1. Introduction

Fiore and Associates, LLC, including its affiliates (“FAA”), is committed to respecting your privacy and complying with applicable data protection and privacy laws and regulations.

This Recruitment Privacy Policy (“Policy”) informs you about how FAA processes information it collects about you during FAA’s recruitment activities. It sets out what kind of Personal Data FAA may collect about you and from other sources, how FAA processes your Personal Data during its recruitment activities, and what rights you have in relation to such data. “Personal Data” means information relating to you or another identifiable individual.

We may provide you additional privacy information to this Policy via supplements and other notices. If Fiore and Associates, LLC is a difference between such notices and this Policy, the notices should be considered first.

Our products, services and websites may contain links to other companies’ websites and services that have privacy policies of their own. FAA is not responsible for the privacy practices of others and we recommend you read their privacy notices.


2. What Personal Data does Fiore and Associates, LLC collect?

FAA collects Personal Data directly from you as well as from other available sources to the extent relevant and permitted by applicable local law. Subject to applicable local law and practice, the categories of Personal Data that are typically collected and processed in the recruitment context are:

  • Information you provide: When you create an account in our recruitment management system or otherwise interact with FAA (either directly or through an agency or other third party), you may be asked to provide FAA with your information, such as
    • your name, street address, telephone number, email address and other contact details;
    • your competencies, skills, experience and education (ex: your CV or resume, previous employments, educational details and qualifications, third party references)
    • your preferences (ex: preferred location of employment, areas of interest, preferred ways to be contacted by FAA); as well as
    • your user identity (ex: usernames and other such information used in connection with authenticating you).
  • Other information, such as information found from public sources as well as information related to credit or background checks, depending on the position you are applying for, and where necessary for the recruitment activities.


3. What will Fiore and Associates, LLC do with your Personal Data?

FAA will collect, use, store and otherwise process your Personal Data for the purposes of FAA’s recruitment or resourcing activities. Additionally your personal data may be processed for other purposes you have consented to. Whenever necessary and subject to statutory record-keeping requirements, FAA will delete and/or anonymize Personal Data that is no longer needed. If there has not been any recent activity on your profile, we may delete your profile after a reasonable time in compliance with applicable laws.

FAA will process your Personal Data for the following purposes:

Communicating with you, in context of recruitment activities, such as:

  • To obtain additional information where necessary;
  • To inform you of available vacancies;
  • To provide you with information relating to your application and to fulfill your requests.

Managing recruitment and resourcing activities, including activities related to organizational planning. In the course of recruitment activities, we may use your information:

  • To set up and conduct interviews and assessments;
  • To evaluate, select and recruit applicants;
  • To conduct background and credit checks and assessments as required or permitted by applicable local law;
  • To contact third party references provided by you to evaluate your previous performances.
  • Or as otherwise necessary in context of recruitment activities.

Development of services:

  • We may use your Personal Data to develop and improve our recruitment processes, websites and other related services. Where feasible, we use aggregated anonymous information in context of the development activities.

Legal and regulatory compliance, including obtaining and releasing Personal Data as required by law, judicial organizations or practice in order to comply with legal obligations imposed on us.


4. Transfer of your Personal Data

FAA will not sell, lease, rent or otherwise disclose your Personal Data except as provided in this section:

  • Consent: FAA may share your Personal Data if you have given your informed consent for FAA to do so.
  • FAA companies and authorized third parties: FAA may share your Personal Data with other FAA companies or authorized third parties who process Personal Data for FAA for the purposes described in this Policy or otherwise provide recruitment related services to FAA. In such cases FAA will ensure that there is a genuine need to transfer your Personal Data.

Authorized third parties include, for example, professional advisors, external legal counsel, consumer credit reporting agencies, recruiting systems providers, and other third party suppliers.

Authorized third parties may technically have access to your Personal Data in the course of providing their services but will be contractually restricted from processing your Personal Data for other purposes. FAA also requires them to act consistently with this Policy and to use appropriate security measures to protect your Personal Data.

  • Mandatory disclosures: FAA may be required by or under mandatory law to disclose your Personal Data to certain authorities or other third parties, for example, to government agencies responsible for the employment activities, statistical information or to the police or other law enforcement agencies, for example in context of conducting a background check
  • Other:FAA may also disclose and otherwise process your Personal Data in accordance with applicable law to defend FAA’s legitimate interests, for example, in civil or criminal legal proceedings.


5. What steps are taken to safeguard Personal Data?

Privacy and security are key considerations for FAA. We have assigned specific responsibilities to address privacy and security related matters. We enforce our internal policies and guidelines through an appropriate selection of activities, including proactive and reactive risk management, security and privacy engineering, training and assessments. We take appropriate steps to address online security, physical security, risk of data loss and other such risks taking into consideration the risk represented by the processing and the nature of the data being protected. Also, we limit access to our databases containing personal data to authorized persons having a justified need to access such information.


6. Data Quality

We take reasonable steps to keep the personal data we possess accurate and to delete incorrect or unnecessary personal data. We encourage you to access your personal data through your account from time to time to ensure that it is up to date. To the extent permitted or required by applicable local law or subject to your consent, we may use public sources in order to verify that Personal Data we hold is correct.


7. Your Rights

With respect to the processing of your Personal Data, you will always have the rights as provided by applicable local law. In addition, this Policy provides you the right to know what personal data we hold about you; to request incomplete, incorrect, unnecessary or outdated personal data deleted or updated as well as to object to FAA’s processing of your Personal Data on compelling legitimate grounds.

There may be certain categories of information prescribed by applicable local law that FAA may lawfully withhold. If FAA declines to provide access to any of the Personal Data you request, you will be provided with the reasons for such a decision.

You are encouraged to use available FAA recruitment tools to access, view and edit your profile. You may be able to delete the entire profile directly from the available tools or you may be required to request such deletion of your profile by contacting your available recruitment support.

In case you revoke your consent or object to certain processing activities or delete your profile completely, FAA may be unable to continue the recruitment process with you.


8. Who to contact?

Fiore and Associates, LLC is the controller of your Personal Data. If you have any queries about your Personal Data, contact primarily the relevant recruiting personnel through provided contacts or channels. Note that you may access and manage much of your Personal Data online by using the available profile management tools.

If you want to exercise your rights as described in the previous section ‎of this Policy you may make a request in writing through provided contacts or channels.

FAA may need to identify you and to ask for additional information to be able to fulfill your request. FAA will fulfill your request within the timeframes required by applicable local law or, in the absence of such timeframes, within a reasonable time.

You may also contact FAA if you have any queries concerning Privacy matters. Such queries and concerns may be made or reported in writing to the following email address: [email protected].


9. Changes to this Policy

FAA may from time to time change this Policy or change, modify or withdraw access to this site at any time with or without notice. However, if this Policy is changed in a material, adverse way, FAA will post a notice advising of such change at the beginning of this Policy and on this site’s home page for 30 days. We recommend that you re-visit this Policy from time to time to learn of any such changes to this Policy.