Privacy Policy

1. Introduction

This Privacy Policy (this “Policy”) explains how Peak CS Limited (“the Company”, “we”, “our”, “us”) collects, uses, shares, retains and protects personal data when you visit or interact with our website at https://loyaledge.net (the “Website”), when you contact us or deal with us in a business capacity, and when you apply for, or express an interest in, a role with us.

We are committed to processing personal data lawfully, fairly and in a transparent manner, in accordance with Regulation (EU) 2016/679 (the “GDPR”) and any other applicable data protection law.

This Policy is provided for information and transparency purposes. It is not a contract, does not create contractual rights or obligations, and does not form part of any contract of employment, engagement or services.

We collect personal data in connection with our activities and services, and for human resources purposes (the “Purpose”). This policy applies to two groups of people:

• Visitors — anyone who browses the Website to learn about the Company or the services we offer; and
• Applicants — anyone who applies for, or expresses an interest in, a role with us, whether directly, through the Website, or through a recruitment agency.

As the owner of this Website, we are committed to protecting the privacy of both Visitors and Applicants. We only collect personal data that you provide to us, or as described in this policy.

The Website is intended for people aged 18 or over, and we do not knowingly collect information from children. If you believe a child has given us their information, please contact us and we will delete it.

The Website may link to other websites we do not control. This Policy does not apply to them, and we are not responsible for their privacy practices.

2. Information We Collect

From Visitors, we may collect technical and usage information such as your IP address, browser and device type, operating system, the pages you view, the links you click and how you found us through cookies. We will not collect anything else about you as a Visitor unless you choose to provide such information to us.

From Applicants, we collect the same technical and usage information, together with:

• identity and contact details: your name, email address, telephone number and current location or postal address;
• application content: your CV, any covering message, and the answers you give in our form, including your work history, education, qualifications and the languages you speak;
• eligibility and relocation information: your nationality and right to work and, at offer stage for a Malta-based role, what we need to help arrange your move (see section 5);
• recruitment records: notes and assessments from interviews, screening calls or exercises, and our correspondence with you;
• references and background checks: feedback from referees you name and, where lawful and relevant to the role, the results of any checks; and
• information you have made public: for example, a professional profile such as LinkedIn.

Most of this comes directly from you. We may also receive information from referees you have named, from a recruitment agency where you applied through one, and from public professional sources.

Please share only the information we ask for. Please do not include sensitive details, such as health information or religious beliefs, in your CV or covering message unless we have specifically asked for them.

3. Purpose of Collection and Processing

We only collect the personal data we need to achieve the Purpose, and we only process that data where we have a proper legal reason to do so. Our purposes, and the reason we rely on for each, are:

We run, secure and maintain the Website and guard against misuse, because we have a legitimate interest in a secure, working Website. We reply to your enquiries and communicate with you, relying on our legitimate interests or, where you have asked us to get in touch, on the steps taken at your request.

Where you apply for a role, we assess your application, arrange interviews and decide whether to make you an offer. This rests on the steps taken at your request before entering a contract, and on our legitimate interest in recruiting suitable people. Where it is relevant to the role, we carry out reference and background checks, relying on our legitimate interests, on a legal obligation where one applies, and on your consent where it is required. We also confirm your right to work and, at offer stage, support your relocation, in order to meet a legal obligation and to take the steps needed before a contract begins.

Where we rely on our legitimate interests, we have weighed them against your rights and do not believe our use of your information is unfair or unexpected. Where we rely on your consent, you are free to refuse or withdraw it at any time, and doing so will have no effect on your application. Applying to us does not guarantee employment. We use application data to assess suitability and run our hiring process.

Where we process sensitive information, we will have a proper basis and, where required, your explicit consent.

4. How Long We Keep Your Data

We keep personal data for as long as we reasonably need it for legal or business reasons. When deciding how long to keep it, we consider applicable laws, our contractual obligations and the expectations of our Applicants. Once the data is no longer needed, we securely delete it.

5. Your Rights

Under data protection law, in certain circumstances you have the right to:

• Access your personal data and receive a copy of what we hold about you.
• Correct any data we hold that is inaccurate or incomplete.
• Erase your personal data where there is no valid reason for us to keep processing it.
• Object to our processing of your data where we rely on our legitimate interests.
• Restrict our processing of your data in certain situations.
• Transfer your data to you or to a third party of your choice.
• Withdraw consent at any time, where our processing is based on your consent. This does not affect any processing carried out before you withdrew it.

In some cases we may be unable to fully meet a request for legal reasons, and we will let you know when that applies.

6. Cookies

Our Website may use cookies. Cookies are small text files stored on your device when you visit certain websites. We use them to recognise your device and improve your experience. You can control or delete cookies at any time through your browser or device settings, and you can block them from being installed. Disabling cookies may stop parts of the Website from working properly. By allowing cookies in your browser settings, you accept their use and agree to this Privacy Policy.

7. Who We Share Your Information With

We do not sell your information, and we share it only where necessary. We may share it with:

• service providers acting for us, such as our website hosting, IT support, analytics and applicant-tracking providers, under contracts requiring them to protect it and use it only on our instructions;
• companies in our group, where relevant to assessing you for a role;
• relocation, travel and administrative partners, at offer stage only, as described in section 5;
• referees and background-check providers, where relevant to the role;
• our professional advisers, such as lawyers, auditors and insurers, where necessary; and
• public authorities, regulators and courts, where the law requires or permits it.

Some of our providers may process information outside the EEA. Where that happens, we make sure an appropriate safeguard is in place such as a European Commission adequacy decision, or the Commission’s Standard Contractual Clauses with any additional measures required.

8. How Long We Keep Your Information

We keep personal data only for as long as we need it. In deciding how long that is, we consider what the law requires, how sensitive the information is, why we collected it and what you would reasonably expect.

If your application is unsuccessful, we keep your information up to the maximum date required by law. Where you have agreed to us keeping your details on file for future roles, we hold them for the maximum amount required under applicable law or until you withdraw your consent, whichever comes first. If your application is successful, the relevant information moves to your employee file. When information is no longer needed, we securely delete or anonymise it.

9. Changes to This Policy

We may update this Privacy Policy at any time at our discretion. Please check the Website from time to time to stay informed of any changes.

10. Acceptance

By using this Website, you agree to the collection and processing of your data as set out in this Privacy Policy, and you confirm that the information you provide is accurate and up to date. If you have any questions about the data we hold about you, please contact us using the details below.

We use appropriate technical and organisational measures to protect your information against loss, misuse and unauthorised access, alteration or disclosure. Access is limited to people who need it, all of whom are bound by confidentiality. No transmission over the internet can be guaranteed completely secure, so while we take all reasonable steps, we cannot guarantee the security of information sent to the Website. If a data breach affects you, we will act on it and notify you and the supervisory authority where the law requires.

11. How to Contact Us

If you have any questions about this Privacy Policy or the personal data we hold about you, please contact us at hr@loyaledge.net.