PRIVACY POLICY

Last updated: 25/12/2025.

This document sets out how we use, process and protect your Personal Data you provide to us (1) during the recruitment process for vacancies at the Company and/or (2) your employment with the Company or when providing services to the Company as an individual.

We are the Company, ABCMobile OÜ, a company incorporated under the laws of Estonia, Registration number: 14710834, VAT ID: EE102157534, located at: Harju maakond, Tallinn, Lasnamäe linnaosa, Peterburi tee 71, 11415, Estonia, acting based on the state registration certificate of a legal entity, conducting the recruitment process, and also being an employer of you or client when services are provided by you as an individual.

You are any individual or individual entrepreneur (sole proprietor) with the necessary legal capacity (personality), searching for a job and intending to participate in the recruitment process for vacancies at the Company (the Applicant), or working in the company on the basis of an employment contract (the Employee), or providing services to the company as an individual (the Contractor).

This Privacy Policy is our notice as the Controller to you as the Personal Data Subject regarding the processing of your Personal Data and it is published at the following websites https://abcgroupcareer.com and https://abcgroup.pro.

We act in your interest and we are transparent about the processing of your Personal Data. That means we are committed to protect and safeguard any Personal Data you give us. 

This Policy applies to all Personal Data you provide to us during the recruitment process for a vacancy at the Company or for the conclusion and performance of an employment contract with you or a service agreement with you as an individual.

We might amend the Privacy Policy from time to time. If you want to know about your privacy, visit this website regularly to know exactly where you stand. If we make changes to the Privacy Policy which will have any significant impact on you (e.g. if we intend to process your Personal Data for other purposes than communicated in this Policy), we will notify you of these changes before the new activities begin.

This Privacy Policy and any issues related to the protection of Personal Data are governed by the EU GDPR REGULATION (EU) 2016/679 OF THE EUROPEAN PARLIAMENT AND OF THE COUNCIL of 27 April 2016 on the protection of natural persons with regard to the processing of Personal Data and on the free movement of such data) and Estonian law.

Personal Data means any information relating to you and mentioned in section 1 of this Policy. Any Personal Data provided by you will be processed by us in accordance with this Privacy Policy.

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This Policy sets out the following:

1. What Personal Data we collect;

2. How the Personal Data is used by us;

3. How do we store and maintain Personal Data

4. Disclosure;

5. Your rights;

6. Contact details.

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1. What Personal Data we collect

The Personal Data we collect is necessary for the recruitment process for a vacancy at the Company as well as for the conclusion and performance of an employment contract with you or a service agreement with you as an individual. Personal data may be collected from information and documents you provide  to us, including but not limited to, via email. Such documents may include, but are not limited to, a CV, identity documents, educational certificates, and other documents.

The Personal Data we collect may include:

Group A

Group B

NOTE: We do not collect, process, use, or store special (sensitive) categories of Personal Data, namely personal data revealing racial or ethnic origin, political opinions, religious or philosophical beliefs, or trade union membership, genetic data, biometric data, data concerning health, or data concerning a natural person's sex life or sexual orientation. We kindly ask that you not provide us with the above-mentioned Personal Data or include it in your CV or other documents and information provided to us. If you include such Personal Data in your CV or other documents and information provided to us, we will not process the relevant CV or other documents and information.

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2. How Personal Data is used and processed by us

2.1.         Personal Data is used and processed by us for the following purposes:

Group A

a) for the purposes of conducting recruitment for Company vacancies, namely, searching for, attracting, evaluating, selecting, and hiring you as a potential employee (candidate);

b) for the purposes of informing you about new vacancies within the Company, recruiting you for other vacancies within the Company, including those that may arise in the future, for which you did not respond, but for which you may be suitable and which may be relevant to you based on the information you provided to us.

Group B

c) for the purposes of concluding and executing an employment contract with you or an agreement for the provision of services with you as an individual;

2.2.     And if you contact us, we may keep a record of your request in order to help solve any issues you might be facing.

2.3.     We will ask for your consent before using your Personal Data for a purpose that is not covered in this Privacy Policy.

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3. How we store and maintain Personal Data

