Copyright © AstroPay
All rights reserved. This document and the information it contains, or may be extracted from it, is subject to the terms and conditions of the agreement or contract under which the document was supplied to the recipient’s organisation. None of the information contained in this document shall be disclosed outside of the recipient’s own organisation without prior written permission of AstroPay, unless the terms of such agreement expressly allow.
In the event of a conflict between this document and a relevant law or regulation, the relevant law or regulation shall be followed. If the document creates a higher obligation, it shall be followed as long as this also achieves full compliance with the law or regulation.
Use of language
Throughout this document, the words ‘may’, ‘should’ and ‘must’ when used in the context of actions of Astropay or others, have specific meanings as follows:
- ‘May’ is used where alternatives are equally acceptable.
- ‘Should’ is used where a provision is preferred.
- ‘Must’ is used where a provision is mandatory.
Note that alternative or preferred requirements may be qualified by AstroPay in another referenced document.
AstroPay and the companies in which it directly or indirectly owns investments are separate and distinct entities. In this publication, however, the collective expression ‘AstroPay’ and ‘AstroPay Group’ may be used for convenience where reference is made in general to those companies. Likewise, the words ‘we’, ‘us’, ‘our’ and ‘ourselves’ are used in some places to refer to the companies of the AstroPay Group in general. These expressions are also used where no useful purpose is served by identifying any particular AstroPay or companies.
In this document, Third Party means any individual or organisation you come into contact with during the course of your work for us, and includes actual and potential clients, customers, suppliers, distributors, business contacts, agents, advisers, and government and public bodies, including their advisors, representatives and officials, politicians and political parties.
The purpose of this Governance Policy describes the DSAR applicability inside AstroPay
Review and maintenance
This Policy will be reviewed and maintained by the Data Compliance Officer at least annually. The provisions of this Policy can be amended and supplemented from time to time by the Head of Compliance.
1. Why do we process information about you?. 1
2. What information do we collect?. 2
3. How will we process your information?. 2
4. How long do we keep your information?. 3
5. Your rights 3
6. Contact information. 4
7. Version. 4
Why do we process information about you?
- In the following text, you can read more about how we process your personal data when applying for a job at AstroPay.
- We only collect your personal data for recruitment purposes, including assessing whether you are qualified for current or future positions at AstroPay.
What information do we collect?
- When applying for a job at AstroPay, we will ask you to create a user account to manage your applications for our job offerings or. To create your account, we ask you to submit your email address and what primary job role that you are interested in (i.e., account management, banking, crypto, customer support, engineering, finance, iOS, marketing, product, etc.), or you may sign in via your Facebook or LinkedIn account.
- Once you have created your account, you can add more information about yourself to let us know you a little better. This includes data about your first and last name, email address, phone no., profile picture, primary job role interests, where you want to work, and whether you want to subscribe to our job offering email list and how often you receive notifications. Once you wish to apply for a specific job offering, we will also need to process data on where you are currently based (city and country), your English communication level, CV, the cover letter on your application, and any additional files you may add (i.e. academic records, etc.). You also have the option to add recommendations from your previous employer(s) by adding their email, name and company/title.
- If you apply for specific jobs at AstroPay as an IT-developer, we may ask you to perform a development test in connection with the recruitment. We will process the results of these tests in this connection.
- In some cases, we may also collect information about you from public sources and social media such as LinkedIn, Facebook, Instagram, etc.
- We urge you not to disclose to us your social security number or other sensitive information, including information on your racial or ethnic background, political, religious or philosophical beliefs, trade union affiliation, or information on health and sexual orientation. We therefore kindly ask you to remove any social security numbers on academic records, etc., as we do not need to process this information during the recruitment process. However, you may be required to inform us at the latest during any job interview if you suffer/have suffered from an illness that will have a significant impact on your performance of the work in the specific position you are applying for in accordance with national health information regulations.
- Personal data that we process with the purpose of aggregated analysis or market research is always made unidentifiable. Such personal data cannot be used to identify you. Thus, such data is not considered personal data.
How will we process your information?
- Your information will be processed by employees of AstroPay for the purposes set out in section 2 above.
- The legal basis for our processing is for the conclusion of a contract with you, cf. GDPR Article 6(1)(b). Any tests as well as references are processed based on your consent in accordance with GDPR Article 6(1)(a). If we collect information about you from public sources and social media such as LinkedIn, Facebook, Instagram, etc., we do this based on our legitimate interest in learning more about you and how you may be suitable for a job position with us, cf. GDPR Article 6(1)(f).
- We also have several data processors who perform tasks on our behalf. These data processors can only access and process your personal data on our behalf and in accordance with our instructions to fulfil the purposes set by us.
- Your information may be transferred to countries outside of the EU/EEA. In this case, we will have secured a legal transfer basis prior to the transfer in the form of an adequacy decision from the EU Commission or via the use of EU Commission Standard Contractual Clauses (SCC’s). Your data will therefore be always protected by the EU's data protection regulation or similar regulation. You may contact us at firstname.lastname@example.org if you wish to get a copy of the legal transfer basis we use or where you can read more about it.
How long do we keep your information?
- In the case you were not offered the position, we will delete your information when the position you applied for is filled and the recruitment process is completed. If we wish to keep your information for a longer period other than the recruitment process, we will obtain your express consent to do so, however deletion will as a main rule happen 3 years after the recruitment process is completed.
- If, on the other hand, you are offered a position, your application, your resume, and any attachments will be stored in your personnel folder in the HR department. You will receive separate information about this processing at that time.
- You have a number of fundamental rights in relation to the personal data regulations that you can use when we collect information about you. Your rights include the right to request access to and rectification or erasure of your personal data, restriction and objection to our processing, and the right to receive your data in a structured, commonly used, and machine-readable format (data portability). You can request access to your data and deletion of your data from the settings menu on your application profile.
- If you have consented to our processing of your information, you have the right to revoke this consent at any time.
- If you are dissatisfied with our processing of your personal data, you may file a complaint with your national data protection authority.
- If you have any questions about our processing of your personal data, you are welcome to contact us at email@example.com.
- The company responsible for processing your personal data is:
- Larstal Denmark ApS
- Company Registration No: 42457590
- Address: c/o Regus Søborg, Automatikvej 1, 3., 2860 Søborg, Denmark
- AP Global Corporation LLP
- Company Registration No: OC346322
- Address: 4 King's Bench Walk, Temple, London, EC4Y 7DL, United Kingdom
- Legal & Compliance affairs: firstname.lastname@example.org
- If you have any questions regarding our processing of your personal data, please for more information email@example.com.
- how can i contact astropay? Email: firstname.lastname@example.org
This document was last revised in February 2023.