Last reviewed: July 2023
1. Who we are?
You may contact the data controller for any questions in relation to the manner in which we use your Personal Data at [email protected].
Full name of legal entity: Gaming Innovation Group plc
Email address: [email protected]
Address: Data Protection Officer – Legal Department
@ GiGBeach, Triq id-Dragunara, St. Julians, STJ 3148, Malta.
2. What data we collect about you?
Personal data or personal information, means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymous data).
We may collect, use, store and transfer different kinds of personal data about you which we have grouped together as follows:
“Identity Data” includes first name, last name, or similar identifier.
“Contact Data” includes email address and telephone numbers.
“Application documents” includes the CV and any covering letter of a job applicant (in the event that he/she chooses to upload this through the Website when applying for a role within GiG).
“Interview date and time” refers to the date and time of an interview of a job applicant with GiG.
“Interview feedback” es includes notes taken for the duration of your recruitment process relating to a job application with GiG which, in the event of an unsuccessful job application, will enable us to consider you such job applicant for future vacancies which may become available.
“Test Data” includes results from tests taken by a job applicant relating to a job application (in the event that you choose to upload this through the Website when applying for a role within GIG).
“Marketing and Communications Data” includes your preferences in receiving marketing from us and our third parties, your communication preferences and any correspondence we had with you.
“Technical Data” includes the Internet protocol (IP) address used to connect your computer to the Internet, your login information, browser type and version, time zone setting, browser plug-in types and versions, your internet service provider (ISP), your device, your location, your operating system and platform, header of your requests and other online identifiers.
“Usage Data” includes information about how you use our Website, including the full Uniform Resource Locators (URL) and page interaction information.
We do not collect any information about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health, and genetic and biometric data.
3. What happens if you fail to provide personal data?
Where we need to collect personal data by law, or under the terms of a contract we have with you, and you fail to provide that data when requested, we may not be able to perform the contract we have or are trying to enter into with you. If you provide incorrect details, we may not be able to provide you with the service for which you are enquiring.
If you are a job applicant applying for a role through the Website, it is important that you provide us with up-to-date and accurate data in order to enable us to process your application. We may need to reject an application on the basis that insufficient information has been provided to completely assess the application.
4. How we collect your personal data?
We use different methods to collect data from and about you including through:
Direct interactions. You may give us your Identity Data, Contact Data and Employment related Data by filling in any one of the following: a) the job application form on the Website when you apply for a job role within GIG, b) provide the email address to receive our newsletter, or c) when you provide your contact details via our contact form.
Automated technologies or interactions. As you interact with our Website, we will automatically collect Technical Data about your equipment, browsing actions and patterns. We collect this data by using cookies, server logs and other similar technologies.
Third parties or publicly available sources. We may partner with third parties (like content providers and analytics companies eg. Google Analytics) to help us improve the services of the Website and better understand how you interact with the Website, as well as support our initiatives. These companies may collect information from you automatically in connection with your visit.
5. How we use your personal data?
We will only use your personal data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose.
We have set out below, in a table format, a description of all the ways we plan to use your personal data, and which of the legal bases we rely on to do so. We have also identified what our legitimate interests are where appropriate.
Note that we may process your personal data for more than one lawful ground depending on the specific purpose for which we are using your data. Please contact us if you need details about the specific legal ground we are relying on to process your personal data where more than one ground has been set out in the table below.
|Purpose/Activity||Type of data||Lawful basis for processing including basis of legitimate interest|
|To administer the website and improve it||(a) Technical Data |
(b) Usage Data
|Necessary for our legitimate interests. Scientific or Historical Purposes|
|To review applications and register candidates as new job applicants||(a) Personal Information |
(b) Contact Data
(c) Application documents
(d) Interview date and time
(e) Interview feedback
(f) Test Data
|Necessary for our and your legitimate interests (to choose the right candidates for the job roles within GIG and to consider your application for the open job role within GIG)|
|To carry out reference checks when reviewing job applications||(a) Personal Information |
(b) Application documents
|Necessary for our legitimate interests (to ensure that the right applicants are put through the recruitment process)|
|To enable GIG to respond to potential employment tribunal claims arising out of the recruitment process||(a) Identity Data |
(b) Contact Data
(c) Interview date and time
(d) Interview feedback
|Necessary for our legitimate interests (to protect the interests of GIG in case of any claims brought against it)|
|To consider you for future job roles which may come available at a later stage||(a) Identity Data |
(b) Contact Data
(c) Application documents
(d) Interview feedback
(e) Test Data
|Legitimate interest (to have your Application documents to find a job which fits you) |
Consent (in case of Application documents, where it has been over 12 months since the end of the recruitment process)
|To create Aggregated Data that GiG will use for daily reporting and generation of statistics||(a) Usage Data |
(b) Technical Data
|Necessary for our legitimate interests (for running our business)|
|To use data analytics to improve our website||(a) Technical Data |
(b) Usage Data
|Necessary for our legitimate interests (to keep our website updated and relevant and to develop our business)|
|To respond to any enquiry through the contact us form, or to contact you with the information requested on our products and services||(a) Identity Data |
(b) Contact Data
|Necessary for our legitimate interests.|
|To send you marketing communications relating to our business which we think may be of interest to you by email, sms, or similar technology (you can inform us at any time if you no longer require marketing communications)||(a) Identity Data |
(b) Contact Data
(c) Usage Data
Please note that we may process your personal data without your knowledge in the limited situations where this is required or permitted by law.
