1. Data processing notice
Shajan Consulting ("Shajan Consulting”) attaches great importance to your privacy and therefore processes your personal data in strict compliance with the applicable statutory provisions (see item 3 below). This Privacy Policy of Shajan Consulting is addressed to all users of the website www.shajanconsulting.ch as well as applicants, employees and business partners, to inform them of the nature and purpose of the data collected by us, as well as the relevant statutory provisions.

2. Purpose of processing the data
Shajan Consulting processes personal data for the purposes of initiating contract negotiations, job application processing, acting as an employment agency for the procurement of permanent positions with customers of Shajan Consulting, for the processing of employment relationships in staff leasing arrangements or internal hiring at Shajan Consulting. We also use personal data to manage our relationship with you and for communication purposes, including to send out newsletters and invitations to events, training programmes or lectures, and to update our contact list. Subject to prior agreement, an applicant authorises Shajan Consulting to contact former employers and other sources of references. The data thus obtained is also processed by us.

3. Legal basis for data processing
The legal basis for our processing of data is provided by the Swiss Federal Act on Data Protection (FADP), the Swiss Employment Services Act (ESA), the Swiss Employment Services Ordinance (ESO) and the EU General Data Protection Regulation (GDPR). The FADP, ESA and ESO are applicable in all cases. The GDPR, on the other hand, is applicable only where so provided for the specific case.
Our processing of personal data for the purposes described hereunder is justified, among other things, by 1) your own interest in initiating contract negotiations, processing of the job application process, the procurement on your behalf of a permanent position with customers of Shajan Consulting, in case of handling an employment relationship through staff leasing or internal hiring, 2) your express consent or, to the extent permitted by law, your implied consent and 3) our legitimate interest in maintaining and managing the business relationship and keeping you informed, as a business contact, of our operations and events.

4. Which personal data is stored?
You supply us with your personal data of your own free will when you apply for a position with us or with one of our customers, when you send us your personal dossier separately from an application, or when you sign up for a newsletter or otherwise contact us. In certain cases, in addition to such personal data, we process information from publicly accessible sources such as online media (or platforms such as Xing or LinkedIn) and employer-websites in order to confirm your background and current position. In some cases, such publicly accessible information is our only source of the personal data that we process.
In particular, the following categories of data will be stored:
Contact details (e.g., full name, postal address, e-mail address, telephone and fax number[s], nationality, date of birth)
Job preferences (e.g., desired position, function, sector, form of employment)
Education and training, professional experience (including your former employers), special expertise
Application documents (e.g., certificates of employment, letters of recommendation, resume, photo, work permits) and other information about you and your skills
Technical information, such as your IP address or other information we receive when you visit our website
Information about meetings with us and their subject matter
For employees in staff leasing arrangements, we store supplementary data needed for personnel administration: salary and bank account details, AHV (pension insurance) number, working hours, holidays, accident and sickness reports, etc.

5. How is the data processed and stored?
Shajan Consulting is a Swiss company and collects and stores data on servers in Switzerland. We sometimes create a physical customer file, too, e.g., when you sign a contract with us. Your data will not be sold or made available to others, especially not to unauthorised third parties. Third parties commissioned by us to perform certain tasks according to our instructions may have access to personal data in their capacity as data processors, such as IT service providers performing tasks related to hosting, database management, website management, maintenance services and web analytics, as well as handling incoming queries and data analysis, including software for personnel service providers used to store data on a server in Switzerland.
We require such third-party service providers to implement and maintain security measures to protect the confidentiality and security of the data that you entrust to our care and to collect, process and use personal data only as instructed by us and as contractually agreed.