A. THE MANNER OF PROTECTING YOUR PERSONAL DATA

  1. We undertake to protect any Personal Data you provide us. We undertake to do everything to protect Personal Data against any violations and abuses.
  2. Taking into account the state of the art, the costs of implementation and the nature, scope, context, purposes of processing as well as the risk of varying likelihood and severity for your rights and freedoms, we shall in relation to the Personal Data implement appropriate technical and organisational measures to ensure a level of security appropriate to that risk, including, as appropriate, the measures referred to in Article 32(1) of the GDPR or other applicable data protection laws. In assessing the appropriate level of security, we shall take into account, in particular, the risks presented by processing, especially arising from a Personal Data breach.
  3. The Personal Data is kept in a written form (in personal folders, in locked cabinets) and/or in computerised form. Our computer systems are protected by technical and organisational measures that prevent accidental or deliberate destruction, loss, damage, alteration and unauthorised disclosure or access to Personal Data.
  4. Among other things, technical and organisational measures that we use to protect Personal Data include:
  1. regular backup of copies, which are properly protected,
  2. limitation of access to Personal Data,
  3. care for the education of employees in the field of Personal Data protection and supervision over the work of employees.
  1. After the expiry of the retention period or the withdrawal of the given consent, the Personal Data (including any copies) shall be immediately irretrievably and permanently deleted. Any carriers of Personal Data where these data are located shall also be destroyed/permanently deleted.
  2. In the event of a Personal Data breach, we will immediately inform the competent supervisory authority of the violation. If, in the event of a Personal Data breach, a suspicion could arise that a criminal offence was committed, we will immediately notify the police or the competent prosecutor's office.
  3. In the event of a Personal Data breach where there is a high risk to your rights and freedoms, we will inform you of such a breach without undue delay.

B. RETENTION PERIOD

  1. We will retain your Personal Data of Group A for the duration of the recruitment process, which ends with the filling of the relevant vacancy within the Company, and for three (3) years after the end of the recruitment process for the purpose specified in Section 2.1 (b) of this Privacy Policy. We will retain your Personal Data of Group B for the duration of your employment contract or service agreement with you as an individual.
  2. We will also retain your Personal Data after the expiration of the period specified in Section 3.8  of this Privacy Policy, if required by applicable law and other regulations binding on us as the Controller, the Company, the Employer, or the Client, for the required period.
  3. With respect to the collection and processing of Personal Data based on your explicit consent, we will retain the Personal Data for the period specified in Section 3.8 of this Privacy Policy or until your consent is withdrawn by you, whichever occurs first. If the purpose for which we processed your Personal Data has been fulfilled, we will delete your Personal Data, even if you do not withdraw your consent.
  4. If you have any questions about the specific retention period for certain types of Personal Data we process about you, please contact us using the contact information provided below.

C. LEGAL BASES FOR THE USE OF PERSONAL DATA

  1. We process your Personal Data for the purposes described in this Privacy Policy, based on the following legal grounds:
  1. the law - we process Personal Data when it is required to do so by the laws;
  2. contractual or pre-contractual relationship with us serves as the basis for the processing your Personal Data of Group B for the purpose specified in Section 2.1 (c) of this Policy;
  3. your explicit consent - we will ask you to provide your explicit consent so that we can process your Personal Data of Group A for the purposes specified in Section 2.1 (a) and (b) of this Privacy Policy. In doing so, we will ask for your separate explicit consent to the processing of your Personal Data of Group A for the purpose specified in Section 2.1 (a) and for the purpose specified in Section 2.1 (b) of this Privacy Policy. Failure to consent to the processing of your Personal Data of Group A for the purpose specified in Section 2.1 (b) of this Privacy Policy will not prevent you from participating in the recruitment process for the vacancy within the Company to which you have applied.
  1. Before submission and processing Personal Data of Group A, we shall ask you and you shall give to us explicit consent for the processing in accordance with this Policy your Personal Data of Group A subsequently submitted. You are obliged to provide us with Personal Data that we collect and process on the basis of the data protection laws.
  2. The submission of Personal Data of Group B for the entry into (and execution) of an employment contract or a service agreement is voluntary. Nevertheless, we warn you that if you do not provide Personal Data of Group B that we absolutely need to conclude and execute an employment contract or a service agreement, we will not be able to do it with you.

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4. Disclosure of Personal Data

