The Altoros Privacy Policy

Reviewed in January 2019.

  1. Altoros makes sure your personal data stays secure. In this privacy policy, you will find information concerning the rights of your personal data protection. “Altoros,” “we,” and “us” refer to Altoros Americas LLC, Altoros Norge AS, Altoros Finland Oy, Altoros A.S., and Altoros Development LLC. (Check out our contact information.)

    This privacy notice applies to potential candidates, current and former employees, as well as workers and contractors. It aims at revealing the way we handle your information, in particular, why and how we collect it during the interviews or communication with us on the point of your employment. It also describes how we use your personal data before, during, and after your working relationship with us, with whom we might share it, and how long we usually keep it, so you are aware of your rights. This policy is not a part of an employment contract or any other contract to provide services.

    Please make sure you read and fully understand this policy, and how your personal information is controlled by Altoros. If you have any questions or concerns about how your information is handled, please direct an inquiry to Alexey Lekontsev is our Data Protection Officer (DPO), dpo@altoros.com, with overall responsibility for day-to-day implementation of this policy or Olga Tikhomirova, Chief People Operations Officer, olga.tikhomirova@altoros.com.

  2. Altoros carefully fulfills its responsibilities to protect your personal data. That is why Altoros is devoted to make the process of collecting and using subject’s data as transparent as possible and meet its data protection obligations.

    1. 2.1. We collect the following categories of data

      Personal information gathered by Altoros includes:

      • your name, passport data, address, and contact details, including e-mail address, telephone number, date of birth, and gender
      • communication history with you regarding potential employment with Altoros and recruitment history: CV details, as well as previous work and educational experiences
      • details of your qualifications, skills, experience, and employment history, including start and end dates
      • information about your willing remuneration
      • information about your marital status, next of kin, and dependants
      • details of your preferred schedule (days of work) and attendance at work
      • details of any disciplinary or grievance procedures you have been involved in, including any warnings issued to you and related correspondence, etc.
      • interview results and feedbacks.

      Altoros may collect personal information in different ways. We can get it directly from you or through application forms, CVs or resumes, as well as interviews, meetings, or any other assessments. Therefore, we collect information through the application and recruitment process with the help of recruitment service providers or consultants, if they were involved.

      In addition, Altoros may also get personal information about you from third parties. It can be either references from former employers provided by you to us or information from employment background check providers. All these are obligatory executed under the law or our contractual obligation with customers (inter alia, out legitimate interest).

    2. 2.2. How we process the data gathered

      Under data processing, we perform any operation or a set of operations, such as collection, recording, organization, structuring, storage, adaptation, alteration, retrieval, consultation, usage, disclosure by transmission, dissemination or otherwise making available, alignment or combination, restriction, erasure or destruction, support, maintenance, etc.

      Data gathered is stored in Altoros's recruitment systems, such as Workable (Privacy Policy) and in other IT systems from the list below (including e-mail systems).

      Altoros uses the following third-party providers to collect and process your personal data. Below, you will find the sources enlisted.

      Altoros may use the gathered information for any purpose that does not violate our legitimate interest or legal ground for data processing stipulated in the next chapter.

    3. 2.3.Purposes and legal basis for data processing
    4. 2.4.Data recipients
    5. 2.5.Data retention period

      Your personal data is stored in Altoros for 1 (one) year from the date when your information was transferred to our recruitment system.

  3. Altoros collects and processes personal data of its personnel to manage the employment relationship or for any other purpose. Altoros carefully treats this information and is committed to meet its data protection obligations.

    1. 3.1. We collect the following categories of data

      Below, you will find the categories of data collected by Altoros:

