Privacy Policy

This Privacy Policy explains how glensparta.com (PE) collects, uses, stores, and retains candidate and client information, including information used for screening and skills assessment, and how you can exercise your rights in Ukraine.

1. Who we are (controller)

glensparta.com (PE)

Address: 15-A Shevchenko Ave, Business Center Orion, 7th Floor, Kyiv, 01004, Ukraine

Email: contact@glensparta.com

Phone: +380 932 608 4134

Legal representative: Michael Weber, Managing Director.

2. What information we collect

Candidate information: name, contact details, resume/CV contents, employment history, education, and other information you provide when applying.
Skills assessment data: results and related submissions from assessments you complete as part of the screening process.
Client information: business contact details and information provided to us for recruitment/selection and service delivery.
Usage/contact communications: messages you send to us through forms or email.

We only collect information that is relevant to recruitment and related services.

3. How we use information

We process information for the following purposes:

to assess candidates and conduct screening and skills assessments;
to manage recruitment for authorized client employers and coordinate submissions;
to provide recruitment-related services and respond to inquiries;
to keep internal records, improve our processes, and ensure compliance with legal obligations.

4. Legal basis for processing (Ukraine)

We process personal data in accordance with Ukrainian data protection rules under the Law of Ukraine "On Protection of Personal Data". Depending on the circumstances, the lawful basis may include:

processing necessary to take steps at the request of the data subject prior to concluding an agreement, or to perform the agreement;
processing based on consent where applicable;
processing for legitimate interests that do not override the rights and freedoms of the data subject;
processing required to comply with legal obligations.

5. Data sharing and authorized recipients

We may share candidate and client information with authorized client employers for recruitment purposes, for example to evaluate suitability and consider employment. We require that recipients process shared data only for specified recruitment purposes and protect it appropriately.

We also may share information with service providers acting on our behalf (e.g., IT and hosting) under appropriate confidentiality and security measures.

6. International transfers

If we transfer data outside Ukraine, we take steps to ensure lawful transfer and comparable protection of personal data in accordance with Ukrainian requirements under the Law of Ukraine "On Protection of Personal Data".

7. Storage and retention

We retain personal data for as long as necessary to fulfill the purposes described in this Policy, including completing the recruitment process. Retention periods depend on the type of data, the interaction history, and any applicable legal requirements.

After the retention period, we delete or anonymize the data where feasible.

8. Your rights as a data subject (Ukraine)

Under the Law of Ukraine "On Protection of Personal Data", you may request information about processing, access to your personal data, and rectification of inaccurate data. You may also request deletion or restriction of processing in cases provided by law, and object to processing where applicable. You have the right to withdraw consent where processing is based on consent.

To exercise your rights, contact us using the details in Section 10.

9. Accuracy and security

We implement reasonable administrative and technical safeguards designed to protect personal data against unauthorized access, loss, misuse, alteration, or disclosure.

If you believe your information is inaccurate, you can request correction.

10. Contact for privacy inquiries

For questions about this Policy or data protection requests, contact: