Privacy Notice

Job Applicant Privacy Notice

1. Who We Are

Introduction

We, at Intelligencia Inc. (“Intelligencia”, “Company”, “we”, “us”, “our”), value your privacy and take serious steps to protect it. We have developed this Privacy Notice to inform you about our practices concerning the collection, use, and sharing of your personal data, when you apply for a position with us.

In our capacity as data controller, we adhere to the principles laid out by Regulation (EU) 2016/679 (General Data Protection Regulation, “GDPR”) and applicable data protection laws. We ensure that your data is managed with care and transparency, and that all your rights are fully respected. 

By applying for a job at our Company, you signify your acknowledgement of this Privacy Notice. This document provides essential information about your rights and our obligations. If you have any questions regarding how your data is handled, please reach out to our team at [email protected] before proceeding with your application.

2. Information We Collect

We collect, use, and retain the following types of personal data provided by you or by third parties you may have engaged (e.g., a head-hunter, a recruitment agency acting on your behalf):

  1. family name, first name, father’s / mother’s name, date of birth, contact details (address, private / business email address, telephone number);
  2. job application, CV, details of your employment history, your references, supporting documents (e.g., transcripts of degrees, certificates);
  3. interview notes and materials, and assessment reports from the hiring process.

We also collect, use, and retain the following types of personal data from third parties:

  1. information about your suitability for the role, from your nominated referees;
  2. information about your profile obtained from recruitment agencies acting on our behalf;
  3. public information about your professional background, from social media platforms you use for this purpose, particularly LinkedIn or similar platforms. 

3. Why We Process Your Data (Legal Basis)

We use your data based on the following legal grounds:

  • To evaluate your application: Where necessary to take steps at your request prior to entering an employment contract (Art. 6(1)(b) GDPR).
  • Legal Obligations: Where necessary to comply with our legal obligations, including tax, labor, or immigration laws (Art. 6(1)(c) GDPR).
  • Legitimate Interests: In connection with our legitimate interests, provided they are not overridden by your own interests, fundamental rights, or freedoms. This includes ensuring your suitability for the role you have applied for, assessing your working capacity, and in relation to any legal proceedings or to establish, exercise, or defend our legal rights. Art. 6(1)(f) GDPR).
  • Consent (Future Opportunities): If we wish to retain your CV for future roles beyond the current recruitment cycle, we will specifically ask for your explicit consent at that time (Art. 6(1)(a) GDPR).

4. How Long We Keep Your Data

  • Unsuccessful Applicants: Personal Data of unsuccessful applicants shall be processed and stored for as long as required to fulfill the recruitment and evidentiary purposes for which it was collected. Data may be retained for a longer period where necessary to comply with applicable legal or regulatory obligations, or where You have provided explicit consent for continued inclusion in a talent pool.
  • Successful Applicants: Your data will be transferred to your employee file and governed by our Employee Privacy Notice.

5. Data Sharing and Disclosure

To streamline our process, your data may be shared with:
  • Internal Teams: Hiring managers, department heads, and HR personnel involved in the selection process.
  • Service Providers: Third-party vendors who provide recruitment software (e.g. ATS), cloud services, background check services, or technical assessment platforms. These vendors are contractually bound to protect your data.
  • Legal Compliance: We may disclose data if required by law, such as for regulatory reporting or defending legal claims

6. International Data Transfers

As a general practice, your personal data is processed by our Company and is therefore subject to the GDPR, regardless of whether processing takes place at our headquarters or at our branch locations.

If your personal data is disclosed to entities outside of the European Economic Area (EEA) — that is, beyond the 27 Member States of the European Union, plus Iceland, Liechtenstein, and Norway — this will only occur only if the recipient entities are in jurisdictions recognized by the European Commission as providing adequate personal data protection, or if the transfer is enabled by appropriate or suitable safeguards or derogations consistent with the GDPR.

7. How do we protect your personal data

We implement appropriate technical and organizational measures to ensure a level of security that matches the risk of processing your personal data. We strive to prevent any loss, misuse, or alteration of your information.

Please be aware, however, that certain data operations, such as transmission over the internet, inherently carry risks. We cannot be held liable for incidents that are beyond our control.

8. Your Rights

You are entitled to exercise any of the following rights concerning your personal data that we process, subject to conditions set forth by the GDPR:

  • The right to be informed about the processing of your personal data and to access it.
  • The right to rectify or erase your personal data.
  • The right to restrict the processing of your personal data.
  • The right to object to processing of your personal data.
  • The right to data portability.
  • The right to withdraw your consent at any time in instances where data processing is based on such consent. Withdrawing your consent will not affect the lawfulness of processing that occurred prior to your notification of withdrawal. 
  • The right to lodge a complaint with a supervisory authority and seek a judicial remedy.

For clarity, the above rights apply to EU, UK and Swiss data subjects, as required under applicable law, but also any other candidate, regardless of location, may exercise any of these rights.

If you wish to exercise your rights, we kindly ask you to contact us at [email protected] to discuss your concerns.

9. Are you a US State resident

While this Privacy Notice is guided by the GDPR and the concepts of European Union law, it is also designed to align with applicable US state privacy laws (such as the California Consumer Privacy Act (CCPA), as amended, and others). This ensures that US residents are afforded protection under their local laws without any diminishment of rights.

Notice at Collection: We collect the following categories of personal information for recruitment purposes: Identifiers (name, contact info), Professional/Employment History, and Education. We may also collect Sensitive Personal Information (such as ethnicity or disability status) where permitted by law for equal opportunity monitoring or to provide accommodations.

US Candidates have the rights:

  • Right to Know & Access: You may request a report of the specific data we hold about your candidacy.
  • Right to Correct & Delete: You may request that we rectify inaccurate data or delete your information, subject to our legal obligations to retain recruitment records for audit purposes.
  • Right to Limit Sensitive Data: You have the right to limit our use of sensitive data to the specific purposes for which it was collected.
  • No Sale or Sharing: We do not sell your personal information, nor do we “share it” for cross-context behavioral advertising. We only share it with essential service providers (e.g., our Applicant Tracking System or background check vendors) to process your application.
  • Automated Decision-Making: If we use AI or automated tools to screen resumes or assess candidates, you have the right to be notified, to receive information about the logic involved, and, in certain states, to opt-out or request a human review.

Please be assured that we do not sell your personal information to third parties

To exercise these rights, please contact us at [email protected]. We will not discriminate or retaliate against you for exercising your privacy rights.

10. Security

We implement robust technical and organizational measures to protect your data against unauthorized access, loss, or misuse. This includes encryption, access controls, and regular security audits.

11. How to complain

If you have concerns about how we handle your personal data, we kindly ask that you contact us first at [email protected] so we can resolve the matter directly.

If you remain unsatisfied, you have the right to lodge a complaint with a data protection supervisory authority.

  • In the EU: You may contact the authority in the Member State of your habitual residence, place of work, or where the alleged infringement occurred. Since our EU branch is in Greece, the lead authority is the Hellenic Data Protection Authority (HDPA) (www.dpa.gr).
  • In the UK: You may contact the Information Commissioner’s Office (ICO) (www.ico.org.uk).
  • In Switzerland: You may contact the Federal Data Protection and Information Commissioner (FDPIC).
  • In the US: For residents of states with specific privacy laws (such as California), you may contact the relevant State Attorney General’s office or specialized agency (e.g., the CPPA).

12. Changes to This Notice

We may update this Recruitment Privacy Notice from time to time. The most recent version will always be available on our website or upon request.