Recruitment Privacy Notice

1. Controller and contact

Controller: APPLYFT LTD (HE 461540).

Contact: hello@applyft.co

Registered office/business address: Griva Digeni, 78, 2nd floor, Flat/Office B1, Neapoli, 3101, Limassol, Cyprus.

2. Categories of Personal Data

We may process:

2.1 Identity and contact: name, email, phone, location/country.

2.2 Professional information: CV/resume, employment history, education, skills, certifications, languages, portfolio, GitHub/LinkedIn links (if provided), salary expectations (if you choose to disclose).

2.3 Recruitment process data: interview scheduling, interview notes, assessment results, communications, decision rationale.

2.4. References: referee contact details and feedback, where you provide references.

3. Purposes and legal bases

We process candidate data to:

3.1 Evaluate suitability and administer recruitment (screening, interviews, selection, offers).

Legal basis: legitimate interests (Art. 6(1)(f)) and/or steps prior to contract (Art. 6(1)(b)).

3.2 Communicate with you during the process.

Legal basis: legitimate interests (Art. 6(1)(f)).

3.3 Conduct proportionate checks (where lawful and relevant): verification of information, portfolio review, reference checks.

Legal basis: legitimate interests (Art. 6(1)(f)) and/or legal obligation (Art. 6(1)(c)) depending on role/jurisdiction.

3.4 Comply with employment and anti-discrimination obligations where applicable.

Legal basis: legal obligation (Art. 6(1)(c)).

3.5 Establish, exercise, or defend legal claims.

Legal basis: legitimate interests (Art. 6(1)(f)).

3.6 Talent pool / future roles (optional).

Legal basis: consent (Art. 6(1)(a)) (recommended for retention beyond the specific vacancy).

If we process special category data, we will rely on an applicable Article 9 GDPR condition (e.g., explicit consent or employment/social protection law) with safeguards.

4. Automated decision-making

We do not intend to make purely automated decisions producing legal or similarly significant effects without meaningful human involvement.

5. Recipients

We may share candidate data with:

• internal stakeholders involved in hiring (Recruitment, HR, hiring managers, interviewers) on a need-to-know basis;
• service providers (e.g., recruitment platforms, email/scheduling, assessment providers, HR systems) acting as processors under contract;
• professional advisers and authorities where required by law.

6. International transfers

Where vendors process data outside the EEA, we implement appropriate safeguards (e.g., SCCs) and supplementary measures where required.

7. Retention

• Unsuccessful candidates: typically retain for 6-12 months after closure to manage queries and legal claims.
• Talent pool: retain for 12–24 months only if you consent (or other lawful basis applies).
• Successful candidates: relevant data becomes part of personnel records, processed under employment privacy notices/policies.

8. Your rights and how to exercise them

You may request access, rectification, erasure, restriction, portability, and object to processing based on legitimate interests; and withdraw consent where relevant.

Contact: hello@applyft.co

9. Complaints (Cyprus authority)

You may lodge a complaint with the Commissioner for Personal Data Protection (Cyprus) (email commissioner@dataprotection.gov.cy; address 1 Iasonos Street, 1082 Nicosia, Cyprus).

10. Governing law and jurisdiction

This Notice is governed by the laws of the Republic of Cyprus and disputes shall be subject to the Cyprus courts, subject to mandatory rights under applicable law.