CANDIDATE PRIVACY – EXECUTIVE SUMMARY

When you apply for a role at Pineca Group, we collect and use your personal data only to manage our recruitment process and assess your suitability for the position.

We process the information you provide (such as your CV, contact details and interview-related information) to communicate with you, conduct interviews, make hiring decisions, and – where applicable – to keep your profile for future opportunities within Pineca Group.

Your data is accessed only by authorised HR professionals, hiring managers and others directly involved in the recruitment process. We use Greenhouse Recruiting as our recruitment system and apply appropriate security and access controls.

If you are not hired, your data is normally deleted within 12 months, unless you request earlier deletion or we keep your profile for future opportunities as described in the Candidate Data Privacy Notice.

You always remain in control of your data and have the right to access it, request correction or deletion, object to certain processing, or withdraw consent where applicable.

For full details, please review our Candidate Data Privacy Notice or contact us using the details provided there.

CANDIDATE DATA PRIVACY NOTICE

1. Data Controller contact details

    1.1. For the purposes of this Notice, “Pineca Group” means all separate legal entities that belong to the Pineca Group, in accordance with the approved group structure, as updated from time to time.

References to the “Company” shall be understood to mean Pineca Group. The specific Pineca Group entity responsible for the relevant job opening will be referred to as the “Hiring Entity”.

    1.2. The Hiring Entity will depend on the role you apply for. In each case – whether you apply via a job posting or we contact you directly – we will inform you which specific Hiring Entity is hiring for the role. However, you can always use the central contact point below to exercise your rights or ask questions, and we will ensure your request is handled by the appropriate Hiring Entity.

    1.3. Central contact point for Pineca Group (for all privacy requests):

    Legal entity name: UAB “AV Projektai”
    Legal entity code: 301793315
    Registered address: Verkų g. 25C-1, Vilnius, Lithuania
    Email: [email protected]

    1.4. The Central contact point receives and coordinates privacy requests across Pineca Group, including with the Hiring Entity.

2. Who is the data controller (and who can see your application)

    2.1. Your personal data is processed by Pineca Group and the relevant Hiring Entity for recruitment purposes, with recruitment activities carried out across Pineca Group. Greenhouse Recruiting is our applicant tracking system used across Pineca Group (the Greenhouse). Authorised users involved in recruitment within Pineca Group, including the Hiring Entity’s recruitment team, may access your application in Greenhouse on a need-to-know basis.

    2.2. Access to your application is limited to People team professionals, hiring managers and selected team members involved in the recruitment process, as well as authorised administrators of the Greenhouse.

3. Why you are receiving this notice

    3.1. This notice is intended to inform you about how we process your personal data when you:

      a) apply for a vacancy within Pineca Group, or
      b) are approached by us for a role (e.g., through LinkedIn or CV databases), or
      c) are referred to us.

    3.2. We process candidate data to manage recruitment for specific roles and, where applicable, to keep a candidate pool for future opportunities.

4. What personal data we process
    4.1. We process the data you provide in your CV/resume and other application documents, and data generated during recruitment. This typically includes:

        a) Identity and contact details: name, surname, phone number, email address, location (if provided), links to professional profiles (e.g., LinkedIn).
        b) Application data: CV/resume, cover letter and other documents you submit.
        c) Education and qualifications: education history, degrees, certifications.
        d) Work experience: employers, employment periods, positions, responsibilities, achievements.
        e) Recruitment process data: interview notes, evaluations, feedback.
        f) Reference checking data: reference check notes and outcomes (where applicable).
        g) Communication data: emails/messages exchanged with you via Greenhouse or other channels.

    4.2. We do not intend to collect or process special category personal data (e.g., health data). Please do not include special category data in your application unless we specifically request it for a lawful reason. If such data is provided without request, we will not use it for recruitment decisions and will handle it in accordance with applicable data protection laws.

