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Privacy Policy

Last Revised 18.08.2023

 

FLH-Services LLC, together with its affiliates, associates and partners (“FLH-Services”, “we” or “us”) is a company specializing in building development team in Ukraine, as well as provision of other operational (back-office) solutions. In the course of its business, FLH-Services collects some information that could be used to identify you. We call this information “Personal data”. We control the collection and processing of personal data relating to individuals who interact with us (“data subjects” or “you”). The data subjects may include (without limitation): visitors and users of our website https://www.flh-services.com (collectively “users”); candidates for current or future roles at our companies or at our customers’ companies (“candidates”); as well as our existing or potential customers (collectively “customers”).

 

Please read this Privacy Policy that explains (1) what personal data we collect; (2) how we use, maintain, and otherwise handle your personal data; (3) the conditions under which we may disclose your personal data to others; (4) how we keep your personal data secure; and (5) the rights available to you regarding your personal data.

  

PERSONAL DATA THAT WE COLLECT

 

The personal data we receive in the course of our business may include the following:

 

  • contact details – such as full name, physical address, e-mail address, postal address, phone number, user IDs in messengers and telecommunication applications (e.g., Skype);

  • demographic information – such as age, gender, country of temporary and/or permanent residence, immigration status;

  • information referring to professional background – such as education data, professional experience & skills, credentials, references, former or current job title, role, occupation, industry, employers and/or clients, and participation in various projects;

  • other information – such as interests and preferences, as well as any other personal data provided by data subjects at their own initiative.

 

Please note that the specific range of personal data we collect varies on a case-by-case basis, and, among other things, depends on how you interact with us and for which purpose.

 

PERSONAL DATA THAT WE DO NOT INTENTIONALLY COLLECT

 

Of course, you are free to decide which information to share with us. However, we ask you to consider the following warnings:

 

  • Sensitive Personal Information: We do not intentionally collect sensitive personal information such as racial or ethnic origin, political opinions, religious beliefs, genetic data, biometric data, health information, or information related to sexual orientation.

  • Criminal Records: We do not intentionally collect information about criminal records or any legal offenses you may have been involved in.

  • Children's Data: We do not intentionally collect personal data from individuals under the age of 18 (or the age defined as "child" under applicable laws), without explicit parental or guardian consent. If we learn that we have unintentionally collected personal data from a child without proper consent, we will take steps to delete the information as soon as possible.

 

HOW WE COLLECT THE PERSONAL DATA

 

We collect personal data directly from you during various interactions, especially when:

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  • You apply for our open vacancies through different channels: -Via our website; Through external platforms (subject to the terms of use and privacy policies of those platforms); By directly contacting us through email, phone, LinkedIn, etc.

  • You engage in discussions regarding open positions, available roles, or potential job opportunities. This can occur through various means, such as email or phone/video calls.

  • You participate in the candidate selection process for available roles. This might involve interviews, assessment tasks, and more.

  • You subscribe to our marketing emails, which may include newsletters, surveys, and other relevant content referred to as "informational content."

  • You provide a testimonial related to our company, business, or services.

  • You communicate with us on third-party social networks like LinkedIn,  etc. (subject to the terms of use and privacy policies of those networks).

  • You request specific information from us.

  • You contact us for any other purposes.

  • You utilize any of FLH’s services or take part in any activities provided by FLH-Services.

 

While providing your personal data to us is generally not obligatory, it's important to note that fulfilling your requests or offering services (either in whole or in part) might be challenging if you choose not to share your data. If you inquire, we can inform you about whether providing your personal data is mandatory in a specific scenario, along with potential consequences if you opt not to provide it.

 

Please be aware that we might combine personal data obtained from various sources.

 

For individuals being considered for present or future positions within our companies or our customers' companies:

 

- We may gather pertinent personal information available to us from public sources, including but not limited to social media profiles (especially on platforms like LinkedIn) and job boards.

- We might receive necessary personal details about you from third parties. This could occur during professional reference checks (for example, confirming previous job titles and employment durations for a particular role).

- We could access your personal data from public records, such as extracts from registers of legal entities and individual entrepreneurs.