      • your name, passport data, address, contact details, including e-mail address, telephone number, date of birth, and gender
      • the terms and conditions of your employment: type of contract, contract details, title, position description, working history and records, working location, and years of service
      • details of your qualifications, skills, experience, employment history, including start and end dates with previous employers and Altoros
      • information about your remuneration, including entitlement to benefits, such as pensions or insurance cover
      • details of your bank account
      • information about your marital status, next of kin, dependants, and emergency contacts
      • information about your citizenship and entitlement to work with Altoros
      • Information about training, educational events attendance, as well as participation in conferences and meetups
      • information about social networks, emergency contacts submitted by you, as well as details of FLSA code, SSN, ethnicity, veteran status, and employment status
      • information about trial period results and exit interview details, as well as performance review information
      • information about company benefits usage, such as health insurance, sports compensation, etc.
      • details of your schedule (days of work and working hours) and attendance at work
      • details of leave periods taken, including holiday, sickness leave, family leave, vacations, remote work requests, and any other absence reasons
      • details of any disciplinary or grievance procedures you have been involved in, including any warnings issued to you and related correspondence
      • assessments of your performance, including appraisals, performance reviews and ratings, performance improvement plans, and related correspondence
      • user logs and access control related information, including physical access to Altoros premises
      • information about your use of our data and communication systems, as well as other Altoros assets, for example, computers, servers, etc.

      From your consent, we may also collect, store, and use the following “special categories” of your personal information, which will be collected and used in accordance with local legislation or the contractual obligations with customers. Sensitive data we may collect about you includes information about medical or health conditions (drug tests) or information about any criminal records, in particular, for employment screening.

    2. 3.2. How we process the data gathered

      When processing your personal information, we perform any operation or set of operations on your personal data or set of personal data, which may include collection, recording, organization, structuring, storage, adaptation or alteration, retrieval, consultation, usage, disclosure by transmission, dissemination, alignment or combination, restriction, erasure or destruction, support, maintenance, etc.

      The data gathered is stored in Altoros's HR management system—BambooHR (Privacy Policy)—and other IT systems, including our corporate e-mail system, hosted on Gmail.com (Privacy Policy). In BambooHR, we do also store the following data collected on the stage of the recruitment process stipulated in Section 2.1. of this policy.

      Altoros uses the following third-party providers to collect and process your personal data. Below, you will find the sources enlisted.

      Altoros may use the gathered information for any purpose that does not violate our legitimate interest or legal ground for data processing stipulated in the next chapter.

    3. 3.3.Purposes and legal basis for data processing
    4. 3.4.Data recipients
    5. 3.5.Data retention period

      Altoros will hold your personal data for the duration of your employment, as well as during obligatory personnel record-keeping in accordance with the legislation. After your employment with Altoros comes to an end, the period for storing and processing your personal information will be set in accordance with the law.

  4. Below, you will find a list of the rights you are subject to. Please note that some of the enlisted rights may be limited for the requests, which expose personal information of another individual, who is subject to the very same rights of privacy. In such a case, we will not be able to satisfy your request for data deletion, if it contains information we are eligible to keep by law.

    1. The right to be informed and to access information. You have legal rights to access your personal data, as well as request it, if we use this data for any purpose. Complying with our general policy, we will provide you with a free copy of your personal information in use within a month, after we receive your request. We will send your information in use via a password-protected PDF file. For excessive or repeated requests, we are eligible to charge a fee. In case of numerous or complex requests, we are eligible to prolong our response time by as much as two additional months. Under such circumstances, you will be informed about the reasons of these extensions. In case we refuse to address a particular request, we will explain why it happens and provide you with a list of further actions you are eligible to proceed. If you will take any further action, we will require two trusted IDs from you to prove your identity. You may forward your requests to our Data Protection Officer (dpo@altoros.com). Please provide information about the nature of your request to help us to process your enquiry.

    2. The right for rectification. In case you believe we store any of your personal data, which is incorrect or incomplete, you may request us to correct or supplement it. You also have the right to introduce changes to your information by logging into your account with us.

    3. The right to erase, or "the right to be forgotten." Under this principle, you may request us to delete or remove your personal data, if there is no solid reason for your data continued processing. If you would like us to remove you from our database, please e-mail to dpo@altoros.com. The right to be forgotten may be brought into force under the following reasons:

      • Data, which no longer has a relation to its original purpose of collection.
      • You withdraw consent with respect to the original reason data was processed under, and there is no other reason for us to continue to store and process your personal data.
      • You have objections to processing your personal data, and there are no overriding legitimate reasons for us to continue processing it.
      • Your personal data has been unlawfully processed.
      • Your personal data has to be deleted to comply with a legal obligation in the European Union or Member State law to which Altoros is subject.
      • Your personal data has been collected in relation to the offer of information society services.
    4. The right to restrict processing. Under this right, you may request us to limit processing your personal data. In this regard, we are eligible to store information that is sufficient to identify which data you want to be blocked, but cannot process it further. The right to restrict processing applies to the following cases:

