Privacy Policy

1. Introduction

This Privacy Policy is effective from July 2024.

This policy is made compliant with the General Data Protection Regulation (the “GDPR”), (Regulation (EU) 2016/679) and with the Data Protection Act (Cap. 586) of the Laws of Malta, (collectively referred to as the ‘Applicable Legislation’).

One of your rights under Applicable Legislation is that you must be informed when your personal data – also known as your personal information – is processed (collected, used, stored) by an organization. You also have the right to know the details and purpose of that processing.

Muovo is owned and operated by Broadwing Limited (“muovo”, “we,” “us”), with registered address at The Penthouse, Ewropa Business Centre, Triq Dun Karm, Birkirkara, BKR 9034, Malta, who shall be the data controller for the purpose of Applicable Legislation  for the processing of personal data undertaken through muovo.eu (the ‘Website’). This Website and all site-related content (collectively, the “Site”) is being made available subject to your compliance with this Privacy Policy as well as your acceptance of the Terms of use and service.

This Privacy Policy covers muovo’s treatment of Personally Identifiable Information (“PII”) that is collected when you are on the Site, when you use Muovo’s services as well as any other access and/or use of the Site.

2. Definitions

The Terms “you” and “user” as used herein refer to all individuals (job seekers, employers or the general public) accessing the Site.

“Personal Data” means information that specifically identifies an individual or that is linked to information that identifies a specific individual.

3. Information we collect

The section below describes how we collect and process personal data of different data subjects through the Website. Please refer to the section which applies to you.

Jobseekers / Candidates

Our primary purpose for collecting Personal Data is to provide you with the services and features in relation to information about vacancies.

Our goal is to provide the best possible employment opportunities to further your career. To achieve this, and to provide you with the services under the agreement that regulates our relationship, we need to process certain information about you. This will enable us to provide you with the best vacancies and save you time in searching through jobs and services that are not relevant to you.

Depending on how you interact with us, the personal information we collect from you may vary. This information may consist of:

  • your name and surname;
  • your mobile number;
  • your  email address;
  • your account password;
  • your curriculum vitae (‘CV’);
  • your job preferences including category, level, type and geographical location;
  • information from accounts you link to us, such as social media profiles;
  • information about your device (phone or laptop) with which you used to browse our Website (as detailed in point 3.3.4 below)
  • your IP address

 

Should you decline to provide us with any such data we may not be able to provide you with our service.

Employers and their HR Team

Our primary purpose for collecting Personal Data about you or members of your HR team is to provide you with the services and features in relation to the listing and advertisement of your vacant job posts.

We will receive data directly from you or members of your HR team in the following ways: through the use of registration forms, contact forms and when you email us your details. Depending on how you interact with us, the personal information we collect from you may vary. This information about you or your team may consist of:

  • name and surname;
  • e-mail address;
  • mobile number;
  • country;
  • physical address.
  • information from accounts you link to us, such as social media profiles
  • information about your device (phone or laptop) with which you used to browse our Website as detailed below under General Website Visitors

Should you decline to provide us with any such data we may not be able to provide you with our service.

General Website Visitors 

Most of the personal information which we may collect about you through this Website is given to us only if you choose to give it to us. Such personal information may be requested from you when you fill in a field (e.g. contact forms, registration forms, and subscription forms). If you send us emails, then the personal data we process will depend on what information you share in such emails.

When you fill the contact forms on this website, we use the personal information submitted in the form to respond to your message and in respect of the services which we provide.

We do not knowingly collect Personal Data from anyone under the age of 16.

When you visit our Website the following information will automatically be processed and this solely to provide the services:

  • The requested web page or download;
  • The status code of the request;
  • The date and time of connection;
  • The IP address  from which you accessed the site;
  • The operating system of the machine running your web browser and the type and version of your web browser.

This information may be utilised for system administration, bug tracking and producing usage statistics. We do not sell, trade or otherwise transfer any information to third parties. This does not however include trusted third parties who would be assisting us in operating this website, conducting our business or providing a service to you and who we ensure are bound by non-disclosure policies and equivalent GDPR standards.

