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, including HLTech (Singapore) PTE., LTD, HLTech Legal Technology & Consulting Ltda., HLTech Legal Technology & Consulting LLC, and ELTEMATE LATAM, S.A. de C.V.) (individually or collectively, "ELTEMATE" "we", "us", or "our") including applications submitted via email, LinkedIn, recruitment agencies, job boards, or post. You are considered an Applicant until 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"), the Brazilian General Data Protection Law ("LGPD"), and the Mexican Federal Law on the Protection of Personal Data Held by Private Parties ("LFPDPPP"). This Notice supplements ELTEMATE’s Privacy Notice and applies specifically to application-related data processing. For Applicants located in Brazil, this Notice also applies to the processing of personal data carried out from outside of Brazil, as provided for in Article 3 of the LGPD.

  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. Depending on your location, our local subsidiaries can also act as data controllers for recruitment purposes. You can contact our Data Protection Officer & AI Compliance Officer ("DPO") at dpo@eltemate.com.

  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. 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, which under applicable laws includes, for example, data concerning health, biometric or genetic data, or union membership. These will only be processed when legally required, strictly necessary for recruitment, or based on your consent where appropriate. Information about criminal records will only be collected where legally required to comply with applicable law.

  4. Purpose and Legal Bases for Processing

Purpose of Processing . Types of Personal Data . Legal Basis


Processing your application and
managing the recruitment process

.


Identification Data, Application Data,
Application Process Data, Third-Party Data, Correspondence Data,
Sensitive Data

 .


Legitimate interest in selecting qualified candidates, performance of pre-contractual procedures (e.g., recruitment), compliance with legal obligations, and, where required by applicable data protection laws, consent.

Communicating with you and relevant third parties regarding your application


Identification Data, Application Data, Application Process Data, Third-Party Data, Correspondence Data

Performance of pre-contractual procedures and legitimate interest in managing the recruitment process effectively.

Maintaining a talent pool and contacting you regarding future job opportunities or events


Application Data, Application Process Data, Correspondence Data, Third-Party Data

Legitimate interest in identifying candidates for future opportunities, and where required by applicable data protection laws, consent.

Improving the recruitment process and application experience


Application Data, Application Process Data, Correspondence Data, Third Party Data

Legitimate interest in enhancing our hiring practices. 

Administering, managing, and improving our website


Technical Data (Site Data)

Legitimate interest in ensuring the effective
operation of our website.

Securing our website


Technical Data (Site Data), Identification Data, Application Data

Legitimate interest in maintaining the security of our systems and data.

Cooperating with regulators and government authorities


Identification Data, Application Data, Application Process Data, Third-Party Data, Correspondence Data, Technical Data (Site Data)

Compliance with legal obligations.

Defending ELTEMATE's and other third parties' rights


Identification Data, Application Data, Application Process Data, Third-Party Data, Correspondence Data, Technical Data (Site Data)

Legitimate interest in protecting our or
third parties’ legal rights.


 5. Data Protection Measures. We protect your Data through implemented access control and encryption, regular security assessments, and contractual obligations imposed on third parties. In line with applicable laws, we adopt technical and organizational measures designed to protect personal data against unauthorized access and accidental or unlawful destruction, loss, alteration, communication, theft, or any form of improper or unlawful processing. While reasonable measures are in place, security risks cannot be eliminated entirely, particularly over networks we do not control.

 6. Internal Data Sharing. Data may be shared internally with the human resources department ("HR"), hiring managers, legal and compliance department, management and with other ELTEMATE entities for recruitment purposes. Such access is limited to personnel who need the information to perform their roles, and it is carried out in accordance with applicable laws, based on legitimate interests and, where relevant, the performance of pre-contractual procedures.

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

    1. Hogan Lovells Cadwalader 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 position the Applicant applied to and from which jurisdictions the Applicant may work, ELTEMATE may share the Applicant's Data with the following third-party service providers assisting ELTEMATE with the recruitment process:

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

 For further information, you can also review the privacy documentation of the third-party service providers, linked above. Equivalent background verification and medical assessments can also take place in other jurisdictions, always in compliance with applicable laws. Any health-related Data and information related to criminal history processed during background verification will only be collected where legally required for specific roles, and where permitted by applicable laws. Additionally, the Data will only be processed under the legal bases provided by applicable data protection laws, such as consent. By agreeing with the background verification by the third-party service providers, you are explicitly consenting to the processing of your Data by such providers.

 9. Data Retention and Deletion. We retain Data only as long as it is necessary to fulfil the purposes described in this Notice and to process your application.. 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. We may transfer your personal data to countries outside of your country of residence, which may have data protection laws and regulations that differ from those in your country. Data may be transferred between Eltemate group companies and to third-party service providers located in countries other than the country in which the data was originally collected or processed for the purposes described in this Notice. Such transfers are carried out by relying on appropriate safeguards approved under applicable data protection laws, such as Adequacy Decisions, Standard Contractual Clauses ("SCCs") Intra-Group Data Transfer Agreements, Supplemental Transfer Tools, or other lawful data transfer mechanisms, such as consent, that are recognized under applicable data protection laws.

 11. Privacy Rights. As an Applicant you have certain rights as a data subject under applicable data protection laws, including the right to lodge a complaint before your local data protection authority and to withdraw consent. Please refer to our Privacy Notice 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, including by posting the updated version of this Notice on our website at the following link - eltemate.com/applicantprivacynotice.

Last updated: 29 September 2026