Privacy Policy

1. INTRODUCTION

 

This Privacy Policy explains how Peak CS Limited, a company registered under the laws of Malta, with company registration number C 91687 and having its registered office at Dragonara Business Centre, Level -1, Ball Street, Paceville, San Giljan, Malta (the “Company”, “we”, “our”, “us”) collects, uses and protects personal data supplied to us through this website [Domain] (the “Website”). This Privacy Policy covers the processing of personal data: it applies to visitors to the Website and to individuals who apply for a role with us, and it sets out the Company’s position on cookies.

 

“Visitor(s)”: any person who visits the Website.

 

“Applicant(s)” or “Candidate(s)”: any person who provides personal data to us, through the Website or otherwise, to be considered for a role with the Company.

 

2. PERSONAL DATA WE COLLECT AND HOW WE COLLECT IT

 

As a Visitor, we collect only the technical information automatically recorded in our server logs when your browser requests a page: your IP address, the date and time of the request, the page requested, the referring page, and your browser type and operating system. We do not assign a unique identifier to your device, and we do not track how often you visit or how you move through the Website.

 

As an Applicant, we collect that same information together with the personal data you provide in connection with your application, namely:

 

– The data you have provided to us in your curriculum vitae (CV) and the personal data contained in your covering letter.

– The data you provide on our application form, including your name, contact details, date of birth, gender, nationality, employment history, qualifications, educational achievements, languages, professional memberships, identification number, and any data you provide during interviews.

– Any personal data provided to us about you by your referees, where applicable.

 

If you contact us through the Website, we also collect the details you choose to give us, such as your name, email address, telephone number and company information.

 

The Company collects personal data from the following sources:

 

-You, the Visitor or Applicant.

-Your named referees, from whom we collect full name, periods of previous employment and performance during previous employment.

-Publicly accessible sources, such as LinkedIn, from which we collect your full name, email address, work history and other data included on your profile.

-Your browser, which automatically transmits the technical information recorded in our server logs, as described above.

 

3. PURPOSES AND LEGAL BASIS

 

Where you apply for a role, we use your personal data to communicate with you about the recruitment process; to assess your skills, qualifications and suitability; to carry out background and reference checks where applicable; to keep records of our hiring processes; and to comply with legal or regulatory requirements. We use it to decide whether to shortlist you, whether to invite you to interview and whether to offer you the role. If you do not provide the data we request, we may be unable to take your application further.

 

We process personal data on the following legal bases under Article 6 of the General Data Protection Regulation: (a) our legitimate interests in operating and securing the Website, responding to enquiries and deciding whether to appoint you to a role, where those interests are not overridden by your rights; (b) steps taken at your request before entering into a contract, where you apply through the Website; and (c) compliance with our legal obligations.

 

Where we rely on your consent, it will be requested from you separately and you may withdraw it at any time.

 

4. SPECIAL CATEGORIES OF PERSONAL DATA

 

We process special categories of personal data within the meaning of Article 9 of the General Data Protection Regulation only where permitted by law. In recruitment we rely on Article 9(2)(b), namely that the processing is necessary to carry out obligations and exercise rights in the field of employment law under Maltese law. Otherwise, we process such data only with your explicit consent, which you may withdraw at any time.

 

We use data about disability status to consider whether adjustments are needed during the recruitment process, and data about nationality or ethnicity to assess whether a work permit or visa will be required.

 

5. AUTOMATED DECISION-MAKING

 

We do not use automated decision-making. Your personal data will not be subject to decisions producing legal effects concerning you, or similarly significantly affecting you, based solely on automated processing.

 

6. SHARING YOUR PERSONAL DATA

 

We do not pass your personal data to third parties except as set out here. We may share an Applicant’s data with other entities in our group, solely to assess suitability for a role. We may disclose personal data where we are legally obliged to do so, or to a service provider acting on our instructions under a written data processing agreement. Where

personal data is transferred outside the European Economic Area, we will ensure an appropriate transfer mechanism under Chapter V of the General Data Protection Regulation is in place.

 

7. DATA SECURITY

 

We have appropriate technical and organisational measures in place to protect your personal data against accidental loss, unauthorised access, alteration or disclosure. Access is limited to specified employees on a need-to-know basis, who process it only on our instructions and are subject to a duty of confidentiality. We have procedures to deal with any suspected data security breach and will notify you and any applicable regulator where legally required to do so.

 

8. HOW LONG WE KEEP YOUR PERSONAL DATA

 

We retain personal data for as long as we reasonably require it for legal or business purposes, taking into account applicable law and our contractual obligations. When it is no longer needed, we securely destroy it.

 

Where you have applied for a role, we retain your personal data for three (3) years from the date of your last application, so that we can demonstrate in the event of a claim that the recruitment process was fair and non-discriminatory, and in case a similar role arises for which you may be suitable.

 

9. YOUR RIGHTS

 

Subject to certain conditions, you have the following rights in relation to your personal data:

 

Access: to receive a copy of the personal data we hold about you. The first copy is free of charge; we may charge a reasonable fee for further copies or refuse requests that are manifestly unfounded or excessive.

 

Correction: to have incomplete or inaccurate data corrected, though we may need to verify the data you provide.

 

Erasure: to have your data deleted where there is no good reason for us to continue processing it, where you have objected to the processing, or where it was processed unlawfully. We may be unable to comply for legal reasons, which we will explain to you at the time.

 

Objection: to object, on grounds relating to your particular situation, to processing based on our legitimate interests.

 

Restriction: to ask us to suspend our processing, for example while its accuracy or the grounds for it are verified.

 

Portability: to receive your personal data, or to have it transferred to a third party of your choice.

 

Withdrawal of consent: where we rely on your consent, to withdraw it at any time, without affecting the lawfulness of processing carried out beforehand.

 

Complaint: to lodge a complaint with the Office of the Information and Data Protection Commissioner of Malta, or with the supervisory authority where you live. We would appreciate the opportunity to address your concerns first.

 

To exercise any of these rights, please contact us using the details in section 12 below.

 

10. COOKIES

 

The Website does not use cookies. A cookie is a small text file stored on your device which allows a website to recognise it or to remember information about your visit. We do not place any cookies on your device, and we do not use web beacons, tracking pixels, tracking scripts, browser local storage or any similar technology to store information on, or to gain access to information already stored on, your device.

 

Because no cookies or similar technologies are used, no consent is required from you and there are no cookie settings for you to manage. No cookie banner is presented on the Website, you do not need to take any action, and no part of the Website’s functionality depends on your accepting cookies.

 

If we introduce cookies or similar technologies in the future, we will update this Privacy Policy and, where required by law, obtain your consent before any such technology is placed on, or accesses information stored on, your device.

 

11. CHANGES TO THIS PRIVACY POLICY

 

We may amend this Privacy Policy from time to time. The version published on the Website is the current version, and we recommend that you review it periodically. Nothing in this Privacy Policy limits or excludes any right you have under applicable data protection law.

 

12. HOW TO CONTACT US

 

If you have any questions about this Privacy Policy or about the personal data we hold about you, please contact our Data Protection Officer at DPO@peak-cs.org. For queries relating to an application for a role, you may also contact us at HR@peak-cs.org.