Privacy Notice
1. Contact information for privacy cases
RubyGarage handle your personal data in accordance with current data protection legislation (including GDPR, E-Privacy directive and other relevant regulations such as national laws and regulations)
This Privacy Notice explains which categories of personal data we collect and process, why they are processed, and which rights you do have. You also receive information about your data privacy rights on [email protected]
If you have any questions regarding your personal data, feel free to contact us via [email protected]
2. Sources of your personal data
RubyGarage may collect and process information that:
- you personally provided to us by email or through messengers to our representatives,
- we generate internally during performance of a contract between you and RubyGarage,
- you provide during interaction with our web sites, through cookies and web forms,
- we obtain from third parties, integrated services or recruitment agencies,
- we obtain from open sources, social media sources, public web sites or press releases.
- RubyGarage will not process your personal data if such is prohibited by data protection laws or regulations.
3. Purposes of processing
RubyGarage processes your personal data linked to particular purposes and corresponding legal bases outlined below:
- purposes to which you agree in a consent form;
- for the fulfilment of the contract as further specified in our contracts with employees, clients and consultants;
- in order to comply with legal obligations specified in a particular law or regulation;
- legitimate interests pursued by RubyGarage, except where such interests are overridden by your interests or fundamental rights and freedoms.
- In case RubyGarage is planning to change the purpose of processing to such that is incompatible with the original one, we will contact you to provide you with further information on purposes for processing prior to it taking place, at all times ensuring appropriate legal basis for processing, which may include asking for your additional consent.
4. Recipients of personal data
RubyGarage in this policy means DigitalRockets OU (Republic of Estonia), which is legal entity and owner of trademark "RubyGarage".
Our full contact details are as follows:
- Full name of company: DigitalRockets OU d/b/a RubyGarage
- Email address: [email protected]
- Physical address: Harju maakond, Tallinn, Lasnamäe linnaosa, Paepargi tn 47-9, 11417
All your personal data will be kept strictly confidential and will not be disclosed to unauthorized third parties or made public without your prior notification by this notice or in person. RubyGarage will not transfer your personal data internationally without reasonably ensuring that the rights and freedoms of you as the data subject are protected.
We never sell your data or share it with other third parties in order to obtain financial gains.
5. RubyGarage stores your personal data
The data collected by RubyGarage is stored within the information in the cloud systems operated by well-known providers. After receiving personal data from you, a third party or a public source, RubyGarage will use all reasonable procedures and security measures to avoid unauthorised access, loss, disclosure or amendment of the personal data.
6. Storage period
We store your personal data for a limited period of time, which varies depending on type of data, the purposes of processing, legal requirements and duration of contractual relationship with RubyGarage.
To obtain information about the storage period of your personal data, please contact us via [email protected]
7. Your rights
As a data subject you have the following rights:
right to obtain information in relation to your personal data - You have a right of access that gives you the possibility to obtain a copy of your personal data, as well as other supplementary information.
right to access your personal data - You have a right of access that gives you the possibility to obtain a copy of your personal data, as well as other supplementary information
right to data portability -
you have a right to receive the personal data concerning you, which has provided to RubyGarage, in a structured, commonly used and machine-readable format and have the right to transmit those data to another controller without hindrance from the controller to which the personal data have been provided, where:
-
he processing is based on your consent or explicit consent; and
-
the processing is carried out by automated means.
- he processing is based on your consent or explicit consent; and
- the processing is carried out by automated means.
right to withdraw the consent -
You have the right to withdraw your consent via google-form.
right to correct mistakes in your personal data – You have the right to obtain from RubyGarage without undue delay the rectification of inaccurate personal data concerning you Taking into account the purposes of the processing, you have the right to have incomplete personal data completed, including by means of providing a supplementary statement.
