Introduction

At Eliteways Recruitment and Consultants Limited ("Eliteways", "we", "us", or "our"), we are committed to safeguarding your privacy and protecting your personal data. This policy outlines how we collect, use, and manage your personal information in accordance with the General Data Protection Regulation (EU) 2016/679 (GDPR), the Cyprus Processing of Personal Data (Protection of Individuals) Law of 2018 (Law 125(I)/2018), and any other relevant national and EU legislation.

This document will inform you of your rights regarding your personal data and how we comply with our obligations as a data controller. We encourage you to read it carefully and contact us with any questions.

 

Who We Are

Eliteways Recruitment and Consultants Limited is a recruitment agency that specializes in connecting employers and candidates. Our business involves collecting, processing, and storing personal data in line with GDPR Article 6(1)(b) (processing necessary for the performance of a contract) and other applicable laws. We are based in 42E Archbishop Makarios avenue, 1065, Nicosia, and our data protection officer (DPO) can be reached at elitewaysconsulting@outlook.com.

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What Personal Data We Collect

As per Article 4(1) of the GDPR, personal data refers to any information relating to an identified or identifiable natural person. Eliteways collects and processes the following categories of personal data:

1. Personal Identification Data: Full name, postal address, email address, telephone number, date of birth, passport/ID numbers, and nationality.

2. Professional Data: Details such as your CV/resume, educational background, job experience, qualifications, skills, certifications, and references.

3. Sensitive Personal Data: We may occasionally process special categories of data, such as health data, in accordance with GDPR Article 9(2)(a) (explicit consent) or where necessary for employment purposes under Article 9(2)(b).

4. Technical Data: Includes your IP address, browser type, browsing history, and usage data as a result of interacting with our website, which we collect in compliance with GDPR Recital 30.

 

How We Collect Your Personal Data

We collect your personal data in several ways:

• Directly from you: When you submit your CV, complete our application forms, or contact us via email, phone, or our website.

• Indirectly: Through job boards, recruitment platforms, social media platforms (e.g., LinkedIn), or when your details are provided by a third party such as a reference.

• Automatically: Through cookies and other tracking technologies, in line with GDPR Article 6(1)(f) (legitimate interest).

 

Purpose of Processing Your Data

We process your personal data for the following purposes:

1. Recruitment Services: To provide you with job placement services, match your qualifications to job vacancies, and communicate with you about employment opportunities, as defined under GDPR Article 6(1)(b) (performance of a contract).

2. Legal and Compliance Obligations: We may process your data to comply with legal obligations, such as employment law, tax law, or other regulatory requirements (Article 6(1)(c)).

3. Legitimate Business Interests: To improve our services, protect our business interests, conduct analytics, and manage our website, as per Article 6(1)(f).

4. Consent-based Processing: For certain activities, such as sending marketing communications, we rely on your explicit consent, as per Article 6(1)(a). You can withdraw your consent at any time.

 

Lawful Basis for Processing

Under the GDPR, the lawful basis for processing personal data must be established. Eliteways processes your personal data based on the following grounds:

• Performance of a contract: This applies when we process your data to provide recruitment services and fulfill our obligations under employment or consultancy agreements (Article 6(1)(b)).

• Legitimate interests: We may process your data for our legitimate interests, provided these interests are not overridden by your rights and freedoms (Article 6(1)(f)).

• Legal obligation: We are legally required to process certain data to comply with statutory regulations, such as employment law and tax requirements (Article 6(1)(c)).

• Consent: In cases where you provide your explicit consent, such as for receiving newsletters or marketing materials (Article 6(1)(a)), we ensure that you can withdraw consent at any time without affecting the lawfulness of processing based on consent before its withdrawal.

 

Data Sharing and Transfers

Eliteways may share your personal data with the following third parties:

• Potential Employers: As part of our recruitment process, your data will be shared with potential employers under GDPR Article 6(1)(b) (performance of a contract) to facilitate job placements.

• Service Providers: We may share your data with external IT providers, cloud storage solutions, and software platforms that help us deliver our services in compliance with GDPR Article 28 (processor obligations).

• Public Authorities: We may disclose your personal data if required by law, regulation, or legal process, including in response to government authorities to comply with Article 6(1)(c) (legal obligation).

In such instances, we will ensure that appropriate safeguards are in place, such as the European Commission’s updated Standard Contractual Clauses (SCCs 2021), and will assess the level of data protection in the recipient country, in line with the guidance from the European Data Protection Board (EDPB).

 

Data Retention

In accordance with the GDPR’s data minimization principle (Article 5(1)(c)), we retain your personal data only for as long as necessary to fulfill the purposes for which it was collected. Typically, we will retain candidate information for 2 years, unless legal obligations require a longer retention period.

Once this period expires, or upon your request, we will securely delete or anonymize your data in compliance with GDPR Article 17 (Right to erasure).

 

Your Rights Under GDPR

As a data subject, you have several rights under the GDPR, including:

1. Right of Access (Article 15): You have the right to request access to the personal data we hold about you.

2. Right to Rectification (Article 16): If your data is inaccurate or incomplete, you have the right to request correction.

3. Right to Erasure (Article 17): You can request that we delete your data if there is no lawful reason to retain it.

4. Right to Restrict Processing (Article 18): You can request a limitation on the processing of your data under certain circumstances.

5. Right to Data Portability (Article 20): You can ask to receive your data in a structured, commonly used, and machine-readable format, and have it transferred to another controller.

6. Right to Object (Article 21): You can object to the processing of your data in cases where we rely on legitimate interests or for direct marketing purposes.

To exercise any of these rights, please contact us at elitewaysconsulting@outlook.com. We will respond to your request in line with GDPR Article 12(3), which sets out our obligations to provide information within one month.

In the event of a personal data breach likely to result in a risk to your rights and freedoms, we will notify the competent supervisory authority within 72 hours as per Article 33 GDPR. Where required, we will also inform you without undue delay in accordance with Article 34 GDPR.

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Data Security

We implement appropriate technical and organizational measures, as required by GDPR Article 32, to protect your personal data against accidental or unlawful destruction, loss, alteration, unauthorized disclosure, or access. These measures include encryption, firewalls, and secure access protocols to ensure the confidentiality and integrity of your data.

 

Automated Decision-Making and Profiling

We may use automated systems or algorithms, including Artificial Intelligence (AI), to screen candidate profiles and match them to job descriptions based on qualifications, experience, and other professional data. Such processing may involve automated decision-making as described in Article 22 GDPR.

 

If you are subject to a decision based solely on automated processing that significantly affects you, you have the right to:

• Obtain human intervention

• Express your point of view

• Contest the decision

You can exercise this right by contacting us at elitewaysconsulting@outlook.com

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Cookies

Our website uses cookies to enhance functionality, analyse website traffic, and personalize content. Non-essential cookies (e.g. for analytics or advertising) are used only upon your explicit consent, in line with Article 6(1)(a) GDPR and the ePrivacy Directive. You can manage your cookie preferences at any time through our Cookie Consent Manager or browser settings.

 

Changes to This Privacy Policy

We may occasionally update this privacy policy to reflect changes in our practices or legal requirements. All updates will be posted on our website, and we encourage you to review this policy periodically. Any significant changes will be communicated in accordance with GDPR Article 13(2).

 

Contact Us

If you have any questions about this privacy policy or wish to exercise your rights, please contact us at:

Eliteways Recruitment and Consultants Limited,
42E Archbishop Makarios avenue, 1065, Nicosia,
elitewaysconsulting@outlook.com,
+35796808809