A&K Travel Group Job Applicant Privacy Notice
OUR CONTACT INFORMATION
A&K Travel Group Ltd
Email address: [email protected]
Data Protection Officer: VeraSafe, LLC, +1 (617) 398-7067, [email protected]
Identity and contact details of A&K’s Data Protection Representative in the EU: please scroll to the bottom of the notice.
Identity and contact details of A&K’s Data Protection Representative in the UK: please scroll to the bottom of the notice.
GENERAL INFORMATION
1. Do we collect Personal Data?
YES. Some of the categories we collect include identifiers, job application-related information, such as your name, education information and your job history.
2. Do we process special categories of data or sensitive personal information, such as health data?
YES. Some categories we collect include gender, ethnic origin, and health data.
PRIVACY RIGHTS
1. Can you request a copy of the Personal Data we have collected about you?
YES
2. Can you request to have your Personal Data deleted?
YES
3. Do we discriminate against you for exercising your privacy rights?
NO
SECURITY
1. Do we protect your Personal Data?
YES
SUMMARY
1. What can you find in this Notice?
This Notice tells you, among other things:
- what Personal Data we collect about you and how we obtain it
- for what purposes we use that Personal Data
- how long we keep your Personal Data
- with whom we share your Personal Data
- your rights about the Personal Data we collect about you and how you can exercise those rights; and how to contact us
1. Introduction
A&K Travel Group Ltd, a company incorporated under the laws of the Bahamas and its affiliates (collectively, “AKTG”, “we”, “us”, “our”) take the protection of the individuals applying for an open position at AKTG (“job applicants”, “you”, “your”) personal data (“Personal Data”) very seriously. Please read this Job Applicant Privacy Notice (this “Notice”) to learn what Personal Data we collect about you in relation to processing your application and evaluating your suitability for working at AKTG, why and how we collect and use it, how we secure it, and with whom we might share it.
- This Notice also informs you of your privacy rights under the:
- European Union General Data Protection Regulation (“GDPR”);
- United Kingdom General Data Protection Regulation (“UK GDPR”) and the Data Protection Act;
- Swiss Federal Act on Data Protection;
- Monaco Bill 1954 on November 28;
- Enacted state and federal laws, acts, and regulations of the United States of America that apply to the Processing of Personal Data, as may be amended from time to time (“United States Data Protection Laws”)
(together, “Applicable Data Protection Laws”).
AKTG has adopted this Notice to comply with Applicable Data Protection Laws. Any terms defined in Applicable Data Protection Laws have the same meaning as when used in this Notice.
2. What Is Covered by this Notice
This Notice is designed to help you understand how we process your Personal Data when you apply for an open position at AKTG. We process your Personal Data for the purposes of recruiting you, which is a process that involves but is not limited to assessing your suitability for an open position at AKTG (the “Recruitment Process”).
Within the scope of this Notice, AKTG is the business that makes the decisions about the processing of the Personal Data we collect or that others collect on our behalf (also known as the “data controller” or the “business”).
This Notice does not cover any other data collection or processing, including the data related to our staff (employees or independent contractors), our websites, or our other activities across all AKTG companies. For more information about our collection of Personal Data in other contexts, please see our Global Privacy Notice. If you are engaged by AKTG as an employee or independent contractor, the processing of your Personal Data will be governed by AKTG’s Global HR Privacy Notice.
3. What Personal Data We Process and How We Obtain It
The table below describes the categories of Personal Data we collect during our Recruitment Process and which we have collected in the preceding twelve (12) months.
