Itransition Software Limited LLC, registered in Georgia (hereinafter referred to as a1qa) acts as a controller of personal data defined by the Law of Georgia No. 3144-XIმს-Xმპ dated 03.07.2023 “On Personal Data Protection” (the “Law”) and is fully committed to ensuring the privacy and security of your personal data.

As used in this Recruitment Privacy Statement (Privacy Statement) «a1qa», «we», «our» and «us» refer to a1qa that may process your personal data.

This Privacy Statement applies to all job candidates or our training courses participants (“candidate” or “you”) who browse this website or come into contact with us through this website.

This Privacy Statement describes how we collect and use your personal data during or after training, recruiting and hiring processes. The statement additionally serves to provide you with information on the rights to which you are entitled in regard to the processing of your personal data by a1qa.

Personal information we collect and use

The types of information requested from you and the manner in which that information is collected and accessed are determined by the requirements of the country in which the position is located, and not the country in which you reside. You are not required to provide any requested information to us but failing to do so may result in not being able to continue your candidacy for the role you have applied for. By submitting your information, you acknowledge that all representations made by you are true and correct to the best of your knowledge and belief. Providing any inaccurate information may make you ineligible for employment.

Types of information about the candidate that we normally collect in our files are as follows: first name, last name, date of birth, contact details, residence, professional profiles and work experience. In connection with your job interviews, we receive additional information about you, which we record for use in the further recruitment process.

Your files can also include letters or other written materials, data generated by interviewers and recruiters, based on their interactions with you or basic Internet searches as well as their considerations regarding you and your suitability for the role, recommendations provided on your behalf by others, documentation required under migration laws if relocation is desired, data generated by your participation in technical assessments.

We do not collect more information than we need to fulfill our purposes listed in this Privacy Statement and will not keep it longer than necessary. If you believe a1qa website has collected excessive information about you, please contact a1qa on the below mentioned email to raise your concerns.

a1qa does not intend to collect sensitive information through its website unless it is legally required to do so or you voluntarily provide such data. Examples of sensitive information include race or ethnic origin, political opinions, religious or philosophical beliefs, physical or mental health, genetic data, biometric data or criminal records.

Purposes for which we collect and use your personal data

The permissibility of personal data processing can only be established when the processing of the data can be supported by an appropriate legal basis. The personal data you provide, and data that is collected publicly, is processed based on your consent and may be used during the recruitment and hiring process, as part of the evaluation and selection of applicants, conducting interviews or tests, negotiation and determination of conditions on which you work for us if your application was successful, and as otherwise needed in the recruitment process (e.g. to consider you and contact you about roles potentially suitable for you in future as well as to receive information about new positions which we think might be of interest to you).

We will reach out to candidates having passed sourcing and the first review. For certain roles, candidates may be invited to complete job-related assessments aligned with the skills and competencies needed for the role. We also may perform a background check for compliance reasons. The processing of your personal data described in this section is based on your consent.

In some cases, we need to process your data to ensure that we are complying with our legal obligations. We may also need to process your personal data to respond to and defend against legal claims.

Under the Law, you have the right to withdraw your consent at any time. You may do so by sending e-mail to privacy@a1qa.com. However, please note that your personal data is used to evaluate your employment application and by exercising this right we cannot proceed to manage your application. The withdrawal of consent shall not affect the lawfulness of processing based on consent before its withdrawal.

Sources from which we obtain your personal data

We may obtain data about you from the following sources:

• when you submit your CV or other information online;
• interview process for the role you have applied for;
• a1qa employees and contractors whom you gave your consent to share your application with us;
• your previous employers;
• third-party recruiters whom you gave your consent to provide us with your application information;
• other public sources, including social media.

Сookies usage

As was mentioned on the entry page we use cookies on this website. Cookies are small text files that may be automatically placed on your computer/device and stored on it. The use of cookies is now standard for most websites.

The first time you visit our website, we notify you about using cookies through a notification banner. By clicking the Accept button you declare your consent to using cookies. You have the capability to refuse (not accept) cookies. You can manage your choice regarding using cookies at the bottom of this section.

Please be informed cookies are placed on your computer/device only if you provide your consent as described above.

You may find more information or change your cookie preferences here.

Transfers to third countries

a1qa is a global group of companies. Therefore, depending on the purpose of processing, your personal data may be transferred outside Georgia. This includes countries that ensure an adequate level and means of personal data protection. Where personal data is transferred to countries that do not provide adequate safeguards, such transfer is carried out in accordance with the requirements of Law.

Data Security

We take appropriate organizational and technical measures to ensure protection of data against accidental or unlawful destruction, alteration, disclosure, collection or any other form of unlawful use, and accidental or unlawful loss.

All operations performed in relation to electronic and/or non-electronic data are registered with respect to disclosure and/or alteration of data. In addition, we limit access to your personal data to only authorized staff and to those who have a business need to know, and they will process your personal data only if they are subject to a duty of confidentiality. The duty of confidentiality stays in force after the termination of the employment contracts of the authorized staff.

We have put in place procedures to deal with any suspected or actual data security breach and will notify you and the supervisory authority of a suspected breach where we are legally required to do so.

Retention of your personal data

We will keep your personal information as long as you are a candidate or until the consent is revoked. After you stop being a candidate, we may keep your data for a reasonable period of time to deal with any matter which may arise in connection with your application, e.g. to respond to any questions or concerns, to resolve possible disputes/claims, or to show that we treated you fairly, or to make sure we do not contact you about a role you have already applied for.

If you consent to join our talent pool, we may also retain your personal information for up to 2 years (after we have communicated to you our decision about your application being unsuccessful) for purposes of assessing your suitability for other roles and contacting you regarding other employment opportunities. You can withdraw your consent regarding such processing at any time.

If your application for employment is successful, your personal data gathered during the recruitment and hiring process will be transferred to your personnel file and retained during your employment and after if required so by law or in order to defend our legal rights.

Rights in relation to your personal data

Under applicable Law, you may exercise the rights in relation to the personal data, including the following:

a. request and receive the information from a data controller on processing of his/her data, including:

• which personal data are being processed;
• the purpose of data processing;
• the legal grounds for data processing;
• the ways in which the data were collected;
• to whom the data were disclosed, and the grounds and purpose of the disclosure.

b. request to correct, update, add, block, delete, or destroy data if the data are incomplete, inaccurate, not updated, or were illegally collected and processed.

c. at any time and without explanation, withdraw the given consent and request that the data processing be stopped and/or the processed data be destroyed, in case the information that is related to fulfillment of a1qa’s financial obligations and processed with the written consent.

d. to apply to the Personal Data Protection Inspector of Georgia or to the court under procedures determined by law and/or require from a body considering the case to block data until a decision is made.

Limitation of your rights

The above-mentioned rights may be limited by the legislation of Georgia, only to the extent necessary to achieve the intent of the limitation, if the exercise of these rights endangers:

a) the interests of the national security and defense

b) the interests of public security

c) crime detection, investigation and prevention

d) significant financial and economic interests of the country (including those related to monetary, budgetary and taxation issues)

e) the rights and freedoms of a data subject and others.

Contact information

If you have any questions or concerns regarding this Recruitment Privacy Statement or the processing of your personal data by us, you can contact us through email privacy@a1qa.com.

This Privacy Statement may be changed. We will provide the updated version on our website.