5. Where we obtain your personal data (sources)

    5.1. We may receive your personal data from:

        a) You directly (e.g., when you apply or submit your CV).
        b) LinkedIn (applications, profiles you share, or if we approach you).
        c) Recommendations/referrals.
        d) CV databases / job portals.
        e) Recruitment agencies (in such cases we may receive your data if you have agreed to share it).
        f) Pineca Group career website(s) or application forms hosted via Greenhouse.

    5.2. Where we receive your personal data from third parties (such as recruitment agencies, referrals, CV databases or professional platforms), we do so only where it is lawful to do so and where you have been informed by the relevant third party, or have otherwise agreed, that your personal data may be shared with potential employers, including Pineca Group.

6. Purposes of processing (why we process your data)

    6.1. We process your personal data to:

        a) Run recruitment for a specific position: review your application, communicate with you, conduct interviews, assess suitability, and make a hiring decision.
        b) Communicate with you during recruitment: initially, communications are related to the recruitment process for the role you applied for.
        c) Maintain a candidate pool for future roles: where applicable, to contact you with invitations to apply for future positions that match your profile.
        d) Security, compliance, and legal matters: protect our systems and recruitment process, and establish/exercise/defend legal claims if needed.

    6.2. We process only personal data that is relevant and necessary for the purposes described above and do not use candidate data for automated decision-making or profiling that produces legal or similarly significant effects on you.

7. Legal basis for processing

    7.1 Depending on the situation, we rely on:

        a) Steps prior to entering into a contract (GDPR Art. 6(1)(b)) – where applicable to your application; and/or
        b) Legitimate interests (GDPR Art. 6(1)(f)) – our interest in managing efficient recruitment, maintaining a candidate pool, ensuring security, and defending legal claims; and/or
        c) Consent (GDPR Art. 6(1)(a)) – where implemented. You can withdraw consent at any time.

    7.2. Where processing is based on legitimate interests, we have assessed and balanced our interests against your rights and freedoms and concluded that such processing is proportionate and does not override your fundamental rights.

8. Who may access your data (recipients)

    8.1. Your data may be accessed by:

        a) People team / recruitment professionals within Pineca Group,
        b) Hiring managers,
        c) selected team members involved in interviews or temporarily representing the hiring manager,
        d) Greenhouse (as our recruitment system provider) and other IT/security service providers supporting the process,
        e) recruitment agencies (if/when we engage them), where sharing is necessary for a recruitment process.

    8.2. All access is provided on a need-to-know basis and subject to confidentiality and appropriate access controls.

    8.3. We do not sell or otherwise disclose your personal data to third parties for their own independent marketing or commercial purposes.

9. Data retention (how long we keep your data) and deletion

    9.1. If you are not hired, we keep your candidate data for up to 12 (twelve) months after the end of the recruitment process (or your last meaningful interaction) and then delete it.

    9.2. If your profile is kept for future opportunities (candidate pool), we keep it for up to 12 (twelve) months from your last meaningful interaction, unless you request deletion earlier.

    9.3. Deletion may be performed using automated retention/deletion settings in the Greenhouse, and/or manual deletion where needed.

    9.4. We may retain data longer only if: it is necessary to resolve a dispute/complaint and/or there is an investigation regarding suspected unlawful activity and/or retention is required/allowed by law.

    9.5. If you are hired, relevant recruitment information may be transferred into your personnel file and retained under employee retention rules.

10. Your rights

    10.1. You have the right to:
        a) be informed about processing;
        b) access your data and receive a copy;
        c) request rectification of inaccurate or incomplete personal data;
        d) request erasure (where applicable);
        e) request restriction of processing;
        f) data portability (where applicable);
        g) object to processing based on legitimate interests;
        h) withdraw consent at any time (where processing is based on consent).

    10.2. You can exercise your rights by contacting us using the details indicated in the Clause 1.3.

    10.3. You also have the right to lodge a complaint with the State Data Protection Inspectorate or another relevant EU/EEA supervisory authority.

EFFECTIVE AND LAST UPDATED JANUARY 29, 2026