right to stop the unwarranted processing -
You can request to limit the use of your personal data if:
-
If the data about you is inaccurate;
-
If the processing is unlawful, but you do not want the data to be erased and requests restriction (which is different from the right to be erased);
-
we no longer needs data, but you want the data to be preserved so the legal claim can be exercised;
right to be forgotten (erase your personal data) -
You have the right to obtain from RubyGarage the erasure of personal data concerning you without undue delay where one of the following grounds applies:
-
the personal data are no longer necessary in relation to the purposes for which they were collected or otherwise processed;
-
you withdraw your consent and where there is no other legal ground for the processing;
-
you object to the processing and there are no overriding legitimate grounds for the processing, or if you object to the processing in case of direct marketing;
right to be aware of the existence of the automated individual decision-making and to object in this regard – You have the right not to be subject to a decision based solely on automated processing, including profiling, which produces legal effects concerning him or her or similarly significantly affects you.;
right to lodge a complaint to a supervisory authority - Without prejudice to any other administrative or judicial remedy, you have the right to lodge a complaint with a supervisory authority, in the Member State of your habitual residence, place of work or place of the alleged infringement if the data subject considers that the processing of personal data relating to your infringes this Regulation. You can also submit a complaint to The Estonian Data Protection Inspectorate (Andmekaitse Inspektsioon) at the place of the company’s main representative office in the EU:
Data Protection Inspectorate
Tatari 39, Tallinn 10134
+372 627 4135
8. How do we process your personal data
Employees and specialists
Sources of your personal data
RubyGarage collects and process the information originated as follows:
- Information that you personally provide, e.g. by filling in questionnaires or during the communication with HR department specialists, information entered into IT systems to which you have been granted access with corporate emails.
- Information that you store at company-owned equipment provided to you;
- Data provided by third parties, e.g., information collected and provided to us by third parties for execution of a contract and maintenance of contractual relationship between you and RubyGarage. This data may include feedback from clients that have experience of working with you, background check results, compliance check results, whistle-blower reports or feedback from RubyGarage client representatives;
- Data generated internally, e.g.,your login in the systems, logs of performed actions in the internal systems, corporate structure data, collaboration history, data obtained from your team leads, other employees or specialists.
Types of information
RubyGarage collects and processes the following types of information:
For the purpose of maintenance of employment records:
Personal data
Legal basis
Purpose of processing
Storage period
Source
Categories of recipients
Personal data
Legal basis
Purpose of processing
Storage period
Source
Categories of recipients
First name, last name, patronymic (if applicable), tax number, registration address, personal e-mail, phone number, contact messenger details, position, performance level (seniority), bank account details, department
1) Contract
2) Legal obligation
2) Legal obligation
1) Identification of an employee for the purpose of establishing employment relations and fulfilling payment obligations
2) Fulfillment of obligations established by law, including tax control
2) Fulfillment of obligations established by law, including tax control
No longer than 1 year after the end of the employment relationship
Data subject
Company, cloud storage systems operated by well-known providers;
Local authorities in case of legal obligation;
HRM systems
Local authorities in case of legal obligation;
HRM systems
Personal data
Legal basis
Purpose of processing
Storage period
Source
Categories of recipients
Passport scan, tax number scan, bank account details
Legal obligation
Fulfillment of obligations established by law, including tax control
No longer than 1 year after the end of the employment relationship
Data subject
Company, cloud storage systems operated by well-known providers;
Local authorities in case of legal obligation;
HRM systems operated by well-known providers
Local authorities in case of legal obligation;
HRM systems operated by well-known providers
Personal data
Legal basis
Purpose of processing
Storage period
Source
Categories of recipients
Date of birth
Legitimate interest
Organization for the birthday congratulations.
During employment
Data subject
Company, cloud storage systems operated by well-known providers;
HRM systems operated by well-known providers
HRM systems operated by well-known providers
Personal data
Legal basis
Purpose of processing
Storage period
Source
Categories of recipients
link to social profiles
Legitimate interest
Verification of compliance with non-compete obligations after dismissal
No longer than 1 year after the end of the employment relationship
Data subject
Company, cloud storage systems operated by well-known providers;
HRM systems operated by well-known providers
HRM systems operated by well-known providers
Personal data
Legal basis
Purpose of processing
Storage period
Source
Categories of recipients
Education, diplomas, certificates, employment history, work experience, CV, references, contracts and amendments to the contracts, start date, end of probation date
Legitimate interest
Employee’s skill set verification
During employment
Data subject
Company, cloud storage systems operated by well-known providers;
HRM systems operated by well-known providers
HRM systems operated by well-known providers
Personal data
Legal basis
Purpose of processing
Storage period
Source
Categories of recipients
job satisfaction surveys, reasons for termination of the employment
Legitimate interest
Improving the process of interaction with human resources in the company
During employment
Data subject, HR department
Company, cloud storage systems operated by well-known providers;
HRM systems operated by well-known providers
HRM systems operated by well-known providers
Personal data
Legal basis
Purpose of processing
Storage period
Source
Categories of recipients
Emergency contacts of the employee (name and telephone of a relative)
Legitimate interest
Communication in emergencies: In the event of a natural disaster, fire, or other emergency that affects the workplace, companies need a way to reach employees' emergency contacts to inform them of the situation and ensure their safety.
