1. The relationship between RecMan and the Client
RecMan is a company that provides IT system services to clients. Clients use the IT system services to manage their employees. As the data controllers, clients are responsible for protecting all personal data of registered employees in accordance with any applicable privacy laws.
RecMan provides the IT system for the Client with the data collected via RecMan’s services. RecMan is the company responsible for processing the data. We process the data in accordance with the data processing agreement (DPA) between RecMan and the Client, which regulates the particularities of the data processing. RecMan and the Client work together to ensure the privacy of the registered employees, as RecMan provides the information necessary for the Client to comply with applicable privacy laws.
2. Information we collect
When you access the RecMan servers via RecMan Employee, RecMan may automatically log the standard usage data provided by your device. This data may include your device’s Internet Protocol (IP) address, your device type and version, your activity within the app, time and date, and other details.
Additionally, if you encounter certain errors while using the app, RecMan collects data about the error and the circumstances in which it occurred. This data may include technical details about your device, what you were trying to do when the error happened, and other technical information that may have contributed to the problem.
The RecMan Employee app may also access and collect data via your device's in-built tools, such as:
- Your identity
- Storage, photos and/or media
- Background data refresh
- Mobile data
The data collected by RecMan will depend on the individual settings of your device and the permissions you grant when you install and use the app. You can change these settings at any time.
The app may ask for personal information, such as your:
- Profile picture
- Date of birth
- Phone/mobile number
- Bank account for salary payment
- SSN Number
Business data refers to data that accumulates over time on the RecMan platform. This may include transaction records, stored files, user profiles, analytics data and other metrics, as well as other types of information, created or generated, as users interact with RecMan services.
3. Legal basis for processing
RecMan will process your personal data lawfully, fairly, and in a transparent manner. RecMan and the Client will only collect and process personal data when we have a valid legal basis for doing so.
The legal basis for personal data processing activity depend on the services you use and how you use them. RecMan and the Client collect and use your information when:
- It’s necessary for you to enter into or carry out a contract with the Client (for example, when we provide a service you request from the Client);
- It satisfies a legitimate interest (which is not overridden by your data protection interests), such as for research and development, to market and promote our services, and to protect our legal rights and interests;
- You give RecMan and the Client consent to do so for a specific purpose (for example, you might consent to your employer sending you a newsletter); or,
- We need to process your data to comply with a legal obligation.
Even if you consent to the use of information about you for a specific purpose, you have the right to revoke your consent at any time (but this will not affect any processing that has already taken place).
RecMan and the Client will only store your personal data as long as it is required. While we retain this information, we will protect it within commercially acceptable means to prevent loss and theft, as well as unauthorised access, disclosure, copying, use, or modification. That said, no method of electronic transmission or storage is 100% secure and we cannot guarantee absolute data security. If necessary, we may retain your personal information for our compliance with a legal obligation or to protect your vital interests or the vital interests of another natural person.
4. Collection and use of information
RecMan and the Client may collect, hold, use, and disclose information for the following purposes:
- For technical assessment, including to operate and improve the RecMan Employee app and associated applications;
- To provide you with the RecMan Employee app and platform's core features;
- To enable you to access and use the RecMan Employee app and associated platforms;
- For internal record keeping and administrative purposes; and,
- To comply with any legal obligations, and to resolve any disputes, that RecMan or the Client may have.
Personal information will not be further processed in any manner incompatible with these purposes.
5. Disclosure of personal information to third parties
RecMan and the Client may disclose personal information to:
- Third party service providers for the purpose of enabling them to provide their services, including (without limitation) IT service providers, data storage, hosting and server providers, analytics, error loggers, maintenance or problem-solving providers, marketing providers and professional advisors;
- Our employees, contractors and/or related entities;
- Courts, tribunals, regulatory authorities and law enforcement officers, as required by law, in connection with any actual or prospective legal proceedings, or in order to establish, exercise or defend our legal rights; and,
- Third party services to collect and process data.
Third party services
The app does use third party services that may collect information used to identify you. Please see the following links to privacy policies of third party service providers used by the app:Google Analytics for
6. International transfers of personal information
The personal information we collect is stored and processed in Norway, or where we or our partners, affiliates and third party providers maintain facilities. By providing us with your personal information, you consent to the disclosure to these third parties.
We will ensure that any transfer of personal information from countries in the European Economic Area (EEA) to countries outside the EEA will be protected by appropriate safeguards (for example, by using standard data protection clauses approved by the European Commission, or the use of binding corporate rules or other legally accepted means).
Where we transfer personal information from a non-EEA country to another country, you acknowledge that third parties in other jurisdictions may not be subject to similar data protection laws to the ones in our jurisdiction. There are risks if any such third party engages in any act or practice that would contravene the data privacy laws in our jurisdiction. This could mean that you will not be able to seek redress under our jurisdiction’s privacy laws.
7. Your rights and controlling your personal information
Restrict: You may choose to restrict the collection or use of your personal information. Contact the Client (the data controller) about such restrictions.
Access and data portability: You may request details about the personal information that we retain. You may also request a copy of your personal information. Where possible, we will provide this information in CSV format or other easily-readable machine format. You may request that we erase the personal information we hold about you at any time. You may also request to transfer this personal information to another third party. All these matters of access and data portability must be done via the Client, since it is the data controller.
Correction: If you believe that any information we hold about you is inaccurate, out of date, incomplete, irrelevant, or misleading, please contact the Client, and they will take reasonable steps to correct any information found to be inaccurate, incomplete, misleading or out of date.
Notification of data breaches: We will comply with laws applicable to us in respect of any data breach.
Complaints: If you believe that RecMan have breached a relevant data protection law and wish to make a complaint, please contact us using the details below and provide us with full details of the alleged breach. We will promptly investigate your complaint and respond to you, in writing, setting out the outcome of our investigation and the steps we will take to deal with your complaint. You also have the right to contact a regulatory body or data protection authority in relation to your complaint.
8. Limits of our policy
The RecMan Employee app may link to external sites that we do not operate. Please be aware that RecMan has no control over the content and policies of those sites, and cannot accept responsibility or liability for their respective privacy practices.
9. Changes to this policy
Recman AS Privacy and data department
This policy is effective as of 15 April 2020.