Data Privacy Notice for Candidates

Virtuozzo International GmbH (European entity), VZ Hybrid Compute (UK) Limited (UK entity), and their affiliated companies listed in the Virtuozzo Group Subprocessors (collectively referred to as “Virtuozzo,” “we,” “us,” or “our”) are committed to respecting your privacy. For that reason, we process your personal data in compliance with the applicable data protection laws. In this Privacy Notice we will explain to you how we collect, use, and safeguard your personal data during the recruitment process, when you apply to work for us either as an employee or a contractor. We use the term “you” to address all candidates directly, regardless of the role applied for or whether the application is for an employee or contractor position at Virtuozzo.

Who are we

We are Virtuozzo, a multinational company with offices in multiple jurisdictions. We ask you to check the table enclosed into this Privacy Notice to find out the details of the Virtuozzo entity operating in your  jurisdiction. For any questions regarding this notice data please contact us at privacy@virtuozzo.com

What personal data we collect during the recruitment process

We typically collect and process the following categories of personal data during our recruitment process:

• Identification and contact information. We typically process personal data that helps us identify and contact you, such as your full name, email address, phone number, gender and country and/or city of residence. If your application is successful, we may also process additional information, including your date of birth, your national insurance or tax number, a copy of your identification document, and any other personal data required under local legislation to enter into an employment or contractor agreement with you, CV/resume details (e.g., education, work history, skills), professional profile links (e.g., LinkedIn, GitHub), portfolios, business cases, or similar materials to support your application.
• Qualifications and work experience. We typically process personal data related to your professional background, including job titles, work history, training records, professional memberships, education, skills (both professional and soft), and other information included in your CV or cover letter. This also includes recruitment-related documentation such as right to work documents, references, interview notes and feedback, and results from any assessments or tests (e.g., psychometric evaluations) used during the recruitment process.
• Compensation history. We typically process information about your previous compensation, including salary, bonuses, and benefits, where relevant to the role or required for benchmarking and offer preparation.
• Information necessary to complete pre-employment security checks. We typically process personal data necessary to complete pre-employment security checks, which may include background verification, criminal record checks, and other compliance-related screenings as required by local laws or company policy.
• Personal interest. We typically process data about your hobbies or interests if you choose to share them during the recruitment process, for example in your CV or interviews.
• Any other information you voluntarily provide during the recruitment process. We may process any other personal data you voluntarily provide during the recruitment process, including additional documents, comments, or disclosures that support your application.

In addition, we may process certain categories of sensitive personal data, where relevant and permitted by law, including:

• Health information, such as medical conditions, disability status and health or sickness records, if necessary for the role you have applied for, such as to assess fitness for work or accommodate specific needs.
• Diversity-related information, such as gender identity, where this is voluntarily provided or necessary to comply with applicable equality and employment laws.
• Equal opportunity monitoring data. We might process personal data about your race or ethnic origin, religious, philosophical or moral beliefs, sexual life or sexual orientation.
• Criminal record information, including details of convictions or offences, where required by law or company policy to determine eligibility for the position.

Please note that if your application is successful, additional personal data may be collected and processed after hiring for employment administration purposes (such as payroll, tax, insurance, or benefits). These activities are covered in our Employee & Contractor Privacy Notice, which applies once you become an employee or contractor.

What are the purposes for processing your personal data

We process your personal data during the recruitment process for the following purposes:

• Evaluating your suitability for the role. This includes reviewing your CV, cover letter, education, work experience, skills, and any other information you provide to assess your qualifications and fit for the position.
• Communicating with you during the recruitment process. We process your contact details to keep you informed about the status of your application, schedule interviews, and share relevant updates or requests.
• Conducting interviews and assessments. We collect and process interview notes, feedback, and results from any tests or assessments (e.g., psychometric evaluations) used to support our decision making.
• Verifying qualifications and references. This includes contacting referees, reviewing right-to-work documentation, and confirming the accuracy of the information you provided.
• Complying with legal and regulatory obligations. We may process data required under local employment laws, such as national insurance or tax numbers, identity verification, and, where applicable, criminal record checks or health-related information relevant to the role, or to support meaningful diversity, equity, and inclusion reporting and monitoring.
• To accommodate specific needs. This includes arranging reasonable accommodations during the recruitment process (e.g., interview accessibility, assessment adjustments) or to support a fair and inclusive evaluation of applications.
• Preparing for potential employment or contractor engagement. If your application is successful, we may collect additional data necessary to draft and execute an employment or contractor agreement, including compensation history and pre-employment screening results.
• Supporting internal reporting and recruitment analytics. Aggregated and anonymized data may be used to improve our recruitment processes, monitor diversity and inclusion efforts, and ensure fair hiring practices.
• Maintaining records of the recruitment process. We retain relevant documentation to demonstrate compliance with applicable laws and internal policies, and to manage future recruitment needs. • Processing voluntarily provided information. Any additional data you choose to share, such as
  hobbies or personal interests, may be used to enrich our understanding of your profile, but only where relevant and appropriate.
• Managing legal disputes involving you. Using relevant personal data to manage, respond to, or resolve legal claims or disputes related to the recruitment process.