| Personal Data We Collect, Process, or Store | How We Obtain It |
|---|
| Identifiers | First and last name, email address, phone number, address, personal photo (optional) | We collect this information when you submit an application by any method. We may also collect this information from your CV or resume when you submit it along with your application. We may also obtain it from third parties such as a recruiting or hiring agency, former employer or reference, public resources. |
| Special Categories of Data | Immigration status and voluntary provided gender, ethnic origin, disability status, data concerning health, nationality | We may collect this information if you voluntary provide it to us when you submit an application or if you provide it in your CV or resume when you submit it along with your application. |
| Education and Employment Background | Previous and current job titles, company, or organization of current or previous employment, location of company or organization, dates of employment, description of work performed, name of school, level of education, degree acquired, major and/or minor studied, time spent acquiring the degree, description of degree obtained, professional qualifications | We collect this information when you submit an application. We may also collect this information from your CV or resume when you submit it along with your application. We may also obtain it from third parties such as a recruiting or hiring agency, former employer or reference, public resources, or during the interview. |
| Skills Acquired | Descriptions of skills acquired | We may collect this information when you submit an application. We may also collect this information from your CV or resume when you submit it along with your application, or during the interview. |
| Work Styles and Preferences | Descriptions of your work style | We may collect this information when you submit an application. We may also collect this information from documents you submit along with your application, or during the interview. |
| Motivations for Performing the Job | Descriptions of what motivates you to perform the job | We may collect this information when you submit an application. We may collect this information from documents you submit along with your application , or during the interview. |
| Licenses and Certifications | Name of license or certification name, license number, date that you achieved the certification, renewal date of the certification date | We collect this information when you submit an application. We may also collect this information from your CV or resume when you submit it along with your application, or during the interview. |
| Links to Personal Websites | Link title and URL | We collect this information when you submit an application. We may also collect this information from your CV or resume when you submit it along with your application. |
| Referrals | Specifics of how you heard about the AKTG opportunity you are applying for and whether you were referred by a current AKTG employee | We may collect this information during the Recruitment Process. |
| Compensation Expectation Information | Details on desired salary, bonus, commission, and on-target earnings | We collect this information when you submit an application. We may also collect this information from your CV, resume, or other documents you submit along with your application, or during the interview. |
| Preferred Working Environment | Details on where and how often you can perform the job in various AKTG locations | We collect this information when you submit an application. We may also collect this information from your CV, resume, or other documents you submit along with your application, or during the interview. |
| Internet or Other Similar Network Activity | Browsing history, search history, information on your interaction with our websites | We collect this information from your activity when you visit AKTG’s websites. |
Some of this information may qualify as special categories of Personal Data or sensitive personal information under Applicable Data Protection Laws. We will only process such Personal Data to comply with our legal obligations under applicable laws and regulations.
We will not collect additional categories of Personal Data without informing you.
4. Lawful Bases for Processing
The Applicable Data Protection Laws require that we have a valid reason to use your Personal Data. This is called the "lawful basis for processing.” We may process your Personal Data:
- Because you gave your consent.
- Because we need to perform a contract with you.
- Because we have a legitimate interest in processing your Personal Data and it is not overridden by your rights. Our interests include: assessing your suitability for employment at AKTG.
- Because we need to comply with the law.
- On another ground, as required or permitted by law.
When we rely on legitimate interests as a lawful basis of processing, you have the right to ask us more about how we decided to choose this legal basis, and you have the right to object to processing on this basis. To do so, please use the contact details provided below.
Where we process your Personal Data based on your consent, you may withdraw it at any time. However, this will not affect the lawfulness of our processing before you withdrew your consent. It will also not affect the validity of our processing of Personal Data performed on other lawful grounds.
Where we receive your Personal Data as part of the Recruitment Process based on a contract, we require such Personal Data to be able to carry out the contract. Without that necessary Personal Data, we will not be able to carry out the Recruitment Process.
5. Cookies
To learn about AKTG’s use of cookies on this website and the use of opt-out preference signals, please read the AKTG Job Applicant Cookie Notice located in the header of the job applicant career site.
6. For What Purposes Do We Use Your Personal Data
We may process your Personal Data (including special categories of Personal Data or sensitive personal information) for one or more of the following purposes:
- Recruiting purposes, such as conducting the Recruitment Process, assessing your skills and qualifications, arranging interviews or testing depending on the role you are applying for, and making hiring decisions;
- Confirm that you have the right to work in the location you have applied for;
- Deciding whether to offer you a job;
- Preparing the offer letter;
- Communicating with you during the Recruitment Process;
- Responding to your requests or questions;
- Engaging in necessary precontractual activities or negotiations;
- Making the needed arrangements for your future employment;
- Proactively conducting research about your educational and professional background and skills and contacting you if we think you would be suitable for another role at AKTG.
