Data Protection Policy

 

Bazinga Marketing is a brand name of Fairsystems LTD.

1. General information

This data protection policy explains how Fairsystems LTD and/or its affiliates, subsidiaries, and newly acquired companies (“Bazinga”; “we”) protect the personal data Bazinga processes and controls relating to you (“your personal data”), why Bazinga processes your personal data, who has access to your personal data and how you can exercise your rights in relation to the processing of your personal data.

This data protection policy provides an overview of Bazinga’s most common processing activities of your personal data. Please note that certain specific processing activities may be subject to a separate and tailored data protection policy.

In the event any translation of this data protection policy is prepared, the English version of this data protection policy shall prevail in case of conflicts between the different language versions.

Which categories of personal data does Bazinga process?

Bazinga will collect personal data about you to achieve the purposes set out in this data protection policy.

For further information on the specific categories of personal data Bazinga is processing, please see section 2. For further information on the sources from which Bazinga has obtained your personal data, please see section 3.

If you provide Bazinga with any personal data of another person (for instance, a potential employee/referral), you are responsible for ensuring that such person is made aware of the information contained in this data protection policy and that the person has given you his/her consent for sharing the information with Bazinga.

Except for certain information that is required by law, your decision to provide any personal data to Bazinga is voluntary. You will therefore not be subject to adverse consequences if you do not wish to provide Bazinga with your personal data. However, please note that if you do not provide certain information, Bazinga may not be able to accomplish some or all of the purposes outlined in this data protection policy, and you may not be able to use certain tools and systems which require the use of such personal data.

Why does Bazinga process your personal data?

Bazinga may collect, use, transfer, disclose and otherwise process your personal data in the context of facilitating communication with you (including in case of emergencies), operating and managing Bazinga’s business operations, complying with legal requirements, monitoring your use of Bazinga’s systems, undertaking data analytics and recruitment. For a more detailed list of the purposes, please see section 4.

Bazinga will not use your personal data for purposes that are incompatible with the purposes listed in this data protection policy unless it is required or authorized by law, or it is in your own vital interest (e.g. in case of a medical emergency) to do so.

On which legal basis does Bazinga process your personal data?

Bazinga processes your personal data as permitted by applicable data privacy laws and its internal policies.

Bazinga processes your personal data for the purposes set out in this data protection policy for one or more of the following reasons: (i) because Bazinga is required to do so for compliance with a legal obligation to which it is subject, (ii) because such information is necessary for the performance of a contract to which you are a party, (iii) because the processing is necessary for the purposes of the legitimate interests pursued by Bazinga or by a third party (as described in the last sentence of this paragraph), or (iv) where necessary in order to protect the vital interests of any person. Bazinga has legitimate interests in collecting and processing personal data, for example: (1) to ensure that Bazinga’s networks and information are secure, (2) to administer and generally conduct business and (3) to prevent fraud.

In addition, Bazinga may process your sensitive data and/or make automated decisions concerning you where permitted by applicable law and/or with your prior consent and for the purposes mentioned in this data protection policy.

Please see section 5 for further information on the legal basis on which Bazinga bases the processing of your personal data for each processing activity.

Who has access to your personal data?

Access to your personal data within Bazinga will be limited to those employees who have a need to know the information for the purposes described in this data protection policy, which may include personnel in Security, HR, IT, Compliance, Legal, Finance and Accounting, Corporate Investigations and Internal Audit. All employees within Bazinga will generally have access to your business contact information (e.g. name, position, telephone number, and e-mail address).

Furthermore, your personal data may be transferred to other Bazinga offices and third parties, which may involve transferring your personal data to other countries.

As a global organization with offices and operations in many countries, your personal data may be transferred or be accessible internationally throughout Bazinga’s business and between its entities and affiliates. Any transfers of your personal data to other Bazinga’s offices will be governed by Bazinga’s corporate rules.

Furthermore, where there is a need, Bazinga may share your personal data with third parties, such as service providers and public authorities. Before doing so, Bazinga takes steps to protect your personal data. Any third-party service providers and professional advisors to whom your personal data are disclosed, are expected and required to protect the confidentiality and security of your personal data and may only use your personal data in compliance with applicable data privacy laws. For the categories of third parties with which Bazinga may share your personal data, please see section 6.

How does Bazinga protect your personal data?

Bazinga maintains organizational, physical and technical security arrangements for all the personal data it holds. Bazinga has protocols, controls and relevant policies, procedures and guidance to maintain these arrangements taking into account the risks associated with the categories of personal data and the processing Bazinga undertakes.

Bazinga adopts market leading security measures to protect your personal data

How long does Bazinga retain your personal data?

Bazinga retains your personal data only for as long as is necessary. Bazinga maintains specific records management and retention policies and procedures so that personal data are deleted after a reasonable time according to the following retention criteria:

  • Bazinga retains your personal data as long as it has an ongoing relationship with you.
  • Bazinga retains your personal data for as long as needed in order to comply with a legal obligation to which it is subject.
  • Bazinga retains your personal data where this is advisable to safeguard or improve Bazinga’s legal position (for instance in relation to statutes of limitations, litigation, or regulatory investigations).