Medical emergencies: If an employee becomes seriously ill or incapacitated while at work, the emergency contact information can help medical professionals get in touch with someone who can provide important medical history or consent for treatment, especially if the employee is unable to communicate.
Contacting employees after hours: In cases such as schedule changes, having an emergency contact can facilitate communication with an employee when they are not at work.
Family emergencies: Sometimes, employees may need to be reached in the event of a family emergency or personal crisis, and having their emergency contact information allows the company to provide support or time off as needed.
Medical emergencies: If an employee becomes seriously ill or incapacitated while at work, the emergency contact information can help medical professionals get in touch with someone who can provide important medical history or consent for treatment, especially if the employee is unable to communicate.
Contacting employees after hours: In cases such as schedule changes, having an emergency contact can facilitate communication with an employee when they are not at work.
Family emergencies: Sometimes, employees may need to be reached in the event of a family emergency or personal crisis, and having their emergency contact information allows the company to provide support or time off as needed.
During employment
Data subject
Company, cloud storage systems operated by well-known providers;
HRM systems operated by well-known providers
HRM systems operated by well-known providers
Personal data
Legal basis
Purpose of processing
Storage period
Source
Categories of recipients
Sick-leave information, for example medical report (May contain diagnosis, treatment terms, test results)
Legal obligation
Processing is necessary for the purposes of carrying out the obligations and exercising specific rights of the controller or of the data subject in the field of employment and social security and social protection law in so far as it is authorized by law
Processing is necessary for the purposes of carrying out the obligations and exercising specific rights of the controller or of the data subject in the field of employment and social security and social protection law in so far as it is authorized by law
Maintain accurate records of employee absences, especially for payroll, HR, and legal purposes. Sick leave and medical reports serve as documentation to support the legitimacy of the leave and to track attendance.
Compliance with labor laws: Depending on local labor laws, company has legal obligations to request medical documentation for extended or frequent sick leave. This helps ensure compliance with statutory requirements and protects both the employee and the employer.
Compliance with labor laws: Depending on local labor laws, company has legal obligations to request medical documentation for extended or frequent sick leave. This helps ensure compliance with statutory requirements and protects both the employee and the employer.
During employment
Data subject
Company, cloud storage systems operated by well-known providers;
HRM systems operated by well-known providers
HRM systems operated by well-known providers
For the purpose of maintenance of records for individual contractors/entrepreneurs:
Personal data
Legal basis
Purpose of processing
Storage period
Source
Categories of recipients
Personal data
Legal basis
Purpose of processing
Storage period
Source
Categories of recipients
First name, last name, patronymic (if applicable), tax number, registration address, personal e-mail, phone number, contact messenger details, position, performance level (seniority), bank account details, department
1) Contract
2) Legal obligation
2) Legal obligation
Identification of a contractor for the purpose of establishing contractual relations and fulfilling payment obligations
Fulfillment of obligations established by law, including KYC and AML
Fulfillment of obligations established by law, including KYC and AML
No longer than 2 years after the end of the contractual relationship
Data subject
Company, cloud storage systems operated by well-known providers;
Local authorities in case of legal obligation;
HRM systems
Local authorities in case of legal obligation;
HRM systems
Personal data
Legal basis
Purpose of processing
Storage period
Source
Categories of recipients
Passport scan, tax number scan, bank account details, individual entrepreneur documents scan
Legal obligation
Fulfillment of obligations established by law, including tax control
No longer than 2 years after the end of the contractual relationship
Data subject
Company, cloud storage systems operated by well-known providers;
Local authorities in case of legal obligation;
HRM systems operated by well-known providers
Local authorities in case of legal obligation;
HRM systems operated by well-known providers
Personal data
Legal basis
Purpose of processing
Storage period
Source
Categories of recipients
Date of birth
Legitimate interest
Organization for the birthday congratulations.
