This Privacy Notice aims to inform you about the purposes for which your personal data is processed in the context of visiting the Gazprom EP International website; the legal grounds for such processing; what types of personal data are processed; and how you can exercise your rights in relation to your personal data.
Gazprom EP International respects your privacy and is committed to handling your personal data in a transparent, secure and lawful manner.
This Privacy Notice may be updated from time to time to reflect changes in the way we process personal data, or to further clarify information we have provided herein. The latest version of the Privacy Notice will be available though our website.
Who is responsible for my personal data?
Gazprom EP International B.V., Museumplein 9, (1071 DJ) Amsterdam, the Netherlands, (“Gazprom EP International”, "we" or "us") is the responsible party ("Data Controller") for the processing of the personal data within the scope of this Privacy Notice. In this capacity, we feel obligated to respond to your questions and requests (if any) in relation to the personal data we obtain about you.
What personal data do we process and for what purpose?
We may process your personal data when you contact one of our Gazprom EP International offices, our public relations team or contact us in the course of responding to one of our career opportunities. This may include, among others, personal contact details, your résumé (curriculum vitae), information to verify your identity, data related to your professional background, education and qualifications and any other information you might voluntarily provide us.
Lawful grounds of processing your personal data
In order to respond soundly to any general information request and more specifically in order to manage job applications, it may be necessary and in our legitimate interest to process your personal data. We may also process your personal data to comply with legal or regulatory obligations, for example, to verify your identity during the job application process.
Your rights in relation to your personal data
The EU General Data Protection Regulation ("GDPR") provides individuals with a number of "data subject rights", which empower them to get more control over their personal data. You may exercise the following rights with respect to your personal data held by us:
Data Subject Right
Right to access
You may access your personal data by requesting information about your personal data held by us. You have the right to obtain a copy of your personal data undergoing processing free of charge. For further copies requested by you, we may charge a reasonable fee based on administrative costs.
Right to rectification
You may request rectification of inaccurate and/or incomplete records of your personal information held by us.
Right to erasure
You may request the erasure of your personal data held by us, in the case that this personal data is no longer needed for the purposes of processing. In some circumstances it may not be possible for us to accept a request to erasure. For example, when the processing of the personal data is required in order for us to comply with a legal obligation.
Right to restriction
You may request to restrict or stop the processing of your personal data held by us for a certain period of time, or for an indefinite period. In some circumstances it may not be possible for us to accept a request to erasure. For example, when the processing of the personal data is required in order for us to comply with a legal obligation.
Right to withdraw consent
Where we obtain your consent for the processing of personal data, you have the right to withdraw such consent. The withdrawal of consent does not affect the lawfulness of processing based on consent before its withdrawal.
Right to object
On grounds relating to your particular situation you may object to the processing of your personal data, if and insofar our processing is based on the statutory 'legitimate interest' processing ground. Exercising this right will not incur any costs. A right to object may not exist, in particular, if the processing of your personal data is necessary to take steps prior to entering into a contract or to perform a contract already concluded. Furthermore a right to object can be overridden by compelling legitimate grounds for the processing by us which prevail over the user’s interests, rights and freedoms.
You can exercise your data subject rights by contacting us using the contact details at the end of this Privacy Notice. We will investigate any request and respond to it within 30 days. The period may be extended for another 60 days if necessary, to help us respond properly. This could, for example, be the case for large and complex requests. In any case we will inform you of the reasons for the extension.
If we decide not to honor your request, we will inform you of the reasons for not taking action. In case of complaints you also have the right to lodge a complaint with the competent data protection supervisory authority, in particular in the Member State of your habitual residence, place of work or place of the alleged infringement, if you consider that our processing of your personal data infringes the GDPR.
Who has access to my personal data?
Your personal data will only be accessed by authorized individuals on a need to know basis, for example managers, HR employees or other authorized third-parties. Where necessary, your personal data may also be shared with other Gazprom Group companies, including global, regional and divisional Human Resources and finance functions. This can be relevant for the assessment of your candidacy for a job vacancy or to address enquiries you sent us.
Disclosure to third parties for the purposes described in this Privacy Notice might include:
Third party service providers, such as HR management systems providers, recruitment/hiring consultants and legal consultants;
Business partners; and
Government agencies as required by applicable law, such as the Tax Authority and Immigration Authority.
Some of the recipients referred to above might be located or have relevant operations outside the European Economic Area ("EEA"), such as Gazprom Group companies in the Russian Federation, where data protection laws may differ from European law. We will take all necessary measures to ensure that transfers out of the EEA are adequately protected as required by applicable data protection law. With respect to transfers to countries not providing an adequate level of data protection, we will base the transfer on appropriate safeguards, such as standard data protection clauses adopted by the European Commission or by a supervisory authority, approved codes of conduct together with binding and enforceable commitments of the recipient, or approved certification mechanisms together with binding and enforceable commitments of the recipient. You can ask for a copy of such appropriate safeguards by contacting us. Our contact details are included at the end of this Privacy Notice.
How we will keep your personal data secure
We have put in place appropriate security measures to prevent your personal data from being accidentally lost or used, accessed, altered or disclosed in an unauthorized way. In addition, we limit access to personal data by our employees, business partners and third party service providers to a need to know basis. They will use your personal data on our terms and are required to keep your personal data confidential. We also put in place procedures to deal with suspected data security incidents and will notify you of personal data incidents in accordance with relevant legal requirements.
How long we will keep your personal data
Your personal data will be processed strictly to the extent necessary for the performance of our legal/regulatory obligations and strictly to the extent necessary to achieve the purposes for which the information is collected, in accordance with applicable data protection laws. When we no longer need to use your personal data, we will remove it from our systems and records and/or take steps to properly anonymize it so that you can no longer be identified from it (unless we must your information to comply with legal or regulatory obligations to which we are subject). In principle, we will delete your personal data 4 weeks after a negative hiring decision by us or after you reject an employment offer we make to you. We may retain your personal data longer, for up to 1 year, if you consent thereto in order to be considered for other positions at Gazprom EP International.
If you accept an offer from us, your personal data will be retained for the duration of your employment.
We may be required to retain your personal data longer to manage, exercise or defend against legal claims that are not yet barred by the applicable statute of limitations. If a judicial or disciplinary action is initiated, anticipated or not yet barred by the applicable statute of limitations, your personal data may be stored until the end of such (potential) action, including any potential periods for appeal, and will then be deleted or archived as permitted by applicable law.
Links to other websites
Our website may contain links to other Gazprom or third-party websites, which may have privacy notices that differ from ours. We are not responsible for the collection, processing or disclosure of information collected through other websites.
We are also not responsible for any information or content contained on such websites. Links to other websites are provided solely for convenience. Your usage and browsing on any such websites is subject to that website’s own policies. Please review the privacy notices posted on other websites that you may access through our website.
Any requests and/or questions concerning this Privacy Notice and the processing of your personal data can be addressed to our Amsterdam office. Gazprom EP International B.V. Museumplein 9 1071 DJ Amsterdam The Netherlands Phone: +31 2030 50 980 Email: personaldata@gazprom–international.com
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