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Privacy Policy

Privacy policy for job applicants

In this policy, you can read about how Lunar A/S ("Lunar", "we", "our", "us") and our group companies process your personal data during recruitment. 

Lunar process personal data during recruitment in various situations:

  • When you apply for an available position directly at Lunar.
  • When you apply for a position at one of our group companies.
  • When you register in our job bank (Connect).

Controller

Lunar are controller for the processing of your personal data performed at Lunar as part of the recruitment process.

If you have consented to the transfer to our group companies of the personal data you have given us during the recruitment process, the relevant group companies will become controllers for the processing of your personal data performed for the group companies' own purposes, including in connection with the assessment of your skills etc. in which persons associated with the relevant group companies may become involved. In that case, this privacy policy will also apply to our group companies' processing of your personal data. See how to contact these companies under "Contact details" below .

Purpose of processing your personal data 

Receipt of applications etc. 

When we receive your application, we will send you a confirmation that we have received it. When we read the applications, we will select the persons who we will call for an interview. The selection is based on your qualifications in relation to the position(s). You will be called for the interview by email or telephone.

As part of the recruitment process, we will receive and process the data that you have stated in your application, CV and any other schedules. We may also ask you to send us additional information. The information obtained in this connection will include information about your previous employments, including information relating to work assignments, skills and performance, and information about your personal appearance and interpersonal skills. We will also obtain other information about you if we consider such information to be necessary for the assessment of your application.

Social media

If relevant, we will obtain available information published by you on social media, such as LinkedIn and Facebook.

References

If we wish to obtain information about you from your current or former employer using your references, we will first ask for your consent. Unless you are otherwise specifically notified by us, the information we obtain in that connection will include the following categories: Information about your previous employments, including information relating to work assignments, skills and performance, your personal appearance and interpersonal skills, and the reason for not being or no longer wanting to be employed by the employer in question.

Use of personality and competency tests

During the recruitment process relating to some positions, we will use a personality test and/or a competency test. Typically, the tests are taken after our first interview with you. The purpose of the tests is to identify your personal preferences and skills, forming a basis for a dialogue with you about your personal resources and conduct. The tests will never stand alone but will be part of the overall basis for selecting the right candidate for the position.

Criminal record

During the recruitment process, we often use criminal record certificates. Whether a criminal record certificate is required depends on the position, including the responsibilities and powers involved. If we consider it to be relevant to the position for which you have applied, we will ask you to request a personal criminal record certificate.

Relating to Lunar Way AB, no processing of personal data takes place regarding criminal records.

Conduct of interviews

If you progress in the recruitment process, we will conduct interviews where we will focus on your professional and personal skills as well as the challenges etc. of the job. We will write down some of the information disclosed during the interview(s). We only use the relevant information in the assessment of whether you should be offered a position.

Drafting of employment agreement

If we offer you a position, we will process the personal data necessary for staff administration purposes. In that case, you will receive further information on this.

Registration in connect function (job bank)

If you register through our connect function (job bank), we will process your registration information (i.e. your name, email address, telephone number, interest in types of positions, office preferences, age, education, experience, and, if relevant, link to previously produced work) and any other information uploaded by you (including your picture).

Legal basis for processing of your personal data 

In the sections below, you can see the legal bases for our processing of your personal data. The legal bases for each of the activities explained above are stated below.

Receipt of applications etc. and conduction of interviews 

The legal basis for processing the said personal data is point (f) of article 6(1) of the General Data Protection Regulation as we pursue the legitimate interest in the processing of the data being necessary for our assessment of you as a person and your skills in relation to the contents of the position. 

Further, our processing of data that you make available to us on your own initiative is deemed to be performed with your consent. Which statutory provision on consent is the relevant one depends on whether the personal data are general personal data (point (a) of article 6(1) of the General Data Protection Regulation); sensitive personal data (point (a) of article 9(2) of the General Data Protection Regulation); information on criminal offences (section 8(3) of the Danish Data Protection Act (databeskyttelsesloven) (no processing takes place regarding Lunar Way AB); or civil registration number (section 11(2)(ii) of the Danish Data Protection Act),. and for Lunar Way AB, section 10 of chapter 3 of the Swedish Data Protection Act (Sw. Dataskyddslagen) (the importance of an accurate identification.)).

