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Recruitment Privacy Policy
1. Introduction
Lodgify is serious about protecting the privacy of candidates. Therefore, Lodgify applies the General Data Protection Regulation (GDPR) (EU) 2016/679 to ensure that their privacy is protected.
Should Lodgify ask you (the candidate) to provide certain information by which you can be identified when using this website, be assured that it will only be used in accordance with this privacy statement.
Please, read the following carefully to understand our views and practices regarding personal data and how we process it.
2. Name and Address of the Controller
The Data Controller is:
- CODEBAY SOLUTIONS, S.L.U. (also referred as “Lodgify”)
- CIF: B-65815037
- Address: Av. Josep Tarradellas 20, Barcelona 08015, Spain
- E-mail: privacy@lodgify.com
- Registration details: listed in the Barcelona Business Registry (Registro Mercantil de Barcelona), under Tomo: 43217, Folio: 56, Hoja: 427456, Incripcion: 1, B-B65815037.
3. Data collected through the website https://lodgify.workable.com/jobs:
Lodgify may collect and process the following data:
- First and last name, e-mail, phone, photo, education, work experience, data regarding qualifications and career development, resume (any information contained in the CV), application details (cover letters, portfolio links or attachments provided by the candidates).
- Any other information that each candidate decides to voluntarily share with Lodgify, such as feedbacks, opinions, information provided in emails and letters, during telephone calls and conversations, etc.
- When candidates use or visit Lodgify’s recruitment website, Lodgify may automatically collect technical information, including the Internet Protocol (IP) address used to connect candidates’ computers to the Internet, login information, browser type and version, time zone setting, browser plug-in types and versions, operating system and platform, the full Uniform Resource Locators (URL) clickstream to, through and from our site (including date and time), page response times, download errors, length of visits to certain pages, page interaction information (such as scrolling, clicks, and mouse-overs), and methods used to browse away from the page.
- Lodgify is also working closely with third parties (including, for example, business partners, sub-contractors in technical, payment and delivery services, advertising networks, social networks, e.g. LinkedIn, analytics providers) and may receive information about candidates from them.
- Lodgify does not use information concerning religion, ethnicity, sexual orientation, age, nationality, gender, or political opinions when assessing candidates for employment. However, candidates may voluntarily disclose gender identity information through a dedicated diversity question for equality monitoring and legal reporting purposes, as described in Section 4.
4. Purposes of the processing
Lodgify will process candidates’ personal information for recruitment and hiring purposes. The aforementioned recruitment and hiring purposes include the following:
- Identifying and evaluating candidates;
- Communicating with candidates by phone or email in order to set up interviews and assessments, as well as for communicating the results of the recruitment processes;
- Conducting background checks and assessments as required or permitted by applicable law;
- Contacting third party references provided by candidates in order to evaluate candidates’ previous performances;
- Retaining candidates’ details and notify them about future job opportunities other than the specific role for which they have contacted Lodgify.
As a company with 50 or more employees operating in Spain, Lodgify is legally required to produce a diagnostic of gender representation across its recruitment process, as part of its plan de igualdad obligation under Ley Orgánica 3/2007 and Real Decreto 901/2020. To meet this obligation without compelling any individual disclosure, Lodgify invites candidates to voluntarily self-identify their gender via a dedicated question. No candidate is required to answer, and declining has no bearing on the recruitment process.
To fulfil this requirement, Lodgify invites candidates to voluntarily disclose their gender identity. Responses are used exclusively for aggregated statistical reporting and are kept strictly confidential and separate from individual application files. They are not accessible to hiring managers and will not influence any hiring decision. The response options are: Female, Male, Non-binary, Other, and Prefer not to disclose.
Lodgify will not use candidates’ personal data for profiling purposes and will not take any automated decision based on it.
Failure to provide information that is necessary to assess an application may affect Lodgify's ability to consider the candidate for the relevant position. This does not apply to voluntary diversity information described above.
5. Data Storage
The data shall only be stored for each purpose of the processing and without prejudice to the legal storage obligations provided for by the law. Likewise, data will be kept according to the legal time-frame set forth in legal, fiscal and accounting matters.
Candidates may request earlier deletion of their data at any time by contacting privacy@lodgify.com, subject to Lodgify's legitimate need to retain certain data for legal, fiscal, or accounting obligations.
6. Legal basis for the processing
Lodgify processes candidates' personal data on the following legal bases:
- Article 6(1)(b) GDPR (necessary for steps prior to entering into a contract, taken at the candidate's request) for the core recruitment data described in Section 3 (identification, CV, application materials, communications related to the recruitment process).
- Article 6(1)(a) GDPR (consent) only where Lodgify processes data on a purely voluntary basis, such as optional fields the candidate chooses to complete.
- Article 6(1)(c) and Article 9(2)(b) GDPR (legal obligation, in conjunction with employment law) for Lodgify's collection and aggregate reporting of gender representation data, as required by Ley Orgánica 3/2007 and Real Decreto 901/2020. Each individual candidate's decision to answer the Candidate Diversity Information question described in Section 4 remains entirely voluntary; declining to answer has no effect on the recruitment process, and Article 9(2)(b) does not require individual consent for Lodgify to rely on this basis for the resulting aggregate processing.
7. Data disclosure
Candidates’ personal data may be disclosed to third parties which are companies that provide services to Lodgify. These third parties are:
- Codebay Solutions Ltd., the parent company
- Analytics providers that assist Lodgify in the improvement and optimization of Lodgify.com.
