Napkin Engineering Group (Napkin) is committed to protecting your privacy.
General principles for the processing of personal data
The GDPR provides a framework to ensure that personal data are processed properly. The Company will at all times ensure that personal data:
- Processed fairly, lawfully, and transparently.
- Are appropriate, relevant, and not excessive.
- Are accurate and up to date – inaccurate or incomplete personal data will be corrected or deleted, or further processing will be suspended.
- Not stored longer than necessary.
- Only processed for a specific, explicit, and lawful purpose and only processed in accordance with the purpose for which they were collected.
- Is safe.
Types of personal data
We collect and process your personal data in several ways:
- Some of the personal data is necessary for us to provide you with the services you have requested, and some other personal data is voluntary to provide.
- The personal data we collect, and process can generally be divided into the following categories:
- Contact information such as name, address, telephone number, e-mail address, position, workplace, etc.
- Information you provide when contacting us.
- A unique ID and user information e.g. technical data regarding the user’s devise, geographical location, use and display, including IP addresses, when you visit our websites or applications, including on third-party websites.
- For recruitment purposes, we will also process:
– Skills, educational background and work experience.
– Assessment results, of assessments made as part of the recruitment process.
– Age and gender. In the initial stages of recruitment, we do not collect or process special categories of data such as racial or ethnic origin, political opinions, religious or philosophical beliefs, trade union membership, genetic/biometric data, sexual orientation and/or health.
However, we may collect special categories of personal or criminal records information at a later stage of the hiring process if local work regulations require it.
Our purpose of processing your personal data
We only process your personal data in connection with a legitimate purpose and, in general, we only process your personal data if:
- You have consented to such processing.
- The processing is necessary for the performance of a contract.
- The processing is necessary to comply with a legal obligation to which we are subject.
- The processing is necessary for the purposes of the legitimate interests pursued by us or third parties – and such processing is not considered to be harmful to you – such as our interests in developing, evaluating, marketing and selling our products and services, developing and maintaining business relationships with our customers, suppliers and other business relationships, for example through customer segmentation and analysis and the compilation of statistics.
We process your personal data for the following purposes:
- – To make it easier for you to use the Site, our services and products.
- – To contact you as part of the regular customer relationship.
- To send you newsletters or other marketing material, including surveys, if you have requested this.
- To provide general customer service and support.
- To gain customer insights and knowledge about how our various services are used, as well as to evaluate and improve them.
- To create and follow up on business opportunities.
- To recruit for vacancies.
- To save candidates for potential future recruitment.
- To save applications for potential future recruitment.
- To comply with applicable law.
Disclosure, transfer and making available of personal data to third parties
Our disclosure and transfer of your personal data to third parties is kept to a minimum and is subject to the existence of an adequate level of data protection. We may disclose or make personal data available to third parties in the following circumstances:
- Third parties who perform services on our behalf, e.g. hosting, IT support, marketing services, administrative services, etc. Such third parties are only allowed to process the personal data in accordance with our instructions and under a written data processing agreement.
- To establish, exercise or defend our legal rights.
- If you have given your prior consent to the disclosure of personal data to a third party.
- In the event of a merger, sale, joint venture, transfer, assignment or other disposition of all or part of the Company’s assets or shares (including without limitation in connection with bankruptcy or the like).
If the recipient of the personal data is located in a country outside the EU/EEA that does not ensure an adequate level of data protection, we will only transfer your personal data to such recipient after entering into a written transfer agreement based on the EU Commission’s standard contractual clauses.
Your consent
As mentioned above, some of our processing activities will be based on your consent. In this case, you have the right to withdraw your consent at any time.
If you withdraw your consent, we will cease processing your personal data unless and to the extent that the continued processing or storage is permitted or required by applicable personal data laws or other applicable laws and regulations.
Please note that withdrawing your consent does not affect the lawfulness of processing before you withdrew it. As a result of the withdrawal of your consent, we may not be able to fulfill your wishes or provide our services to you.
Security
The Company undertakes to have the necessary security measures in place to guarantee the security of your personal data, and the Website has implemented security measures to protect against the loss, misuse, and alteration of personal data under our control.
Your rights
You have the right to access the personal data processed about you, subject to certain statutory exceptions. You can also object to the collection and further processing of your personal data, and you have the right to correct your personal data if necessary. You can also request us to restrict processing.
We will delete or correct any information that is inaccurate or out of date when requested by the you.
The information is stored in accordance with applicable legal and regulatory requirements. Data will be deleted according to local deletion rules configured in the system. The retention period is 6 months unless local legal requirements provide for a longer or shorter mandatory retention period.
We will also delete your personal data without undue delay, unless we have a legal basis to continue processing, e.g., if the processing is necessary for the establishment, exercise or defense of a legal claim or is necessary for the performance of a contract with you.
To exercise any of the above rights, please contact us.
In connection with such requests, please provide us with the relevant information so that we can handle your request, including your full name and email address, so that we can identify you. We will respond to your request as soon as possible and at the latest within one month.
If you disagree with the processing of your personal data, please note that you can lodge a complaint with your local data protection authority.
Complaints
If you have any complaints about the processing of personal data carried out by the Company, you are welcome to contact us at any time.
We will review and assess your complaint and, if necessary, we will contact you for further information.
We strive to process any complaint or objection within one month. If it is not possible to make a decision within one month, we will inform you of the reasons for the delay and when the decision can be expected to be submitted (no more than 6 months after receipt).
At any time before, during or after the complaint process described above, you may also lodge a complaint with your local data protection authority or other relevant court or authority.
Contact information
If you have a request or question regarding our processing of your personal data or this privacy policy in general, please contact us:
Napkin Engineering Group, Att.: Data Protection Manager, Phone +45 31 40 00 90
Mail: hello@napkineng.com