Candidate Privacy Notice

1. Purpose and Scope

We process applicant data in accordance with this Candidate Privacy Notice (the “Notice”). The term “Company” (also referred to as “we”, “our”, or “us”) refers to the legal entity responsible for processing your personal data when you apply for an employment role: Simoresta UAB (registration number 303108621, registered address Kuršių g. 1, K2, Slengių k., Klaipėdos r., Lithuania), which acts as the data controller for all personal data processed during the recruitment process.

For the purposes of this Notice:

  • “Candidate” or “you” means any natural person applying for employment (and internship opportunities, if offered by the Company).

This Notice applies to the processing of personal data from Candidates. Its purpose is to explain:

  • How we collect, process, and protect your personal data, and
  • How you can exercise your rights.

This Notice is intended to ensure the fair and transparent use of your information while protecting your personal data and privacy.

2. Legal Basis

Any personal data that the Company gathers, uses, or shares about you is processed in accordance with:

  • The General Data Protection Regulation (Regulation (EU) 2016/679) (“GDPR”), and
  • Other applicable data protection and privacy laws, depending on the jurisdiction in which you apply or are engaged.

3. Principles of Personal Data Protection

The Company undertakes to ensure that your personal data is:

  • Accurate and, where necessary, kept up-to-date;
  • Kept in a form which permits your identification for no longer than is necessary for the purposes for which the personal data was processed;
  • Collected for specified, explicit, and legitimate purposes and not further processed in a manner that is incompatible with those purposes;
  • Adequate, relevant, and limited to what is necessary in relation to the purposes for which it is processed;
  • Processed lawfully, fairly, and in a transparent manner in relation to you;
  • Processed in a manner that ensures the appropriate security of your personal data.

The Company follows the above-indicated principles strictly during the processing of your personal data and requires the same from processors acting on the Company’s behalf.

4. Purposes, Legal Bases, and Categories of Personal Data

We collect and process Candidates’ personal data only to the extent necessary for recruitment and related purposes. Your information is used to evaluate your suitability for a specific job (and internship opportunities, if applicable), to make hiring decisions, and, if successful, to prepare for the conclusion of an employment contract. In certain cases, we may also process data to comply with legal obligations (for example, verifying eligibility to work or other statutory or regulatory requirements). If you do not provide the personal data necessary for recruitment or for the preparation or performance of a contract, we may be unable to consider your application, enter into an agreement with you, or perform related functions.

In some cases, you may provide us with details of other individuals (for example, referees). Where you do so, you are responsible for informing those individuals and drawing their attention to the provisions of this Notice.

We generally do not process special categories of personal data about Candidates. Exceptions may apply only where such processing is strictly required to confirm that you meet the applicable legal requirements necessary for the position.

Categories of Personal Data

Depending on the position applied for and the information you choose to provide, we may process the following categories of personal data:

  • Personal identification data – name, surname, date of birth (age);
  • Contact details – address, telephone number, email address, or professional social network profile link(s);
  • Location information – country, city, or region of residence (to assess suitability for remote or on-site positions);
  • Data on qualifications and experience – employment history (e.g., employer, period of work, duties, responsibilities, achievements), education details (e.g., institution, study period, degree/qualification), professional training and development (e.g., courses attended, certificates obtained), skills (e.g., languages, IT), and other information you provide in your CV, cover letter, professional profile (e.g., LinkedIn), or documents received from third parties;
  • References and recommendations – contact details of referees or former employers, and the content of their feedback or recommendations;
  • Evaluation data – interview summaries, results of tests, tasks performed, or similar assessments;
  • Compensation-related data – information on your salary expectations, if voluntarily provided or requested during the recruitment process;
  • Photographs/Images – if voluntarily provided;
  • Audio and video recordings and interview transcriptions generated using AI-assisted tools (e.g., Metaview), where applicable.

Purposes and Legal Bases

The table below outlines the purposes of processing your personal data, the legal bases we rely on, and the categories of data that may be processed.

Purpose of processing Legal basis Categories of personal data
Recruitment and selection:

• assessing your application, qualifications, and suitability for a role;
• managing the hiring process; and
• preparing an employment contract where appropriate.

This may include the use of AI-assisted interview tools (e.g., Metaview) to record and transcribe interviews, automatically generate summaries and notes, and assist hiring managers in ensuring fair, consistent, and well-documented recruitment decisions.		 • Processing necessary to take steps at your request prior to entering into an employment contract;
• Legitimate interests of the Company in obtaining references and assessing the suitability for a role;
• Candidate’s consent (voluntary and withdrawable) when interviews are recorded or transcribed using AI-assisted tools.		 • Personal identification data;
• Contact details;
• Photographs/Images (if voluntarily provided);
• Data on qualifications and experience;
• References, recommendations, employers’ feedback;
• Evaluation information;
• Audio and video recordings, interview transcripts, automatically generated summaries, notes, and related interview metadata (e.g., date and time);
• Other information you provide.
Administration of the Candidate database (talent pool) – maintaining a record of applicants for current and future opportunities. Candidate’s consent (voluntary and withdrawable at any time). • Personal identification data;
• Contact details;
• Photographs/Images (if voluntarily provided);
• Data on qualifications and experience;
• References, recommendations, employers’ feedback;
• Evaluation information;
• Other information you provide.
Compliance with legal obligations – verifying eligibility to work, meeting regulatory or statutory requirements. Legal obligation. • Personal identification data;
• Contact details;
• Documents required by applicable law (e.g., eligibility to work).