Social media

The legal basis for processing the personal data published by you is point (f) of article 6(1) of the General Data Protection Regulation as we pursue the legitimate interest in the processing of the data being necessary for our assessment of you as a person in relation to the contents of the position.

References 

The legal basis is the consent you give for the purpose of using your references; see point (a) of article 6(1) of the General Data Protection Regulation.

Personality and competencies tests

The legal basis for processing the said personal data is point (f) of article 6(1) of the General Data Protection Regulation as we pursue the legitimate interest in the processing of the data being necessary for our assessment of you as a person and your skills in relation to the contents of the position.

Criminal record
If you provide us with a personal criminal record certificate, our processing of the personal data is deemed to take place with your consent. The rules for issuing a personal criminal record certificate are provided by the Danish Consolidated Act on the Processing of Personal Data in the Danish Criminal Register (kriminalregisterbekendtgørelsen). If you have provided us with a criminal record certificate containing information about criminal offences, our processing is based on section 8(3) of the Danish Data Protection Act. Relating to Lunar Way AB, no processing of personal data regarding criminal records takes place (see section regarding Criminal records above).

Drafting of employment agreement
The legal basis for processing the general personal data stated in the application documents may also be point (b) of article 6(1) of the General Data Protection Regulation as it may be necessary to process the personal data in question for the purpose of drafting an employment agreement, if relevant. 

Registration in connect function (job bank)
The legal basis for the processing of your personal data when you register in our connect function is the consent you give when you register; see point (a) of article 6(1) of the General Data Protection Regulation.

Recipients of your personal data

If it is relevant for Lunar to involve other group companies in the recruitment process (e.g. if you have applied for a position in another group company or a person in a group company needs to be involved in the assessment of your skills), the personal data that Lunar  A/S have processed about you during the recruitment process will be disclosed to another group company. Such transfer is based on your consent. We may also disclose your personal data to our recruitment partner if it is relevant to involve them in the assessment of your skills.

Further, your personal data will be made available to our processors, for example the processors hosting our IT systems and offering personality tests. We have entered into data processing agreements with all our processors.

Further, your personal data will be made available to our processors, for example the processors hosting our IT systems and offering personality tests. We have entered into data processing agreements with all our processors.

Transfer to third countries 
We transfer your personal data to recipients outside the EU and EEA. Such transfer will be made if we use processors and/or subprocessors located outside the EU and EEA. This may also be the case if one or more of our relevant business partners are located outside the EU and EEA. You can see a list of our third country transfers here. The list also contains an account of the relevant basis for the transfers (i.e. the statutory authority for our transfer of your personal data to third countries).

If you want additional information about our transfer of personal data outside the EU and EEA, including a copy of the relevant security measures etc., you may make a request to that effect by exercising your rights as stated below under the title "Your rights etc.".

Storage of your personal data 

Rejection for a specific position

If your application is rejected, Lunar will generally delete the information that we have processed about you during the recruitment process when it is completed. This will typically coincide with the time when Lunar enters into an employment agreement with the selected candidate and generally no more than 6 months after the date when you were informed of the rejection.

Job bank

If you are registered in our connect function, the information entered in that connection will be stored in your connect profile for as long as it remains active. The profile is active for 6 months from registration unless you deactivate your profile (i.e. closes your connect profile) at an earlier date. Your personal data will be deleted immediately after your profile has been deactivated.

If we employ you

If we employ you, the data that we have processed during the recruitment process will, if relevant, be stored in your personnel file in accordance with the applicable guidelines. In that case, you will be further notified of the processing of your personal data.

Right to withdraw consent 

You have the right to withdraw your consent at any time. You may do so by contacting Lunar  A/S using the contact details stated below under the title "Contact details".

