This is the Policy of the ELINIO AG, a company registered under the laws of Switzerland, having registered office at  Löwenstrasse 20, 8001 Zürich Switzerland (we, us, our). This Privacy Policy outlines our commitment to respecting your privacy rights concerning the processing of your personal information in connection with our website and/or for the purposes outlined in this Privacy Policy.

This Privacy Policy apply when you are: 

• visiting or browsing elwisapp.com website (“Website”);
• conducting business with ELINIO AG or any of our subsidiaries;
• applying for the position at ELINIO AG or its subsidiaries;

This Privacy Policy may be updated from time to time and you will be informed about any such updates if you agreed to receive our newsletters and emails with updates. More details concerning the collection or processing of personal information may be requested from us at any time.

ELINIO AG serves as the entity responsible for managing your personal information, determining the purposes and methods of its processing, thus functioning as the “Data Controller” for such personal information. 

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A. PERSONAL INFORMATION THAT WE COLLECT

When you are browsing our Website, we collect: device information, session statistics, latitude (of city), longitude (of city), browser information, usage data, device identifiers, browser details, and location data. This data assists in maintaining service levels, diagnosing technical issues, and recording user preferences.

 When you are contacting us via email or via contact form on our Website: name, surname, phone number, email, any other information you decide to share with us. 

 When you apply for a job with us we will collect:

• Contact and general identification details (e.g., name, preferred first name, surname, gender, ethnicity, disability, veteran status, date and place of birth, nationality, email and/or postal address, fixed and/or mobile phone number, immigration status). 
• Social media profile data (i.e., when utilizing your social media accounts to register in our application management system; your profile particulars like name, email address, and other information you opt to share when linking your social media account with our talent management system).
• Family, hobbies, or interests (not obligatory and only as you choose to disclose or voluntarily include in your CV/Resume). 
• Education, professional credentials, and job preferences (including employment and educational background, professional certifications, skills, academic transcripts, letters of recommendation, certifications and experience, previous employers and their contact details, location and role preferences (function and discipline), language proficiency, information necessary for completing background checks as required and legally permitted, and any other details voluntarily provided in your CV/Resume/Cover letter).

When signing up for our newsletter, you will be required to provide your email address. By giving us your consent we utilize and store the personal information provided solely for delivering the newsletter service and informing you about ELINIO events, products, services, and/or promotions as per your subscription preferences. 

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B. INFORMATION THAT IS COLLECTED AUTOMATICALLY

We may collect and process information regarding Website visits, including the pages viewed. This data aids in enhancing website content, compiling aggregate user statistics, and conducting internal usage analyses and market research. To achieve this, we may employ technologies like cookies, which collect domain names, internet service provider details, operating system information, and timestamps. Cookies are stored on your device and facilitate functions such as remembering preferences, improving services through analytics, delivering relevant content or ads, and authenticating users. To find out more about our cookies please see our Cookies Policy.

We utilize Google Analytics to optimize performance of our Website. Google Analytics collects data via cookies to create page visit profiles, with the information transmitted and stored on Google servers. Data from Google Analytics aids in business planning, internal activities, and marketing strategies. “Google Analytics” is provided by Google LLC, of 1600 Amphitheatre Parkway, Mountain View, CA 94043, USA. We utilize the "anonymize IP" function or other features provided by Google in order to increase security and to keep you anonymous. For more information on how IP anonymization works, click https://support.google.com/analytics/answer/2763052

Additionally, we utilize Google Tag Manager for tag management to manage JavaScript and HTML tags used for tracking and analytics on websites, which helps in tracking and analyzing website traffic and visitor behavior.

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C. LEGAL BASIS FOR PROCESSING

We refrain from processing your personal information unless there is a lawful justification stipulated by applicable law. 

Thus, we only process your personal information if any of the following criteria are met:

• We have obtained your explicit prior consent;
• The processing is necessary for fulfilling our contractual obligations;
• The processing is necessary for undertaking pre-contractual measures; 
• The processing is necessary potential employment;
• The processing is essential for our legitimate interests and does not unreasonably impinge upon your interests or fundamental rights and freedoms;
• The processing is obligatory to comply with our legal or regulatory obligations;
• The processing is necessary to safeguard your vital interests or those of other individuals. 

D. PURPOSE OF PROCESSING

We consistently process your personal information for specific purposes, ensuring that only relevant data is utilized to achieve those aims. In particular, we process your personal information for the following purpose(s):

• Provide you with our Website;
• Conducting phone, email and other electronic communications;
• Respond to your inquiries or questions;
• Perform our contractual obligations;
• Inform you about our new products, services and special offers;
• For onboarding purposes (Performing personality assessments or other suitability evaluations tailored to the corresponding open position; Verifying your identity, academic achievements, or qualifications concerning your application; Administering your application using internal or external recruitment platforms like job boards)
• Fulfilling obligations under the applicable law.

