Applicant Privacy Notice

1. Background, Scope & Applicability. This Applicant Privacy Notice ("Notice") applies to all individuals ("Applicant", "you", or "your") applying for roles, either directly or through third parties, at ELTEMATE (i.e., HLTech Legal Technology & Consulting B.V. and their present and future subsidiaries, "ELTEMATE" "we", "us", or "our") including applications submitted via email, LinkedIn, recruitment agencies, job boards, or post. You are considered an Applicant till either the application process has been concluded, you withdraw your application or the retention period for unsuccessful applications has expired. This Notice helps ELTEMATE comply with data protection laws such as the EU General Data Protection Regulation ("GDPR"), the UK General Data Protection Regulation ("UK GDPR"), the Dutch Data Protection Act ("AVG"), the German Federal Data Protection Act ("BDSG"), the Singapore Personal Data Protection Act ("PDPA"), and the Brazilian General Data Protection Law ("LGPD"). This Notice supplements ELTEMATE’s Privacy Policy and applies specifically to application-related data processing.
   
   
2. Data Controller. ELTEMATE, headquartered at 2Amsterdam Building, Eduard van Beinumstraat 10, Amsterdam 1077 CZ, The Netherlands, is the data controller responsible for processing your personal data.
   
   
3. Types of Collected Data. We collect, either directly or indirectly, the following categories of personal data, which is any information that can potentially identify you directly or in combination with other information ("Data").

1. 1. Identification Data, such as name, contact details, date of birth, nationality, ID documents etc.
   2. Application Data, such as CV, education, work history, and skills.
   3. Screening Data, such as background checks, and employment/education verification.
   4. Application Process Data, such as interview notes, assessments, and feedback.
   5. Correspondence Data, such as communications with ELTEMATE or third parties.
   6. Technical Data (Site Data), such as IP address, browser type, and cookies.
   7. Third-Party Data, such as references, background checks, and public profiles.
   8. Future Opportunities Data, such as name, email address, and the types of roles you may be interested in etc.
   9. Sensitive Data, such as health, criminal records, only processed when legally required or with your consent
      

  4. Purpose and Legal Bases for Processing

 5. Data Protection Measures. We protect your Data through implemented access control and encryption, regular security assessments, and contractual obligations imposed on third parties.           While reasonable measures are in place, no system is completely secure. We cannot guarantee absolute security, especially over networks we do not control.

 6. Internal Data Sharing. Data may be shared internally with HR, hiring managers, legal, management and with other ELTEMATE entities for recruitment purposes, and in accordance with our        legitimate interests.

 7. External Data Sharing. Data may be transmitted externally to the following recipients:

1. 1. Hogan Lovells to conduct HR and conflict checks.
   2. IT Service Providers for website operation, analytics and optimization, IT support and data storage.
   3. HR Support Companies for immigration, payroll, employment logistics and general HR administration.
   4. Employment Consultants to support us with employment logistics.
   5. Screening Agencies to conduct background verification.
   6. Healthcare Service Providers to conduct medical assessments for facilitating special working conditions
   7. Legal and Regulatory Authorities to help comply with the law.
   8. Professional Advisors for legal and financial advice.
   9. Business Transaction Partners for mergers and acquisitions.

 8. Screening, Conflict Checks & Medical Assessments. Based on where the Applicant is located, which positions are open and which jurisdiction the Applicant may work from, ELTEMATE        may involve the following third-party service providers:

1. 1. Hogan Lovells to conduct conflict checks globally.
   2. HireRight to conduct employment and education verification in the EU/EEA.
   3. Accurate to conduct background checks in the United Kingdom.
   4. Dutch Ministry of Justice to request a Certificate of Conduct (VOG) in the Netherlands.
   5. German Federal Office of Justice to request a Certificate of Good Conduct (Führungszeugnis) in Germany.
   6. Roodlane Medical to conduct medical assessments in the United Kingdom.

 For further information, you are required to independently review the privacy documentation of the third-party service providers, linked above. Similar processes for Applicants may also be in place in other non-EU/EEA or non-UK jurisdictions.

 9. Data Retention and Deletion. We and our third-party service providers retain Data only as long as it is necessary to process your application. If your application is unsuccessful or if you withdraw your application, we delete your Data– in accordance with applicable laws. Your Data will become part of the employee personnel file if your application is successful. For further information on the retention periods, contact dpo@eltemate.com.

 10. International Data Transfers. Data may be transferred outside the EU/EEA/UK/Brazil by relying on certain safeguards, such Adequacy Decisions, Standard Contractual Clauses (SCCs), Intra-Group Data Transfer Agreements and Supplemental Security Measures.

 11. Privacy Rights. As an Applicant you have certain rights as a data subject. Please refer to our Privacy Policy for further information.

 12. Contact Details. For questions or to exercise your rights, contact dpo@eltemate.com.

 13. Changes to this Notice. This Notice may be updated, and we will take reasonable steps to inform you regarding changes that may have a substantial effect on you.