- Making improvements to AKTG’s job application and/or Recruitment Process, including improving interview practices, and improving diversity, equity, and inclusion in our Recruitment Process;
- Talent management; and
- Record keeping.
To achieve the above purposes, we need to perform different types of processing activities on your Personal Data, such as storage, access, transmission, consultation, manipulation, and combination.
7. How Long We Keep Your Personal Data
If you are offered and accept a job at AKTG, the Personal Data we collect about you during the Recruitment Process will be included as part of your ongoing employment record. We retain your employment record in accordance with our employment record retention policy.
If you do not receive or accept a job offer from AKTG, we will keep your Personal Data for 12 months after the relevant Recruitment Process. We keep this data for future opportunities that better align with your profile, build our talent pipeline, prevent duplicate applications, and for metrics and reporting purposes. You also have an option to voluntary submit your CV/Resume to our “Talent Pool” should you not see a position you are interested in but want us to have your CV/Resume on file should an opportunity arise.
When the purposes of processing are satisfied, we will delete your Personal Data in accordance with our data retention policy and applicable laws and regulations. We will also delete your Personal Data upon receipt of a verified request.
8. Automated Decision-Making
You will not be subject to decisions that will have a significant impact on you based solely on automated decision-making. There will always be human intervention into decisions based on automated processing, including automated profiling. If this position changes, or there is a need and lawful basis to do so, we will inform by updating this Notice.
9. Sharing Personal Data with Third Parties
We share your Personal Data with certain third parties who assist us in operating our Recruitment Process. We do not sell your Personal Data (or “share” it as defined under California law).
The categories of third parties to which we may disclose your Personal Data include:
- Recruiting service providers
- Internet service providers
- Cloud service providers
- Email service providers
- Email security services providers
- Project management tool providers
- Office tool providers
- Online work collaboration tools
- Reporting, business intelligence, and analytics service providers
- Online job listing boards providers
For individuals whose Personal Data is safeguarded by data protection laws in the EU or UK: Before transferring your Personal Data from these regions to third parties outside the European Economic Area or the UK, we ensure that there are adequate levels of protection in place for your Personal Data. In cases where we transfer your Personal Data from these regions to third parties in countries which are not recognized as providing an adequate level of protection to Personal Data, we transfer Personal Data when there are appropriate safeguards in place. These safeguards include the EU 2021 SCCs, UK International Data Transfer Agreement, and any other approved data transfer mechanisms.
AKTG does not expect that the Personal Data of individuals under 18 is being collected, sold or shared, given that children are not expected to apply for an open position at AKTG.
Other Disclosures of Your Personal Data
We may disclose your Personal Data to the extent required by law or if we have a good-faith belief that we need to disclose it in order to comply with official investigations or legal proceedings (whether initiated by governmental/law enforcement officials, or private parties). If we have to disclose your Personal Data to governmental/law enforcement officials, we may not be able to ensure that those officials will maintain the privacy and security of your Personal Data.
We may also disclose your Personal Data if we sell or transfer all or some of our company’s business interests, assets, or both, or in connection with a corporate restructuring. Finally, we may disclose your Personal Data to our subsidiaries or affiliates, but only if necessary for Recruitment Purposes, as described in the section above.
10. What Privacy Rights Do You Have?
You have specific rights regarding your Personal Data collected and processed by us. In this section, we first describe those rights and then we explain how you can exercise those rights.
Right to Know What Happens to Your Personal Data
This is called the right to be informed. It means that you have the right to obtain from us all information about our Personal Data processing activities that concern you, such as how we collect and use your Personal Data, how long we will keep it, and who it will be shared with, among other things. We are informing you of how we process your Personal Data with this Notice.
