Privacy Policy

Last updated: [July 11, 2025]

This Privacy Policy explains how BOLD. Website collects, uses, stores, and discloses personal data, particularly from job applicants, in compliance with the General Data Protection Regulation (GDPR) and other applicable data protection laws.

1. Who We Are BOLD. is an independent recruitment service connecting talented professionals with leading companies. We act as a data controller for the personal data we collect from you, determining the purposes and means of processing your data.

2. What Personal Data We Collect We collect various types of personal data to facilitate our recruitment services. This may include, but is not limited to:

• Contact Information: Name, email address, phone number, physical address.

• Professional Information: Data contained in your CV/Resume, cover letter, and professional profiles (e.g., LinkedIn). This includes employment history, education, skills, qualifications, work preferences, and salary expectations.

• Identification Data: In some cases, and only when legally required or specifically for a client's request, we might collect national ID numbers or other identification details.

• Communication Data: Records of our correspondence and communications with you.

• Technical Data: Information about your visit to our website, including IP address, browser type, operating system, and pages viewed (collected via Squarespace's default analytics and cookies – see section 6).

3. How We Collect Your Data We collect personal data primarily through:

• Online Application Forms: When you submit your CV or apply for a specific role through our website.

• Direct Contact: Via email, phone calls, or professional networking platforms (e.g., LinkedIn).

• Publicly Available Sources: With your implied consent or where permitted by law, from professional social media platforms or public databases.

4. Why We Collect Your Data (Purposes of Processing) We collect and process your personal data for the following purposes:

• Recruitment Services: To assess your suitability for current and future job opportunities with our clients, match your skills and experience with client requirements, and present your application to potential employers.

• Communication: To contact you regarding job opportunities, application status, and other recruitment-related matters.

• Compliance: To fulfill our legal and regulatory obligations.

• Website Improvement: To understand how visitors use our website and improve user experience (through anonymized data where possible).

5. Legal Basis for Processing We rely on the following legal bases under GDPR to process your personal data:

• Consent: Where you have given clear consent for us to process your personal data for specific purposes (e.g., by submitting your application and ticking a consent box). You have the right to withdraw your consent at any time.

• Legitimate Interests: Where processing is necessary for our legitimate interests (e.g., maintaining a database of candidates for future relevant roles), provided your fundamental rights and freedoms do not override those interests.

• Performance of a Contract: Where processing is necessary for the performance of a contract to which you are a party or to take steps at your request before entering into such a contract.

• Legal Obligation: Where processing is necessary for compliance with a legal obligation to which we are subject.

6. Who We Share Your Data With We take your privacy seriously and share your data only when necessary and with appropriate safeguards:

• Our Clients (Potential Employers): We share your CV and relevant personal data with our clients for whom we are recruiting. We only share your data with your explicit consent or implied consent based on your application for a specific role.

• Service Providers: We use third-party services that assist us in operating our website and providing our services (e.g., email providers, cloud storage for CVs). These providers are contractually bound to process data only on our instructions and in compliance with GDPR.

• Legal & Regulatory Bodies: Where required by law or necessary to protect our legal rights, we may disclose your data to authorities.

7. Data Storage and Retention We retain your personal data only for as long as necessary to fulfill the purposes for which it was collected, including for the purposes of satisfying any legal, accounting, or reporting requirements.

• For active candidates: We retain your data for the duration of the recruitment process and for 12 months thereafter, to consider you for other relevant opportunities, unless you request earlier deletion.

• For inactive candidates or upon request: If you ask us to remove your data, we will do so promptly, subject to any legal obligations to retain certain information.

8. International Data Transfers Your personal data may be transferred to, and stored at, a destination outside the European Economic Area (EEA), the UK, or Switzerland. Squarespace (our website provider) processes data in the United States, utilizing Standard Contractual Clauses (SCCs) and the EU-U.S. Data Privacy Framework, Swiss-U.S. Data Privacy Framework, and the UK Extension to the EU-U.S. Data Privacy Framework to ensure adequate protection. When we transfer your data to our clients located outside these regions, we ensure appropriate safeguards are in place (e.g., SCCs, adequate decisions) to protect your privacy rights.

9. Your Data Protection Rights Under GDPR, you have the following rights regarding your personal data:

• Right to Information: To be informed about how your personal data is collected and used.

• Right of Access: To request access to the personal data we hold about you.

• Right to Rectification: To request correction of inaccurate or incomplete data.

• Right to Erasure ("Right to be Forgotten"): To request the deletion of your personal data, under certain conditions.

• Right to Restriction of Processing: To request the restriction of processing of your personal data, under certain conditions.

• Right to Data Portability: To request your personal data in a structured, commonly used, and machine-readable format.

• Right to Object: To object to the processing of your personal data, under certain conditions.

• Right to Withdraw Consent: To withdraw your consent at any time where processing is based on consent.

• Right to Lodge a Complaint: To lodge a complaint with a supervisory authority, particularly in the EU Member State of your habitual residence, place of work, or place of the alleged infringement if you believe your rights have been violated.

To exercise any of these rights, please contact us at camelia@bold-hr.com

10. Cookies and Similar Technologies Our website uses cookies and similar technologies. These are small data files stored on your device that help us provide and improve our services.

• Essential Cookies: Necessary for the website to function (e.g., Squarespace's default cookies). These do not require your explicit consent.

• Non-Essential Cookies: Used for analytics, personalization, and marketing (e.g., Squarespace Analytics cookies, Google Analytics if enabled). We will only place these on your device after obtaining your clear and affirmative consent via our cookie banner.

You can manage your cookie preferences through our cookie banner or your browser settings. For more details on the cookies our Squarespace site uses, please refer to Squarespace's documentation.

11. Third-Party Services We integrate with various third-party services (e.g., Mailchimp, Google Drive via form blocks). These services have their own privacy policies. We strongly advise you to review their policies as we are not responsible for their data processing practices.

12. Changes to This Privacy Policy We may update this Privacy Policy from time to time to reflect changes in our practices or legal requirements. We will post any updates on this page with a revised "Last updated" date.

13. Contact Us If you have any questions about this Privacy Policy or our data practices, please contact us:

Email: camelia@bold-hr.com