Employment Candidate Privacy Policy
(important information about how we collect, use and store personal data during job application and recruitment process and why we collect it)
Last updated on May 6, 2026
1. What information will you find on this document
Gurtam companies (“Gurtam”, “we”, “us”, “the Company”, “controller”) respect your privacy and are committed to protecting your personal data. As part of our recruitment process, we collect and process personal data relating to candidates. We are committed to be transparent about how we collect and use your personal data and to meet our obligations under the relevant data protection laws. This Employment Candidate Privacy Policy (“Privacy Policy”) explains what types of personal data we may collect during job application and recruitment process, why we collect it and how it may be used and other useful information.
While this Privacy Policy is intended to describe the broadest range of our information processing activities globally, those processing activities may be more limited in some jurisdictions based on the restrictions of their laws. For example, the laws of a country may limit the types of personal data we can collect or the manner in which we process that information. In those instances, we adjust our internal policies and practices to reflect the requirements of local law.
Gurtam is a “data controller”. This means that we are responsible for deciding how we hold and use personal data about you.
2. Who is responsible for the protection of your information and processing of your data
Depending on the Gurtam company you are in contact with or applying to, the data controller of your personal data can be either of the following companies:
UAB Gurtam (Lithuania)
Company code: 302506437
Ozo g. 12A (5th floor), 08200, Vilnius, Lithuania;
Gurtam LLC (Georgia)
Tax Code: 405541285
Georgia, Tbilisi, Saburtalo district, Mikheil Tamarashvili avenue, N 13h, office space; 4th floor, block b
Gurtam DMCC (UAE)
Tax Code: TRN:100504539600003
Unit No: 1801, Indigo Icon, Plot No: JLT-PH1-F3A, Jumeirah Lakes Towers, Dubai
Our e-mail: privacy@gurtam.com.
3. What principles do we follow when processing information about you
We will comply with data protection law and principles, which means that your data will be:
- Used lawfully, fairly, and in a transparent way.
- Collected only for valid purposes that we have clearly explained to you and not used in any way that is incompatible with those purposes.
- Accurate and kept up to date.
- Maintained only for as long as necessary for the purposes we have told you about, i.e. in relation to the recruitment exercise.
- Kept securely and protected against unauthorized or unlawful processing and against loss or destruction using appropriate technical and organizational measures.
4. Why do we collect information about you
We collect and process your information where it is necessary in order to take steps, at your request, prior to potentially entering into a contract of employment with you.
We may also process your personal data in specific circumstances, such as for example a similar role becomes vacant for which you may be a suitable candidate (where we have your explicit consent), or where necessary to comply with a legal obligation or for purposes connected to legal claims. If we use your information to improve our recruitment process, we do so on the basis that it is in our legitimate interests to ensure we recruit the best possible candidates.
5. What personal data we collect from you
In connection with your application for work, we will collect, store, and process personal data about you.
The personal data can include the following:
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Your full name;
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Contact details (e.g., email, telephone number, address, current location, or country of residence);
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Publicly available information (e.g., information from professional social networks, professional profiles, or portfolios);
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Education history (including copies of relevant degrees, diplomas or certificates if required);
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Current and past employment details;
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Immigration status and work permits;
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Languages spoken and level of proficiency;
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Recommendations;
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Other information given in your CV and attachments to it;
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Interview notes and recordings;
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Recruiting tasks performed by you and information about your skills and competencies relevant to the role;
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Desired salary or salary expectations relevant to the role;
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Information required to prepare the employment contract;
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Other information submitted by you.
We may also collect the following information about you if you choose to provide it:
- Information about your health, such as any disability you might have;
- Gender.
Please note that the provision of this information is entirely voluntary and you are under no obligation to provide it. Your decision to provide or withhold this information will not affect your application.
When submitting your application, please do not include any information that is not relevant to the recruitment process.
6. How is your personal data collected
We collect most of the personal data described above from you directly. This may include personal data you submit via the application form on our website, as well as personal data you send to our official recruitment contact email address published on our website (e.g., jobs@gurtam.com), or personal data you provide to us when communicating with us via professional networking platforms or recruitment tools.
