How Tengai AB Handles Your Personal Data

ABOUT YOU

We only collect and process personal data about you when we need to, and for a specific purpose – which of course is different depending on your relationship with us.

Click on the category below that best matches you, to learn more about why we need your personal data, what data is needed for that purpose, and how we process it. You will also learn under what circumstances we share that data with suppliers or partners.

WHO WE ARE

Tengai AB (559196-2377) (hereafter Tengai, we or us) is the data controller for the processing of your personal data described in this policy. This means we have a responsibility to keep your personal data safe, to only use it for legal purposes, and to inform you about it – so that you can exercise your rights!

WHAT THIS POLICY COVERS

At Tengai AB we respect your privacy and want you to feel safe and informed of how your personal data is processed by us. Here you will find information about which information about you that Tengai processes, for what purposes, the legal basis for the processing, for how long the information is processed and your rights under GDPR (General Data Protection Regulation (EU) 2016/679). This privacy policy governs the manner in which Tengai AB collects, uses, maintains and discloses information about you, including processing in connection with the world’s first unbiased interview robot (hereafter “Tengai Robot”). This privacy policy also applies to the websites (www.tengai-unbiased.com and www.tengai-recruit.com) and all products and services offered by Tengai AB.

 

THIRD COUNTRY TRANSFERS

In some cases, the best suppliers are outside of the EU, and to not deprive us, or you, of these possibilities, we will occasionally use a sub-contractor outside the EU/EES. This puts extra demands on us to ensure that the processing of personal data is given pretty much the same protection as you could expect if it took place in the EU. Currently, personal data is transferred to, and processed by, the following data processor(s) in so called third countries (where personal data is either processed and/or under control of people in areas outside of EU/EES).

For processing of audio files and for the purpose of research and development:

  • Amazon AWS (USA), SCC (Standard Contractual Clauses).
  • Google ASR (USA), SCC (Standard Contractual Clauses).

Even though Amazon is subject to the GDPR just like any company processing personal data of data subjects within the EU, they also have responsibilities under American legislation. This means that some of the data they process on our behalf and (commercially) under our command, could be further shared with American authorities during the course of mass surveillance. To mitigate this risk, we have gone to great lengths in separating any identifiable information about you from the audio files that they process, so that any audio file is only tied to a universally unique identifier (uuid), as well as state of the art in transit encryption. We will continue to monitor the situation, to keep you informed and further update our protection when possible.

 

LEGAL BASIS

In order for us to be able to process your personal data, we must have a legal basis for each personal data processing. There are six available legal bases under the GDPR and there are four that are relevant to us:

Consent – You have given us permission to process your personal data for a specific purpose, being fully informed about what data we process, how and why. You can withdraw your consent at any time, after which we will stop any process for this purpose, without negative impact on any contract with us.

Agreement – You have entered into an agreement with us or have asked us to do so. We will manage your personal data to fulfil the terms and conditions of the agreement.

Legal obligation – We, as a company, must process your personal data in order to comply with legislation.

Legitimate interest – When we have a legitimate interest in processing your data, the purpose is similar to that which it was collected for, and while there is little risk of the processing infringing on your privacy, we may rely on the legal basis of legitimate interest.

Click on the relevant category of data subjects (menus on top) to learn more about what specific legal basis we use for each purpose.

YOUR RIGHTS

Right to access

You have the right to know what personal data we process about you and for what purpose. This is easily exercised through a so-called Data Subject Access Request (DSAR). Find our contact details below to start the process. To make sure that no one except you gets access to your data for this purpose, we will first ask you to identify yourself. This can be done more than once but be aware that misuse of this right and excessive amounts of requests will result in a small charge to cover our administrative expenses.

Right to rectification

You have the right to have inaccurate personal data about you rectified. You can also ask us to supplement any incomplete personal data.

Right to deletion

You can request that we delete the personal data we process about you, if any of the following applies:

  • If the personal data were obtained and are processed with the legal basis of your consent and you want to revoke your consent.
  • The personal data are no longer necessary for the purposes for which they were collected or otherwise processed.
  • If deletion is required to fulfill a legal obligation.
  • If the personal data has been processed illegally.

If you request to delete of your personal data, we will make an effort to also inform those we may have provided/transferred the personal data to about the request.

Right to restriction

You have the right to request that our processing of your personal data is restricted. Restriction means that the data information is marked so that in the future it may only be processed for certain limited purposes. We may also restrict the processing awaiting a decision on deletion.