 

Rest assured that if a portion of your personal data is collected indirectly (such as discovering your profile online and adding your details to our database for the purpose of contacting you about participating in a role selection process), we will always notify you when collecting such data, or at the latest, within a month from the data collection date. We will process this personal data for the intended purpose until you request its removal. However, in such cases, FLH-Services reserves the right to retain some personal data to the extent necessary according to domestic and/or international legal provisions.

 

HOW WE USE THE PERSONAL DATA

 

FLH-Services employs your personal data for the following outlined purposes:

 

  • To furnish, uphold, manage, support, safeguard, and enhance our services, and to execute relevant transactions.

  • To streamline our recruitment endeavors, including but not limited to:

  • Handling inquiries and applications for various roles.

  • Engaging in communication with role applicants.

  • Assessing candidate data against role-specific criteria to identify suitable candidates.

  • Dispatching offers to choose candidates.

  • Coordinating subsequent collaboration with selected candidates, such as contract execution.

  • Maintaining a roster of potential future role candidates.

  • Reaching out to candidates for forthcoming opportunities that align with their interests.

  • Monitoring recruitment-related statistics.

  • To oversee the functionality of our website, encompassing:

  • Enabling users to explore and navigate our website.

  • Empowering users to engage in interactive features, if they opt to do so.

  • Enhancing the operation and user experience of the website.

  • Generating, publishing, and refining content of utmost relevance to users.

  • Addressing issues, investigating, and rectifying website-related errors.

  • For our internal marketing objectives, including but not limited to:

  • Conducting direct marketing initiatives, such as distributing subscribed informational content. However, you can opt out of such communications anytime by contacting us (please refer to the "Contacts" section).

  • Evaluating the effectiveness of ongoing marketing campaigns (e.g., gauging interactions with our website or responses to our emails).

  • Tailoring, analyzing, and enhancing informational content across our website.

  • To fulfill obligations stipulated by domestic and/or international law (e.g., health and safety regulations, taxation, accounting, reporting, anti-money laundering statutes) and to comply with court orders and legitimate requests from authorized entities.

  • To safeguard the rights, assets, and security of FLH-Services and third parties (e.g., deterring fraud and other prohibited or illicit activities).

  • For communication with you, encompassing but not limited to:

  • Providing real-time chat assistance via our website.

  • Addressing your online inquiries.

  • Supplying customer support.

  • Updating your particulars.

  • Soliciting your feedback or remarks regarding the services we furnish.

  • To respond to your requests for exercising your rights as a data subject under applicable data protection laws (more information available in the "Your Rights Regarding Personal Data" section).

  • To uphold the security and integrity of our website, business, and services.

 

This enumeration is not exhaustive; we may also process your personal data for any other purpose as disclosed to you, to which you have given explicit consent, or as necessitated or permitted by domestic and/or international law. 

 

LEGAL BASIS FOR PROCESSING OF YOUR PERSONAL DATA

 

The legal foundation for collecting, utilizing, storing, and processing your personal data hinges upon the nature of the data in question and the precise purpose it serves.

 

In a general context, we rely on the following bases:

 

• Legitimate Interest:

 

We have a legitimate interest in:

- Efficiently delivering information and services to fulfill your needs, including seeking, and selecting suitable candidates for roles at our customers' companies.

- Expanding and enhancing our business by reaching out to potential specialists for available positions within our organizations.

- The lawful operation and growth of our business.

 

Rest assured that we employ your personal data in manners that align with reasonable expectations. Our legitimate interest acts as a legal basis for collecting and processing your personal data only to the extent that it doesn't infringe upon your rights and freedoms.

You maintain the right to object to these grounds for processing your personal data by reaching out to us (please refer to the "Contacts" section). Upon your objection, we will promptly delete your personal data, unless an independent legitimate reason for further processing exists.

 

• Explicit Consent:

 

This applies when you permit us to process your personal data for a specific purpose.

 

NOTE: You retain the freedom to withdraw your consent at any time by contacting us (details available in the "Contacts" section). In such cases, we will promptly erase your personal data, except if another legitimate ground for further processing is present. The withdrawal of consent won't affect the legality of previous data processing based on your consent before its withdrawal.

 

• Contractual Obligations and Legal Compliance:

 

This encompasses:

-Meeting any stipulation of domestic and/or international law (e.g., health and safety, taxation, accounting, reporting, anti-money laundering regulations).

-Adhering to court orders or authorized requests.

-Asserting and/or defending against legal claims.