4. How we use your Personal Information

Jobseekers / Candidates

Your Personal Data is processed by us to perform our obligations with you and provide you with the Service. In particular, we collect your Personal Data in order to enable us to:

  • Match you with job vacancies based on your skills and preferences to assist in finding you the position that suis your career;
  • Share your details with our clients and prospective employers for you to be considered for vacancies. Your details will only be shared with the employers of vacancies you apply for;
  • Facilitate your potential employment with our clients and prospective employers;
  • Keep you informed of available opportunities as they arise via job alerts and mailshots;
  • Contact you about service related announcements.

In the case of job alerts, we will only send these once you personally enable them. Once a job alert is removed, you will cease to receive these notifications.

Please note further to our sharing of your data with prospective employer/s to provide you with the Service, the manner in which any of your personal data is processed by prospective employer’/s is the sole responsibility of that employer/s. The deletion of your CV sent to any employers through the Muovo portal, will be at the discretion of the prospective employer/s. If you wish to have this information deleted or have any other questions, you may contact the prospective employer/s or refer to their privacy notice.

Employers and their HR Team 

Your Personal Data is processed by us to provide you with the Service. In particular, we collect your Personal Data in order to enable us:

  • To advertise your vacancies;
  • To publish your articles in ‘HR Talks’;
  • To link to jobsseekers via the platform who are the right fit for you or your organisation; and
  • To contact you about service-related announcements.

General Website Visitors

In the majority of the time, we will be processing your contact details and history in order to answer your queries as well as provide customer service and support. We need to do this to perform our contract with you to your best satisfaction.

Additionally, where you have shown interest, we understand that you would be interested in receiving information about our products and services. Where you have said we can (i.e you gave us your clear confirmation),we would like to keep in touch with you  and send you marketing messages via email about services and offers that might interest you. We will never sell your data and we promise to keep your details safe and secure. You can stop receiving marketing messages from us at any time by clicking on the ‘unsubscribe’ (opt-out) link in any email we send you.

5. Information sharing and disclosure

We do not, and will not, sell any of your personal data to any third party – including your name, address, email address, cv, or credit card information.

However, we may share your data with companies which form part of the same group of companies that Muovo forms part of (our ‘Subsidiaries’), where necessary for the processing of your requests or to enhance your experience.

Additionally, we may share your data with the following categories of companies as an essential part of being able to provide our services to you, as set out in this statement:

  • Companies that are involved in the process of getting our services from us to you, such as prospective employers and business (solely in the case of job applicants), as well as payment service provides and hosting providers, amongst others;
  • Professional service providers, such as advertising partners, website hosts, I.T. consultants, who service us in turn to operate our business;
  • Credit reference agencies, law enforcement and fraud prevention agencies, so we can help tackle fraud;
  • Other companies that you may approve, such as social media sites (if you choose to link your accounts to us)

In addition, there may be case where we may disclose Personal Data because we are obliged to, as set out below:

  • to the extent that we are required to do so by law or by a competent authority;
  • in connection with any legal proceedings or prospective legal proceedings;
  • for the proper administration of justice
  • to protect your vital interests
  • to safeguard the integrity of the relevant website operated by us
  • and to the purchaser (or prospective purchaser) of any business or asset which we are (or are contemplating) selling in the event of a corporate sale, merger, reorganisation, dissolution or similar event involving us and/or our Subsidiaries;

When we do share data, we do so on an understanding with the other entities that the data is to be used only for the purposes for which we originally intended – again, we don’t want you to have any surprises.

We may also provide third parties with aggregated but anonymised information and analytics about our customers and, before we do so, we will make sure that it does not identify you. Anonymous information means it is anonymous.

If we ever have to share data with entities that are outside of the EEA, we will be sure to do so in a manner that complies with the requirements established by under Applicable Legislation.

6. Data Subject Rights

You enjoy several rights relating to your personal information under Applicable Legislation. We respect your privacy rights and provide you with reasonable access to the Personal Data that you may have provided through your use of the service. Your principal rights under data protection law are:

  • the right for information;
  • the right to access;
  • the right to rectification;
  • the right to erasure;
  • the right to restrict processing;
  • the right to object to processing;
  • the right to data portability;
  • the right to complain to a supervisory authority; and
  • the right to withdraw consent.