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E. WHO HAS ACCESS TO YOUR PERSONAL INFORMATION

In the course of our operations and for the same purposes outlined in this Privacy Policy, your personal information may be accessed by or transferred to the following categories of recipients or third parties on a need-to-know basis to achieve such purposes:

• Our personnel, including personnel, departments, or european subsidiaries; 
• Our service providers offering services and products to us;
• Our IT systems providers, cloud service providers, database providers, and consultants.
• Any third party to whom we assign or transfer any of our rights or obligations. 
• Our advisors and external legal counsel in the context of the sale or transfer of any part of our business or its assets.

The aforementioned third parties are contractually obligated to safeguard the confidentiality and security of your personal information in compliance with applicable law.

We may share the personal information you submit as part of the job application process with selected service providers or consultants acting on our behalf who may assist us in recruiting talent, delivering IT or related infrastructure, offering communication or outreach services, administering and evaluating pre-employment screening and testing, and enhancing our recruitment process. 

F. HOW DO WE STORE YOUR PERSONAL INFORMATION

When you provide us with personal information we process it in a way that assures appropriate levels of security, including protection against unauthorized processing, destruction, accidental loss, or damage. We apply suitable organizational and technical measures under industry standards and in compliance with the following principles of processing of personal data: (a) lawfully, fairly and transparently; (b) processing is specified, explicit and only for legitimate purposes; (c) processing is adequate, relevant and limited to necessary purpose; accurate and kept up to date; limitation of the storage for periods not longer than necessary; (d) processing is held in a manner that ensures appropriate security of the personal information.

1. We apply following principles in order to protect your privacy: (a) we will not sell or lease your personal information to third parties; (b) any personal information that you provide to us will be secured with industry standard safety protocols and technology.
2. Personal information shall be processed and stored for as long as required by the purpose they have been collected for. Once the retention period expires, personal information shall be deleted. Therefore, the right to access, the right to erasure, the right to rectification and the right to data portability cannot be enforced after expiration of the retention period.

The personal information we collect from you may also be processed, accessed, or stored in a country outside the one where you are located, which may not offer the same level of personal information protection. Personal information is generally processed at our operating offices and in any other places where the parties involved in the processing are located. 

We do not sell, share, or transfer your personal information to recipients or third parties other than those specified in this Privacy Policy.

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G. SPECIAL SECTION FOR JOB APPLICANTS

When you apply for a job position with ELINIOE, we only handle information pertinent to you as a potential job applicant, which may necessitate strategic validation of skills and professional qualifications.

Primarily, we gather personal information directly from you when you apply for a position through our application management system or participate in an interview or assessment. In such instances, we act as the Data Controller for your personal information.

Additionally, we may obtain information from professional social networks like LinkedIn or other job boards, as well as other publicly accessible sources (limited to information relevant to your professional life) to actively engage you with job opportunities. If we haven't previously obtained your consent to retain your data, we'll request your consent during our initial contact with you.

We may also receive personal information when you apply through third parties such as recruitment agencies or consultants. In such cases, the third party may also act as a вata сontroller for your personal information.

To exercise your data protection rights concerning processing activities conducted by such third parties, you may need to contact the third party through which you applied for a position with us. 

Our recruitment processes do not rely on automated decision-making.

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H. YOUR RIGHTS 

In our processing of personal information, we take reasonable measures to maintain accuracy and currency aligned with the purposes for which they were collected. We afford you the ability to exercise the following rights in accordance with the conditions and constraints outlined in the law:

• The right to be informed about the personal information we possess about you and how we manage your data;
• The right to access your personal information as processed by us, and if you believe any information concerning you is inaccurate, outdated, or incomplete, to request its rectification or updating;
• The right to request the deletion of your personal information or restriction thereof to specific processing categories;
• The right to withdraw your consent at any time, without affecting the lawfulness of processing prior to such withdrawal;
• The right to object, wholly or partially, to the processing of your personal information. This includes, with certain exceptions, the right to object to direct marketing and to the use of your data for research purposes;
• The right to request data portability, meaning the personal information you have provided to us should be returned to you or transferred to a person of your choice in a structured, commonly used, and machine-readable format without hindrance from us and subject to your confidentiality obligations;
• The right to object to automated decision-making, including profiling. You can request human intervention in any automated decision-making process related to the processing of your data, provided such processing is not based on your consent, authorized by law, or necessary for the performance of a contract. For clarity, we currently do not make decisions solely through automated processes.

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I. AGE LIMITATION

We do not knowingly Process any personal information from persons under 18 years of age. If you learn that anyone younger than 18 has provided us with personal information, please contact us at info@elwisapp.com.