Last updated: 27/05/2021
(hereinafter, the “Policy”).
This Privacy Policy governs your use of the website which is accessed at the web address www.avanzpro.mt (“this Website”) and the use of any and all services provided in relation thereto (the “Services”). The Website is owned and operated by Kbiz1 Ltd (“We”; “Us”; “Our”; “Avanzpro”). We are committed to protecting and respecting your privacy.
This Policy sets out the basis on which any personal data that We collect from you, or that you provide to Us, will be processed by Us. It should be read in conjunction with such other terms as are applicable to you, including without limitation, in the case of users providing jobs (“Recruiters”), the Terms and Conditions applicable to Recruiters or in the case of users who are potential candidates for such jobs (“Job Seekers”), the Terms and Conditions applicable to Job Seekers. The Terms and Conditions applicable to both Recruiters and Job Seekers (together, the “Users”; “You”) are accessible via the following links www.avanzpro.mt/job-seeker-terms and www.avanzpro.mt/employer-terms (each as applicable being hereinafter referred to as Our “Terms of Service”).
Please read the following carefully to understand Our views and practices regarding your personal data and how We will treat it. You must give your express consent to the terms and practices set out in this Policy in order to access and browse the Website.
If you do not consent to the terms and practices set out in this Policy, you must immediately exit Our Website.
Therefore, please read this Policy carefully.
For the purposes of the Data Protection Act (Chapter 440 of the Laws of Malta) (the “Act”) and/or the General Data Protection Regulation (Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 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, the “Regulation”), together with any amendments from time to time (once the latter are in force), Avanzpro is the data controller.
A. Legal Basis for Processing Activities
We principally rely on three separate and overlapping legal bases to process your personal information lawfully, and to ensure conformity with Our obligations under applicable data protection laws. Firstly, it is necessary for Us to process your personal information in certain ways, in order to provide the services available over the Website to you, in accordance with the contract created between you and Us as a result of your acceptance of Our Terms of Service and to ensure the performance of this contract.
Secondly, where you have given Us valid consent to use your data in certain ways (that is, affirmative, free and unambiguous consent), We will rely on such consent. Lastly, in very specific cases, We may process your information where necessary to further Our legitimate interests, and where those particular interests are not overridden by your interests or fundamental rights and freedoms. The circumstances giving rise to this latter scenario are described below in the section entitled: ‘Disclosure of Your Information’.
B. Information We Collect From You
Kindly note that the provision of certain information is mandatory in order to use the Website and this will be clearly indicated to You. For instance, if You fail to complete a required field, then further use of the Website will be blocked. If a Job Seeker or Recruiter profile is not completed (for the purposes of account registration), logging-in to Avanzpro and/or making use of Our services will not be possible.
Job Seekers will be able to browse through all job vacancies available at any one time on Avanzpro or alternatively may peruse job postings which will be filtered on the basis of their choice of industry, job category, basis of employment (e.g. full-time, part-time etc.) as well as channel (that is, either vacancies posted directly from employers or vacancies posted by recruitment agencies). Job Seekers can submit their application in respect of a particular listing and Avanzpro will forward such application to the relevant Recruiter accordingly. Any information which You provide at this stage to the Recruiter or, as applicable, to the Job Seeker (excluding that which has already been made available or visible via the Website), is entirely at your own discretion and choosing.
Recruiters posting job listings on Avanzpro may opt to receive job applications directly through their own website/career portal and in this case Avanzpro will not be forwarding applications/candidate resumes to the employer but will simply re-direct the Job Seeker to the web address at the external link as provided by the employer at the job posting stage. In these instances, Job Seekers who are made to apply for a job directly through the employer’s website are informed that those websites will have their own privacy policies and that We do not accept any responsibility or liability for those policies.
We will collect and process the following data about you:
1. Information that You Give Us
a. Basic Account Information: Job Seekers who choose to create a profile on the Website, must provide Us with some personal information, including name and surname, e-mail address (which will act as the username), password, and a confirmation whether the Job Seeker is currently based in Malta. Job Seekers may also opt to receive e-mail notifications when vacancies are posted on the Site in the categories which are of interest to them. Should Job Seekers not wish to receive further job alerts from Us, they are to disable this function accordingly from their profile.
As a Job Seeker, you will also be requested to provide us with your Curriculum Vitae (C.V.), but this will not be available or visible to other users of the Website. To this end, We will only use your C.V. for the purpose of making it available specifically to the Recruiters for whose job the Job Seeker has applied for through Our site. Upon receiving a job application through Our site, Recruiters can only use the C.V. and any other supporting document for the purpose of the job application and any other use or misuse of such information is strictly prohibited. Avanzpro shall in no way be held liable for any use or misuse of such information out of context. Once a Job Seeker’s C.V. and other personal data of the candidate are transferred to the Recruiter, the Recruiter, in terms of the General Data Protection Regulation (Regulation (EU) 2016/679) becomes a data controller in its own right and thus will have to abide by its own data protection obligations, including but not limited to, the obligation to store personal data for a period that is not longer then necessary for the purposes of data processing.