Right to data portability

You have the right to obtain your personal data in a structured and machine-readable format. You also have the right to get your personal data transferred to another data controller, where technically feasible. This right only applies to personal data which you yourself have provided us, and when the data has been processed on the legal basis of consent or contract.

OUR CONTACT DETAILS

If you would like to get in touch with us regarding our processing of your personal data, you can send an e-mail to hello@tengai-unbiased.com. At this address you can also:

  • Make a DSAR (Data Subject Access Request, for information of all personal data processing on your person), as well as request modification or deletion of your personal data;
  • Submit comments or suggestions regarding our Privacy Policy.

Or, if you would rather get in touch with us by post:

Tengai AB

Box 637

101 32 Stockholm

SUPERVISORY AUTHORITY

If you believe that we in any way violated your rights during the processing of your personal data, you can lodge a complaint regarding this to Datainspektionen (The Swedish Data Protection Authority). They are the supervisory authority in Sweden and are monitoring the application of the GDPR.

Contact Information:

Telephone: 08-657 61 00

E-mail: datainspektionen@datainspektionen.se

Fax: 08-652 86 52

Post address:

Datainspektionen

Box 8114

104 20 Stockholm

For further information visit their website: www.datainspektionen.se.

1. Candidates

When you apply for a job at a company other than us, which uses Tengai Robot, that company is generally considered the data controller for personal data processing. They are responsible to inform you about this, please check their privacy policy.

When you apply for a job at Tengai or at another company where we decide on the process (what questions to ask and why), we are the data controller of the personal data processing as described below.

WHY DO WE PROCESS YOUR PERSONAL DATA?
  • Manage your application for job vacancies, which means that we evaluate your competencies – professional knowledge and experience, talent, motivation, and personality.
  • Offer you jobs related to your wishes and/or your competencies, as well as to provide you with personalized offers, information or invitations that we consider to be of interest to you.
  • Continuous communication about the jobs you applied for.
  • Other statistical purposes, e.g. to maintain and develop the quality of our services.
  • For development and research purposes.

 

WHAT PERSONAL DATA MAY WE COLLECT AND PROCESS?
  • Name
  • In some cases, we may, in connection with a recruitment process, obtain a so-called background check. This may contain information about your income, information from Skatteverket (Tax Authority) and Kronofogdemyndigheten (Enforcement Authority), marital status, driving license, lawsuits, and any judgments. Before we obtain that information, we will ask for your written consent. Please note that the above information is not saved by us.
  • E-mail address.
  • Mobile phone number.
  • Competences and previous experience through your CV, your LinkedIn or Facebook profile (if you registered your application through any of these channels), through interviews and based on the knowledge and experience you inform us of.
  • Test results, if you performed tests as part of our unbiased recruitment process.
  • Photography, if you included one in your CV.
  • Personal identity number, if you are a final candidate in a process, we need to be able to validate your identity.
  • Transcribed answers from the interview with Tengai Robot.
  • Other personal data you choose to share with us in your CV and possibly other uploaded documents.*

* We advise you not to provide us with sensitive personal information regarding ethnic origin; political opinions; religious or philosophical beliefs; membership of trade union, information on health, and information on gender affiliation. We, therefore, reserve the right, without your consent, to delete all the above information, as well as personal information relating to others than yourself.

 

HOW WE COLLECT YOUR PERSONAL DATA

From you:

  • We have received the information from you when applying for a job.

By us:

  • We have collected the data when you have e-mailed, phoned us or provided contact information when you asked us to contact you.
  • We have collected the data automatically during your visits to our website by saving interesting job ads or chatting with us.

From third party:

  • We have collected the data from another source – eg. reference persons, our customers or job sites such as LinkedIn and Monster.

WHAT LEGAL BASIS DO WE BASE OUR PROCESSING OF YOUR PERSONAL DATA ON?

When you apply for a job with us, we process your data based upon you wanting an employment contract with us (legal basis: agreement, under GDPR). Some processing is only done after your explicit consent, for example, photographs when that is not strictly necessary to fill a position.

When we are responsible for the screening process at another company, we are responsible for the processing and base it on our legitimate interest.