- Lever Software Limited. Lodgify uses Lever, an online application provided by Lever Software Limited, to assist with the recruitment process. Lodgify uses Lever to process personal information as a data processor on Lodgify behalf. Lever is only entitled to process candidates’ personal data in accordance with Lodgify ‘s instructions.
The data collected from candidates and processed using Lever’s Services may be transferred to, and stored at, a destination outside the European Economic Area ("EEA"). It may also be processed by staff operating outside the EEA who work for Lodgify or for one of our partners or services providers. By submitting personal data, candidates agree to this transfer, storing or processing. Lodgify will take all steps reasonable necessary to ensure that candidates’ data are treated securely.
Lodgify also may disclose personal data of candidates as required by law, or when we believe in good faith that disclosure is necessary to protect our rights, protect the safety of candidates or the safety of others, investigate fraud, or respond to a government request.
8. Rights of the Data Subject
Each candidate (data subject) has the following rights regarding his or her personal data:
a) Right of confirmation: to obtain from the controller the confirmation as to whether or not personal data concerning him or her are being processed. If a data subject wishes to avail himself of this right of confirmation, he or she may at any time contact our data protection manager or another employee of the controller.
b) Right of access: to obtain from the controller free information about his or her personal data stored at any time and a copy of this information.
c) Right to rectification: to obtain from the controller without undue delay the rectification of inaccurate personal data concerning him or her.
d) Right to erasure (Right to be forgotten): to obtain from the controller the erasure of personal data concerning him or her without undue delay and the controller shall have the obligation to erase personal data without undue delay where one of the following grounds applies and as long as the processing is not necessary:
- The personal data are no longer necessary in relation to the purposes for which they were collected or otherwise processed.
- The data subject withdraws consent on which the processing is based according to point (a) of Article 6 (1) of the GDPR, or point (a) of Article 9 (2) of the GDPR, and where there is no other legal ground for the processing.
- The data subject objects to the processing pursuant to Article 21 (1) of the GDPR and there are no overriding legitimate grounds for the processing, or the data subject objects to the processing pursuant to Article 21 (2) of the GDPR.
- The personal data have been unlawfully processed.
- The personal data have to be erased for compliance with a legal obligation in Union or Member State law to which the controller is subject.
- The personal data have been collected in relation to the offer of information society services referred to in Article 8 (1) of the GDPR.
e) Right of restriction of processing: to obtain from the controller restriction of processing where one of the following applies:
- The accuracy of the personal data is contested by the data subject, for a period enabling the Controller to verify the accuracy of the personal data.
- The processing is unlawful and the data subject opposes the erasure of the personal data and requests instead the restriction of their use instead.
- The controller no longer needs the personal data for the purposes of the processing, but they are required by the data subject for the establishment, exercise or defence of legal claims.
- The data subject has objected to processing pursuant to Article 21 (1) of the GDPR pending the verification whether the legitimate grounds of the controller override those of the data subject.
f) Right to data portability: to receive the personal data concerning the candidate, which was provided to a controller, in a structured, commonly used and machine-readable format. The candidate shall have the right to transmit those data to another controller without hindrance from the controller to which the personal data have been provided as long as the processing is based on consent and the processing is carried out by automated means. Furthermore, in exercising his or her right to data portability pursuant to Article 20 (1) of the GDPR, the data subject shall have the right to have the personal data transmitted directly from one controller to another, where technically feasible and does not adversely affect the rights and freedoms of others.
g) Right to object: to object, on grounds relating to the candidate’s particular situation, at any time to processing of personal data concerning the candidate which is based on point (e) or (f) of Article 6 (1) of the GDPR. This also applies to profiling based on these provisions.
i) Right to withdraw data protection consent: to withdraw consent to processing of the candidate personal data at any time.
If the data subject wishes to exercise any of the aforementioned rights, he or she may at any time directly contact Lodgify by sending the appropriated request at the following addresses:
- Spain, Barcelona, street Av. Josep Tarradellas Num. 20, P.5.
- privacy@lodgify.com
Finally, each data subject has the right to lodge a complaint before the appropriate Data Supervisory Authority.
9. Security
We are committed to ensuring that candidates’ information is secure. In order to prevent unauthorised access or disclosure, Lodgify has put in place suitable physical, electronic and managerial procedures to safeguard and secure the information we collect online.
When candidates enter sensitive information on our site, we encrypt the transmission of that information using secure socket layer technology (SSL).
Nevertheless, please note that no data transmission over the Internet or information storage technology can be guaranteed to be totally secure. As a result, whilst we strive to protect our candidates’ information, we cannot ensure or warrant the security of any information which candidates send to us, and candidates do so at their own risk.
10. Links
https://www.lodgify.com/careers/ may contain links to other websites of interest. However, once you have used these links to leave our site, you should note that we do not have any control over that other website. Therefore, Lodgify cannot be responsible for the protection and privacy of any information which you provide whilst visiting such sites and such sites are not governed by this privacy statement. Candidates should exercise caution and look at the privacy statement applicable to the website in question.
11. Cookies
www.lodgify.com uses cookies. Candidates have the option to prevent the generation of cookies, by selecting the corresponding option in their browser program.
For more information, visit Lodgify’s Cookies Policy.
12. Validity and modifications
Lodgify will be able to modify, totally or partially, this Privacy Policy, publishing any change or alteration in the same manner in which these conditions appear or via any type of communication directed to the candidates, as Lodgify chooses.
The temporary validity of this Privacy Policy coincides, therefore, with the time of exposure, until they are totally or partially modified, in which case these latter modified will become the valid ones.