      • Where you contest the accuracy of your personal data, we will restrict data processing until we have verified the accuracy of your personal data.
      • Where you have objected to data processing under legitimate interests, we will consider whether our legitimate interests override yours.
      • When data processing is unlawful, and you oppose data deletion and request restriction instead.
      • If we no longer need your personal data, but you require this data to establish, exercise, or defend a legal claim.
    5. If we have disclosed your personal data in question to third parties, we will inform them about the restriction on data processing, unless it is impossible or involves disproportionate effort to do so. We will inform you, if we decide to lift a restriction on data processing.

    6. The right to object. You are eligible to object to processing your personal data based on legitimate interests (including profiling) and direct marketing (including profiling). The objection must be on “grounds relating to his or her particular situation.” We will inform you of your right to object in the first communication you receive from us. We will stop processing your personal data for direct marketing purposes, as soon as we receive an objection.

    7. The right to data portability. You are eligible to obtain your personal data, which is processed by Altoros, to use it for your own purposes. It means you have the right to receive your personal data—that you have shared with us—in a structured machine readable format, so you can further transfer the data to a different data controller. This right applies in the following circumstances:

      • Where you have provided the data to Altoros.
      • Where data processing is carried out, because you have given Altoros your consent to do so.
      • Where data processing is carried out to develop a contract between you and Altoros.
      • Where data processing is carried out automatically. (No membership data is processed using automated means, so this right does not apply.)
    8. Withdrawal of consent. If we process your personal data based on your consent (as indicated at the time of collection of such data), you have the right to withdraw your consent at any point in time. Please note that if you exercise this right, you may have to provide your consent on a case-by-case basis for the use or disclosure of certain personal data, if such use or disclosure is necessary to enable you to utilize some or all of our services.

    9. Right to file a complaint. You have the right to file a complaint about manipulations applied to your data by Altoros with the supervisory authority of your country or a European Union Member State.

    It is important that the personal information we hold about you is accurate and current. Please keep us informed if your personal information changes during your working relationship with us.

  5. We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used, altered, disclosed, or accessed in an unauthorised way.

    We limit access to your personal data to those employees, agents, contractors, and other third parties on a need-to-know basis, i.e., who need the access in order to fulfil the tasks and duties relating to a service provision. All service providers are permitted to process your personal data based on our instructions, they are subject to a duty of confidentiality, and they are required to be compliant and demonstrate the compliance with personal data protection and secuгity.

    Our IT systems are protected against unauthorised access with various level of controlled and password-protected access rights.

    When transferring or disclosing your personal data, the safety measures vary based on the sensitivity of data and may include, e.g., strong identification of the recipient and encryption of the transferred information.

    Any sensitive information (such as health-related information or any sensitive data required by local legislation) will usually be used separately from other personal data, and access rights to such sensitive personal data are granted only with weighty reasons to persons making decisions, usually HR representatives, as well as direct manager and direct manager’s manager.

    We have implemented procedures to deal with any actual or suspected data security breach and will notify you and any applicable authority about breach, when we are legally required to do so.

    We are avoiding personal data collection and usage in a paper format. If required so, paper documents and copies will always be stored in locked-up premises. Our IT organization together with our DPO and Information Security Manager monitor the safety and integrity of personal data protection on a regular basis and have implemented technical measures to prevent and detect any safety breaches that may threaten your personal data.

  6. As an international company, if necessary, we will transfer the personal information we collect about you to the Altoros entities.

    We ensure that appropriate safeguards are in place to provide adequate levels of protection of your personal data as required by applicable data protection laws. The data collected by Altoros may be transferred across our offices. Headquartered in the USA, Altoros is an international company with the offices in Norway, Finland, Argentina (there is adequacy decision of the European Commission), and Belarus. Belarus may not have equivalent privacy and data protection laws as the laws of many of the countries, where our customers and users are based. When we share information about you within and among Altoros Development LLC (Minsk, Belarus), we make use of standard contractual data protection clauses. If you have questions about the transfer, please contact our data protection officer.