 

WHO WE SHARE YOUR PERSONAL DATA WITH

We share your personal data with sub-contractors (sub-processors) who perform services on our behalf (such as technical, administrative, market-related, or other services) when required for the purposes mentioned above. These suppliers may not use your personal data for their own purposes, which we have regulated in agreements with these suppliers.

Your personal data may also be disclosed when required by law such as, for example, the Discrimination Act or to the Data Protection Authority.

We use the following categories of sub-contractors (processors):

  • Storage, research and development, USA (see THIRD COUNTRY TRANSFERS).
  • CRM-Software.
  • Back-office functionality.
  • Robot platform supplier.
  • Software development.

When a recruitment company or one of our clients use Robot for part of their recruiting process, they are themselves controlling the purpose and means and are therefore the data controller (they will inform you about this themselves).

HOW LONG WILL WE KEEP THE DATA?

We will keep your personal data as long as we have your consent and we have a further use and purpose for the data. When your personal data is processed to protect our legitimate interest, we will keep the data for 24 months due to the provisions of the Discrimination Act and possible appeals.

We do not keep your personal data for undefined purposes.

2. Employees

WHY DO WE PROCESS YOUR PERSONAL DATA?
  • When you become an employee of Tengai, you enter into an agreement with us as an employer. We are also required to process personal data about you to comply with several different types of legislation that we as an employer are subject to.

 

WHAT PERSONAL DATA MAY WE COLLECT AND PROCESS?
  • Name.
  • Address.
  • Phone number.
  • Personal identity number.
  • E-mail address.
  • Bank account number.
  • Salary, pension and benefits.
  • Employment history and time reporting.
  • Medical history.
  • Photographs.
  • Family Relationship – Nearest relative as emergency contact. Number of children and their birth year if you have small children for whom you are entitled to compensation from the Swedish Social Insurance Agency.
  • Allergies and sensitivity to foodstuff.
  • Information related to your achievements such as annual follow-ups and completed courses.

Please note that the above list is not exhaustive and other information may be considered.

HOW WE COLLECT YOUR PERSONAL DATA

From you

  • You have stated these yourself in the recruitment process and in connection with the start of your employment, as well as during your employment.

By us

  • The data has been generated associated with your employment. For example, data about your attendance, sick leave and vacation.

From third parties

  • The data has come from other sources such as authorities, third-party suppliers who provide services for us (salaries), and from reference persons and customers.

 

WHO WE SHARE YOUR PERSONAL DATA WITH

We share your personal data with third party providers that we use to perform services on our behalf (such as technical, administrative, market related, or other services) when required for the purpose of managing your employment. These third-party suppliers may not use your personal data for their own purposes, which we have regulated in agreements with these suppliers.

We use the following categories of sub-contractors (processors):

  • Accounting services.
  • Human resources platform.
  • Employee benefits platform.

We share data within our company group, Key People Group, based on our legitimate interest and for administration purposes.

 

WHAT LEGAL BASIS DO WE BASE OUR PROCESSING OF YOUR PERSONAL DATA ON?

As our employee, you have an employment contract. When you later end your employment, we must, according to Swedish law, further process some of your personal data, for example to ensure you get the right pension (legal obligation). We may also keep some of your personal data based on your consent, to act as a reference for future employment elsewhere.

 

HOW LONG WILL WE KEEP THE DATA?

We will keep your personal data as long as is needed to fulfill our obligations from your employment, to fulfill legal obligations, or as long as your consent is valid, based on the purpose and legal basis of the processing. We do not keep data just for the sake of keeping data.

3. Suppliers

WHY DO WE PROCESS YOUR PERSONAL DATA?

We may process personal data about you (as an employee of our supplier), to maintain our professional relationship and ensure continued services between our companies. This may apply to personal data concerning customer managers, support functions, service personnel, finance department or other key personnel.

 

WHAT PERSONAL DATA MAY WE COLLECT AND PROCESS?
  • Name.
  • Title.
  • Phone number for work.
  • Mail address to work.

 

HOW WE COLLECT YOUR PERSONAL DATA

From you:

  • Through emails and information by phone.

By us:

  • We have found the data on your company’s website.

From third party:

  • We have received the data from your employer or colleague.
WHO WE SHARE YOUR PERSONAL DATA WITH

We share your personal data with sub-contractors (sub processors) who perform services on our behalf (such as administrative, market-related or other services) when required for the purposes mentioned above. These suppliers may not use your personal data for their own purposes, which we have regulated in agreements with these suppliers.

