EMCD CANDIDATE PRIVACY POLICY
Last Updated: Apr 28, 2026
This EMCD Candidate Privacy Policy (the “Policy”) explains how EMCD companies (collectively, “EMCD” or “we”):
This Policy does not apply when you use any of our services or products and it does not apply to employees and individual contractors of EMCD.
1. Collected Personal Data
1.1 In order to apply to an open position with us you might provide following personal data:
Category | Data |
Identification Data | Full name, date of birth, address of residence, date of birth, gender, your image or a recording of you, passport or ID details |
Work experience and skills | Job titles, employment history, skills, qualifications, education, achievements, languages spoken and level of proficiency |
Public profile information | If you apply using social media or HR services (such us Linkedin, Facebook) |
Technical data | IP address, browser type and version, time zone setting, browser plug-in types and versions, operating system and platform, usage data. |
Contact Data | Email, phone number, name, social media account |
Background check Data | Previous employers, criminal records / convictions, ongoing investigations (where legally permissible), court judgments and enforcement proceedings, sanctions / watchlists, credit history / score, bankruptcy records, politically exposed person (PEP) status |
Other Data | Information that we receive on interview, video footage of interview or call |
1.2 Most of data is collected directly from you, when you apply to open vacancies or communicate with talent acquisitions. However, we can also collect personal data about you from third parties.
1.3 Please note that the provision of Personal Data is entirely voluntary. Refusal to provide data may affect our decision or restrict your ability to proceed with our recruitment process.
2. Purposes, Lawfulness of Personal Data processing
2.1 We process your Personal Data for the following purposes:
Purpose | Lawful basis |
Communications with you | Your consent to receive feedback and follow recruitment process |
Verification of your information; | Legitimate interests Performance of agreement |
Identity verification; | Legitimate interests (to insure that you are suitable candidate) |
Compliance with applicable laws, legal processes, or enforceable government request; | Legal obligation, depending on applicable laws |
Candidate registry formation (notifying you of future opportunites offerings) | Your consent to receive news from us |
Carrying out background checks as appropriate and in accordance with applicable law. | Legal obligation, depending on applicable laws Legitimate interests |
Formation of blacklist | Legitimate interests (in cases of fraud or provision of false information) |
Conclude and perform agreement | Agreement between EMCD and you |
2.2 We undertake to use your Personal Data EXCLUSIVELY for the purposes stated above. Exceptions are cases where the collection and use of data are required for other purposes compatible with the original purpose, or when it is necessary in accordance with applicable laws, court decisions, or orders from executive authorities.
2.3 If we need to use your Personal Data for other purposes not specified above, we will notify you in advance and provide information about the legal grounds for such use.
3. Data Retention
3.1 We retain personal data only for as long as necessary to fulfil the purposes for which it was collected, including for the purposes of satisfying legal, regulatory, accounting, or reporting requirements.
3.2 We will retain your personal data for a period of up to 12 months following the communication of our decision. We do so to:
manage and document the recruitment process;
consider you for future opportunities (where applicable);
exercise, establish, or defend legal claims, including demonstrating that recruitment decisions were made fairly and without discrimination.
3.3 Where we wish to retain your personal data for consideration for future roles beyond the recruitment process, we will rely on:
your consent, where required; or
our legitimate interest in maintaining a candidate pool, provided such interest is not overridden by your rights.
3.4 You may withdraw your consent at any time, in which case your personal data will be deleted from the candidate pool without undue delay. Please note that some information cannot be deleted due to the applicable law requirements and legal obligations.
3.5 Notwithstanding the above, certain categories of personal data may be subject to shorter retention periods.
4. Transfer of Personal Data
4.1 We may disclose your Personal Data to third parties when we believe it is necessary to do so under a contract involving you or us, or when required by applicable laws, regulations, or legal proceedings. If we share your Personal Data with other EMCD group companies, we will make every reasonable effort to ensure they either comply with this Privacy Policy or apply data protection standards that are equally protective.