    If you are part of our management team, sales organization, or sourcing organisation, we will transfer name, e-mail address, telephone number, job position, place of work, country, and other business-related data, such as personal data included in purchase orders, quality documentations, e-mail correspondences, contracts, and other agreements between a customer/supplier and Altoros. In addition, we will transfer business-related documentations to an Altoros site or to customers or suppliers, strictly in order to perform our contract with such customers or suppliers.

  7. We may supplement or amend this policy by additional policies and guidelines from time to time. We will post any privacy policy changes on this page. We encourage you to review our privacy policy, whenever you use our services to stay informed about our data practices and the ways you can help to protect your privacy.

    We do not knowingly collect personal information from individuals under 16. If we become aware that an individual under 16 has provided us with personal information, we will take measures to delete such information.

  8. Your information is controlled by Altoros Americas LLC and Altoros Development LLC. If you have questions or concerns about how your information is handled, please direct your inquiry to Altoros Development LLC, which we have appointed responsible for facilitating such inquiries or, if you are a resident of the European Economic Area, please contact our EU Representative.

    Altoros Development LLC:

    9 Dombrovskaya str., Office 5.1.4, Minsk, Belarus, 220140

    Phone/fax: +37517 3880132

    E-Mail: dpo@altoros.com

    EEA Representative:

    Altoros Norge AS.

    Kongens gate 3

    0153 Oslo, Norway

    Phone: +47 21 92 93 00

    Org. num.: 894 684 992

1. Introduction

Altoros makes sure your personal data stays secure. In this privacy policy, you will find information concerning the rights of your personal data protection. “Altoros,” “we,” and “us” refer to Altoros Americas LLC, Altoros Norge AS, Altoros Finland Oy, Altoros A.S., and Altoros Development LLC. (Check out our contact information.)

This privacy notice applies to potential candidates, current and former employees, as well as workers and contractors. It aims at revealing the way we handle your information, in particular, why and how we collect it during the interviews or communication with us on the point of your employment. It also describes how we use your personal data before, during, and after your working relationship with us, with whom we might share it, and how long we usually keep it, so you are aware of your rights. This policy is not a part of an employment contract or any other contract to provide services.

Please make sure you read and fully understand this policy, and how your personal information is controlled by Altoros. If you have any questions or concerns about how your information is handled, please direct an inquiry to Alexey Lekontsev is our Data Protection Officer (DPO), dpo@altoros.com, with overall responsibility for day-to-day implementation of this policy or Olga Tikhomirova, Chief People Operations Officer, olga.tikhomirova@altoros.com.

2. Data we gather about our candidates

Altoros carefully fulfills its responsibilities to protect your personal data. That is why Altoros is devoted to make the process of collecting and using subject’s data as transparent as possible and meet its data protection obligations.

2.1. We collect the following categories of data

Personal information gathered by Altoros includes:

  • your name, passport data, address, and contact details, including e-mail address, telephone number, date of birth, and gender
  • communication history with you regarding potential employment with Altoros and recruitment history: CV details, as well as previous work and educational experiences
  • details of your qualifications, skills, experience, and employment history, including start and end dates
  • information about your willing remuneration
  • information about your marital status, next of kin, and dependants
  • details of your preferred schedule (days of work) and attendance at work
  • details of any disciplinary or grievance procedures you have been involved in, including any warnings issued to you and related correspondence, etc.
  • interview results and feedbacks.

Altoros may collect personal information in different ways. We can get it directly from you or through application forms, CVs or resumes, as well as interviews, meetings, or any other assessments. Therefore, we collect information through the application and recruitment process with the help of recruitment service providers or consultants, if they were involved.

In addition, Altoros may also get personal information about you from third parties. It can be either references from former employers provided by you to us or information from employment background check providers. All these are obligatory executed under the law or our contractual obligation with customers (inter alia, out legitimate interest).

2.2. How we process the data gathered

Under data processing, we perform any operation or a set of operations, such as collection, recording, organization, structuring, storage, adaptation, alteration, retrieval, consultation, usage, disclosure by transmission, dissemination or otherwise making available, alignment or combination, restriction, erasure or destruction, support, maintenance, etc.

Data gathered is stored in Altoros's recruitment systems, such as Workable (Privacy Policy) and in other IT systems from the list below (including e-mail systems).