Please appreciate that the rights must be exercised within some limitation – for example, if you ask us for information we can only give you what relates to you and not what relates to other persons. Additionally, in accordance with Applicable Legislation, we reserve the right to withhold Personal Data if disclosing it would adversely affect the rights and freedoms of others. When we receive requests, we may also request that you identify yourself and provide documentation or information for verification (we would not want to disclose information to the wrong person). Unreasonable requests may be subjected to a reasonable fee.

To get in touch about these rights or to learn more, please contact us on info@muovo.eu. We will seek to deal with your request without undue delay, and in any event within one month (subject to any extensions to which we are lawfully entitled). Please note that we may keep a record of your communications to help us resolve any issues which you raise.

You may delete your profile. By doing so you agree to remove any history related to your job applications from our database and you will no longer receive any job notifications. To delete your profile, kindly contact us on info@muovo.eu. We will request an additional confirmation prior to deleting your account to ensure that this is not a malicious attempt to delete your data by a third-party.

Once the profile is deleted, any applications sent to employers will be automatically removed from the Application History of the relevant employer’s profile on Muovo. You will need to re-register with Muovo in order to submit new job applications.

Please note that your data will not be removed from any employers’s records you have applied with through Muovo. To delete this data, please get in touch with each employer where you applied.

7. Security

We take appropriate security measures to protect against loss, misuse and unauthorised access, alteration, disclosure, or destruction of your information. We take integrated steps to ensure the ongoing confidentiality, integrity, availability, and resilience of systems and services processing personal information, and will restore the availability and access to information in a timely manner in the event of a physical or technical incident.

If Muovo identifies a breach to its’ security systems, we may attempt to notify you electronically so that you can take appropriate protective steps. By using this Website or providing Personal Data to us, you agree that we can communicate with you electronically regarding security, privacy and administrative issues relating to your use of this site. We may post a notice on our website if a security breach occurs. Muovo may also send an email to you at the email address you have provided to us in these circumstances.

8. Data Retention

We will hold on to your information for no longer than is necessary keeping in mind the purpose/s (or compatible purposes) for which we first collected the data.

Please note the following information on retention as a guide:

Jobseekers / Candidates

We will retain your information for as long as needed to provide you with our service, or to comply with our legal obligations, resolve disputes and enforce our agreements, as follows:

  • We will delete your Personal Data from our systems if we have not had any meaningful contact with you for five (5) years. After this period, it is likely your data will no longer be relevant for the purposes for which it was collected. By “meaningful contact”, we mean, for example, communication between us (either verbal or written), or where you are actively engaging with our online services and logging in.
  • Applications kept under the employer’s profile shall be automatically removed after twelve (12) months from the job closing date.
  • As noted above, once Personal Data of a jobseeker are shared and transferred to the prospective employers, the prospective employers shall become Data Controllers in their own right, and will thus have to abide by their own data protection obligations, including but not limited to, the obligation to store Personal Data for a period that is not longer than the one necessary for the purposes of the data processing. We advise you to read through the privacy notices of relevant prospective employers for more information on retention or to contact them directly.

Employers and their HR Team

We will retain your information for as long as needed to provide you with our service, or to comply with our legal obligations, resolve disputes and enforce our agreements, as follows:

  • We will delete the Personal Data of employers and/or human resources management personnel from our systems, as well as Company profiles, if we have not had any meaningful contact for five (5) years. After this period, it is likely that this data will no longer be relevant for the purposes for which it was collected. By “meaningful contact”, we mean, for example, communication between us and the job seeker or employer (either verbal or written), or where they are actively engaging with our online services.
  • Payment Safety – We do not store credit card information. All transactions are performed through a secure gateway with myPOS or PayPal, and the only records kept by Muovo are transaction details of your purchase records.

11. Changes to this Privacy Policy

If we decide to change this Privacy Policy, we will post those changes to this Website, and other places we deem appropriate so that you are aware of what information we collect, how we use it, and under what circumstances, if any, we may disclose it.

We reserve the right to modify this Privacy Policy at any time. It is the user’s obligation to review it frequently. Your continued use of this web site constitutes your agreement to this Privacy Policy and any updates.

12. Contacting us

If you have any questions about this Privacy Policy, or if you wish to make a complaint about how we have handled your personal information, please contact us at:

Muovo
Broadwing Ltd
The Penthouse, Ewropa Business Centre, Triq Dun Karm, Birkirkara, BKR 9034, Malta
info@muovo.eu

This document was last updated on 23/07/2024