Privacy Policy Last updated at 2024-03-04 13:27:37

Unloq.ai is a product of CV Keskus OÜ, a pioneering RecTech company headquartered in the vibrant city of Tallinn, Estonia (European Union). We value your privacy and are committed to protecting your personal information in compliance with the General Data Protection Regulation (GDPR) and other applicable data protection legislation. This privacy policy outlines how we collect, use, disclose, and protect your personal data when you interact with our landing pages on the unloq.ai platform.

1. The scope

1.1. The following privacy policy (Privacy Policy) applies to all situations where CV Keskus OÜ (CV Keskus) processes personal data of natural persons (Data Subject) as a controller when enabling the use of its online platform www.unloq.ai (Platform) and by providing various services (Services) to the users of the Platform (User) via the Platform.

1.2. The Privacy Policy is valid from the date as indicated above. CV Keskus OÜ reserves the right to unilaterally amend the Privacy Policy at any time. The amended Privacy Policy shall be made available on the Platform and Data Subjects shall be notified of this by e-mail or by other means.

2. Data controller and the principles of processing

2.1 For the purpose of clarity, the data controller is CV Keskus OÜ with the registry code 11325768, and registry address A. H. Tammsaare tee 56, Tallinn, 11316, Estonia.

2.2 In all matters related to the Privacy Policy and the processing of personal data, with regards to which CV Keskus is the controller, can be addressed to the data protection officer of CV Keskus by sending an inquiry email to dpo@cvkeskus.ee.

2.3 CV Keskus processes all personal data in accordance with the principles of data protection recognized in the European Union as well as with the requirements established by the applicable legislation.

3. The purposes of processing and categories of personal data

3.1 CV Keskus may process the Data Subject’s personal data for the following purposes:

(a) intermediating the performance of the contract on the Platform;

(b) communicating with the Data Subject

(d) performing obligations arising from applicable legislation

(e) exercising rights arising from the applicable legislation and from existing legal relations

3.2 CV Keskus may process the following categories of personal data:

(a) for the purpose stated in section 3.1(a): primarily Data Subject’s email address, any other personal data concerning the Data Subject’s career (e.g., training and skills), username and any other data that is related to the usage of the Platform by the Data Subject (e.g., Data Subject’s salary request), IP-address, Browser Agent, and personal data collected by cookies (if such personal data is collected at all);

(b) for the purpose stated in section 3.1(b): primarily email address and any personal data contained in other information which such person may submit;

(d) for the purpose stated in section 3.1(d): any personal data mentioned above, determined on a case-by-case basis according to the obligation which CV Keskus must fulfill;

(e) for the purpose stated in section 3.1(e): any personal data mentioned above, determined on a case-by-case basis according to the right which CV Keskus executes.

3.3 If the entry of personal data has been made mandatory upon account registration or after registration when using the functions of the Platform, then the submission of the respective personal data is necessary for the performance of the contract between the Data Subject and CV Keskus. In that case, the submission of personal data is mandatory, and it is impossible to perform this agreement if such personal data has not been submitted. If the entry of personal data has not been made mandatory on the Platform and the submission of personal data is not required from the Data Subject in any other way, then the submission of personal data is voluntary and non-submission does not have any direct adverse consequences for the Data Subject. However, failure to provide personal data may limit the use of the Platform functions.

3.4 As a general rule, the above-mentioned personal data is collected by CV Keskus directly from the Data Subject, except in the following case:

(a) if the Data Subject uses a Google account to log in to the Platform.

4. Legal basis for the processing of personal data

4.1 CV Keskus processes the Data Subject’s personal data as it is necessary for the performance of the agreement (section 3.1(a)) or for taking steps at the Data Subject’s request prior to the agreement (section 3.1(b)). In such a case the legal basis for processing personal data is the performance of the agreement.

4.2 CV Keskus processes the Data Subject’s personal data additionally to improve the Platform (section 3.1(c)). In such cases the legal basis for processing personal data is the legitimate interest of CV Keskus as the controller to improve and develop the functioning of the Platform and its quality. CV Keskus cannot guarantee the best user experience without development, statistics, and market analysis. Impact of such processing is minimal to the rights of the Data Subject since, as a general rule, personal data is processed in a minimal manner for this purpose.

4.3 CV Keskus also processes the Data Subject’s personal data to fulfil the obligations arising from applicable legislation (section 3.1(d)). In such cases, the legal basis for processing personal data is the fulfillment of legal obligations applicable to CV Keskus as a controller.

4.4 CV Keskus processes the Data Subject’s personal data also to exercise the rights arising from applicable legislation and from the agreement entered into with the Data Subject (section 3.1(e)). In such cases, the legal basis for the processing of personal data is the legitimate interest of CV Keskus as the controller.

5. Data retention

5.1 CV Keskus reserves the right to store personal data to the extent necessary for the purposes outlined in the Privacy Policy. The Data Subject’s personal data will be retained for as long as is required in order to fulfill these purposes, and as allowed by applicable legislation.

6. Data disclosure

6.1 CV Keskus reserves the right to share personal data with trusted third-party service providers who assist in operating the Platform, such as hosting and email marketing services. All authorized third-party processors to whom CV Keskus transmits personal data shall ensure the protection of personal data as stipulated by the applicable legislation.

6.2 CV Keskus generally processes personal data only in the European Economic Area and does not transfer it to third countries or international organizations. However, if CV Keskus does so, it shall ensure that personal data is only transferred to a third country or international organization which complies with the personal data protection requirements that are equivalent to those in force in the European Economic Area.

7. Data security

7.1 CV Keskus shall implement appropriate technical and organizational measures to protect Data Subject’s personal data from unauthorized access, disclosure, alteration, or destruction. However, please note that no method of transmission over the internet or electronic storage is 100% secure, and CV Keskus cannot guarantee absolute security.

8. Data Subject’s rights

8.1 The Data Subject has the right at any time to contact CV Keskus by writing an email at dpo@cvkeskus.ee and exercise their right to:

(a) request access of personal data;

(b) request rectification of personal data;

(d) request restriction of processing of personal data;

(e) object to processing of personal data;

(f) request portability of personal data;

(g) request that any decision based on automated decision-making, concerning the Data Subject, is not taken;

(h) withdraw a consent for the processing of data;

(i) lodge a complaint with a supervisory authority (Estonian Data Protection Inspectorate).