Recruitment Privacy Statement

Last modified: 25 March 2018

We are Gradient B.V., TT Vasumweg 122-2, 1033 SH, Amsterdam, The Netherlands. In this privacy document, we explain to you how we process your personal data in our recruitment process.

First, we explain for what purpose and on what legal ground(s) we process your personal data and who we involve. Also, we explain on what legal basis we transfer your personal data to other countries, what your rights are towards us processing your personal data and how you can contact us.

Legal basis and purpose of processing

Attracting and selecting the best people for our current and future vacancies

If you apply to one of our vacancies, we will process the personal data you supply to us to assess your application. To establish an informed hiring decision, we might call, email, text, or have a (video)chat with each other. We might contact you when there is something unclear or when we would like to invite you for a conversation. You will also receive an email confirming your application. You might conduct an interview or job-related assessment with us. To make sure your story doesn't have to be told twice, we record it. And, to make finding new colleagues a little bit better every day, we might analyze past interactions and try to learn from them. That is why we keep a record of your application.

In the application process, we will ask you for your ID, as we are legally required to do so. If you supply us with a referee or if we ask you to perform an assessment, we will of course process this data as well.

To make your application as smooth as possible and for us to make the best hiring decision, we have the legitimate interest to store your personal data in our Recruiting Database System. If applicable, we will combine this data with data from your public profiles, but only if such is necessary for us to make an informed decision about your application, taking into account the specific position that you are applying for.

In case we take the initiative to reach out to you about a vacancy through publicly available addresses, we will ask for your consent to use your data. We will inform you about how we obtained your contact details, and we will delete your data within four weeks, in case you do not actively consent.

We will use your data for recruitment purposes only. We do not pass on your information to third parties for commercial purposes.

Recipients of personal data

We store your personal data in a secure and compliant Recruiting Database System hosted by our service provider in the U.S. The service provider adheres to the EU/US Privacy Shield. Internally, only recruitment professionals and staff involved in the recruitment process have access to your personal data.

Retention of personal data

If we decide to reject your application or you do not respond if we reach out to you, we will delete your personal data within four weeks. If we see a potential fit for future vacancies, we will ask you if we can keep your personal data for another year and possibly contact you about future job opportunities as they arise. If you consent to this, we then keep your personal data for maximum of one year.

Your rights

You have certain legal rights that we wish to inform you of.

You have the right to have your personal data rectified or completed by us without undue delay.

Right to be forgotten
You have the right to have your personal data erased by us without undue delay. This right is limited to specific grounds, for example, if you have withdrawn your consent, or if you object and there are no overriding legitimate grounds for us to maintain the processing.

Restriction of processing
You have the right to request that we restrict the processing of your personal data based on specific grounds. These are (1) the time for us to verify the accuracy of your personal data on your request; (2) instead of erasure of unlawful processing, you request restriction of use instead; (3) you need personal data in legal proceedings; or (4) we are verifying whether our legitimate grounds override your objection to the processing.

Right to object
You have the right to object at any time to our processing of your personal data if such processing is (1) based on our legitimate interest; or (2) necessary for the performance of a task carried out in the public interest or exercise of official authority vested in us. We shall cease to process your personal data based on your objection, unless we demonstrate compelling legitimate grounds overriding your interests, rights, and freedoms or if we need your personal data in legal proceedings.

Data portability
We are required to inform you of your right to receive your personal data from us so that you can transmit that personal data to another service provider. That means that at your request we shall supply you with your personal data related to your candidate profile. It does not include any device data, including data that was transmitted to us in a log file.

Consent withdrawal
If you have supplied us with your personal data based on your consent, you have the right to withdraw such consent at any time. You may do so by sending us an email to We shall then permanently remove your personal data from our database.

Lodging a complaint
You have the right to lodge a complaint with a supervisory authority about our processing of your personal data.International Transfers

As stated above, we may transfer your personal data to a subsidiary or third party that is located in a different country than where Gradient B.V. are located. If such country does not provide for an adequate level of protection by domestic law according to the European Commission, we have ensured this adequate level of protection by agreeing on additional appropriate safeguards with that subsidiary or third party through the Standard Data Protection Clauses adopted by the European Commission, or through the EU-US Privacy Shield. A list of countries that have ensured an adequate level of protection according to the European Commission can be found here. Alternatively, we may ask you for your explicit consent to the proposed transfer. You may request a copy of the Standard Data Protection Clauses by sending us an email, motivating your request.

Exercising your rights and contacting us

We have a privacy professional available to assist you with your queries. If you wish to exercise any of your rights, or you have a question about this document, please contact us via email, or send us a letter to the address below:

Gradient B.V.
Attn.: Data Protection Office
TT Vasumweg 122-2
1033 SH Amsterdam
The Netherlands

Please inform us of your country of residence. Also please note that in exercising your rights, we may ask you to complete a request form. We shall then inform you of the process of handling your request.

Changes to this document

If we modify this document, we will publish it on our website with a revised publication date and, if applicable, notify you of the changed document.