legal rights.

Your right to object to processing

  • you have the right to object the processing of personal data, which is processed based on the legitimate interest, including profiling. Upon objection, we will no longer process the personal data unless we demonstrate compelling legitimate grounds for the processing which override your interests, rights and freedoms.

Your right to data portability

  • if processing of your personal data is based on your consent or the contract with us and the data processing is carried out by automated means, then you have the right to receive the personal data concerning you, which you have provided to us, in a structured, commonly used and machine-readable format. Also, you have the right to claim to transmit those personal data to another data controller if it is technically possible.

5. Retention of personal data

Your personal data shall not be kept for longer than is necessary for the recruitment process as following:

  • If you are not selected for the position, then we will store your data for 3 years to resolve possible disputes arising from the recruitment process.
  • If we conclude an employment contract with you, then we will store the personal data collected during the recruitment process for at least the duration of the employment relationship.

6. Dispute resolution

Disputes relating to the processing of personal data are resolved through customer support (info@bolt.eu) in the first instance. You have the right to contact Bolt's Data Protection Officer (privacy@bolt.eu).

Our supervisory authority is the Estonian Data Protection Inspectorate (www.aki.ee).

7. Making this notice great

We hope you have found this privacy notice easy to understand. Data protection laws are important. They strengthen rules and enhance your information rights. Many of these rules may appear complicated, but most are grounded in common sense. We take our responsibilities with your data seriously. Bolt will continue to make changes to this privacy notice as part of our commitment to protecting your privacy and affording you even more transparency.