Recruiters shall have access to the C.V. which the Job Seeker has stored on their profile for a period of not longer then three (3) months from the date of application. If during the three (3) months following a job application, a Job Seeker replaces the C.V. he/she has stored on his/her profile (from the one which he/she applied for the job with), Recruiters would then have access to the updated C.V. as stored on Our Website. The deletion of a Job Seeker’s C.V. and any supporting documents held by a Recruiter following an application through Our site will be at the discretion of the Recruiter. Job Seekers who wish to have their information, as held by Recruiters, following an application through Our site, deleted, are to request this directly from the Recruiter.
Recruiters who choose to create an account on the Website will be requested to provide Us with the company name, the company’s VAT number, the company e-mail address, the company’s website, the company’s billing address, the industry in which the company operates, an e-mail address which will be used to receive notifications of any new job applications, a brief description about the company, the name of the company representative who is utilising Our Website, the company representative’s position within the company and his/her contact number. Recruiters may also provide Us with their logo which will be displayed on the individual job listings as well as a promotional banner which will be displayed on the company’s dedicated page on Our site.
b. Contact Information: We will use the e-mail address provided to us to send an initial e-mail to all new Users which will then allow them to activate their profile on our Site. Users may use their contact information, such as e-mail address or phone number, to, for instance, (i) report an issue with the Website, (ii) report a problem they may have encountered in relation to any of the features on the Website (e.g. an unsatisfactory service) and/or (iii) contact Our customer support team or correspond with Us in general.
c. Payment Information: If you are a Recruiter, depending on the payment method you select to affect payment to Avanzpro, You may be required to supply your valid credit card information as well as billing address details. The payment information that you supply is processed on Our behalf, and at Our instructions, by Our third-party payment processing and billing service provider/s.
2. Information We collect about You
a. Visit and Search Information: With regards to each of your visits to the Website, we collect and process information about the searches that you have placed, your browsing results, the particular industries and categories you have indicated an interest in and your user history.
b. Technical Information: With regards to each of your visits to the Website, we collect and process technical information about the devices which you use to access the Website. Additionally, We also collect and process the full Uniform Resource Locators (URL), clickstream to, through and from our Website (including date and time). Other technical information that we process includes Your log-in information, page response times, download errors, length of visits to certain pages, page interaction information (such as scrolling, clicks, and mouse-overs) and methods used to browse away from the page/Website.
3. Information we receive from other sources
We work closely with third parties in order to be able to provide you with the particular services available over the Website. Namely, these third parties include the payment gateway operators which we use for the purposes of the Website, advertising networks, analytics providers, and search information providers. We will use the information we receive from these sources to provide you with a better service and better communication, to run our overall statistics and to evaluate the performance of the Website.
We will provide you with the information We receive about you from these third parties and the purposes for which We intend to use that information, upon your request.
C. Uses Made of the Information
We use information held about you in the following ways:
1. Information you give to us. We will use this information:
a. to facilitate the provision of the Services available over and through the Website in accordance with Our Terms of Services.
b. to resolve any issues which you may have reported with regards to the Website;
c. to provide You, or permit selected third parties to provide You, with information about other, separate services which may interest You. Where You have registered an account, We will contact You by electronic means (i.e. e-mail) with information about such services, provided You opt in to receiving such information when registering for your account;
d. to notify You about changes to the Website, and/or the services that We provide over the Website;
e. to generate reports for statistical purposes; and
f. to ensure that content featured and displayed on the Website generally is presented in the most effective manner for You and for your devices or mediums.
2. Information we collect about You. We will use this information:
a. to administer the Website, and for internal operations, including troubleshooting, data analysis, testing, research, statistical and survey purposes;
b. to improve the Website, and to ensure that content is presented in the most effective manner for You and for your device and mediums;
c. to allow You to participate in interactive features of the Website, when You choose to do so;
d. to provide suggested job opportunities, based on your page browsing, history and any other information that You give us or place on the Website;
e. as part of our efforts to keep the Website safe and secure;
f. to measure or understand the effectiveness of advertising featured on the Website; and
g. to make suggestions and recommendations about other services which may be of interest to You.
3. Information We receive from other sources
We will combine this information with information You give to Us and information We collect about You. We will use this information and the combined information for the purposes set out above (depending on the types of information We receive).
D. Disclosure of your Information
As stated above, to be able to provide You with the services available over the Website, We work closely with third parties as well as various partners including the payment processing and billing service provider that We have engaged.
Such selected third parties shall include:
a. The payment processing and billing service provider which We use in order to process any transaction over the Website.
b. Additionally:
- Advertisers and advertising networks that require the data to select and serve relevant adverts to you and others. We do not disclose information about identifiable individuals to our advertisers, but we will provide them with aggregate information about our users (for example, the number of people that have clicked on an advert in any one day). We may also use such aggregate information to help advertisers reach the kind of audience they want to target.
- Web analytics and search engine providers that assist us in the improvement and optimisation of our Website (including in respect of email delivery).
Except for the instances outlined directly above, We shall not, without your prior consent, disclose, or otherwise make accessible, the information that You give Us or which We collect from You.
