Recruitment Privacy Policy

1  General Provisions

We are committed to respecting your privacy and protecting your personal data, which is any information that is capable of identifying you as an individual person. This Recruitment Privacy Policy (the “Privacy Policy”) describes how CTP Invest (“CTP Invest” or “we”) handles, processes and protects your personal data in connection with the recruitment process. As used in this Privacy Policy, “personal data” means information that identifies job applicants and potential candidates for employment with us (“You” or the “candidate”), either submitted to us as part of your job application (whether online or in writing) and/or through alternative channels (e.g., via professional recruiting firms).

This Privacy Policy also informs you about your rights regarding personal data processing and how and by what means you can exercise them.

We recommend that you carefully familiarize yourself with this Privacy Policy.


2  Personal Data Controller

2.1 Identification of your data controller

The controller of your personal data is CTP Invest, spol. s r.o., with its registered office at Central Trade Park D1 1571, 396 01 Humpolec, ID: 261 66 453, registered in the Commercial Register maintained by the Regional Court in České Budějovice, file C 15647.

As set in this Privacy Policy, your personal data may be shared with other CTP Invest’s affiliates or subsidiaries being part of CTP Group (“CTP Group”).

Updated contact details and other information about CTP Invest and other CTP Group companies can be found at

For requests and/or complaints related to this Privacy Policy you can contact us via e-mail


3  Purpose, Legal basis, scope and duration of processing of personal data

3.1 Purposes, legal bases and duration of processing

We only process your personal data within the scope necessary for the fulfillment of our contractual or statutory obligations, or on the basis of a consent granted by you for the purposes as set out below.

3.1.1  We process your personal data for the purposes of the recruitment and hiring process. We use your personal data in order to identify and evaluate candidates for potential employment (i.e. for a specific job position in CTP Invest or potentially other entity of CTP Group).

We use the personal when necessary to enter into an employment contract with you. For that reason, we process your personal data until the recruitment process is terminated. For this purpose, your personal data may be transferred to the specific company of the CTP Group having the job vacancy available.

3.1.2  We may desire to retain your personal data to consider you for future employment opportunities in CTP Invest, or, potentially, other entities of the CTP Group. In such an event, we will seek your consent, either prior to or after you formally apply for a job opportunity, to be part of our recruiting program that provides you ways to receive further offers of job vacancies in the CTP Group. This recruiting program is entirely optional.

If you give us your consent, we might process your personal data for contacting you in regard of job opportunities (vacancies) for an appropriate job position in CTP Invest (or another CTP Group entity).  We will process your personal data at maximum for the period defined in the consent; this period will usually not exceed the period of 2 years from the moment when the consent was granted.


3.2  Scope of processing

We process your personal data within the following scope: data that you provide us with during the recruitment and hiring process and in your résumé, particularly your name and surname, address, email address, telephone, work and educational history, achievements, and test results (if applicable), photograph and any other personal data contained in your résumé or otherwise provided to or obtained by us, for example, data that we collect performing candidate screening, including lawful background checks.

4  Sharing and transfer of the personal data (Recipients of personal data)

4.1       Recipients of personal data

Some categories of the personal data that we collect in the manners set out above may be shared by us with third parties that are either independent controllers or provide certain services to us relating to the recruitment process, as our processors, in particular:

I.  within the CTP Group for the purpose the recruitment and hiring process;

II. with entities administering our IT systems and providing IT services utilized for the purpose of administration and organization of the recruitment process;

III. with entities providing recruitment services and advertising of job positions;

IV. with public authorities or other third parties for the fulfilment of obligations in accordance with legal regulations.


4.2       Safeguards

We have entered into agreements on processing of personal data with the processors of personal data, as per the previous paragraph (with the exception of cases where the conclusion of such agreement is not obligatory, for example, when transferring personal data to public authorities), which ensure at least the same level of protection thereof as this Privacy Policy.


5  Data Security

We have implemented and maintain appropriate technical and organizational measures, internal controls and information security processes in accordance with legal requirements and market standards corresponding to a possible threat to you as the data subject. We also take into consideration the state of technological development in order to protect your personal data from accidental loss, destruction, alterations, unauthorized disclosure or access. Such measures may, among other things, include taking reasonable steps to ensure the liability of relevant employees who have access to your data, training of employees, regular backups, procedures for data renewal and management of incidents, software protection for devices on which personal data are stored, etc.


6  Your Rights as a Data Subject

If you wish to exercise any of your rights according to this Article or according to applicable legislation, please contact us using the contact information listed in Article 2 above.

Also, if applicable, we will inform each recipient to whom your data have been provided according to Article 4 of this Privacy Policy of the measures taken or of the erasure of your personal data or of the restriction of processing in accordance with your request, if such a notification is possible and/or does not involve disproportionate effort.


6.1  Access to and portability of your personal data

You have the right to request information whether and to what extent we process your personal data. You also have the right to receive personal data which you have provided to us and other personal data related to you (unless we have deleted your data prior to your request).

Should you request so, we can send some of your personal data (namely the data that we process on the basis of performance of a contract and/or your consent, and by automatic means) directly to a third party (to another data controller) whom you state in your request, provided that such request does not affect the rights and freedoms of other persons, and provided that it is technically feasible.


6.2  Withdrawal of consent

You can withdraw your consent (if you have given it to us) at any time without giving reason. In such a case, we will erase your personal data as soon as reasonable and practicable, but no later than 30 days from the withdrawal of your consent.

Please note that the withdrawal of your consent does not affect the lawfulness of processing conducted on the basis of consent prior to its withdrawal.


6.3  Rectification of your personal data

According to applicable legislation, you have the right to rectification of your personal data that we are processing if you find that they are inaccurate or incomplete.

You can at any time request information about whether we still process your personal data or not.


6.4  Erasure of your personal data

You can request erasure of your personal data at any time (e.g., if you choose to withdraw from our recruiting program). If you contact us with such request, we will erase all your personal data that we have without undue delay, unless we need your personal data for the fulfilment of contractual or statutory obligations.

Further, we will also erase all of your personal data (and ensure erasure thereof by the processors that we engage) if you withdraw your consent.


6.5  Objections to processing

If we process some of your personal data on the basis of our legitimate interest, you have the right to object, at any time, to the processing of personal data. If significant legitimate interests for processing – that prevail the interests or rights and freedoms of the data subject – are not proven on our part, or further processing is not necessary for the establishment, exercise or defense of our legal claims, we will no longer process your personal data.


6.6 Restriction of processing

If you request restriction of processing of your personal data, e.g. in the event that you question the accuracy or lawfulness, or our need to process your personal data, we will restrict the processing of your personal data to the necessary minimum (storage), and we may only process them for the establishment, exercise or defense of legal claims, or on grounds of the protection of the rights of another natural person or legal entity, or other limited reasons prescribed by applicable legislation. If a restriction of processing is lifted and we continue to process your personal data, we will inform you without undue delay.


6.7  Complaint to the Office for Personal Data Protection

You have the right to lodge a complaint pertaining to processing of data conducted by us with the competent data protection authority, i.e. in Czech Republic the Office for Personal Data Protection, Pplk. Sochora 27, 170 00 Praha 7; website:

7 Updates to the Privacy Policy

We may modify or update the Privacy Policy from time to time. Any changes to this Privacy Policy shall become effective with publication of the updated Privacy Policy at











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