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We collect personal data directly from you when you contact us, meet us personally or otherwise interact with us. The collected personal data includes, for example:. We process your personal data to enter into and execute agreements, to provide and market our services and products, to communicate with you and to develop our business. We process personal data when it is necessary for the preparation and execution of agreements. Please note that without your personal data we may not be able to enter into an agreement or provide you with our products and services.

We also process personal data in connection with other commonly agreed testing and supply arrangements relating to our products and services based on our legitimate interest to market our products and services and grow our professional network. In addition, we process personal data to develop our business operations and offering. When a legitimate interest is regarded as the basis for the processing, we have conducted a balancing test to ensure that your rights are taken into account.


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You can object to such processing and request more information about the balancing test by using the contact details below. Processing of your personal data can be based on your consent, for example, if you order our newsletter.

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A withdrawal of consent does not affect the lawfulness of processing based on consent before the withdrawal. You can withdraw your consent by clicking unsubscribe link at the bottom of the newsletter or by contacting us by using the contact details provided below. Where necessary, we also process personal data to comply with the legal requirements to which HMD is subject to.

Your personal data is processed within HMD entities. We do not disclose or otherwise transfer your personal data unless otherwise stated below. Service providers. We obtain assistance and use service providers, such as CRM tool providers, in processing personal data for the purposes described in this Notice.


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Running our business involves using resources and servers located in various countries around the world. Therefore, your personal data can be transferred across international borders, including to countries outside the EU or EEA that do not have laws providing specific protection for personal data or that have different legal rules on data protection. In such cases, adequate protection for your personal data is provided as required by applicable law, for example, by using standard data protection clauses and by requiring the use of other appropriate technical and organisational information security measures.

You may request information on the details of transfers to third countries and safeguards by using the contact details below. Mandatory disclosures and legal proceedings. We can be obligated by mandatory law to disclose your personal data to certain authorities or other third parties to comply with our legal obligations. We may also need to disclose and otherwise process your personal data in accordance with applicable law to defend our legitimate interests, for example, in civil or criminal legal proceedings.

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If we decide to sell, buy, merge or otherwise reorganise our businesses in certain countries, this can involve us disclosing personal data to prospective or actual purchasers and their advisers, or receiving personal data from sellers and their advisers. We review personal data held in our systems on a periodic basis to ensure that it is not retained longer than it is necessary.

Contact details and other information will be deleted within six 6 months after they are no longer needed for the purposes they were collected for for example, when the role of the person changes in a way that s he is no longer representing the organization of which contact person s he was. We are committed to ensure that your personal data is secure. To prevent unauthorised access or disclosure we implement technical, physical and organizational measures to protect personal data against accidental or unlawful destruction, accidental loss or alteration, and unauthorized disclosure, or access.

We have implemented appropriate access control measures to ensure that personal data can only be accessed by those who need to process it by virtue of their tasks. You have a right to have incomplete or incorrect personal data rectified. This means that if there are errors in the data concerning you, or if it is inaccurate or deficient, you have the right to ask HMD to rectify or complete that data.

You have the right to have your personal data erased in certain situations, for example, when the processing of your data is no longer necessary for the purposes for which it was collected.

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When the processing of your personal data is based on legitimate interest, you have a right to object to such processing on grounds relating to your particular situation. You have always a right to object to direct marketing. In certain situations you might have a right to restrict the processing of your personal data.

For example, if you contest the accuracy of your data, you have the right to have the contested data under a restriction of processing during the time when it is ensured that the data is accurate. When the processing of your personal data is based on a contract or consent and carried out by automated means, you have a right to obtain the data you have provided to HMD in a machine-readable format so that you can transfer it to another controller.

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If you believe that HMD, regardless of the principles set out in this Notice, infringed upon your rights according to applicable data protection law, you have a right to lodge a complaint with the data protection authority. In case you want to use your data protection rights or you have any questions concerning the processing of your personal data, please contact us via.

We update and modify this Notice from time to time, should it become necessary to do so. This Policy explains, inter alia, what kind of personal data we collect about you, how your personal data is processed during the recruitment activities, and what rights you have in relation to such processing of personal data. This Policy will be supplemented by applicable local mandatory law where necessary. In case mandatory law is in conflict with this Policy, mandatory local law will prevail.

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We may also provide you with additional information concerning the processing of your personal data in connection with recruitment related systems or services. We collect personal data primarily directly from you. In addition, when it is necessary for assessing your suitability for the position you are applying for, personal data can be collected from third party sources to the extent permitted by applicable legislation, or based on your consent. When you apply for a position with HMD, we only collect personal data which is relevant for making the recruitment decision.

We collect e. Your personal data is processed for assessing your suitability for the role for which you are applying for. We can also assess your suitability for the future roles that may become available. In addition, we process your personal data, inter alia, when communicating with you in relation to our recruitment activities, when managing our recruitment and resourcing activities, for developing our recruitment services and systems, and to comply with legal obligations.


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  4. Processing of your personal data is necessary for the preparation and execution of an employment or other contract and for compliance with legal obligations. Please notice that failure to provide necessary personal data may disqualify you from employment or other engagement. We process personal data based on our legitimate interests where applicable.

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    Our legitimate interests include interest to receive and process applications and corresponding data for our recruitment purposes and lawful activities related to running and developing our business, such as developing our recruitment and resources systems and processes. When our legitimate interest is the basis for the processing, we have conducted a balancing test to ensure that your interests are not interfered more than necessary.

    You have a right to object to the processing based on our legitimate interest. To request more information about the balancing test, please contact us by using the contact details below. We collect personal data also based on your consent. For example, we may ask you to provide contact details of your references and your consent for contacting them. When we process your personal data on the basis of your consent, you have the right to withdraw your consent any time.

    You can withdraw your consent by using the contact details below or, in case you have been directly contacted by us, by using the contact details of your recruitment contact. Withdrawal of the consent does not affect the lawfulness of processing based on consent before its withdrawal. Your personal data is processed only by those members of the staff who are assessing your application and other related information for making the recruitment decision or who are performing support functions to recruiting. These include, for instance, recruiters, hiring managers and other interviewers and individuals performing administrative and IT support functions.

    We do not transfer or disclose your personal data to other parties unless otherwise stated below. We obtain assistance or use service providers for conducting our recruitment activities. We utilize LinkedIn recruitment services in our recruitment activities. When a person is hired, we will form a new employee record to our HR system of which service provider is Sage People Limited.