Personal data submitted via email is processed in accordance with this Privacy Policy in the same manner as personal data submitted through the website application form.
However, we may also collect personal data about you from third parties, including:
- Existing Gurtam employees who refer or nominate you for roles with us;
- Other Gurtam companies (e.g., when you are recommended for another job position at Gurtam);
- Recruitment agencies, job portals or other third parties;
- Governmental authorities (such as local tax authorities);
- Your named referees who you’ve asked to provide us with references;
- Where allowed by law, other publicly available sources, such as social media networking sites and recruitment sources (such as LinkedIn, Instagram, Glassdoor, Indeed, Cvbankas.lt, etc.).
7. How we will use your personal data
We may process your personal data for the following purposes:
Recruitment administration and communication: to review your application, contact you, arrange interviews, and manage the recruitment process.
Legal basis: taking steps at your request prior to entering into an employment relationship, Article 6(1)(b) GDPR, and where applicable, our legitimate interests in managing the recruitment process, Article 6(1)(f) GDPR.
Candidate assessment and selection: to assess your suitability for the role.
Legal basis: Article 6(1)(b) GDPR and/or our legitimate interests in selecting an appropriate candidate, Article 6(1)(f) GDPR.
Preparation for employment: to take necessary steps before entering into an employment relationship.
Legal basis: taking steps at your request prior to entering into an employment relationship, Article 6(1)(b) GDPR.
Immigration, work authorization, and compliance checks: where relevant for a particular role, to assess eligibility to work, visa or permit requirements, and compliance with applicable laws.
Legal basis: compliance with legal obligations, Article 6(1)(c) GDPR, and where applicable Article 6(1)(b) GDPR, Article 6(1)(f) GDPR.
Retention of recruitment records: to establish, exercise, or defend legal claims and to demonstrate a fair and non-discriminatory recruitment process.
Legal basis: our legitimate interests, Article 6(1)(f) GDPR, and where applicable compliance with legal obligations, Article 6(1)(c) GDPR.
Future employment opportunities: if we would like to retain your data in order to contact you about future suitable vacancies.
Legal basis: your explicit consent, Article 6(1)(a) GDPR.
After receiving your application materials (such as your CV and cover letter (if applicable), we will process that information to decide whether you meet the basic requirements to be shortlisted for the position. If you do, we shall decide whether to invite you for an interview. If you are called for an interview, we will use the information you provide to us during the interview, to decide whether to offer the position to you. If we decide to offer you the position, we will take up references.
It is in our legitimate interest to decide whether to appoint you to a position since it would be beneficial to our business to appoint the appropriate candidate to that position.
We also need to process your personal data to decide whether to enter into a contract of employment or engagement with you.
If you are offered and accept employment with Gurtam, the information collected during the application and recruitment process will become part of your employment record.
If you fail to provide personal data
If you fail to provide personal data when requested, which is necessary for us to consider your application (such as evidence of qualifications or work history), we may not be able to process your application further. For example, if we require references for this role and you fail to provide us with relevant details, we will not be able to take your application further.
Interviews and recordings
As part of the recruitment process, we may create interview notes and, in limited cases, make audio or video recordings of interviews or assessment sessions. Where recordings are used, we will inform you in advance about the recording and its purpose.
Such materials may be used for recruitment administration, internal evaluation, and, where applicable, for the establishment, exercise, or defense of legal claims.
Where required by law, or where the specific circumstances make consent the appropriate legal basis, we will obtain your consent before making such recordings.
8. Automated decision-making
Automated decisions are currently not being made, you are not being profiled.
9. Who do we share information about you with
In addition to the specific situations discussed elsewhere in this Privacy Policy, we may share personal information in the following circumstances:
Affiliates. We may share information with our corporate affiliates for recruitment, operational, administrative, compliance, and security purposes, including to assess your application, support hiring decisions, or comply with internal reporting obligations.
