Application Privacy Policy

Effective date: 22/03/2023

Introduction

This privacy policy (hereinafter “Policy”) provides information on how personal data is processed by Evolution regarding Job application management process.

Each Evolution entity acts as Data Controller regarding your personal data for application process depending on the location or the position you have applied for.

In case you have questions regarding the usage of your personal data, please contact the corresponding Human Resources department or Data Protection Team dataprivacy@evolution.com.

How do we collect your personal data?

Personal data are collected either directly from you when you apply for the job position using our career page or social media accounts such as Facebook or LinkedIn, or indirectly using third-party job research platforms, recruitment agencies, data obtained from reference persons or information available publicly within social media platforms such as LinkedIn.

When you apply directly for the job position the lawful basis for personal data processing are your given consent. This means that you can withdraw your application any time, without affecting the legality of the previous processing. Additionally, there might be cases where personal data are processed based on legitimate interests, for instance in cases if Evolution has approached the candidate.

If your personal data is forwarded using third party job research platforms, recruitment agencies, referred by reference person or publicly available information, the lawful basis for personal data processing is based on legitimate interests to fulfill the necessary job position.

What personal data do we collect, for what purpose and for how long period do we store the data?

When you apply for job positions at Evolution, we collect personal data that is necessary to evaluate your qualification and eligibility towards the position you have applied.

The personal data collected depends on the data collection purpose and may include your full name, contact information such as telephone number and address, previous work experience and other relevant qualifications, information about education, language skills etc. Depending on the job position and location where you apply, additional personal data may be required due to legal and regulatory requirements.

More information about personal data processes with regards to application management can be found in table below.

Purpose	Personal Data	Legal basis	Retention period
Handle recruitment process	First name, Last name, Contact details (telephone number, email address), Address, Photo (if applicable), Video (for Game Presenter position, if applicable) , Location data, Work Experience description , Education description, CV, Feedback data from Reference person (if applicable), Other information if linked with social media such as LinkedIn page, Cover letter.	Your freely given consent.	Job applications are stored for maximum 2 years after the application process for concrete position is completed. However, the data storage period might be different depending on the location you have applied due to legal and regulatory requirements.
Carry out background checks (applicable only if required and allowed by local legal requirements)	First name, Last name, Personal number, Educational/ professional background, Other information of relevance regarding background check	Legitimate interests to further evaluate and validate your application. Data from criminal records will only be processed if necessary to fulfil a legal and/or regulatory obligation to which Evolution is subject.	Personal data processed for this purpose is only checked and not stored.
Conduct personality and knowledge tests	First name, Last name, Personal ID number (if required by local legislation), Test data, Video (for Game Presenter position)	Legitimate interests to further evaluate and validate your application. The processing of video is necessary to evaluate your behaving and performance of tasks related to job position in front of camera.	Personal data processed for this purpose is retained during the recruitment process and kept for the period as long as all application data to fulfil our legitimate interest to establish, exercise and defend any legal claims.
Evaluate recruitment process and create statistics	First name, Last name, Contact details, Location data, Work experience description, Education description, CV, Feedback data from Reference person, Other information if applicable from connected LinkedIn page and cover letter	Legitimate interests to evaluate the recruitment process.	Reports and statistics on aggregated level which do not contain personal data will be saved until further notice.
Establish, exercise, and defend legal claims	First name, Last name, Contact details, Other data that is necessary to establish, exercise or defend the legal claim	Legitimate interests to establish, exercise or defend the legal claim, for example in connection with a dispute or legal process.	Your personal data is retained for the period required for us to establish, exercise, or defend the legal claim.
Fulfil legal obligations	First name, Last name, Contact details, Other data that is necessary to fulfil legal obligations	Necessary for a legal or regulatory obligation for example within the area of book-keeping and taxation.	Personal data is retained for the period as necessary to fulfil the legal obligations which apply to Evolution.

What rights do you have?

Due to legal requirements, you have several rights towards your personal data. It is important that your personal data are always accurate and up to date, therefore you are obliged to inform us if your personal data has any changes during the application process.

In addition, you have right to request access, correct, erase, transfer your personal data and restrict personal data processing. It should be considered, that in certain situations we will not be able to complete your right requests in full extent due to legal requirements.

In case you have given consent for application process, you can withdraw your consent any time, without affecting the legality of the previous processing. In addition, you also have right to contact Data Protection Supervisory authority in the country you are located. The list of national supervisory authorities can be found here: https://edpb.europa.eu/about-edpb/board/members_en

If you would like to exercise your rights, please contact Data Protection Team dataprivacy@evolution.com .

• Right to access your personal data

You may request at any time the confirmation whether we process your personal data. If we process your personal data, you can request to receive a copy of your personal data. For example: if you are Evolution employee, you can request to receive information on your data processed and for what reasons.

• Right to rectify your personal data

You have the right at any time request to correct your personal data that is inaccurate, as well as supplement your personal data that is incomplete. For example: if you ar e Evolution business partner and your contact information such as telephone number or email address have been changed, you can request to edit this data.

• Right to erase your personal data

You may request to erase your personal data under certain circumstances such as when your personal data is no longer needed for the purposes for which it was collected. For example: if you were Evolution employee and you have provided your contact information for employment related communication purposes. When terminating employment relations, you can ask to delete your contact information unless it is requested to be stored otherwise by law.

