Privacy Policy – Clever Recruiting

Last updated: 2-12-2025

1. Who we are

This website is operated by Clever Recruiting (“we”, “us”, “our”).
Clever Recruiting acts as data controller for the personal data we receive through our website and recruitment activities.

If you have any questions, you can contact us at: hr@clever-recruiting.dk.

2. What this policy covers

This Privacy Policy explains how we collect and use personal data when:

  • You visit our website clever-recruiting.dk (“Website”)

  • You apply for a job or register as a candidate / job seeker

  • You contact us or work with us as an employer / company

We are committed to protecting your privacy and handling your data in a transparent and secure way, in line with the EU General Data Protection Regulation (GDPR).

3. Personal data we collect

3.1 Data we collect from job seekers / candidates

If you apply for a job through our forms, email or other channels, we may collect:

  • Identification details: name, surname, date of birth (if provided)

  • Contact details: email address, phone number, city/country of residence

  • CV and application data: work experience, education, skills, languages, certificates, driving licence, references, salary expectations, availability, preferred working time and industry, and other information you choose to include

  • Documents: CV, cover letter and any other files you upload

  • Communication data: emails, messages and notes from interviews or calls

  • Consent records: when and how you gave your consent (e.g. GDPR checkbox on forms)

3.2 Data we collect from employers / companies

If you contact us as an employer or client, we may collect:

  • Contact person details: name, role, email, phone number

  • Company details: company name, address, industry, recruitment needs

  • Contract and billing data where relevant (e.g. invoicing information)

  • Communication data: emails, messages, meeting notes

3.3 Data we automatically collect when you visit the Website (“Device Information”)

When you browse our Website, we automatically collect limited technical data, such as:

  • IP address

  • Browser type and version

  • Time zone and language settings

  • Pages visited and time spent on them

  • Referring website or search term

  • Cookies and similar technologies

This information is used for security, basic analytics and to improve the Website. It is not used to personally identify you unless this is necessary for security reasons.

4. Why we process your data (purposes & legal bases)

We only process your data when we have a legal basis under GDPR. The main purposes are:

4.1 For job seekers / candidates

We process your data in order to:

  • Receive, review and manage your job applications

  • Match your profile with suitable job opportunities

  • Present your profile or CV to potential employers (only when relevant)

  • Communicate with you about applications, interviews and offers

  • Comply with legal obligations (e.g. documentation duties)

Legal bases:

  • Art. 6(1)(b) GDPR – Contract: processing is necessary to take steps at your request prior to entering into an employment or recruitment agreement.

  • Art. 6(1)(f) GDPR – Legitimate interests: to run our recruitment business, find suitable roles for candidates and improve our services.

  • Art. 6(1)(a) GDPR – Consent: for specific actions such as keeping your profile for future roles beyond the normal retention period or sending newsletters (if used).

4.2 For employers / companies

We process your data in order to:

  • Respond to your enquiries and discuss recruitment needs

  • Propose suitable candidates and manage recruitment assignments

  • Maintain our business relationship and contracts

  • Send service-related information and updates

Legal bases:

  • Art. 6(1)(b) GDPR – Contract: to fulfil or enter into a contract with your company.

  • Art. 6(1)(f) GDPR – Legitimate interests: to manage our business operations and client relationships.

4.3 For website operation and security

We process Device Information to:

  • Operate and secure the Website

  • Detect and prevent misuse or attacks

  • Compile anonymous statistics about Website usage

Legal bases:

  • Art. 6(1)(f) GDPR – Legitimate interests: ensuring the security and proper functioning of our Website.

5. How long we keep your data (retention)

We do not keep your data longer than necessary.

  • Candidates / job seekers:
    We normally keep your application data and CV for up to 12 months from your last interaction with us (e.g. last application, update or communication), unless we are required by law to keep it longer or you give explicit consent to store it for a longer period for future opportunities.

  • Employers / companies:
    We keep business contact and contract-related data for as long as we work together and for a reasonable period thereafter, for accounting, legal and business record purposes.

  • Website logs and Device Information:
    These are kept for a short period needed for security and analytics, typically a few months, unless a security incident requires a longer retention.

You may request deletion of your data at any time (see “Your rights” below), unless we are legally obliged to keep some of it.

6. Who we share your data with

We only share personal data when necessary and with appropriate safeguards:

  • With employers / companies who have open positions matching your profile (for candidates).

  • With service providers / data processors who help us operate our business, e.g. email providers, hosting, recruitment or CRM systems. These providers may only process data under our instruction and must protect it.

  • With public authorities, regulators or legal advisors where required by law or to establish, exercise or defend legal claims.

We do not sell your personal data.

7. International data transfers

Some of our service providers or recipients may be located outside the EU/EEA. When this happens, we ensure that a valid transfer mechanism is in place, such as:

  • An adequacy decision by the European Commission, or

  • Standard Contractual Clauses (SCCs) approved by the European Commission.

8. Your rights under GDPR

As an individual in the EU/EEA, you have the following rights regarding your personal data:

  • Right to be informed – to know how we use your data (this policy).

  • Right of access – to request a copy of the personal data we hold about you.

  • Right to rectification – to correct inaccurate or incomplete data.

  • Right to erasure – to request deletion of your data, subject to legal obligations.

  • Right to restrict processing – to limit how we use your data in certain cases.

  • Right to data portability – to receive your data in a structured, commonly used format and transmit it to another controller.

  • Right to object – to object to processing based on our legitimate interests or to direct marketing.

  • Rights related to automated decision-making – we do not use automated decision-making or profiling that produces legal or similarly significant effects.

9. How to exercise your rights

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

📧 hr@clever-recruiting.dk

We may need to verify your identity before fulfilling your request. We aim to respond within one month, as required by GDPR.

You also have the right to lodge a complaint with your local Data Protection Authority if you believe that our processing of your personal data breaches data protection law.

10. Information security

We take reasonable technical and organisational measures to protect your personal data against accidental or unlawful destruction, loss, alteration, unauthorised disclosure or access.

However, no method of transmission over the internet or electronic storage is 100% secure, so we cannot guarantee absolute security.

11. Links to other websites

Our Website may contain links to third-party websites that are not controlled by us. We are not responsible for the privacy practices of these websites. We encourage you to read the privacy policies of every site you visit that collects personal data.

12. Changes to this Privacy Policy

We may update this Privacy Policy from time to time to reflect changes in our services, legal requirements or other reasons. The most current version will always be available on our Website, with the date of the latest update.

13. Contact

If you would like to contact us regarding this Privacy Policy or our handling of your personal data, please use:

📧 hr@clever-recruiting.dk