6. Sharing of certain data
After obtaining your consent, we may share your personal data with our clients and data processors of Shajan Consulting for the purpose of our business activities, especially for providing our services, i.e., finding a suitable position for you, including by means of our back-office and CRM tools. Possible recipients may thus e.g. include potential employers (companies, personnel department employees, managers) or [employment] agents working for such potential employers. The contractors hired by us are contractually bound to maintain confidentiality and comply with the applicable data protection provisions.
The registered office or HR department of some of the clients and contractors to which Shajan Consulting may forward your personal data when providing its services may sometimes not be located in either Switzerland or an EU Member State, so that they may not have the same standards of security as in Switzerland and in the EU. Your data will be forwarded in strict compliance with the applicable data protection provisions for the sole purpose of providing our services. Please note that we cannot know the place of data storage used by each contractor or client to which we forward your data in your interest. Although we take all legally required and practically feasible measures required to protect your data, we cannot guarantee that after such forwarding your data will be stored in a place with the same standard of security as in Switzerland or the EU.
Even in the case of government agencies and institutions that have the right to demand disclosure, Shajan Consulting will disclose your data only to the extent required by law or disclosure order issued by a final judicial decision.

7. Data security
We use appropriate technical and organisational measures to protect your personal data against loss, destruction, unauthorised access, and modification or dissemination of such data by unauthorised third parties. We also review of our security policy and procedures on a regular basis to ensure that our systems are secure.

8. What steps do we take in case of data theft?
In case of data theft, the competent authorities of the Canton of Zurich and the data subjects are informed immediately.

9. Use of anonymised data
To continually optimise and organise our website to meet your needs, we use various web analytics services and functions providing us with anonymised data, such as the user's IP address, the data consulted on our website, the location of the user's device (provided the locating function is enabled), the type of device, etc. Your data may possibly be sent to the USA in this context. From the user's perspective, it is important to know that the European Commission has adopted an adequacy decision according to which there is an adequate standard of security for data transmissions to the USA.
We also make use of cookies (small text files allowing user-specific information to be stored on the user's terminal during use of our website). In particular, cookies make it possible to determine the frequency of use and number of users of the pages, to analyse page usage behaviour, and to make our presentation of products and services more user-friendly (e.g., language settings, operating system, etc.). Cookies remain in storage after the end of the browser session and can be retrieved the next time the user visits our website. If you disagree with such use of cookies, you can disable cookies in your browser settings, but in that case you may not be able to benefit from all the features of our website.
Please note that the website www.shajanconsulting.ch uses Google Analytics, a web analytics service of Google Inc., 1600 Amphitheatre Parkway, Mountain View, CA 94043 (USA), whose parent corporation is the holding company Alphabet Inc, likewise domiciled in the USA. Google Analytics uses a specific form of cookies allowing us to analyse your usage of our website. The resulting information that we obtain is generally transmitted to a Google server in the USA and stored there. Since IP anonymising is enabled on our website, your IP address will be truncated by Google prior to transmission. It is only in exceptional cases that the full IP address will be transmitted to a Google server in the USA and truncated there upon arrival. Google will use such information on our behalf to evaluate your use of the website, compile reports on website activities and provide us with additional services related to website and internet usage. According to Google, the IP address will never be associated with other user-related data.
For more information about the handling of user data at Google Analytics, see the Google Privacy Policy: https://support.google.com/analytics/answer/6004245?hl=en. In addition, you can opt out of the Google Analytics feature by installing the browser add-on available here: https://tools.google.com/dlpage/gaoptout?hl=en.
The website www.shajanconsulting.ch also uses Google AdWords, a Google analytics service that uses conversion tracking (tracking by means of conversion cookies) to check whether you clicked on certain advertisements on our website. Conversion cookies, which remain valid for a limited time only, contain no personal data and thus cannot be used to identify the user but only to generate statistics for AdWords customers based on such analysis, i.e., regarding the total number of users who clicked on an ad. Each Google AdWords customer receives a different cookie so that there is no way that cookies can be tracked through the websites of AdWords customers. More information about the terms of use and data protection related to Google AdWords is available here: https://policies.google.com/technologies/ads?hl=en. In addition, you can turn off personalised ads on the Ad Settings page of Google by following these instructions: https://support.google.com/ads/answer/2662922?hl=en.
Furthermore, we use the following Google features: remarketing, audiences with common interests, user-defined audiences with common interests, in-market audiences, similar audiences, demographic and geographical trend. These features serve the purpose of analysing the behaviour and interests of visitors. Google uses cookies to analyse website use, which provides the basis for creating interest-based ads. That sometimes enables us to display ads tailored to your needs and/or background. None of the personal data of our website visitors is stored. If you subsequently visit another website in the Google Display Network, you will be shown ads that will very likely take into account the types of products and information that you clicked on previously. Please also note that AdWords identifies common interests and characteristics of our website users based on user behaviour on websites in the Google Ad Network within the past 30 days and based on context-dependent search engines. In that way, AdWords finds new potential customers for marketing purposes whose interests and characteristics are similar to those of our website users. More information about Google Remarketing and the associated Privacy Policy is available here: https://policies.google.com/technologies/ads?hl=en. In addition, you can permanently opt out of Google's use of cookies by downloading and installing the plug-in available here: https://support.google.com/ads/answer/7395996?hl=en.
Finally, the website www.2parseit.swiss uses Google Maps to provide visual displays of geographical information, which may result in certain data being identified, stored and used by Google (e.g., your IP address). Once again, such data is generally stored on servers in the USA (the terms of use are available here: https://www.google.com/intl/en_en/help/terms_maps.html).