During contractual relationship
Data subject
Company, cloud storage systems operated by well-known providers;
HRM systems operated by well-known providers
HRM systems operated by well-known providers
Personal data
Legal basis
Purpose of processing
Storage period
Source
Categories of recipients
link to social profiles
Legitimate interest
Verification of compliance with non-compete obligations after dismissal
No longer than 1 year after the end of the contractual relationship
Data subject
Company, cloud storage systems operated by well-known providers;
HRM systems operated by well-known providers
HRM systems operated by well-known providers
Personal data
Legal basis
Purpose of processing
Storage period
Source
Categories of recipients
Education, diplomas, certificates, employment history, work experience, CV, references, contracts and amendments to the contracts, start date, end of probation date
Legitimate interest
Contractor’s skill set verification
During contractual relationship
Data subject
Company, cloud storage systems operated by well-known providers;
HRM systems operated by well-known providers
HRM systems operated by well-known providers
Personal data
Legal basis
Purpose of processing
Storage period
Source
Categories of recipients
Emergency contacts of the contractor (name and telephone of a relative)
Legitimate interest
Medical emergencies: If an employee becomes seriously ill or incapacitated, the emergency contact information can help medical professionals get in touch with someone who can provide important medical history or consent for treatment, especially if the contractor is unable to communicate.
Contacting contractors in case of non-communication: In cases such as schedule changes, having an emergency contact can facilitate communication with a contractor when they are not available.
Family emergencies: Sometimes, contractors may need to be reached in the event of a family emergency or personal crisis, and having their emergency contact information allows the company to provide support or time off as needed.
Contacting contractors in case of non-communication: In cases such as schedule changes, having an emergency contact can facilitate communication with a contractor when they are not available.
Family emergencies: Sometimes, contractors may need to be reached in the event of a family emergency or personal crisis, and having their emergency contact information allows the company to provide support or time off as needed.
During contractual relationship
Data subject
Company, cloud storage systems operated by well-known providers;
HRM systems operated by well-known providers
HRM systems operated by well-known providers
Personal data
Legal basis
Purpose of processing
Storage period
Source
Categories of recipients
Sick-leave information, for example medical report (May contain diagnosis, treatment terms, test results)
Explicit consent
Sick Leave bonus payment
No longer than 1 month after the payment
Data subject
Company, cloud storage systems operated by well-known providers;
HRM systems operated by well-known providers
HRM systems operated by well-known providers
For the purpose of maintenance of records for recruitment process:
Personal data
Legal basis
Purpose of processing
Storage period
Source
Categories of recipients
Personal data
Legal basis
Purpose of processing
Storage period
Source
Categories of recipients
First name, last name, patronymic (if applicable), tax number, registration address, personal e-mail, phone number, contact messenger details, position, performance level (seniority)
1) Contract
2) Legitimate interest
2) Legitimate interest
1) Identification of a candidate for the purpose of validation, communication
2) Identification of a candidate for the purpose of background check
2) Identification of a candidate for the purpose of background check
No longer than 2 years after the end of last communication with company
Data subject
Company, cloud storage systems operated by well-known providers;
Personal data
Legal basis
Purpose of processing
Storage period
Source
Categories of recipients
Passport scan, tax number scan, individual entrepreneur documents scan
Contract
Identification of a candidate for the purpose of establishing working/contractual relations
During contract conclusion/hiring process.
Data subject
Company, cloud storage systems operated by well-known providers;
Local authorities in case of legal obligation;
HRM systems operated by well-known providers
Local authorities in case of legal obligation;
HRM systems operated by well-known providers
Personal data
Legal basis
Purpose of processing
Storage period
Source
Categories of recipients
link to social profiles
Legitimate interest
Identification of a candidate for the purpose of validation, communication, to provide additional offers about open vacancies that may be interesting for you
No longer than 2 years after the end of last communication with company
Data subject
Company, cloud storage systems operated by well-known providers;
HRM systems operated by well-known providers
HRM systems operated by well-known providers
Personal data
Legal basis
Purpose of processing
Storage period
Source
Categories of recipients
Education, diplomas, certificates, employment history, work experience, CV, references, contracts and amendments to the contracts, start date, end of probation date
Legitimate interest
Candidate skill set verification
During contract conclusion/hiring process.