We use the following categories of sub-contractors (processors):

  • Customer relationship management system.

 

WHAT LEGAL BASIS DO WE BASE OUR PROCESSING OF YOUR PERSONAL DATA ON?

We have a legitimate interest based on a contract with your employer.

 

HOW LONG WILL WE KEEP THE DATA?

As long as you are an important contact for us regarding our professional relationship, we will save your data. If it comes to our knowledge that your duties at your company have changed or that you no longer are employed, the data will be deleted.

4. Customers and potential customers

WHY DO WE PROCESS YOUR PERSONAL DATA?

Customer: If you work at one of our customer companies, as a recruitment manager or as a contact person, we process certain personal data to be able to maintain our professional relationship and to provide the service to our customers as well as keep you updated by periodic emails. Further, to comply with legislation eg. Book-keeping Act and tax law.

Potential customers: To be able to offer our services to companies that don’t know about us or don’t buy services from us, we collect contact information for key people at companies that we want to be able to contact and process for marketing purposes.

Demo participant: If you sign up for a demo at our website, we will process your personal data in order to send you an invitation for the demo and also to reach out afterwards and ask you how your experience was. If we perform demo on site with you, we will process your interview with the Tengai Robot to demonstrate its functions.

Customer service requests: Information you provide helps us respond to your customer service request and support needs more efficiently.

 

WHAT TYPES OF PERSONAL DATA MAY WE COLLECT AND PROCESS?
  • Name.
  • Title (your workplace/where you work).
  • Phone number for work.
  • Mail address to work.
  • IP address.
  • Notes on our cooperation and / or dialogues.
HOW WE COLLECT YOUR PERSONAL DATA

From you:

  • When you signed the demo request form at our website.
  • By visiting our website, signing up for and visiting any of our events.
  • Subscribing to newsletters regarding HR-news and information about unbiased recruitment.

By us:

  • We will continuously update our CRM database. This means that we continuously work on having an updated and up-to-date database of current and correct contact information. This will be done through contacts with you by phone, e-mail, social media and in personal meetings, but also through external sources.
  • Notes about our discussions and decisions.

From third party:

  • from your employer or colleague.
  • We have found the data on the Internet. It can be from the company’s website or at job sites such as LinkedIn (publicly accessible sources).
  • We have received your contact information from our sister companies within the company group – Key People Group AB.
  • We have purchased data from external sources.
WHO WE SHARE YOUR PERSONAL DATA WITH

We share your personal data with sub-contractors that we use to perform services on our behalf (such as technical, administrative, market-related or other services) when required for the purpose of managing our collaboration or for us to process you as a potential customer. These sub-contractors may not use your personal data for their own purposes, which we have regulated in agreements with these suppliers.

We use the following categories of sub-contractors:

  • Storage, research and development, USA (see THIRD COUNTRY TRANSFERS).
  • CRM-Software.

We share data within our company group, Key People Group, based on our legitimate interest and for administration purposes.

 

WHAT LEGAL BASIS DO WE BASE OUR PROCESSING OF YOUR PERSONAL DATA ON?

When we provide services as well as market ourselves to other companies and process personal data of their employees, we use legitimate interest as a legal basis. When you have signed up for a demo, we will process your personal data based upon your consent. For personal data processing to comply with legislation, eg. Book-keeping Act, we base the processing on legal obligations.

 

HOW LONG WILL WE KEEP THE DATA?

As long as you are an important contact for us regarding our professional relationship, we will save your data. If it comes to our knowledge that your duties at your company have changed or that you no longer are employed, the data will be deleted. For the processing based upon consent, we will process your personal data until you revoke your consent.

5. Other data subject

WHY DO WE USE YOUR PERSONAL DATA?

References in an employment procedure

References are contacted in a recruitment process. For us to be able to contact the reference we need name and telephone number. In most cases, we also need to know the reference’s position and relationship with the candidate (e.g. manager).

Emergency contacts / closest relative of employees

When someone is employed, we collect a so-called emergency contact, a close relative of the employee whom we can contact if it should happen during working hours or on commitment / travels that takes place within the framework of work.

Social media contacts

People who contact us on social media, by phone, website (including chat) and by email.

If you as an individual have contacted us with questions of any kind, we may save your personal data in order to be able to contact you later on.