Right to Know What Personal Data AKTG Has About You
This is called the right of access. This right allows you to ask for full details of the Personal Data we hold about you.
You have the right to obtain from us confirmation as to whether or not we process Personal Data concerning you, and, where that is the case, a copy or access to the Personal Data and certain related information. Once we receive and confirm that the request comes from you or your authorized agent, we will disclose to you:
- The categories of Personal Data we collected about you;
- The categories of sources for the Personal Data we collected about you;
- Our purposes for processing that Personal Data;
- Where possible, the envisaged period for which the Personal Data will be stored, or, if not possible, the criteria used to determine that period;
- The categories of third parties to which we disclose that Personal Data, with whom we share it, or “sell” it to;
- The specific pieces of Personal Data we collected about you;
- If we rely on legitimate interests as a lawful basis to process your Personal Data, the legitimate interests pursued; and
- The appropriate safeguards for transferring data from the EEA, or UK to a third country, if applicable.
Please take into account that some Applicable Data Protection Laws allow us not to satisfy your access request when:
- you already have the information;
- providing such information proves impossible or would involve a disproportionate effort, or in so far providing such information is likely to render impossible or seriously impair the achievement of the objectives of that processing; and
- that Personal Data must remain confidential subject to an obligation of professional secrecy regulated by Union or Member State law, including a statutory obligation of secrecy.
We will not disclose account passwords or security questions and answers. We can inform you that we have this information generally, but we may not provide the specific items to you for security and legal reasons.
Right to Correct Your Personal Data
This is called the right to rectification. It gives you the right to ask us to correct anything that you think is wrong with the Personal Data we have on file about you and to complete any incomplete Personal Data.
Right to Delete Your Personal Data
This is called the right to erasure, right to deletion or the "right to be forgotten". This right means you can ask for your Personal Data to be deleted.
- Sometimes we can delete your information, but other times it may not be possible, such as when the law requires us to keep certain information. If that is the case, we will consider if we can limit how we use it.There may also be circumstances where we deny your request to delete your information under applicable law, such as if we or our third party service providers need to retain the Personal Data to:
- complete the Recruitment Process;
- provide a service you requested that is linked to the Recruitment Process;
- take actions reasonably anticipated within the context of our ongoing relationship with you, or otherwise perform a contract with you that is linked to the Recruitment Process;
- detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity, or prosecute those responsible for such activities;
- debug products to identify and repair errors that impair existing intended functionality;
- enable solely internal uses reasonably aligned with your expectations based on your relationship with us during the Recruitment Process;
- comply with a legal obligation, including (but not limited to) obligations from the California Electronic Communications Privacy Act; or
- make other internal and lawful uses of that information that are compatible with the context in which you provided it.
Right to Ask Us to Change How We Process Your Personal Data
This is called the right to restrict processing. It is the right to ask us to only use or store your Personal Data for certain purposes.
You have this right in certain circumstances, such as where you believe your Personal Data is inaccurate or the processing activity is unlawful. This right enables you to ask us to suspend the usage of Personal Data about you, for example if you want us to establish its accuracy or the reason for processing it.
Right to Ask Us to Stop Using Your Personal Data
This is called the right to object. This is your right to tell us to stop using your Personal Data. You have this right where we rely on a legitimate interest of ours (or of a third party).
We will stop processing the relevant Personal Data unless: (i) we have compelling legitimate grounds for the processing that override your interests, rights, or freedoms; or (ii) we need to continue processing your Personal Data to establish, exercise, or defend a legal claim.
Right to Port or Move Your Personal Data
This is called the right to data portability. It is the right to ask for and download Personal Data about you that you have given us or that you have generated by virtue of your participation in the Recruitment Process, so that you can:
- move it;
- copy it;
- keep it for yourself; or
- transfer it to another organization.
We will provide your Personal Data in a structured, commonly used, and machine-readable format. When you make a data portability request electronically, we will provide you a copy in electronic format.