Please keep your personal data at all times up to date and inform Bazinga of any material changes to your personal data.

Which rights do you have concerning your personal data?

Please contact Bazinga’s Data Privacy Officer if you (i) have any questions or concerns about how Bazinga processes your personal data or (ii) want to exercise any of your rights in relation to your personal data.

You have the right (in the circumstances and under the conditions, and subject to the exceptions, set out in applicable law) to:

  • Request access to the personal data we process about you: This right entitles you to know whether Bazinga holds personal data of you and, if so, obtain information on and a copy of those personal data.
  • Request rectification of your personal data: This right entitles you to have your personal data be corrected if it is inaccurate or incomplete.
  • Object to the processing of your personal data: This right entitles you to request that Bazinga no longer processes your personal data.
  • Request the erasure of your personal data: This right entitles you to request the erasure of your personal data, including where such personal data would no longer be necessary to achieve the purposes.
  • Request the restriction of the processing of your personal data: This right entitles you to request that Bazinga only processes your personal data in limited circumstances, including with your consent.
  • Request portability of your personal data: This right entitles you to receive a copy (in a structured, commonly used, and machine-readable format) of personal data that you have provided to Bazinga, or request Bazinga to transmit such personal data to another data controller.

To the extent that the processing of your personal data is based on your consent, you have the right to withdraw such consent at any time by contacting Bazinga’s Data Privacy Officer. Please note that this will not affect Bazinga’s right to process personal data obtained prior to the withdrawal of your consent, or its right to continue parts of the processing based on other legal bases than your consent.

Please note, however, that certain personal data may be exempt from the above-mentioned rights pursuant to applicable data privacy or other laws and regulations.

If despite Bazinga’s commitment and efforts to protect your personal data, you believe that your data privacy rights have been violated, we encourage and welcome you to come to Bazinga first to seek resolution of any complaint. You have the right at all times to register a complaint directly with the relevant supervisory authority or to make a claim against Bazinga with a competent court (either in the country where you live, the country where you work, or the country where you deem that data privacy law has been infringed).

What if you have questions or want further information?

This data protection policy, and the web pages referred to therein, aims to give you complete and transparent information on how Bazinga processes your personal data.

If you have any further questions or concerns regarding how Bazinga processes your personal data, or if you wish to exercise any of your foregoing rights, please contact the Data Privacy Officer.

2. Further information on categories of personal data

The below table sets out the categories of personal data that Bazinga processes or may process in the context of the processing activities described in the data protection policy.

Category of personal data Explanation
Personal details Name, preferred pronoun, all types of contact details (such as e-mail, phone numbers, physical address), gender, date of birth, age, place of birth.
Sensitive data. Bazinga may also collect certain types of sensitive information when permitted by local law or with your consent, such as health/medical information (including disability status and dietary requirements/allergies in the framework of the events we organize/sponsor). Bazinga will only use such sensitive information for the purposes described in section 4.
Audiovisual materials Photograph, and images/footage captured on CCTV or other video and related security/monitoring systems.
Position Description of the current position, job title, employer, location, Bazinga contact(s).
System and application access data Where you are provided with access to Bazinga’s systems, Bazinga may collect information required to access such Bazinga systems and applications such as System ID, LAN ID, e-mail account, instant messaging account, mainframe ID, system passwords, access logs, activity logs, and electronic content produced using Bazinga’s systems.

In addition, for recruitment purposes, Bazinga may process the personal data set out in the below table.

Personal details In addition to the personal details listed above, Bazinga may collect additional personal details for recruitment purposes, such as national identification number, social security number, insurance information, marital/civil partnership status, domestic partners, dependents, emergency contact information, military history.
Sensitive data Bazinga may collect certain types of sensitive information when permitted by local law or with your consent, such as health/medical information (including disability status), trade union membership information, religion, race or ethnicity, minority flag, and (where authorized by law) information on criminal convictions and offenses. Bazinga collects this information for specific purposes, such as health/medical information in order to accommodate a disability or illness and to provide benefits; background checks; and diversity-related personal data (such as race or ethnicity) in order to comply with legal obligations and internal policies relating to diversity and anti-discrimination.
Documentation required under immigration laws Bazinga may collect data on citizenship, passport data, details of residency, or work permit (a physical copy and/or an electronic copy).
Talent management information Information necessary to complete a background check, details on performance decisions and outcomes, performance feedback and warnings, e-learning/training programs, performance and development reviews (including information you provide when asking for/providing feedback, creating priorities, updating your input in relevant tools), driver’s license and car ownership information, and information used to populate biographies.

3. Further information on sources of personal data

Your personal data have been obtained by Bazinga from the sources set out in the below table.

Source from which BAZINGA obtains the personal data
Yourself.
Bazinga’s employees.
Bazinga’s affiliates.
Employers of the visitors and contractors.
Public authorities.
Public websites and social media.
Suppliers and vendors.

In addition, for recruitment purposes, Bazinga may obtain personal data from the sources set out in the below table.

Previous employers.
Educational institutions.
Background check providers.
Talent management providers.

