1.Introduction
Jivy Group SRL (“we,” “us,” or “our”), operating as a data controller located at 1A Ciuflea st. Chisinau, Republic of Moldova, is committed to protecting your privacy. This Recruitment Privacy Policy describes how we collect, use, process, and safeguard your personal data during our application and recruitment processes. 

At Jivy Group, we consider your privacy to be extremely important to us. Further information regarding our fundamental principles and practices on data privacy can be found in our Privacy Policy. 
This policy is drafted in accordance with Law No. 195/2024 on Personal Data Protection of the Republic of Moldova and Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 on the protection of natural persons with regard to the processing of personal data and on the free movement of such data, and repealing Directive 95/46/EC. 

2. Categories of Personal Data We Collect
We process personal data that you provide directly to us, or that we receive from your application, resume, or professional networks (such as LinkedIn). This may include: 
Contact Information: Full name, address, email address, and telephone number. 
Professional and Educational History: CV/resume, cover letter, education history, employment background, certifications, and skills. 
Interview Records: Any correspondence you may have had with us during the recruitment application process, assessment results, and any references provided. 
Identification & Legal Status: National identification number (where required by Moldovan labor law for contract preparation), citizenship, and work permit status. 

3. Legal Basis for Processing
Under Law No. 195/2024 and Regulation (EU) 2016/679, we process your data based on the following legal grounds: 
Pre-contractual Steps: Processing is necessary to take steps at your request prior to potentially entering an employment contract. 
Legitimate Interest: To assess your suitability for a role, manage our recruitment processes efficiently, and defend against potential legal claims. 
Consent: In specific cases where you explicitly agree to let us retain your profile for future, unrelated career opportunities. 

We use your personal information as part of the recruitment process at Jivy Group. Using your information allows us to: 

• Carry out recruitment operations; 

• Assess your skills, qualifications, and suitability for the role; 

• Communicate with you as part of the recruitment process; 

• Communicate with and verify your references where required; 

• Keep records regarding our recruitment and hiring processes; 

• Comply with our legal or regulatory requirements; 

• Respond to and defend against legal claims. 

4. Use of SmartRecruiters (Applicant Tracking System)
To ensure a seamless and efficient hiring process, we use SmartRecruiters as our digital cloud-based Applicant Tracking System (ATS). 
SmartRecruiters acts as our Data Processor under strict instructions. Your information is securely hosted on servers that comply with rigorous international security standards. Because SmartRecruiters operates globally, any international transfer of your data outside the Republic of Moldova is bound by Data Processing Agreement and strict legal safeguards to guarantee that your information remains fully protected at the same high standard mandated by Moldovan law and EU GDPR regulation. Further information on SmartRecruiters’ Data Protection Policy can be found in the Candidate Privacy Policy.

5. Data Retention
We take the security of your personal information seriously, and have implemented appropriate security measures, internal policies and controls to prevent your information from being lost, misused, accessed without authorisation, altered or accidentally destroyed. Our security policy includes systems restrictions, encrypted and password protected files, retention protocols, and security training. 

In addition, we use strict access controls to ensure that your information is only accessible on a need-to-know basis, by employees who are directly involved in your recruitment application. Any third party that processes your information acts on our instructions and is subject to a duty of confidentiality. 

Unsuccessful Applicants: If your application is not successful for the current role, we will securely delete or anonymize your data 1 year after the recruitment process concludes, unless you give us explicit consent to keep your CV in our talent pool for future vacancies.

Successful Applicants: If you accept an offer of employment, the data collected during the recruitment process will be transferred to your personnel file and retained according to our Employee Privacy Policy and Moldovan Labor Code requirements.

If you do not want us to keep your information after the recruitment process has ended, please contact us at dataprotection@jivygroup.com. 

6. Your Legal Rights
Under Law No. 195/202 you have the right to: 
Access: View the data we hold about you. 
Rectification: Correct incomplete or inaccurate data. 
Erasure (“Right to be Forgotten”): Request deletion of your data where there is no legal reason for us to keep processing it.   
Restriction: Pause the processing of your data under certain circumstances.   
Data Portability: Receive your data in a structured, machine-readable format.   
Withdrawal of Consent: Withdraw your consent at any time for future candidate pooling. 

To exercise any of these rights, please contact us at dataprotection@jivygroup.com.

7. Complaints
If you believe your data has been handled incorrectly, you have the right to file a complaint with the national supervisory authority: The National Centre for Personal Data Protection of the Republic of Moldova (NCPDP). Website: www.datepersonale.md. 

8. Policy Changes
This is the latest version of our Recruitment Privacy Policy and is in effect as of the “Last Updated” date which may be found at the top of the notice. Whenever updates are made, the version number will be revised accordingly. As we may change this notice from time to time, you should check here regularly for the most up-to-date version.