Other disclosures with your consent. If we wish to share your information with unaffiliated third parties not covered by this Privacy Policy, we will seek your explicit consent before doing so.
Other disclosures without your consent. We may disclose your personal information as required by law, including:
Legal compliance. To comply with subpoenas, court orders, or legal obligations.
Enforcement of rights. To establish, exercise, or defend against legal claims.
Fraud prevention and security. To investigate, prevent, or take action regarding potential violations of our policies, suspected fraud, security threats, or illegal activities.
Service providers. We engage third-party service providers for various business-related functions necessary to operate and support our recruitment process, including, but not limited to:
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cloud and hosting services (e.g., storage, IT infrastructure);
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email, communications, and recruitment administration tools;
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applicant tracking, interview scheduling services;
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IT security, maintenance, and technical support;
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accounting, auditing, legal, and consulting services;
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background verification, reference check, immigration, relocation, travel, or similar support services, where relevant to a particular role or hiring stage.
We share your personal information with these providers only to the extent necessary for them to perform their functions. They are contractually required to:
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Process your data solely on our behalf and under our instructions;
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Implement appropriate security and confidentiality measures;
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Comply with applicable data protection laws, including GDPR when processing data of EU residents.
International Data Transfers
Your personal data may be processed and stored in jurisdictions outside the European Economic Area (EEA), where data protection laws may differ. In such cases, we ensure adequate protection of your personal data by implementing one or more of the following safeguards:
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Standard Contractual Clauses (SCCs) as approved by the European Commission;
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Adequacy decisions recognizing certain countries as having sufficient data protection standards;
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Other legally recognized transfer mechanisms in compliance with applicable data protection laws.
Examples of service providers that may process personal data outside the EEA include providers of cloud infrastructure, communications, and other support services.
10. Data security measures
We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorized way, altered or disclosed. In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a business need-to-know. They will only process your personal data on our specific instructions and they are subject to a duty of confidentiality.
We have put in place procedures to deal with any suspected data security breach and will notify you and any applicable regulator of a suspected breach where we are legally required to do so.
11. For how long we store information about you
The retention periods described in this section apply regardless of how you submit your personal data (including via the website application form or by email).
We retain your personal data until the end of the recruitment process has been completed and for as long as is necessary to comply with our legal obligations or to enable us to demonstrate, in the case of a legal claim, that we have not discriminated against candidates on any prohibited grounds and that we have conducted the recruitment exercise in a fair and transparent manner. With your explicit consent, we will retain your personal data for three years from the date of your last application in case a similar role becomes vacant for which you will be a suitable candidate. After this period, we will securely destroy or anonymize your personal data. If you become an employee at Gurtam, we will save your information within the employee file in accordance with our internal data retention terms for employee data.
12. What rights do you have
Under certain circumstances, by law you have the right to:
- Request access to your personal data (commonly known as a “data subject access request”). This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it.
- Request correction of the personal data that we hold about you. This enables you to have any incomplete or inaccurate data corrected.
- Request erasure of your personal data. This enables you to ask us to delete or remove personal data where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal data where you have exercised your right to object to processing (see below).
- Object to processing of your personal data where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground. You also have the right to object where we are processing your personal data for direct marketing purposes.
- Request the restriction of processing of your personal data. This enables you to ask us to suspend the processing of personal data about you, for example if you want us to establish its accuracy or the reason for processing it.
- Request the transfer of your personal data to another party.
You have the right to withdraw the consent you gave us in relation to the processing of your personal data at any time. To withdraw your consent, please send an email to privacy@gurtam.com, expressing your desire for withdrawal of your consent. The withdrawal of consent shall not affect the lawfulness of processing based on consent before its withdrawal. Once we have received notification that you wish to withdraw your consent, we will no longer process your application and we will dispose of your personal data securely.
You also have the right to lodge a complaint with your local data protection authority or another regulatory body responsible for ensuring the protection of your personal data rights.
13. Contact information
If you have any questions, comments or complaints regarding how we collect, use and store information about you, we are ready to help you. If you need our help, please send an e-mail to privacy@gurtam.com