Altoros uses the following third-party providers to collect and process your personal data. Below, you will find the sources enlisted.

Altoros may use the gathered information for any purpose that does not violate our legitimate interest or legal ground for data processing stipulated in the next chapter.

2.4. Data recipients

The subject’s personal data may be shared between in-house HR team members, as well as your potential resource manager, managers in the service/business area you work in, and company’s IT staff, if data access is needed to fulfil their roles.

Altoros shares your data with third parties to obtain pre-employment references from other employers, employment background checks from third-party providers, as well as necessary criminal records checks, if it is needed, under the law or under our contractual obligation with customers. In such cases, we limit the amount of personal data shared to an absolute minimum required.

2.5. Data retention period

Your personal data is stored in Altoros for 1 (one) year from the date when your information was transferred to our recruitment system.

3. Data we gather from our personnel

Altoros collects and processes personal data of its personnel to manage the employment relationship or for any other purpose. Altoros carefully treats this information and is committed to meet its data protection obligations.

3.1. We collect the following categories of data

Below, you will find the categories of data collected by Altoros:

  • your name, passport data, address, contact details, including e-mail address, telephone number, date of birth, and gender
  • the terms and conditions of your employment: type of contract, contract details, title, position description, working history and records, working location, and years of service
  • details of your qualifications, skills, experience, employment history, including start and end dates with previous employers and Altoros
  • information about your remuneration, including entitlement to benefits, such as pensions or insurance cover
  • details of your bank account
  • information about your marital status, next of kin, dependants, and emergency contacts
  • information about your citizenship and entitlement to work with Altoros
  • Information about training, educational events attendance, as well as participation in conferences and meetups
  • information about social networks, emergency contacts submitted by you, as well as details of FLSA code, SSN, ethnicity, veteran status, and employment status
  • information about trial period results and exit interview details, as well as performance review information
  • information about company benefits usage, such as health insurance, sports compensation, etc.
  • details of your schedule (days of work and working hours) and attendance at work
  • details of leave periods taken, including holiday, sickness leave, family leave, vacations, remote work requests, and any other absence reasons
  • details of any disciplinary or grievance procedures you have been involved in, including any warnings issued to you and related correspondence
  • assessments of your performance, including appraisals, performance reviews and ratings, performance improvement plans, and related correspondence
  • user logs and access control related information, including physical access to Altoros premises
  • information about your use of our data and communication systems, as well as other Altoros assets, for example, computers, servers, etc.

From your consent, we may also collect, store, and use the following “special categories” of your personal information, which will be collected and used in accordance with local legislation or the contractual obligations with customers. Sensitive data we may collect about you includes information about medical or health conditions (drug tests) or information about any criminal records, in particular, for employment screening.

3.2. How we process the data gathered

When processing your personal information, we perform any operation or set of operations on your personal data or set of personal data, which may include collection, recording, organization, structuring, storage, adaptation or alteration, retrieval, consultation, usage, disclosure by transmission, dissemination, alignment or combination, restriction, erasure or destruction, support, maintenance, etc.

The data gathered is stored in Altoros's HR management system—BambooHR (Privacy Policy)—and other IT systems, including our corporate e-mail system, hosted on Gmail.com (Privacy Policy). In BambooHR, we do also store the following data collected on the stage of the recruitment process stipulated in Section 2.1. of this policy.

Altoros uses the following third-party providers to collect and process your personal data. Below, you will find the sources enlisted.

Altoros may use the gathered information for any purpose that does not violate our legitimate interest or legal ground for data processing stipulated in the next chapter.

3.4. Data recipients

The subject’s personal data may be shared between in-house HR team members, as well as your potential resource manager, managers in the service/business area you work in, and company’s IT staff, if data access is needed to fulfil their roles.

Altoros shares your data with third parties to obtain pre-employment references from other employers, employment background checks from third-party providers, as well as necessary criminal records checks, if it is needed, under the law or under our contractual obligation with customers. In such cases, we limit the amount of personal data shared to an absolute minimum required.

Furthermore, Altoros shares your data with third parties that process data on their behalf. This data is related to payroll, pension providers, insurance provider/broker, absence management system, HR consultants, the provision of benefits,occupational health services, etc.