Right to Withdraw Your Consent
Where we rely on your consent as the legal basis for processing your Personal Data, you may withdraw your consent at any time. If you withdraw your consent, our use of your Personal Data before you withdraw is still lawful.
If you have given consent for your details to be shared with a third party, and wish to withdraw this consent, please also contact the relevant third party in order to change your preferences.
Right Not to be Discriminated Against for Exercising your Privacy Rights
We will not discriminate against you for exercising any of your privacy rights, meaning we will not deny you a chance to apply or re-apply for future positions at AKTG.
Right to Lodge a Complaint with a Supervisory Authority
Some of the Applicable Data Protection Laws grant you the right to lodge a complaint with a supervisory authority if you are not satisfied with how we process your Personal Data. You can find the details of the authorities of each member state in the EEA here. If the UK GDPR applies to our processing of your Personal Data, you have the right to lodge a complaint with the UK Information Commissioner’s Office.
11. How Can You Exercise Your Privacy Rights?
To exercise any of the rights described above, please submit a request by using any of the contact methods under the “Contact Us” section below.
12. Response Timing and Format of Our Responses
Please allow us up to thirty (30) days to reply to you from the day we received your request. If we need more time (up to 90 days in total), we will inform you of the reason why, and the extension period, in writing. If we cannot satisfy a request from you, we will also explain why in our response.
We will not charge a fee for processing or responding to your requests unless we determine that your request is excessive, repetitive, or manifestly unfounded. In those cases, we will tell you why we made that determination and provide you with a cost estimate before completing your request.
13. Privacy of Children
The Recruitment Process is not directed at children under the age of 18. Children under the age of 18 will not participate in the Recruitment Process. If you believe we might have any Personal Data from or about a child under 18, please contact us by using the contact details provided below. If we learn that we have collected or received Personal Data from a child under 18 without parental consent, we will delete that Personal Data.
14. Do Not Track
"Do Not Track" is an optional browser setting that you can use to express your preferences regarding tracking by advertisers and other third-parties. Given uncertainty over what constitutes a “do not track” signal, we do not currently process such signals.
15. Data Integrity & Security
We are strongly committed to keeping your Personal Data safe. We have implemented and will maintain technical, administrative, and physical measures that are reasonably designed to help protect your Personal Data from unauthorized processing. Unauthorized processing includes unauthorized access, exfiltration, theft, disclosure, alteration, or destruction. In addition, we limit access to Personal Data to those employees, agents, contractors, and other third parties who have a legitimate business need for such access. In the event your Personal Data is compromised, we will notify you in the most expedient time reasonable under the circumstances and where required by law.
16. Contact Us
Contact us if you have any questions about this Notice or our processing of your Personal Data or want to submit a verifiable consumer request. Please write to the AKTG privacy team by email at [email protected]. Please allow up to four weeks for us to reply.
European Union Representative
We have appointed one of our subsidiary companies as our representative in the EU for data protection matters. To contact our EU representative, please email [email protected].
Alternatively, our EU representative can be contacted at:
Abercrombie & Kent Italy S.r.L.
Via Fattori 10
Florence 50132
Italy
United Kingdom Representative
We have appointed one of our subsidiary companies as our representative in the UK for data protection matters. To contact our UK representative, please email [email protected].
Alternatively, our UK representative can be contacted at:
Abercrombie & Kent Ltd.
St George’s House
Ambrose Street
Cheltenham
GL50 3LG
Data Protection Officer
We have appointed VeraSafe as our Data Protection Officer (“DPO”). While you may contact us directly, VeraSafe can also be contacted on matters related to the processing of Personal Data. VeraSafe’s contact details are:
VeraSafe, LLC
100 M Street S.E., Suite 600
Washington, D.C. 20003
USA
Email: [email protected]
Web: https://www.verasafe.com/about-verasafe/contact-us/
17. Changes to This Notice
If we make any material change to this Notice, we will post the revised Notice to this webpage. We will also update the “Effective” date. By continuing to participate in the Recruitment Process after we post any of these changes, you accept the modified Notice.