10. Use of especially sensitive personal data
When we talk over the telephone or in person, or when you send us application documents, we may receive sensitive data from you (e.g., concerning your health, criminal record or debt collection register entries, religion, etc.). You hereby expressly consent to our processing of such personal data if necessary for the purposes of our business activities.

11. Continued use of data after the end of the business relationship
Even after the end of business relationships, your data may continue to be processed to enable us to advise you on future career planning, offer you possible job opportunities and interesting job vacancies, so that we can prepare and you can sign new employment contracts. In so doing, we comply with the statutory retention periods. If your consent is or was required by law for such processing, you may revoke it any time, without prejudice to any statutory provisions requiring us to retain certain items of data.

12. Who has access to the data?
Your personal data is accessible to all 2parse.it's employees and external service providers (IT Host, Back-Office, CRM, trustees, etc.). We select such service providers carefully, require them to commit to process data in compliance with the applicable laws, and monitor them.

13. What are the data subject's rights?
You have the right, at any time, to view and/or receive information about your personal data stored by Shajan Consulting (right to information), to rectify any false or supplement any incomplete stored personal data (right to correction/rectification), to delete your stored personal data (right to deletion) and/or restrict the processing thereof (right to restriction of processing).
In addition, you have the right to revoke your declaration of consent and to have your data transferred to you or to another data controller, providing the data processing is or was permissible exclusively on the basis of your consent. Any such revocation shall be without prejudice to the legality of such processing as was completed based on your consent, which shall not become unlawful because of the subsequent withdrawal of consent.

14. Deletion of data upon expiry of limitation period
The data is generally deleted as soon as it has served the purpose for which it was collected. For example, the data is deleted upon expiry of the limitation period commencing at the time of its most recent use, or when it can no longer serve a future purpose, e.g., if you move outside Shajan Consulting's geographical area of activities and Shajan Consulting is informed of that fact.

15. Changes in data protection laws and the Privacy Policy
The data protection laws are subject to change at any time, so we may have to adapt out Privacy Policy and/or internal procedures accordingly. We reserve the right to make such changes from time to time. Each time you visit our website, check whether any changes have occurred in the meantime, leading to a new version of the Privacy Policy. The present document is the version of [21.01.2019].

16. Right to complain
To the extent provided for by the relevant statutory provisions, you have the right to complain to a supervisory authority if you believe that your personal data is being processed in an unlawful manner.

17. Who is responsible for data protection (data protection officer) at Shajan Consulting
The owner of Shajan Consulting is responsible for data protection and the terms of use:
Parastoo Shajan (shajan@shajanconsulting.ch / +41 43 244 75 75)