In addition, we share your personal information with other entities in the Altoros group as part of our regular reporting activities on company performance regarding business reorganization or restructuring exercise for system maintenance support and hosting of data.

We also share your personal information with different governmental authorities, institutions or agencies (or similar), as well as insurance companies when required by law for the purpose of their regulatory tasks. We may also transfer your personal information to a regulator or any other legal body.

We may share your personal data with other third parties, e.g., service providers, suppliers, customers, and business partners to fulfil our contractual obligations. In such cases, we limit personal data shared to the absolute minimum required.

3.5. Data retention period

Altoros will hold your personal data for the duration of your employment, as well as during obligatory personnel record-keeping in accordance with the legislation. After your employment with Altoros comes to an end, the period for storing and processing your personal information will be set in accordance with the law.

4. Your rights

Below, you will find a list of the rights you are subject to. Please note that some of the enlisted rights may be limited for the requests, which expose personal information of another individual, who is subject to the very same rights of privacy. In such a case, we will not be able to satisfy your request for data deletion, if it contains information we are eligible to keep by law.

  1. The right to be informed and to access information. You have legal rights to access your personal data, as well as request it, if we use this data for any purpose. Complying with our general policy, we will provide you with a free copy of your personal information in use within a month, after we receive your request. We will send your information in use via a password-protected PDF file. For excessive or repeated requests, we are eligible to charge a fee. In case of numerous or complex requests, we are eligible to prolong our response time by as much as two additional months. Under such circumstances, you will be informed about the reasons of these extensions. In case we refuse to address a particular request, we will explain why it happens and provide you with a list of further actions you are eligible to proceed. If you will take any further action, we will require two trusted IDs from you to prove your identity. You may forward your requests to our Data Protection Officer (dpo@altoros.com). Please provide information about the nature of your request to help us to process your enquiry.

  2. The right for rectification. In case you believe we store any of your personal data, which is incorrect or incomplete, you may request us to correct or supplement it. You also have the right to introduce changes to your information by logging into your account with us.

  3. The right to erase, or "the right to be forgotten." Under this principle, you may request us to delete or remove your personal data, if there is no solid reason for your data continued processing. If you would like us to remove you from our database, please e-mail to dpo@altoros.com. The right to be forgotten may be brought into force under the following reasons:

    • Data, which no longer has a relation to its original purpose of collection.
    • You withdraw consent with respect to the original reason data was processed under, and there is no other reason for us to continue to store and process your personal data.
    • You have objections to processing your personal data, and there are no overriding legitimate reasons for us to continue processing it.
    • Your personal data has been unlawfully processed.
    • Your personal data has to be deleted to comply with a legal obligation in the European Union or Member State law to which Altoros is subject.
    • Your personal data has been collected in relation to the offer of information society services.
  4. The right to restrict processing. Under this right, you may request us to limit processing your personal data. In this regard, we are eligible to store information that is sufficient to identify which data you want to be blocked, but cannot process it further. The right to restrict processing applies to the following cases:

    • Where you contest the accuracy of your personal data, we will restrict data processing until we have verified the accuracy of your personal data.
    • Where you have objected to data processing under legitimate interests, we will consider whether our legitimate interests override yours.
    • When data processing is unlawful, and you oppose data deletion and request restriction instead.
    • If we no longer need your personal data, but you require this data to establish, exercise, or defend a legal claim.
  5. If we have disclosed your personal data in question to third parties, we will inform them about the restriction on data processing, unless it is impossible or involves disproportionate effort to do so. We will inform you, if we decide to lift a restriction on data processing.

  6. The right to object. You are eligible to object to processing your personal data based on legitimate interests (including profiling) and direct marketing (including profiling). The objection must be on “grounds relating to his or her particular situation.” We will inform you of your right to object in the first communication you receive from us. We will stop processing your personal data for direct marketing purposes, as soon as we receive an objection.