5. Methods of Personal Data Collection

We primarily process the personal data that you provide to us during the recruitment process. This may include information contained in your CV, cover letter, application form, questionnaires, references, correspondence, interview notes, assessments, and other materials you choose to submit.

During interviews, we may also collect personal data through an AI-assisted tool (Metaview) that records and transcribes interviews to generate summaries and notes. The tool is used solely to support fair, consistent, and well-documented evaluation of Candidates.

In addition, we may obtain personal data about you from other sources, such as:

  • Referees you have named in your application;
  • Recruitment agencies or headhunters;
  • Job boards, professional networking platforms, or other recruitment service providers;
  • Relevant public authorities or official registers where applicable and permitted by law.

When a Candidate’s application is submitted through a recruitment service provider (e.g., job board or intermediary), we rely on that provider to ensure compliance with applicable data protection requirements before forwarding your details to us.

We may also contact your previous employers to obtain information relating to your qualifications, skills, and professional experience. However, if we wish to contact your current employer, we will only do so with your explicit written consent.

6. Disclosure of Personal Data to Other Parties

We disclose personal data only where there is a lawful basis for doing so and always in accordance with applicable legal requirements. Your data may be shared with:

  • Third parties assisting in recruitment, Candidate evaluation, and related services, including providers of interview recording and transcription tools that support fair and consistent assessment of Candidates;
  • Public authorities or competent institutions, where required by law or necessary to establish, exercise, or defend legal claims;
  • Service providers who support us in areas such as HR systems, IT infrastructure (including cloud services), communication, consultancy, and similar support functions;
  • Other persons or entities where disclosure is necessary to fulfil legal obligations, protect our legitimate interests, or where you have provided your consent.

All third parties that process personal data on our behalf are required to apply appropriate safeguards and handle such data in accordance with GDPR and other applicable data protection laws.

We do not transfer personal data of Candidates located in the European Union or European Economic Area (EEA) outside the EEA unless such a transfer is necessary and carried out in compliance with applicable data-protection laws and supported by appropriate safeguards. Where relevant third parties process personal data of EU/EEA Candidates outside the EEA, we ensure that such transfers take place only where an adequate level of data protection is provided — for example, through an adequacy decision of the European Commission, Standard Contractual Clauses, or other legally approved safeguards.

7. Your Rights and How to Exercise Them

As a Candidate, you have the following rights under applicable data protection laws:

  • The right to be informed about the processing of your personal data;
  • The right to request access to your personal data;
  • The right to request rectification of your inaccurate or incomplete personal data;
  • The right to request erasure of your personal data, except where further processing is necessary;
  • The right to request restriction of processing while the lawfulness of processing is being verified;
  • The right to request the transfer of your personal data to another controller, where technically feasible, or to provide it directly to you in a commonly used, machine-readable format (applicable to personal data you have provided and which is processed automatically based on your consent or for the conclusion or performance of a contract);
  • The right to withdraw consent at any time, without affecting the lawfulness of processing carried out before withdrawal;
  • The right to lodge a complaint with the relevant supervisory authority, if you believe that your personal data is being processed unlawfully.

To exercise your rights, you may contact us using the details provided in this Notice. We may ask you to confirm your identity before responding to your request.

We will provide a response within one (1) month of receiving your request. In complex or exceptional cases, we may extend this period by up to two (2) further months, and we will inform you in advance. Requests may be refused only where justified under the GDPR or other applicable laws, and in such cases you will be informed in writing of the reasons.

8. Data Retention

If your application is not successful, your personal data will be stored until the recruitment process has ended.

Interview recordings, transcriptions, and automatically generated notes created through AI-assisted tools (e.g., Metaview) are stored securely for up to 14 days after the interview and then permanently deleted.

With your consent, we may retain your application and related personal data for up to two (2) years for consideration in future recruitment opportunities, unless you request earlier deletion. You may withdraw your consent at any time by contacting us at [email protected] .

If you are hired, the data provided during recruitment will be further processed for internal administration purposes, in accordance with your employment contract, and applicable legal requirements.

In certain cases, we may retain personal data for longer periods, for example:

  • Where necessary to defend legal claims or exercise our rights;
  • Where there are reasonable grounds to suspect unlawful activity;
  • Where data is needed to resolve a dispute or complaint;
  • Where longer retention is required by law.

9. Security of Your Data

We implement technical and organizational measures to protect personal data against unauthorized access, use, or disclosure. Our service providers are carefully selected and required to ensure confidentiality and apply appropriate safeguards.

Please note, however, that communications sent over email or mobile networks may not always be fully secure due to factors beyond our control. You should exercise caution and avoid providing personal data in circumstances you consider suspicious or where the recipient cannot be verified.

10. Contact Details

Simoresta UAB is the data controller responsible for processing your personal data during recruitment. You may contact us at [email protected] .

11. Notice Updates

We may occasionally make changes to this Notice. The most recent version of this Notice will always be available on our website.