4.2 We may also share personal data with the following persons or in the following circumstances:
1. Affiliates: Personal data that we process and collect may be transferred between EMCD companies as a normal part of recruiting process.
2. Third Parties: We engage external companies to carry out recruiting and HR processes. These third-party service providers are given access only to the personal information necessary to perform their specific duties and are not allowed to use it for any other purpose.
4.3 We may use the services of foreign data processing service providers where permitted by the law applicable to the processing of your Personal Data. In addition, some jurisdictions establish requirements for storing Personal Data on servers located within the territory of the state of the Personal Data subject.
4.4 In the event of the transfer of your Personal Data we ensure compliance with all requirements of applicable law, including: (a) Ensuring an adequate level of data protection in the recipient country;
(b) Concluding agreements with data recipients containing provisions on data protection; (c) Obtaining your consent if required by law.
5. Your Rights as Subjects of Personal Data
5.1 If any of the rights listed below are not provided under law for your operating entity or jurisdiction, EMCD has absolute discretion in providing you with these rights:
Right of Access: You have the right to know whether we are processing your personal data and to request a copy of that data, along with relevant details about how it is being used.
Right to Correction: If any of your personal data is inaccurate or incomplete, you can ask us to correct or update it. You can also make changes directly in your account settings at any time.
Right to Erasure ("Right to be Forgotten"): In certain circumstances, you may ask us to delete your personal data.
Right to Object: You have the right to object to the processing of your personal data based on reasons related to your particular situation. This includes the right to object if we rely on our legitimate interests, or if your data is being used for direct marketing.
Right to Restrict Processing: Under specific conditions, you may request that we temporarily limit how we use your personal data. Even during such a restriction, we may still process your data if required for legal claims or as otherwise allowed by law.
Right to Data Portability: In some cases, you can request that we provide you with your personal data in a structured, commonly used, and machine-readable format. Where technically possible, you can also ask us to transfer this data directly to another organization.
Right to Withdraw Consent: If you’ve given consent for your data to be processed, you can withdraw it at any time. This won’t affect the lawfulness of any processing that took place before the withdrawal.
Right to File a Complaint: If you have concerns about how we handle your personal data, you can contact us. If you're not satisfied with our response, you also have the right to lodge a complaint with your local data protection authority—typically in the country where you live, work, or believe a privacy violation has occurred.
5.2 If you have questions regarding execution of your rights please contact us via data_privacy@emcd.io
6. Automated decision-making
6.1 We do not make decisions about candidates based solely on automated processing, including profiling, that produce legal effects concerning you or similarly significantly affect you.
6.2 We may use automated tools and technologies to assist in the recruitment process, including to review, filter, and rank CVs or applications based on predefined criteria relevant to the role. Such tools are used solely to support the initial screening process and to improve efficiency, as we receive a lot of CVs.
6.3 However, all hiring decisions are made by qualified personnel and are based on human review and assessment. Automated tools do not replace human judgment and do not independently determine the outcome of your application.
7. Amendments to the Policy
7.1 Our Policy is reviewed regularly in light of new regulations, technologies, and any changes to our business operations. We hereby reserve the right, at its sole discretion and at any time, to make changes to this Policy by publishing its amended version. The new version of the Policy will include the amended date of the last update on its first page.
7.2 You undertake, at your own risk, to constantly check for changes to the Policy and to perform the following actions: (i) remember/note the date of the last update indicated in the Policy (for example, save a copy of the Policy, etc.), (ii) regularly visit the relevant page and review the document if the update date changes.
8. How to Contact Us
If you are User and have questions or concerns regarding this Policy, or if you have a complaint, please contact us on support portal (located at Site) or by e-mail: support@emcd.io
For official correspondence and requests from government authorities, regulators, law enforcement agencies, and other competent institutions contact us by e-mail: data_privacy@emcd.io