Job Seekers, however, acknowledge that the information provided to us for the registration of their account will, in the instance of a job application, be made available to the Recruiters using the Website (please refer to Section 1 above).
Notwithstanding the above, we may disclose your personal information to third parties:
- In the event that We sell or buy any business or assets, in which case We may disclose your personal data to the prospective seller or buyer of such business or assets;
- If all of Our assets are acquired by a third party, in which case the personal data held by Us regarding the users of our Website will be one of the transferred assets; and
- If We are under a duty to disclose or share your personal data to comply with any legal obligation, judgement, court order or regulatory order, or to enforce or apply our Terms and Conditions, or to protect Our rights, property, or safety or that of Our users or partners, or others. This includes exchanging information with other companies and organisations for the purposes of fraud protection and credit risk reduction.
E. Where We Store your Personal Data
The data that We collect from you, as outlined and described by this Policy, will remain stored on Our servers and shall not, at any point in time, be transferred to any destination outside of the European Economic Area (“EEA”).
F. Period of Storage
Both in the case of Job Seekers as well as Recruiters, We will only store your account information that We process as part of your registration (as described above) for a period of five (5) years from the date of the termination of your registered account on the Website, so as to be in a position to use such data for the defence of possible, future legal claims and taking into account the applicable prescriptive period at law, saving your specific rights to request erasure, rectification and restriction outlined below. All other information which you provide as part of your use of the Website will be deleted shortly following the termination of your registered account. Specifically with respect to the financial transactions (receipts from sales, any payments relating to refunds etc) which we conduct with Recruiters, We will store this financial information for a period of ten (10) years following the termination of the relationship between Us and the Recruiter.
Both in the case of Job Seekers as well as Recruiters, should there be no active engagement of Our Services or communication between us for a consecutive period of five (5) years, we will delete your personal data from our systems as your data would no longer be relevant for the purposes for which it was collected.
In cases where You are only visiting the Website anonymously, your personal data will only be processed and stored temporarily, and shall be deleted shortly following your exit from the Website.
G. Your Rights
You are entitled to exercise the following rights [without expense]:
a. Right to Withdraw Consent: You have the right to withdraw your consent to this Policy, and the processing practices described herein, at any time by sending an email to info@avanzpro.mt. Withdrawing your consent would be tantamount to your terminating your account in accordance with the Terms of Service applicable to You which termination will be processed at our end without delay including through the deactivation of your account. This will not however affect the lawfulness of processing which We carried out on the basis of such consent before its withdrawal.
b. Data Marketing: You have the right to ask us at any time not to process your personal data for marketing purposes (even if such processing activities have already commenced). We will usually inform You (before collecting your data) if we intend to use your data for such purposes or if We intend to disclose your information to any third party for such purposes. You can exercise your right to prevent or object to such processing at any time by contacting Us at info@avanzpro.mt.
c. Right of Access: You have the right to request confirmation from Us whether or not We have processed personal data concerning You and, if this is the case, you also further have the right to request access to such personal data.
d. Right to Rectification: You have the right to obtain the rectification of any inaccurate personal data about you that We have processed, and the right to have incomplete personal data completed, including by means of providing a supplementary statement.
e. Right to Erasure: You have the right to obtain the erasure of the personal data We may have processed concerning You and We shall have the obligation to erase such personal data where, for instance, you have withdrawn your consent to these processing activities.
f. Right of Restriction of Processing: You have the right, in the following scenarios, to obtain restriction/s to Our processing activities; namely where:
- You contest the accuracy of your personal data, for a period enabling Us to verify the accuracy of the same personal data;
- Our processing is deemed unlawful, and You oppose the erasure of your personal data and request restriction of its use instead;
- We no longer need your personal data for the purposes stated in this Policy, but You require it for the establishment, exercise or defence of legal claims;
- You have objected to Our processing, pending verification whether the legitimate grounds of Our processing activities override those pertaining to You.
g. Right of Data Portability: You have the right to receive your personal data which we have processed, in a structured, commonly used and machine-readable format from Us, and to have this data transmitted to another data controller.
H. Third-Party Links
Our Site may also, from time to time, contain links to and from the websites or related mobile applications of our partner networks, advertisers, news portals, educational institutes and affiliates (and other third party sites). If You follow a link to any of these websites, please note that these websites have their own privacy policies and that We do not accept any responsibility or liability for these policies. Please check these policies before You submit any personal data to these websites.
I. Google Analytics
So as to improve the quality and user experience of the Website, we are using Google Analytics Advertising Features. If You would like to opt-out of Google Analytics for display advertising You may do so by using the Ads Preference Manager.
In addition, there is also a Google Analytics opt-out browser add-on that You can download at https://tools.google.com/dlpage/gaoptout/.
J. Changes to our Privacy Policy
We may change this Privacy Policy at any time and any changes we may make will be posted on this page.
Please check back frequently to see any updates or changes to Our Policy.
K. Contact
Questions, comments and requests regarding this Policy should be addressed to info@avanzpro.mt with “Privacy Policy Query” being in the subject line.