What are the legal bases for processing your personal data

We process your personal data in accordance with applicable data protection laws, including the General Data Protection Regulation (GDPR), based on the following legal bases or grounds:

• Your consent (where applicable). In specific situations where no other legal basis applies, we may request your explicit consent to process certain types of personal data, for example, sensitive data such as health-related details, results from psychometric assessments used during recruitment or data about your race or national or ethnic origin, religious, philosophical or moral beliefs, or your sexual life or sexual orientation, where collected to support meaningful equal opportunity monitoring and reporting.
• Our legitimate interests. We have a legitimate interest in recruiting qualified candidates to support our business operations. This includes evaluating your application, conducting interviews and assessments, verifying qualifications, managing or responding to legal claims or disputes involving you. and maintaining records of the recruitment process. We ensure that our legitimate interests do not override your rights and freedoms.
• Compliance with legal obligations. We may process your personal data to comply with legal and regulatory requirements, such as verifying your right to work, conducting criminal record checks where required, and collecting tax or national insurance information necessary for employment or contractor agreements.
• Performance of a contract or steps prior to entering a contract. Where your application is successful, we process your data to prepare and execute an employment or contractor agreement. This includes collecting necessary identification, compensation history, and other onboarding information.

Please note that where we process your personal data based on your consent, you have the right to withdraw that consent at any time. This will not affect the lawfulness of any processing carried out before the withdrawal.

Where the processing of your personal data is necessary to comply with legal obligations or to take steps toward entering into an employment or contractor agreement with you, withholding such data may prevent us from proceeding with your application or finalizing the contract.

Whom we share your personal data with

We typically share your personal data with the following recipients:

• Internal HR and hiring teams. Your data will be accessed by authorized personnel involved in the recruitment process, including human resources staff, hiring managers, and relevant team leads responsible for evaluating your application and conducting interviews.
• Affiliated companies within the Virtuozzo Group. If your application relates to a role within one of our affiliated entities, or if cross-entity collaboration is required, your data may be shared with other Virtuozzo companies listed at the end of this notice.
• Third-party service providers. We may engage external providers to support our recruitment activities, including recruitment platforms and applicant tracking systems; background check and pre-employment screening providers; psychometric and assessment test vendors; employers or contractors of record; IT and cloud service providers hosting recruitment-related systems, and company email accounts
• Legal and regulatory authorities. Where required by law, regulation, or legal process, we may disclose your personal data to competent authorities, such as tax offices, labour regulators, or law enforcement agencies.
• Legal advisors and auditors. In the event of a legal claim, dispute, or audit, your data may be shared with external legal counsel or auditors to ensure compliance and protect our legal interests.

We bind our third-party suppliers by contractual obligations requiring them to implement data security measures that are equivalent to, or consistent with, the standards we apply to protect your personal data.

Your personal data will be transferred or be accessible internationally as we are a global organization. Any transfers of personal data from within the EEA (European Economic Area) will take place in accordance with applicable data protection legislation and applicable additional safeguards and supplementary measures; Any personal data transfers from non-EEA countries will take place in accordance with applicable data protection legislation.

How long do we retain your personal data

We retain your personal data for as long as necessary to evaluate your application and manage the recruitment process. This retention period will not exceed four years after the recruitment process concludes, unless you request earlier deletion or we are legally required to retain the data for a longer period.

Which are your rights under the applicable data protection law

Under applicable data protection laws, including the General Data Protection Regulation (GDPR), you have the following rights in relation to your personal data, subject to certain conditions: • Right of access. You may request access to the personal data we hold about you (commonly known as a “data subject access request”). This allows you to receive a copy of your data and verify that we are processing it lawfully.

• Right to rectification. You may request correction of any inaccurate or incomplete personal data we hold about you to ensure it is up to date and accurate.
• Right to erasure. You may request the deletion or removal of your personal data where there is no valid reason for us to continue processing it.
• Right to Object to Processing. You may object to the processing of your personal data where we rely on legitimate interests (or those of a third party) and your specific circumstances justify the objection.
• Right to Restrict Processing. You may request that we restrict the processing of your personal data, for example, for a period until we will verify its accuracy or the reason for processing. • Right to Data Portability. You may request the transfer of your personal data to another party in a structured, commonly used, and machine-readable format.
• Right Not to Be Subject to Automated Decision-Making. We do not use automated decision making or profiling in our recruitment process.
• The right to lodge a complaint to the supervisory authority in your jurisdiction. You have the right to file a complaint with the data protection supervisory authority in your jurisdiction if you believe that your personal data has been processed unlawfully or that your rights under applicable data protection laws have been violated.

If you have any questions about this privacy notice or wish to exercise your data protection rights, please contact us at privacy@virtuozzo.com.