Partners and re-sellers

Collaborators, colleagues in our industry, people in professional networks, media contacts etc. We may save your contact information for future communication. We, as a company, must be able to save this information in order to effectively operate in the market and create relationships that promote our and other companies’ growth.

Website visitor

To improve our website, we may use feedback you provide to improve our products and services 

Survey participant

To run a promotion, contest, survey or other website feature or to send information you agreed to receive about topics we think will be of interest to you.

Newsletter / periodic email subscribers

If you decide to opt-in to our mailing list, you will receive emails that may include company news, updates, related products or service information, etc.

 

WHAT PERSONAL DATA MAY WE COLLECT AND PROCESS?

We may collect personal data from you in a variety of ways, including but not limited to, when you visit our site, register on the website, subscribe to the newsletter, respond to a survey, fill out a form, and in connection with other activities, services, features or resources we make available on our website. We may collect, as appropriate, name, email address and phone number.

We may collect non personal identification information about visitors whenever they interact with our website. Non-personal identification information may include the browser name, the type of computer and technical information about visitors means of connection to our website, such as the operating system and the Internet service providers utilized and other similar information.

HOW DID WE COLLECT THESE PERSONAL DATA?

From you:

  • You have contacted us via Facebook, Messenger or Instagram when you commented on something or was asking us questions within these media.
  • We have received personal data from you personally, by mail or business card.
  • We have received personal data from you when asking us to be contacted or having contacted us via telephone, social media, website (including chat), info-mail or personal mailboxes.

By us:

  • We have found the data in our own individual networks on eg. LinkedIn.

From third party:

  • We have received personal data from your employer or colleague.
  • We have received personal data from job seekers for reference purposes.
  • Someone named you as an emergency contact.

 

WHO WE SHARE YOUR PERSONAL DATA WITH

We distinguish between people who are in contact with us as a private person and people who are in contact with us as a representative from another company. Personal data for private persons, we are more restrictive with and generally don’t share these data with anyone external. When it comes to personal data for professionals, we are not as restrictive, as sharing contacts within the professional network promotes business and corporate growth. We have the opinion that personal data regarding representatives from a company isn’t as sensitive to privacy as personal data relating to a private person.

We use sub-contractors that perform services on our behalf (such as technical, administrative, market-related or other services) when required for the purpose of managing contacts with other stakeholders. These sub-contractors may not use your personal data for their own purposes, which we have regulated in agreements with these suppliers.

We use the following categories of sub-contractors:

  • Storage, research and development, USA (see THIRD COUNTRY TRANSFERS).
  • CRM-Software.
  • Survey platform.
  • Social media platforms.
  • Backoffice functionality.

We share data within our company group, Key People Group, based on our legitimate interest and for administration purposes.

 

 

WHAT LEGAL BASIS DO WE BASE OUR PROCESSING OF YOUR PERSONAL DATA ON?

The legal basis for processing personal data for this group may vary depending on in what respect our contact has arisen. In most cases, we will use legitimate interest as a legal basis. If we see that the individual who’s personal data, we processed ends up in one of the other interest groups, the legal basis that is applicable to that group will apply.

If at any time you would like to unsubscribe from receiving future emails, we include detailed unsubscribe instructions at the bottom of each email or you may contact us via our website.

 

HOW LONG WILL WE KEEP THE DATA?

References in a recruitment process

The references’ contact details will be saved solely regarding the candidate who has been hired. We save the data and the reference protocol together with the candidate’s other documents for 24 months due to the provisions of the Discrimination Act and possible appeals.

Emergency contacts / closest relatives of employees

Saved as long as someone is employed. The employee is responsible for ensuring that the data is correct and updated.

Social media contacts

Personal data is processed as long as the data is needed to enable and maintain communication.

Partners and re-sellers

During the process of establishing a professional relationship and contact in marketing purposes we will keep the data as long as we maintain a legitimate interest.

Website visitor

We process cookies according to our separate cookie policy. Apart from cookies that are needed for the website to run and any setting you have yourself requested, we only collect data via cookies after and based on your consent. Further processing might be based on other legal bases according to its purpose and as otherwise described in this policy.

Survey participant

We occasionally conduct surveys via our newsletter and other communication with you. This is based on your consent. The personal data is saved and processed for as long as we have your consent, or at most for as long as we need the data for the purpose of the survey.

Newsletter / periodic email subscribers

Until you decide to opt-out of our mailing list. In each email there is information about how to opt-out.