  7. The right to data portability. You are eligible to obtain your personal data, which is processed by Altoros, to use it for your own purposes. It means you have the right to receive your personal data—that you have shared with us—in a structured machine readable format, so you can further transfer the data to a different data controller. This right applies in the following circumstances:

    • Where you have provided the data to Altoros.
    • Where data processing is carried out, because you have given Altoros your consent to do so.
    • Where data processing is carried out to develop a contract between you and Altoros.
    • Where data processing is carried out automatically. (No membership data is processed using automated means, so this right does not apply.)
  8. Withdrawal of consent. If we process your personal data based on your consent (as indicated at the time of collection of such data), you have the right to withdraw your consent at any point in time. Please note that if you exercise this right, you may have to provide your consent on a case-by-case basis for the use or disclosure of certain personal data, if such use or disclosure is necessary to enable you to utilize some or all of our services.

  9. Right to file a complaint. You have the right to file a complaint about manipulations applied to your data by Altoros with the supervisory authority of your country or a European Union Member State.

It is important that the personal information we hold about you is accurate and current. Please keep us informed if your personal information changes during your working relationship with us.

5. Data security and protection

We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used, altered, disclosed, or accessed in an unauthorised way.

We limit access to your personal data to those employees, agents, contractors, and other third parties on a need-to-know basis, i.e., who need the access in order to fulfil the tasks and duties relating to a service provision. All service providers are permitted to process your personal data based on our instructions, they are subject to a duty of confidentiality, and they are required to be compliant and demonstrate the compliance with personal data protection and secuгity.

Our IT systems are protected against unauthorised access with various level of controlled and password-protected access rights.

When transferring or disclosing your personal data, the safety measures vary based on the sensitivity of data and may include, e.g., strong identification of the recipient and encryption of the transferred information.

Any sensitive information (such as health-related information or any sensitive data required by local legislation) will usually be used separately from other personal data, and access rights to such sensitive personal data are granted only with weighty reasons to persons making decisions, usually HR representatives, as well as direct manager and direct manager’s manager.

We have implemented procedures to deal with any actual or suspected data security breach and will notify you and any applicable authority about breach, when we are legally required to do so.

We are avoiding personal data collection and usage in a paper format. If required so, paper documents and copies will always be stored in locked-up premises. Our IT organization together with our DPO and Information Security Manager monitor the safety and integrity of personal data protection on a regular basis and have implemented technical measures to prevent and detect any safety breaches that may threaten your personal data.

6. Data transfer outside EEA

As an international company, if necessary, we will transfer the personal information we collect about you to the Altoros entities.

We ensure that appropriate safeguards are in place to provide adequate levels of protection of your personal data as required by applicable data protection laws. The data collected by Altoros may be transferred across our offices. Headquartered in the USA, Altoros is an international company with the offices in Norway, Finland, Argentina (there is adequacy decision of the European Commission), and Belarus. Belarus may not have equivalent privacy and data protection laws as the laws of many of the countries, where our customers and users are based. When we share information about you within and among Altoros Development LLC (Minsk, Belarus), we make use of standard contractual data protection clauses. If you have questions about the transfer, please contact our data protection officer.

If you are part of our management team, sales organization, or sourcing organisation, we will transfer name, e-mail address, telephone number, job position, place of work, country, and other business-related data, such as personal data included in purchase orders, quality documentations, e-mail correspondences, contracts, and other agreements between a customer/supplier and Altoros. In addition, we will transfer business-related documentations to an Altoros site or to customers or suppliers, strictly in order to perform our contract with such customers or suppliers.

7. General description

We may supplement or amend this policy by additional policies and guidelines from time to time. We will post any privacy policy changes on this page. We encourage you to review our privacy policy, whenever you use our services to stay informed about our data practices and the ways you can help to protect your privacy.

We do not knowingly collect personal information from individuals under 16. If we become aware that an individual under 16 has provided us with personal information, we will take measures to delete such information.

Contact us

Your information is controlled by Altoros Americas LLC and Altoros Development LLC. If you have questions or concerns about how your information is handled, please direct your inquiry to Altoros Development LLC, which we have appointed responsible for facilitating such inquiries or, if you are a resident of the European Economic Area, please contact our EU Representative.

Altoros Development LLC:

9 Dombrovskaya str., Office 5.1.4, Minsk, Belarus, 220140

Phone/fax: +37517 3880132

E-Mail: dpo@altoros.com

EEA Representative:

Altoros Norge AS.

Kongens gate 3

0153 Oslo, Norway

Phone: +47 21 92 93 00

Org. num.: 894 684 992