POLICIES & CERTIFICATES

This Recruitment Privacy Notice explains how we UAB “TELTONIKA IoT GROUP” and its current and future subsidiaries and affiliates (collectively referred to as the "Group", "we", or "us") handle your personal data when you apply for a job with us directly or through a recruitment agency, or when you are referred to us by someone else.

For the purposes of recruitment, talent acquisition, and the management of our global hiring systems, UAB “TELTONIKA IoT GROUP” and the specific Group entity to which you are applying (or where a relevant vacancy exists) act as Joint Controllers of your personal data.

What does this mean for you? This means that the Group companies jointly determine the purposes and means of processing your application. We share common recruitment platforms and processes to ensure your application is assessed efficiently and to match your skills with opportunities across the Group.

Your Point of Contact. Although multiple Group entities may process your data, we have arranged for UAB “TELTONIKA IoT GROUP” to act as your main contact point. You may exercise your rights under the GDPR (such as access or deletion) in respect of and against each of the joint controllers, but for your convenience, we recommend directing all inquiries to:

Email: privacy@telonika.lt
Address: Ditvos str. 6, Vilnius, Lithuania, LT-02121.

We use Workable, an online application provided by Workable Software Limited, to assist with our recruitment process. Workable acts as a Data Processor on our behalf.

When you apply for a job with us, your data will be stored and processed on Workable’s secure servers.
We have signed a Data Processing Agreement with Workable to ensure your data is protected in accordance with the GDPR.
Workable may use automated means to assist us in organizing applications (e.g., filtering), but the final decision on recruitment is always made by our human recruitment team.
Where you apply for a job opening via the application function on a job site or similar online service provider (“Partner”), you should note that the relevant Partner may retain your personal data and may also collect data from Us in respect of the progress of your application. Any use by the Partner of your data will be in accordance with the Partner’s Privacy Notice.

2. What Personal Data We Collect

We collect data to evaluate your suitability for the role. This includes:

Identity & Contact Info: Name, email, phone number, location, links to social media (e.g., LinkedIn).
Professional Info: CV/Resume, employment history, education, skills, and qualifications.
Interview Notes: Records of interviews, assessments, or coding tests completed during the process.
Communication: Emails and messages exchanged with you via the Workable platform.

Background Checks: (Only where legally permissible and relevant to the specific role) Criminal record or credit checks.

Video Interview Recordings: Video and audio recordings of your interview, but only where you have explicitly agreed to such recording prior to the interview.

Information We Collect from Other Sources

In addition to the information you provide directly, we may collect information about you from third parties:

Workable provides us with the facility to link the data you provide to us with other publicly available information about you that you have published on the Internet. This may include sources such as LinkedIn and other social media profiles.
Workable’s technology allows Us to search various databases – some publicly available and others not, which may include your personal data (include your CV or Resumé), to find possible candidates to fill our job openings. Where We find you in this way we will obtain your personal data from these sources.
We may receive your personal data from a third party who recommends you as a candidate for a specific job opening or for our business more generally.

3. Purposes and Legal Basis for Processing

We process your data for the following purposes based on specific legal grounds:

Purpose

Legal Basis (GDPR)

We process your data for the following purposes based on specific legal grounds:

Purpose	Legal Basis (GDPR)
Assessing your application for the specific role you applied for.	Contractual Necessity (Art. 6(1)(b)): Steps taken at your request prior to entering into an employment contract.
Sourcing & Enrichment: Identifying potential candidates via external databases or enriching profile data with public social media info.	Legitimate Interest (Art. 6(1)(f)): Our interest in identifying the best talent in the market and verifying professional experience.
Recording Interviews: Keeping a video record of the interview for review.	Consent (Art. 6(1)(a)): We will only record the interview if you have given your explicit agreement.
Communicating with you about the process.	Contractual Necessity (Art. 6(1)(b)).
Internal Reporting (hiring statistics).	Legitimate Interest (Art. 6(1)(f)): To improve our hiring efficiency.
Future Opportunities: Keeping your CV for future roles if you are not hired for this one.	Consent (Art. 6(1)(a)): We will ask you to "opt-in" to our Talent Pool. You can withdraw this consent at any time.
Legal Compliance: Verifying eligibility to work or sanctions checks.	Legal Obligation (Art. 6(1)(c)).