Rest assured that we manage your personal data exclusively for the purpose it was collected. If we intend to process your personal data for any other purpose, we won't proceed without notifying you or obtaining your explicit consent (subject to exclusions and limitations prescribed by domestic and/or international law).

 

NOTE! If you share the personal data of a third party with us, you confirm that you have acquired explicit, informed, and unequivocal consent from that individual for such data transfer and subsequent processing by us. You may be required to provide evidence of this upon request.

For inquiries or additional details regarding the legal basis for collecting your personal data, please feel free to reach out to us (details available in the "Contacts" section).

 

HOW LONG WE KEEP YOUR PERSONAL DATA

 

In order to determine the appropriate duration for retaining your personal data, we take into account the following factors: (1) the volume, nature, and sensitivity of the specific personal data; (2) the potential risks associated with unauthorized use or disclosure of the said data; (3) the objectives for which we process your personal data; (4) whether these objectives can be achieved through alternative means; and (5) the pertinent legal obligations.

 

We strictly adhere to the principle of retaining your personal data only for as long as necessary. This entails (a) fulfilling the purpose for which the data was originally collected (more information can be found in the "How We Use Personal Data" section); (b) complying with domestic and/or international laws or other regulatory requirements (such as accounting or reporting obligations) relevant to our business and the services we offer; or (c) asserting and/or defending against legal claims.

 

For instance:

• We will retain personal data collected with your explicit consent for the duration you have agreed upon.

• Personal data acquired in connection with your email subscription will be retained until you choose to unsubscribe.

• Personal data gathered in relation to your inquiries, requests, and/or complaints will be kept until the matter linked to these issues is resolved.

Below, you'll find specifics on the duration for which we retain personal data in certain scenarios (please be aware that this list is not exhaustive).:

 

CASE DESCRIPTION

RETENTION PERIOD

(starting from the moment of personal data collection)

Filling in ‘Contact us’ form on our website - 2 years

Sending us your CV and other personal data to be considered for specific IT vacancy - 2 years

Sending us your CV and other personal data to be considered for current and future available open positioins - 2 years

 

As a standard practice, the retention period usually spans up to 2 years. Nevertheless, certain legal obligations mandate us to retain specific types of personal data to fulfill statutory requirements (such as taxation, accounting, or reporting obligations).

 

In such instances, we will retain your personal data in our systems for as long as necessary to meet the pertinent obligations. Furthermore, in certain scenarios, we might anonymize your personal data (rendering it non-identifiable) for research or statistical purposes. In such cases, this information may be used indefinitely without additional notice to you.

 

We consistently conduct reviews of our personal data retention periods to ensure their appropriateness. Should you have any inquiries about the duration for which we retain your personal data, please don't hesitate to contact us (details available in the "Contacts" section) for comprehensive clarification.

 

YOUR RIGHTS WITH RESPECT TO PERSONAL DATA

 

As an individual whose data is being processed, you possess specific rights according to domestic and/or international law concerning the personal data we possess about you. If the handling of your personal data falls under the jurisdiction of European Union data protection regulations, including the General Data Protection Regulation (for instance, when you are situated within one of the European Union/European Economic Area countries), you are entitled to a minimum set of data subject rights outlined below.

 

Right of access:

 

If you ask us, we will confirm whether we are processing your personal data and, if necessary, provide you with a copy of such personal data (along with other details). There are some limitations and exceptions concerning this right: for example, where information is legally privileged, or if providing you with the information would reveal any personal data of another person.

 

Right to Data Portability:

 

In specific circumstances, you possess the right to receive the personal data you have provided to us and use it elsewhere or transfer it to another organization (or request us to do so if technically possible). This applies when (1) our legal grounds for processing the personal data are consent or the necessity to fulfill our contract with you, and (2) the processing is conducted through automated means.

 

Right to Rectification:

 

You can ask us to update or correct any inaccuracies in your personal data or complete any incomplete information related to you. If you do so, we will take reasonable steps to verify accuracy and rectify your personal data. Kindly inform us of any changes in your personal data to maintain its accuracy and currency. If rectification is applicable and we have shared your personal data with others, we will strive to notify them about the rectification where feasible. Upon your request, where feasible and lawful, we will also disclose the parties with whom your personal data has been shared, allowing you to contact them directly. Additionally, please note that FLH-Services is not obligated to inform third parties about rectifications when such notifications are unreasonably burdensome or disproportionately difficult.