Data subject
Company, cloud storage systems operated by well-known providers;
HRM systems operated by well-known providers
HRM systems operated by well-known providers
Personal data
Legal basis
Purpose of processing
Storage period
Source
Categories of recipients
Data from the criminal records register, data from the register of court cases, data of seizure of property and claims by authorities
Legitimate interest
Identification of a candidate for the purpose of background check. This information is very important from the point of view of establishing the candidate’s business reputation and his ability to provide services to the company
During contract conclusion/hiring process.
Official authorities information
Company, cloud storage systems operated by well-known providers
Personal data
Legal basis
Purpose of processing
Storage period
Source
Categories of recipients
English level test results
Legitimate interest
Candidate skill set verification
During contract conclusion/hiring process.
English level validator (tutor)
Company, cloud storage systems operated by well-known providers
Recipients
Like exception your personal data can be wholly or partially disclosed to the following third parties:
- client, whom you are providing services too, for performance of a contract;
- external tutors;
- external providers of benefits;
- external auditors;
- attorneys and legal councils;
- banks and other financial service providers for transfer of remuneration for your services;
- governmental entities where required by law or mandatory order;
- security operation centres and other service providers;
Web-Site Visitors
Types of information
RubyGarage collects and processes the following types of information:
Personal data
Legal basis
Purpose of processing
Storage period
Source
Categories of recipients
Personal data
Legal basis
Purpose of processing
Storage period
Source
Categories of recipients
Name e-mail, phone number (optional)
Consent
Start of possible provision of business services
No longer than 2 years after the end of last communication with company
Data subject
Company, cloud storage systems operated by well-known providers;
СRM systems operated by well-known providers
СRM systems operated by well-known providers
Personal data
Legal basis
Purpose of processing
Storage period
Source
Categories of recipients
Name e-mail, phone number (optional)
Consent
Subscription to company news and promotional offers
Until consent is withdrawn
Data subject
Company, cloud storage systems operated by well-known providers;
СRM systems operated by well-known providers
СRM systems operated by well-known providers
Personal data
Legal basis
Purpose of processing
Storage period
Source
Categories of recipients
Browser information about visit
Legitimate interest
To improve the quality of company services and visit analytics
For the lifetime of the cookie
Data subject
Company, cloud storage systems operated by well-known providers;
Personal data
Legal basis
Purpose of processing
Storage period
Source
Categories of recipients
IP address in case of leaving a request for communication with a company representative
Legal obligation
To determine the country of a potential client in order to exclude business interactions with customers from countries subject to international sanctions regime
For the lifetime of the cookie
Data subject
Company, cloud storage systems operated by well-known providers;
During visiting our web-site RubyGarage may collect information directly entered by you in contact us forms or through cookies, beacons and other trackers. In this case, RubyGarage may process your personal data which include your IP, location, visited web pages on our web-site, and, if you filled your name, email, phone and country and information in text of the message.