• Right to object to certain personal data processing

You may object to the processing of your personal data if you have a particular situation, your data are being used for direct marketing purposes and the legal grounds of data processing are legitimate interests. For example: If you receive any marketing related materials that you have not agreed to, you can object and request to stop receiving them.

• Right to restrict the processing of personal data

You may ask us to restrict the processing of your personal data under certain circumstances, such as when the processing is unlawful, but you do not wish your personal data erased. Additionally, in case if you have concerns about your data accuracy, you can ask us to restrict data usage until we verify the accuracy of your data. For example: In you are Evolution employee and you have concerns that your provided bank account data are not accurate, we will stop using this data until we will verify the accuracy of it.

• Right to withdraw your consent

If you have agreed on data processing based on your consent, you have the right at any time withdraw your consent. The consent withdrawal will not affect the legality of the previous processing. For example: In case if you have agreed to receive newsletters from Evolution and you would not like to receive them anymore. You can withdraw your consent at any time, and you won’t receive them in future.

• Right to transfer your personal data

You may ask to provide you the copy of your personal data and if technically possible you can request to transfer this data to another Data Controller (Company or Institution, where possible). This is only applicable if personal data are processed on the legal basis of your consent or on necessity to comply with agreement concluded with you, and only for the data that is provided by you. For example: if you are Evolution employee you could ask to transfer your provided data to Public Revenue Service or any other Public Institution.

• The right to complain to the data protection supervisory authority

You have the right to lodge complaints regarding your personal data processing to the relevant data protection supervisory authority. The list of national supervisory authorities can be found here: https://edpb.europa.eu/about-edpb/board/members_en

Where may we disclose and transfer your personal data?

Evolution might share your personal data between the Evolution Group entities and contracted third parties (service providers) for various purposes. The personal data might be shared based on legal basis such as legitimate interests to fulfill the business needs, based on your consent or mutually agreed contractual obligations.

Evolution ensures that before we transfer your personal data appropriate safeguards are set in place. For instance, the Evolution Group has established an Intra-Group Data Transfer Agreement which governs transfers of personal data between the Group entities. The same applies to third party service providers, the personal data are transferred if required legal documentation is concluded to ensure an adequate level of protection.

Additionally, there might be situations where Evolution might transfer personal data to Evolution’s entities, or third parties located outside the EU/EEA. In these cases, Evolution will ensure that the Standard Contractual Clauses or other legally required documentations have been concluded to ensure an adequate level of protection before transferring personal data outside EU/EEA.

If you would like to know more about the transfer of your personal data between the Evolution Group entities and third parties and whether your personal data is transferred outside the EU/EEA, please contact Data Protection Team at dataprivacy@evolution.com.

Evolution Group entities
In order to fulfill data processing purposes Evolution may disclose your personal data to other Evolution Group entities. The data transfers between Evolution entities are governed with concluded Intra-Group data processing agreement which includes the Standard Contractual Clauses.

Please note, that other legal safeguards for data transfer might apply in certain cases.

The data transfer purposes may be:

To answer various of your requests and questions regarding our provided services (based on necessary to comply with a legal/regulatory requirements)
To better understand our business practices, services, and products across the Evolution Group entities (based on legitimate interests)
To provide Evolution Group entities with marketing and promotional materials (based on your provided consent)
To identify fraud and other criminal activities including anti money-laundering (based on necessary to comply with a legal/regulatory requirement)
To provide you with the customer support including the obligation to ensure that information is up-to-date and accurate (based on necessary to comply with a legal/regulatory obligation)
To comply with legal requirements towards identification of responsible gaming measures across the Evolution Group entities (based on necessary to comply with a legal/regulatory requirement)
To provide you services agreed, ensuring the implementation of security measures (based on necessary to comply with a legal/regulatory requirement).

In case you have any questions regarding data transfer between the Evolution Group entities, please contact our Data Protection Team at dataprivacy@evolution.com.

Data processors acting on behalf of Evolution
Evolution may disclose personal data to external parties, such as vendors and service providers. Third parties might process personal data on behalf of and under the instructions of Evolution.

The Evolution engages with data processors (incl. sub-processors) in order to deliver you the agreed services and to comply with legal and regulatory requirements. The data processors might vary from such as cloud services for data storage purposes, marketing companies in preparing and delivering marketing related materials, until external advisors and auditors. In case of engagement of processors, we inform you as far as it is required by legal and regulatory requirements.

What are the security measures implemented?

We ensure that all necessary appropriate security measures are in place to keep and process your personal data securely. In support of this commitment, we have implemented appropriate technical, physical, and organizational measures to protect your personal data against unauthorized or accidental destruction, alteration or disclosure, misuse, damage, theft or accidental loss, or unauthorized access.

For more details, please contact us at dataprivacy@evolution.com.

What is the data retention period?

The personal data are kept for period that is either required by law and regulatory requirements or for as long as necessary to fulfill the personal data collection purpose. The storage period might differ from the location and services that you are receiving.

What is the Controller and what is our contact information?

If you have any questions or concerns regarding the processing of your personal data regarding of websites or applications, please contact Data Protection Team at dataprivacy@evolution.com.

Data Controller:
Evolution Gaming Ltd.
Registration No. 05944946,
Sackwille House, 40 Picadilly, W1J 0DR, London, United Kingdom.