The above sources are private sources, unless where the source is expressly stated to be “public”.

4. Further information on the purposes

As set out in the data protection policy, Bazinga processes your personal data for multiple purposes. The below table sets out each of the purposes for which Bazinga processes your personal data.

Purpose Explanation
Facilitating communication with you (including in case of emergencies) Facilitating communication with you, ensuring business continuity, protecting the health and safety of employees and others, safeguarding IT infrastructure, office equipment and other property, facilitating communication with you and your nominated contacts in an emergency.
Operating and managing Bazinga’s business operations (including security) Operating and managing the IT and communications systems, IT security operations, security access control to facilities, managing Bazinga’s assets, business continuity and disaster recovery, compilation of audit trails and other reporting tools, maintaining records relating to business activities and organizing Bazinga’s events/seminars.
Complying with legal requirements Complying with legal requirements, such as mandatory filings, record-keeping and reporting obligations, conducting audits, compliance with government inspections and other requests from government or other public authorities, responding to legal process such as subpoenas, pursuing legal rights and remedies, defending litigation and managing any internal complaints or claims, conducting investigations and complying with internal policies and procedures, protecting, enforcing or defending the legal rights, privacy, safety, or property of Bazinga, Bazinga’s affiliates or their employees, agents and contractors (including enforcement of relevant agreements and terms of use), protecting the safety, privacy, and security of users of Bazinga’s products or services or members of the public, or protecting against fraud or for risk management purposes.
Monitoring your use of Bazinga’s assets Monitoring activities as permitted by local law and/or in accordance with applicable Bazinga’s policies (including monitoring the use of Bazinga’s resources).
Undertaking data analytics Applying analytics to business operations and data to describe, predict and improve business performance within Bazinga and/or to provide a better user experience. Specifically, areas within analytics include descriptive analytics, predictive analytics, analytics involving individuals (clients, business contacts) use personal data, analytics driven by marketing, single customer view and customer journey and workplace analytics.
Recruitment Managing job applications, including conducting interviews, undertaking appraisals, assessing performance, financial planning, undertaking payment administration, managing inclusion and diversity programs, performing background checks, planning and monitoring training requirements.

5. Further information on the legal basis

Bazinga processes your personal data based on the legal bases set out in the below table.

Purpose Legal basis
Facilitating communication with you (including in case of emergencies). Justified on the basis of Bazinga’s legitimate interests for ensuring proper communication and emergency handling within the organization.
Operating and managing Bazinga’s business operations (including security). Justified on the basis of Bazinga’s legitimate interests for ensuring the proper functioning of its business operations.
Complying with legal requirements. Necessary for compliance with a legal obligation to which Bazinga is subject.
Monitoring your use of Bazinga’s systems. Justified on the basis of Bazinga’s legitimate interests of avoiding non-compliance and protecting its reputation.
Undertaking data analytics. Justified on the basis of Bazinga’s legitimate interests of analyzing and improving the proper functioning of its business operations.
Recruitment. Justified on the basis of Bazinga’s legitimate interests for ensuring that it recruits the appropriate employees.

Please note that:

  • Where the above table states that Bazinga relies on its legitimate interests for a given purpose, Bazinga is of the opinion that its legitimate interests are not overridden by your interests, rights, or freedoms given (i) the transparency Bazinga provides on the processing activity, (ii) Bazinga’s privacy by design approach, (iii) Bazinga’s regular privacy review and (iv) the rights you have in relation to the processing activity. If you wish to obtain further information on this balancing test approach, please contact Bazinga’s Data Privacy Officer.
  • Where any of the above purposes require the processing of sensitive data, Bazinga will only do so where permitted under applicable law, or with your prior consent.
  • Where any of the above purposes involve an automated decision, Bazinga will only make such automated decision with your prior consent and after having informed you of meaningful information about the logic involved in the automated decision, as well as the significance and the envisaged consequences of such automated decision for you.
  • Bazinga will process your personal data based on your prior consent to the extent such consent is required by mandatory law.

6. Further information on categories of third party recipients

In addition to transferring personal data to its affiliates and relevant internal staff, Bazinga may also transfer your personal data to the categories of unaffiliated third parties set out in the below table.

Category of third party Explanation
Professional advisors. Accountants, auditors, lawyers, insurers, bankers, and other outside professional advisors in all of the countries in which Bazinga operates.
Service providers. Companies that provide products and services to Bazinga such as IT systems suppliers and support, trade bodies and associations, and other service providers.
For recruitment purposes, Bazinga may also transfer your personal data to companies that provide products and services to Bazinga in relation to performance, training, expense management, and background searches.
Public and governmental authorities. Entities that regulate or have jurisdiction over Bazinga such as regulatory authorities, law enforcement, public bodies, and judicial bodies.
Corporate / commercial transaction. A third party in connection with any proposed or actual reorganization, merger, sale, joint venture, assignment, transfer, or other disposition of all or any portion of Bazinga’s business, assets, or stock (including in connection with any bankruptcy or similar proceedings). A third party in connection with any proposed or actual client project.

7. Contact us

You can contact Bazinga as data controller of your personal data via our Data Privacy Officer.