 

Withdrawal of Consent:

 

Should we rely on your explicit consent as the legal basis for processing your personal data, you retain the right to withdraw that consent at any time by reaching out to us (please refer to the "Contacts" section). Withdrawing consent does not affect the legality of processing that occurred based on your consent before its withdrawal.

 

Right to object:

 

You can ask us to stop processing your personal data and we will abide so, if we are:

 

  • relying on our legitimate interest to process your personal data, except if we can demonstrate other compelling legal grounds for the processing; or

  • processing your personal data for direct marketing purposes.

 

Right to erasure:

 

In certain circumstances, you can request the 'blocking' or suppression of the processing of your personal data (such as when you challenge the accuracy of the data or object to our processing). This means we will refrain from processing your personal data until the restriction is lifted. If you are entitled to this restriction and we have shared your personal data with others, we will strive to notify them about the restriction if it is feasible for us to do so. Similarly, upon your request and if feasible and lawful, we will disclose the parties with whom your personal data has been shared, enabling you to contact them directly.

 

Right to restriction of processing:

 

You can ask us to ‘block’ or suppress the processing of your personal data in certain circumstances (such as where you contest the accuracy of that data or you object to us), so that we no longer process that personal data until that restriction is lifted. If you are entitled to restriction and if we have shared your personal data with others, we will let them know about the restriction where it is possible for us to do so. If you ask us, where it is possible and lawful for us to do so, we will also tell you who we have shared your personal data with, so that you can contact them directly.

 

Rights in relation to automated individual decision-making, including profiling:

 

You possess the entitlement to be safeguarded from decisions exclusively reliant on automated processing of your personal data, encompassing profiling, except when these decisions are indispensable for the initiation or fulfillment of a contract between you and us, or when they are grounded in your explicit consent (though such consent can still be retracted as outlined in the "Withdrawal of Consent" subsection).

 

For this reason, we typically seek your consent before analyzing your personal data (either independently or through our providers) to construct individual profiles. These profiles can aid in discovering your interests and showcasing targeted online advertisements, with the objective of presenting you with pertinent and captivating offers. The profiling is predicated on interactions with our website, emails, and content. As we refrain from collecting crucial personal information like your name, addresses, or financial details during this profiling process, we anticipate that the impact of such profiling will be limited, primarily enhancing your user experience while navigating the internet. We will abstain from making automated decisions that could lead to legal consequences or substantially impact you in a similar manner.

 

Right to file a complaint:

 

If you have a concern with respect to the way we process your personal data, you can report it to the relevant supervisory authority (the contacts of the European Union national data protection authorities are available at the website of the European Data Protection Board).

 

Please note that these rights are not absolute and in certain cases are subject to conditions as specified in the provisions of domestic and/or internationals law. For instance, it may happen if we have an overriding interest or legal obligation to continue to process your personal data.

 

You can exercise the above rights, where applicable, by contacting us directly (please see details in Section “Contacts”). We will respond to your request within the statutory period and typically seek to resolve the matter within one month. We will require you to provide satisfactory proof of your identity in order to ensure that your personal data is disclosed only to you.

 

While we will make reasonable efforts to accommodate your request, we reserve the right to reject such access requests, or to impose restrictions or requirements upon such requests if required or permitted by provisions of domestic and/or internationals law, but will explain “why” if we do so.

 

SHARING AND TRANSFERRING PERSONAL DATA

 

Please note that your personal data may be processed outside of the European Economic Area, particularly in Ukraine. If you are from one of the European Union/ European Economic Area countries, you should be informed that the European Commission hasn’t determined Ukraine as a country that offers an adequate level of data protection, which entails certain risks of losing the protection provided under the General Data Protection Regulation when your personal data is transferred outside of the European Union/ European Economic Area. Moreover, we may transfer your personal data to other countries outside the European Union/ European Economic Area (such as the United States, United Kingdom, etc.). In order to provide adequate protection for the transfer of your personal data, we have in place contractual arrangements such as the standard contractual clauses (as appropriate) implemented in the agreements executed with our customers and third-party service providers.