Recipients
Your personal data may be wholly or partially disclosed to the following third parties:
email service provider if the data is transferred to us via email or “get in touch” form;
service providers supplying and servicing our internal system for customer relation management;
Representatives of Potential Clients
Types of information
RubyGarage collects and processes the following types of information:
Personal data
Legal basis
Purpose of processing
Storage period
Source
Categories of recipients
Personal data
Legal basis
Purpose of processing
Storage period
Source
Categories of recipients
First name, last name, patronymic (if applicable), e-mail, phone number, contact messenger details, position
Contract
Identification of a potential client representative for communication
No longer than 2 years after the end of last communication with company
Data subject
Company, cloud storage systems operated by well-known providers;
СRM systems operated by well-known providers
СRM systems operated by well-known providers
Personal data
Legal basis
Purpose of processing
Storage period
Source
Categories of recipients
First name, last name, patronymic (if applicable), e-mail, phone number, contact messenger details, position
Contract
Entering personal data into draft agreements to regulate business relations
No longer than 2 years after the end of last communication with company
Data subject
Company, cloud storage systems operated by well-known providers;
СRM systems operated by well-known providers
СRM systems operated by well-known providers
Personal data
Legal basis
Purpose of processing
Storage period
Source
Categories of recipients
e-mail or messenger correspondence
Consent
Possibility of clarifying the details of negotiations to correctly offer the best service
No longer than 2 years after the end of last communication with company
Data subject
Company, cloud storage systems operated by well-known providers;
СRM systems operated by well-known providers
СRM systems operated by well-known providers
Representatives of Current or Former Clients
Types of information
RubyGarage collects and processes the following types of information:
Personal data
Legal basis
Purpose of processing
Storage period
Source
Categories of recipients
Personal data
Legal basis
Purpose of processing
Storage period
Source
Categories of recipients
First name, last name, patronymic (if applicable), e-mail, phone number, contact messenger details, position
Contract
Identification of a potential client representative for communication
No longer than 2 years after the end of last communication with company
Data subject
Company, cloud storage systems operated by well-known providers;
СRM systems operated by well-known providers
СRM systems operated by well-known providers
Personal data
Legal basis
Purpose of processing
Storage period
Source
Categories of recipients
First name, last name, patronymic (if applicable), e-mail, phone number, contact messenger details, position
1) Contract
2) Legal obligation
2) Legal obligation
1) Personal data of the client’s representative is stored in contracts concluded with the company in order to verify at any time the powers of the representative and the procedure for fulfilling the contract
2) Fulfillment of the Company’s obligations to the authorities, during which the Company is obliged to transfer concluded contracts to government authorities
2) Fulfillment of the Company’s obligations to the authorities, during which the Company is obliged to transfer concluded contracts to government authorities
No longer than 5 years after the agreement expiration
Data subject
Company, cloud storage systems operated by well-known providers;
СRM systems operated by well-known providers
СRM systems operated by well-known providers
Personal data
Legal basis
Purpose of processing
Storage period
Source
Categories of recipients
e-mail or messenger correspondence
Consent
Possibility of clarifying the details of negotiations to ensure the correct provision of services under agreement
No longer than 5 years after the end of last communication with company
Data subject
Company, cloud storage systems operated by well-known providers;
СRM systems operated by well-known providers
СRM systems operated by well-known providers
Representatives of Vendors and Service Providers
Types of information
RubyGarage collects and processes the following types of information:
Personal data
Legal basis
Purpose of processing
Storage period
Source
Categories of recipients
Personal data
Legal basis
Purpose of processing
Storage period
Source
Categories of recipients
First name, last name, patronymic (if applicable), e-mail, phone number, contact messenger details, position
1) Contract
2) Legal obligation
2) Legal obligation
Identification of a counterparty representative for communication
No longer than 2 years after the end of last communication with company
Data subject
Company, cloud storage systems operated by well-known providers;
Personal data
Legal basis
Purpose of processing
Storage period
Source
Categories of recipients
First name, last name, patronymic (if applicable), e-mail, phone number, contact messenger details, position
1) Contract
2) Legal obligation
2) Legal obligation
1) Personal data of the client’s representative is stored in contracts concluded with the company in order to verify at any time the powers of the representative and the procedure for fulfilling the contract
2) Fulfillment of the Company’s obligations to the authorities, during which the Company is obliged to transfer concluded contracts to government authorities
2) Fulfillment of the Company’s obligations to the authorities, during which the Company is obliged to transfer concluded contracts to government authorities
No longer than 5 years after the agreement expiration
Data subject
Company, cloud storage systems operated by well-known providers;
Personal data
Legal basis
Purpose of processing
Storage period
Source
Categories of recipients
e-mail or messenger correspondence
Consent
Possibility of clarifying the details of negotiations to ensure the correct provision of services under agreement
No longer than 5 years after the end of last communication with company
Data subject
Company, cloud storage systems operated by well-known providers;
In any cases we are not working with data of individuals under the age of 18
If you have any questions regarding your personal data, feel free to contact us via [email protected]
Ver. 2.0 Updated on: February 15, 2024