4. Who We Share Your Data With

Your data is strictly confidential and access is segregated based on your location and the role you apply for:

1. Group Companies: Your data may be shared with hiring managers and HR teams within the Group entities relevant to your application. We do not share your data with other Group companies unless you explicitly apply for a role in multiple countries or if a global hiring manager sits in a different office.

2. HQ: Authorized personnel at our Headquarters have access to the global system for administrative, legal, and reporting purposes.

3. Service Providers (Processors):

Workable: To store and manage your application.
IT Providers: Providers of email and document storage (e.g., Microsoft).
Assessment Partners: If you take a technical or psychometric test via a third-party link.

4. Legal Authorities: Only if required by law. This includes social security institutions (such as "Sodra" in Lithuania), data protection regulators (such as the "VDAI"), tax authorities, or law enforcement agencies in Lithuania or the specific country where you are applying.

5. International Data Transfers

Because we are an international Group and use global software (Workable), your data may be transferred outside the European Economic Area (EEA).

• Group Companies: If we share data with a subsidiary outside the EEA (e.g., in the UK, USA, or Ukraine), we do so based on Standard Contractual Clauses (SCCs) approved by the European Commission to ensure your data remains protected.

• Workable: Workable utilizes servers in the USA and EU. Transfers to Workable Inc. (USA) are protected via the EU-U.S. Data Privacy Framework or Standard Contractual Clauses.

6. How We store and secure your personal data

We take appropriate measures to ensure that all personal data is kept secure including security measures to prevent personal data from being accidentally lost, or used or accessed in an unauthorised way. We limit access to your personal data to those who have a genuine business need to know it. Those processing your information will do so only in an authorised manner and are subject to a duty of confidentiality.

We also have procedures in place to deal with any suspected data security breach. We will notify you and any applicable regulator of a suspected data security breach where We are legally required to do so.

7. Data Retention

We will not keep your personal data for longer than is necessary.

• Standard Retention Period: By default, we retain your candidate profile and application data for 6 months from the date your profile was created.

• Active Engagement Extension: If there is recent activity on your profile (e.g., new emails, interview notes, or comments) within the last 1 months, your data will be excluded from automatic deletion to ensure we do not delete your application while the hiring process is still active.

• Hired Candidates: If you are successfully hired, your recruitment data will be transferred to your employee file and retained according to our Employee Privacy Policy.

• Talent Pool: This allows us to consider you for the current role and potentially for future opportunities if you have opted into our Talent Pool.

• Sourced Candidates: If we identify you through external sources (sourcing) and do not notify you of our Privacy Notice within 30 days, your data is automatically and permanently deleted from our systems.

• Video Recordings: Video interview recordings are retained for the duration of the hiring process and are deleted thereafter unless you consent to their retention in our Talent Pool.

8. Your Rights

Under the GDPR, you have the right to:

• Access the data we hold about you.

• Correct inaccurate data.

• Delete your data ("Right to be forgotten"), subject to our legal retention obligations.

• Object to processing based on legitimate interest.

• Withdraw Consent at any time (for the Talent Pool or Video Recordings).

To exercise any of these rights, please contact us at privacy@teltonika.lt. When submitting a request, please identify yourself and specify your request, provide your full name, a description of the data that you are requesting, all email addresses (past and present).

If you are domiciled in the EU and you think your privacy rights were breached, you may lodge a complaint with the data protection authority of the country of your domicile. You may find the list and contact details of EU data protection authorities: https://ec.europa.eu/justice/article-29/structure/data-protection-authorities/index_en.htm