If you decide to withdraw your consent, it will not affect the lawfulness of our processing of your personal data on the basis of the consent previously given by you and up to the time of withdrawal. If you withdraw your consent, it will not become effective until such time

Your rights etc.

Under the GDPR, you have several rights in relation to our processing of data about you.  Please contact us if you wish to exercise your rights. Your data protection rights comprise:

Right to access data (right of access)

You have the right to access the data which we process about you and several other data.

Right to rectification (correction)

You have the right to have inaccurate data about you rectified.

Right to erasure

In certain circumstances, you have the right to have data about you erased before we are generally required to erase such data.

Right to restriction of processing

You have the right to restrict the processing of your personal data in certain circumstances. If you have the right to restrict the processing, we can, in future, only process the data – except for storage – with your consent or for the establishment, exercise or defence of legal claims or for the protection of a person or important public interests.

Right to object

In certain circumstances, you have the right to object to our otherwise lawful processing of your personal data.

Right to transmit data (data portability)

In certain circumstances, you have the right to receive your personal data in a structured, commonly used and machine-readable format and to have such data transferred from one controller to another without hindrance.

You can read more about your rights in the Danish Data Protection Agency's guidance on the data subjects' rights, which is available on www.datatilsynet.dk.

Mandatory processing of personal data 

Under the data protection rules, you are e.g. entitled to be informed of whether the provision of personal data is a statutory requirement, or a requirement necessary to enter into a contract, and of whether you are obligated to provide the personal data and of the possible consequences of failure to provide such data.

It should be noted in that respect that, under the Danish Health Information Act (helbredsoplysningsloven), an employee must state of its own motion or at the employer's request to that effect whether the employee knows that (s)he suffers from an illness or shows symptoms of an illness which will significantly affect the employee's ability to carry out the work in question.

Further, as a potential future employee, you are subject to the general duty of transfer which means that you must not knowingly withhold information that may be relevant to your opportunity for being employed.

According to the Swedish Discrimination Act (Sw. Diskrimineringslagen), Lunar Way AB needs to retain information about your merits for 2 years after the finalization of a recruitment process you have participated in if you have been employed by Lunar Way AB or taken out to an interview. This processing is carried out in order to comply with the legal requirements regarding anti-discrimination under Swedish law.

Moreover, it should be noted that, if you are offered a position, Lunar or another group company employing you will use certain personal data about you to draft your employment agreement, including your name and address; see the provisions of the Danish Employment Contracts Act.   

If you do not wish to provide the information that you are required to provide under the provisions of the Danish Health Information Act and/or according to your duty of transfer or the information necessary for drafting an employment agreement, we will be unable to offer you a position. 

Complaint to the Danish Data Protection Agency 
You have the right to file a complaint with the Danish Data Protection Agency if you are not satisfied with our processing of your personal data. You will find the Danish Data Protection Agency's contact details on www.datatilsynet.dk.

Contact details 

Lunar A/S

Hack Kampmanns Plads 1, st. th., DK-8000 Aarhus C 

CVR no.: 36982837

Tel.: +45 70 60 54 54

Email: hello@lunarway.com

Contact details of the data protection officer 

If you have any questions about how we process your data, you are welcome to contact our data protection officer (DPO) at any time. You may contact our DPO in the following ways:

  • By email to: dpo@lunarway.com 
  • By letter to: Hack Kampmanns Plads 1-3, DK-8000 Aarhus C, attn. "DPO"

Group companies

The following is a list of group companies that may receive your personal data in connection with the recruitment process:

Lunar Bank A/S

Hack Kampmanns Plads 1, st. th., DK-8000 Aarhus C 

CVR no.: 39697696 

Tel.: +45 61 20 98 07

Email: ps@lunarway.com 

Lunar Way AB

Box 7527

SE-103 92 Stockholm Stockholms län

Registration number: 559124-9072

Tel.: +45 70 60 54 54

Email: hello@lunarway.com

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