  1. We keep your Personal Data in our records available to you.
  2. We shall take reasonable steps to ensure the reliability of any of our employees, agents or contractors who may have access to Personal Data, ensuring in each case that access is strictly limited to those people who need to know / access the relevant Personal Data, as strictly necessary for the purposes of this Policy, and to comply with data protection laws in the context of their duties to us, ensuring that all of them are subject to confidentiality undertakings or professional or statutory obligations of confidentiality.
  3. We can forward (disclosure) Personal Data to the following recipients:
  1. to our affiliated companies and/or to the third parties for purposes of processing set out in this Policy;
  2. to suppliers and service providers in connection with the normal operation of our business activities and (or) with carrying out functions on our behalf, which may require access to your Personal Data, and also the Processors providing certain services to us;
  3. to the public administration bodies and the courts when required by law.
  1. Personal Data submitted may be transferred by us to our affiliated companies and/or to the third parties, which may be situated outside the European Economic Area and may be processed by staff operating outside the European Economic Area.
  2. By submitting Personal Data to us, you agree to this storing, processing and/or transfer your Personal Data outside the European Economic Area.
  3. In our affiliated companies Personal Data are processed only by people who are authorised by them to process Personal Data. The authorisation can be explicit (for example, given by the director or the head of the department) or general (such authorisation is evident from the description of the tasks of a particular position). The access to Personal Data shall be limited to those employees, agents or contractors of any of our affiliated companies who need access to Personal Data to perform their work. All employees, agents or contractors of any of our affiliated companies who have access to Personal Data are obliged to protect the Personal Data they process.
  4. We shall take reasonable steps to ensure the reliability of  third parties and other recipients referred to in this section of the Policy, who may have access to the Personal Data, ensuring in each case that access is strictly limited to the purposes of this Policy, and to comply with data protection laws and the Policy, ensuring that all third parties and other recipients are subject to confidentiality undertakings or professional or statutory obligations of confidentiality.
  5. When we forward Personal Data to third parties and other recipients referred to in this section of the Policy, it is provided in the scope and in the manner prescribed by data protection laws and the Policy. Personal Data may also be processed by them outside the European Economic Area, including in some countries that may not provide the same level of personal data protection as it applies within the European Economic Area. In accordance with the relevant data protection laws, we will take appropriate measures to ensure that Personal Data remains secure and safe in every transfer. We will set out these measures by concluding appropriate contractual frameworks that will define the protection of Personal Data.
  6. We disclose personal data to law enforcement insofar as it is required by law or is strictly necessary for the prevention, detection or prosecution of criminal acts and fraud or if we're otherwise legally obliged to do so. We may need to further disclose Personal Data to competent authorities to protect and defend our rights or properties, or the rights and properties of our business partners.
  7. Recipients of Personal Data corresponding to this section of the Policy include: PeopleForce and Google. The processing and use of Personal Data by PeopleForce and Google are carried out in accordance with the Privacy Policies posted on the websites of PeopleForce and Google: https://peopleforce.io/privacy-policy and https://policies.google.com/privacy. By agreeing to the Policy, you confirm that you have read and fully agree with the PeopleForce and Google Privacy Policies. For the purposes of this Policy and the provision of our related services, the above-mentioned PeopleForce and Google Privacy Policies are integral parts of the Policy in the event of transfer of Personal Data to PeopleForce and Google for processing and/or use. Your consent to this Policy also constitutes your consent with the PeopleForce and Google Privacy Policies.
  8. We have the right to transfer Personal Data also to other recipients (users) of Personal Data, not mentioned in this clause, corresponding to this section of the Policy, when it is consistent with the purposes of this Policy.

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5. Your rights

  1. We enable you to exercise all of the rights related to the processing of Personal Data. You can request us to:
  1. confirm whether your Personal Data is processed or not;
  2. request information about what Personal Data we processes, about the source of Personal Data;
  3. ask any questions about the confidentiality of Personal Data, the manner of collecting and processing of Personal Data, exercising the rights related to Personal Data processing;
  4. enable the access to Personal Data, when we confirm that Personal Data is being processed;
  5. allow rectification of inaccurate or incomplete your Personal Data. We ask you to inform it of any change in Personal Data as soon as possible, as this is the only way to ensure the accuracy and integrity of the Personal Data that the we keep;
  6. enable the right to delete Personal Data (i.e. the right to be forgotten). The right to the erasure of Personal Data is limited. We cannot delete Personal Data that it processed on the basis of the law or on the basis of a contractual relationship (including any warranty and other time periods that may arise from a particular contract);
  7. enable the right to the restriction of processing, when it is possible;
  8. allow the right to object to the processing. The right to object to the processing of Personal Data is limited to the processing for the purposes of direct marketing, including profiling;
  9. enable to receive Personal Data provided to us in a structured, commonly used, machine-readable form;
  10. enable the right to Personal Data portability and provide Personal Data  in a structured, commonly used and machine-readable form to another controller;
  11. allow the right to withdraw consent where Personal Data is processed on the basis of consent, whereby the withdrawal of the consent does not affect the legality of the processing of Personal Data that was carried out prior to its withdrawal. The consent may be withdrawn by you in written form through e-mail or postal mail. The withdrawal of consent does not create any negative consequences for you. It may happen that after you withdraw your consent, we will not be able to provide you with certain services if these services are of such a nature that we cannot perform them without the transmission of Personal Data.
  1. You have the right to file a complaint against us in regard to Data Protection Laws to the relevant supervisory authority, which is the National Data Protection Authority in Estonia.

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6. Contact details

  1. We control the processing of Personal Data as described in this Privacy Policy.
  2. If you have any questions, requests or complaints about this Privacy Policy, our processing of your Personal Data. your rights or others, please contact us at  info@abcmobile.com with the mark “Personal Data protection” in the subject line and we’ll get right back to you.
  3. All your questions, requests or complaints regarding this Private Policy will be processed and answered by us without undue delay and at the latest within no later than 30 (thirty) days from the date of our receipt of the relevant request.