Privacy & Data Protection Policy

1. Introduction

NƎƎDED ("we", "us") is committed to protecting the privacy of all candidates, clients, and website users. This policy explains how we collect, process, and safeguard personal data in accordance with:

  • General Data Protection Regulation (GDPR)
  • GDPR Article 22 on automated decision-making
  • EU AI Act (2024)
  • EU Platform Work Directive (2024)
  • Cyprus data protection legislation

We use technology to support our recruitment services, including AI-assisted tools within our Applicant Tracking System (ATS) and other analytics platforms. All processing is conducted under strict human oversight.

2. Data We Collect

2.1 Candidate Data:

  • CVs, cover letters, portfolios;
  • Employment history, skills, qualifications;
  • Job preferences, salary expectations;
  • Communication records (emails, messages, interview notes);
  • Assessment results;
  • Work eligibility documentation;
  • Interview recordings (only with consent).

2.2 Client or Employer Data:

  • Contact details;
  • Job descriptions;
  • Communications and feedback.

2.3 Website, Cookies & Analytics:

Standard website and device data for security and performance.

3. How We Use Personal Data

We process personal data to:

  • Provide recruitment, placement, and talent advisory services.
  • Match candidates to suitable roles and introduce them to clients.
  • Meet legal and regulatory requirements.

We do not sell personal data.

4. AI, Automated Processing & Human Oversight

4.1 Use of AI within our ATS:

NƎƎDED uses an ATS with AI-assisted features (CV parsing, skills matching, keyword recommendations). These features support our consultants but do not replace human decision-making.

4.2 No Fully Automated Decisions:

We do not make recruitment decisions solely using automated processing. A human recruiter reviews all candidate profiles before decisions are made.

4.3 EU AI Act Compliance:

We ensure human oversight, transparency, bias monitoring, and vendor governance for all high-risk AI systems.

4.4 Platform Work Directive Transparency:

We comply with principles regarding algorithmic logic transparency and human monitoring. Candidates may request an explanation of how AI tools contributed to an assessment.

5. Legal Basis for Processing

We process personal data under the following GDPR bases:

  • Consent – when you submit a CV or apply for a job;
  • Contract – when we provide recruitment services to clients or candidates;
  • Legitimate interest – for sourcing, matching, and assessing suitability;
  • Legal obligations – compliance with employment, tax, audit, or regulatory requirements;

Where required, we obtain additional explicit consent (e.g., for video interviews or personality assessments).

6. Sharing of Personal Data

We may share data with employers seeking to hire, assessment providers, and technology vendors (ATS). We never share data with clients without a recruiter first reviewing suitability.

7. International Transfers

For transfers outside the EU/EEA, NƎƎDED ensures the presence of Adequacy decisions or Standard Contractual Clauses (SCCs).

8. Data Retention

We retain candidate data for 48 months unless removal is requested or laws require longer retention.

9. Your Rights

Under GDPR and the EU AI Act, you have the right to access, rectify, delete, or restrict processing of your data, as well as the right to request human intervention in any AI-supported assessment. To exercise these rights, contact: contact@n33ded.com.

10. Security Measures

We use encrypted storage, access controls, audit logs, and vendor compliance checks to protect your data.

11. Children's Data

We do not process data of individuals under 18 for recruitment purposes.

12. Updates to This Policy

The most recent version will always be available on https://n33ded.com/.

13. Marketing & Communications

NƎƎDED may contact you regarding job opportunities or industry insights under "soft opt-in" rules if you have previously engaged with our services. You may opt out at any time by emailing contact@n33ded.com.

14. Contact Us

For any questions regarding this policy, please reach out to us at contact@n33ded.com.