 

FLH-Services LLC may exchange your personal data with its affiliates, associates, and partners. Moreover, we may share your personal data with our customers and third-party service providers (as described below) where and to the extent necessary in connection with the purposes described in this Privacy Policy. Anyway, you may be assured that we do not share personal data with third parties, except as (a) necessary for our legitimate professional and business needs; (b) necessary to carry out your requests; (c) necessary to provide our services to you; (d) pursuant to your explicit consent; (e) required or permitted by law; and/or (f) as otherwise described in this Privacy Policy. FLH-Services will only transfer personal data to such persons when they meet our strict standards on the processing of personal data and security and pass those same standards down to their sub-processors.

 

Where we believe that processing or other business activities on our behalf or in our interest are better performed by third parties (“third party service providers”), we may outsource respective operations to them and, consequently, transfer your personal data to those persons, such as our IT systems providers, website hosting providers, data analysis, data backup, security and cloud storage services, consultants and other providers. We only share personal data that they reasonably need to provide their services and will not transfer your personal data to any third parties for their own direct marketing purposes. We ensure that third party service providers are authorized to use your personal data only as necessary to provide services on our behalf or in our interest.

 

Please note that the storage of your personal data on servers and/or on software made available or hosted by third party service providers shall not be considered a disclosure of your personal data to third parties as far as third party service providers do not have direct access to it. In all events, we shall ensure by contract that our third party service providers protect your personal data that is shared with them.

 

In an ongoing effort to better understand users of our website, we may analyze anonymous and aggregate information in order to operate, maintain, manage, and improve our website and/or services that we render. This aggregate information does not identify you personally. We may share this aggregate data with our customers, third party service providers and other persons. We may also disclose aggregated user statistics in order to describe FLH-Services services (or pursuing other lawful purposes) to current and prospective business partners, customers and other persons.

 

In certain situations, we may be required to disclose your personal data where we have a legal necessity or obligation to do so, including to meet the requirements set forth by domestic and/or international law. For instance, we may disclose your personal data to assert and/or defend against legal claims.

 

In the event of a sale, merger, receivership or transfer of all assets of FLH-Services, we reserve the right to assign or share your personal data with such third parties and their advisors. Please be assured that you will be sent notice of such an event should it occur with the ability to opt-out of such a transfer unless FLH-Services and/or such third parties have a separate legitimate ground for such transfer and further processing of your personal data.

 

PERSONAL DATA SECURITY

 

FLH-Services employs robust security measures to safeguard the information we handle, including your personal data. These measures encompass prevention, detection, investigation, and resolution of security threats, both during data transmission and upon receipt.

 

We make diligent efforts to ensure the protection of your personal data, whether in electronic or physical form (such as hard copies). This commitment is upheld through adherence to appropriate internal policies and the utilization of advanced technical and organizational measures that align with the European Union's requirements for secure and lawful personal data processing.

 

Furthermore, access to your personal data is limited to authorized personnel within FLH-Services, including internal staff, agents, or contractors, who require access to fulfill specific tasks. Your personal data is securely stored within restricted networks, accessible only to a limited number of individuals who are bound to maintain its confidentiality.

 

While we employ industry-standard precautions to fortify the security of your personal data, the transmission of data over the Internet (including via email) is never entirely immune to risk. Although we strive to safeguard personal data, achieving 100% security is not currently feasible in any online or offline setting. As a result, it's advisable to exercise caution when deciding which information to share with us, particularly when initiating such communication on your own.

 

If you have inquiries regarding security matters, please don't hesitate to contact us (details available in the "Contacts" section).

 

LINKS TO OTHER WEBSITES

 

Our website (including this Privacy Policy) may contain links to other websites and you should review the privacy policies on those sites. We have no responsibility for the policies and practices of those sites.

 

CHANGES TO THIS PRIVACY POLICY

 

We may from time to time, modify this Privacy Policy, upon which we will also update the ‘Last Revised’ date stated herein above. Even though we may inform you about any changes hereof (especially by sending you an electronic notice if you provided us with your e-mail address), you are still advised to visit this page regularly for the latest information on our privacy practices with regard to our privacy practices.

 

 

CONTACTS

 

If you (a) have any questions or complaints regarding this Privacy Policy or the way your personal data is processed; (b) would like to report any suspicious activity, including automated messages or calls from parties you cannot identify; or (c) would like to exercise a legal right in relation to your personal data, please contact us via the address below.

 

Email: info@flh-services.com

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