6. Who we share your personal data with?
We may share your personal data with the parties set out below for the purposes set out in the table above:
(1) Software companies engaged by GIG from time to time to optimize and facilitate the recruiting process by supplying GIG with recruitment management software;
(2) Parent or subsidiary companies of GIG forming part of Gaming Innovation Group;
(3) Hiring managers involved with respect to a particular job role you have applied for;
(4) Individuals within the Human Resources Team at GIG as necessary;
(5) Individuals within the marketing and the sales team at GiG in order to send you the newsletter and other marketing communications you may have subscribed for or consented to as applicable.
(6) Any potential acquirer, successor, or the assignee as part of any proposed merger, acquisition, sale of assets, or similar transaction in which information is required to be transferred to one or more third parties as part of such transaction.
Workable`s support in the hiring process
We use Workable, an online application system provided by Workable Software Limited, to assist with our recruitment process. Workable processes your personal data as a data processor on our behalf and is only entitled to process it in accordance with our instructions.
Workable provides us with the facility to link the data you provide to us, with other publicly available information about you that you have published on the Internet – this may include sources such as LinkedIn and other social media profiles. Workable’s technology allows us to search various databases – some publicly available and others not, which may include your personal data (include your CV or Resumé), to find possible candidates to fill our job openings. Where We find you in this way, we will obtain your personal data from these sources.
We may receive your personal data from a third party who recommends you as a candidate for a specific job opening or for our business more generally.
Automated decision making and profiling
We may use Workable’s technology to select appropriate candidates for us to consider based on criteria expressly identified by us, or typical in relation to the role for which you have applied. The process of finding suitable candidates is automatic, however, any decision as to who we will engage to fill the job opening will be made by our staff.
We transfer your personal data to our service providers or partners outside the European Economic Area (EEA). We shall only transfer your personal data outside the EEA in the event that the respective countries to which such data is to be transferred provide an adequate level of protection for your personal information.
Determining whether an adequate level of protection of your personal data is provided is based on the existence of one of the following:
- The European Commission has determined that the respective third country, territory or a specified sector within that third country ensures an adequate level of protection for data transfers;
- The service provider or partner to whom your personal data is to be transferred provides appropriate safeguards and data subject rights and adequate legal remedies for data subjects are available. Appropriate safeguards can be provided in various ways including the use of standard contractual clauses approved by the EU Commission. For more information kindly click here.
We require all third parties to respect the security of your personal data and to treat it in accordance with the law. We do not allow our third-party service providers to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our instructions.
7. What are your rights?
Under certain circumstances, you have rights under data protection laws in relation to your personal data:
You have the right to:
- Request access to your personal data (commonly known as a “data subject access request”). This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it.
- Request correction of the personal data that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.
- Request erasure of your personal data. This enables you to ask us to delete or remove personal data where there is no good reason for us to continue to process it. You also have the right to ask us to delete or remove your personal data where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your personal data to comply with local law. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons where we need to abide by applicable laws or where otherwise there is a legitimate interest for us not to comply with such request. Otherwise, you may ask users to delete all your personal data at any point in time, and at which point we will use our best endeavours to adhere to your request. Please note that in the event that you wish for us to delete your data related to a job application, we will not be able to consider you for future job roles which may become available and which may fit your application unless you re-apply and submit the information again.
- Object to processing of your personal data where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms. In some cases, however, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms.
- Request restriction of processing of your personal data. This enables you to ask us to suspend the processing of your personal data in the following scenarios:
a) if you want us to establish the data’s accuracy
b) where our use of the data is unlawful but you do not want us to erase it
c) where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims.
d) you have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.
- Request the transfer of your personal data to you or to a third party. We will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.
- Withdraw consent at any time where we are relying on consent to process your personal data. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain products or services to you. We will advise you if this is the case at the time you withdraw your consent.
You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we could refuse to comply with your request in these circumstances.
We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.
We try to respond to all legitimate requests within one month. Occasionally it could take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.
We will retain copies of any communications that you send to us (including copies of any emails) in order to maintain accurate records of the information that we have received from you.
You can exercise your rights at any time by contacting us at [email protected].
8. How long we keep your personal data?
To determine the appropriate retention period for personal data, we consider the amount, nature and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data (kindly refer to the table above) and whether we can achieve those purposes through other means, and the applicable legal and regulatory requirements. We might keep your personal data for a longer period of time with your explicit consent.
If you unsuccessfully apply to a position within GiG you might request the removal of your personal data after 12 months by sending an email to [email protected] and we will make sure to delete all personal data within the regulatory timelines.
|Date Category||Lawful Basis||Retention Period||Date when retention period starts to apply|
|Personal Information||Legitimate interest||2 years||The end of recruitment or time of receipt of unsolicited application|
|Contact Data||Legitimate interest||2 years||The end of recruitment or time of receipt of unsolicited application|
|Application Documents||Consent||2 years||The end of recruitment or time of receipt of unsolicited application|
|Interview date and time||Legitimate interest||2 years||The end of recruitment|
|Interview feedback||Consent||2 years||The end of recruitment|
|Test Data||Legitimate interest||3 months||Date when data is collected|
|Usage Data||Scientific & Historical Purposes||2 years||Date when data is collected|
|Technical Data||Scientific or Historical Purposes||2 years||Date when data is collected|
We shall retain Aggregated Data for an indefinite period of time as, although this stems from personal data, it does not identify you in any way and does not amount to personal data.
In some circumstances, we will anonymise your personal data (so that it can no longer be associated with you) for research or statistical purposes, in which case we may use this information indefinitely without further notice to you.
9. Is your data safe?
The Site has implemented the necessary and digital and infrastructure security measures at the physical IT and data storage facilities to protect against the loss, misuse and alteration of your information.