Candidate Privacy Notice

1) Introduction

This Candidate Privacy Notice (“Notice”) describes how iPronics Programmable Photonics, S.L. (“iPronics” or the “Company”), in its capacity as data controller, collects, uses, stores, discloses, and otherwise processes personal data relating to individuals applying for employment, internship, consultancy, or other engagement opportunities with the Company (each, a “Candidate”).

This Notice is provided pursuant to Articles 13 and 14 of Regulation (EU) 2016/679 (“GDPR”), Organic Law 3/2018 on the Protection of Personal Data and Guarantee of Digital Rights (“LOPDGDD”), and other applicable data protection legislation.

2) Identity of the Data Controller

Data Controller: iPronics Programmable Photonics, S.L.
Registered Office: C. del Convent dels Carmelites 2, Entresuelo, 46010 Valencia, Spain
Email: data.protection@ipronics.com

For any questions regarding this Notice or the processing of personal data, Candidate may contact the Company using the contact details above.

3) Categories of Personal Data

The Company may process the following categories of personal data:

Identification and Contact Information;
Name and surname;
Date of birth;
Postal address;
Telephone number;
Email address;
Nationality and work authorization status;
Professional and Educational Information;
Curriculum vitae and cover letters;
Professional qualifications and certifications;
Employment history;
Academic background and achievements;
Language skills and technical competencies;
Recruitment and Assessment Information;
Interview notes and evaluations;
Results of skills assessments, technical tests, and recruitment exercises;
Salary expectations and availability information;
Communications relating to the recruitment process;
Reference Information;
Professional references provided by Candidates;
Information obtained from referees where authorized by the Candidate;
Publicly Available Professional Information.

Information made publicly available by the Candidate through professional networking platforms or professional publications here relevant to assessing suitability for a position.

4) Sources of Personal Data

Personal data may be collected directly from the Candidate or indirectly through:

Recruitment agencies;
Employee referrals;
Professional networking platforms;
Publicly available professional sources;
Background verification providers where legally permissible;
Referees identified by the Candidate.

Where personal data is obtained from sources other than the Candidate, the Company shall provide the information required under Article 14 GDPR unless an exemption applies.

5) Purposes and Legal Bases of Processing

The Company processes Candidate personal data for the following purposes:

a) Management of Recruitment and Selection Processes
To assess qualifications, experience, suitability, and eligibility for employment opportunities with the Company.
Legal Basis: Article 6(1)(b) GDPR (taking steps at the request of the data subject prior to entering into a contract) and Article 6(1)(f) GDPR (legitimate interest in recruiting suitable personnel).

b) Communication with Candidates
To schedule interviews, administer recruitment procedures, provide updates regarding applications, and respond to candidate enquiries.
Legal Basis: Article 6(1)(b) GDPR and Article 6(1)(f) GDPR.

c) Verification of Information
To verify professional qualifications, employment history, references, eligibility to work, and other information relevant to the recruitment process where legally permissible.
Legal Basis: Article 6(1)(f) GDPR and, where applicable, Article 6(1)(c) GDPR.

d) Compliance with Legal and Regulatory Obligations
To comply with obligations arising under employment, immigration, tax, antidiscrimination, health and safety, and other applicable laws.
Legal Basis: Article 6(1)(c) GDPR.

e) Establishment, Exercise, or Defence of Legal Claims
To protect the Company’s legal rights and interests and to defend against actual or potential claims arising from the recruitment process.
Legal Basis: Article 6(1)(f) GDPR.

f) Consideration for Future Opportunities
Where the Candidate has expressly consented, the Company may retain application materials to consider the Candidate for future positions.
Legal Basis: Article 6(1)(a) GDPR.

The Candidate may withdraw such consent at any time without affecting the lawfulness of processing carried out prior to withdrawal.

6) Special Categories of Personal Data

Candidates should refrain from providing special categories of personal data within the meaning of Article 9 GDPR unless specifically requested by the Company or required by applicable law.

Where processing of special categories of personal data is necessary, the Company shall ensure that an appropriate legal basis under Articles 9 and, where applicable, 10 GDPR is identified before such processing takes place.

7) Recipients of Personal Data

Personal data may be disclosed to:

Human Resources personnel;
Relevant hiring managers and interview panel members;
Group companies, where relevant to recruitment activities;
Recruitment agencies and talent acquisition providers;
Information technology and applicant-tracking service providers;
Professional advisers, including legal advisers;

Public authorities, regulators, courts, or law enforcement bodies where required by law. All recipients shall be subject to appropriate confidentiality and data protection obligations.

8) International Transfers

Where personal data is transferred outside the European Economic Area (“EEA”), the Company shall ensure that such transfers are subject to appropriate safeguards in accordance with Chapter V GDPR, including adequacy decisions, Standard Contractual Clauses, or any other transfer mechanism recognized under applicable law.

9) Retention of Personal Data

Candidate personal data shall be retained only for as long as necessary to fulfil the purposes described in this Notice and to comply with applicable legal obligations. Unless a longer retention period is required by law or necessary for the establishment, exercise, or defence of legal claims:

Recruitment records relating to unsuccessful Candidates shall generally be retained for a period of two (2) years following the closure of the relevant recruitment process;
Where a Candidate has consented to be considered for future opportunities, the Company may retain the Candidate’s information for the duration of the consent period or until such consent is withdrawn;
Where a Candidate is hired, relevant recruitment records may become part of the employee personnel file and shall thereafter be retained in accordance with the Company’s employee privacy and records retention policies.

10) Rights of Data Subjects

Subject to applicable legal requirements and limitations, Candidates have the right to:

Obtain confirmation as to whether personal data concerning them is processed;
Access their personal data;
Request rectification of inaccurate or incomplete data;
Request erasure of personal data;
Request restriction of processing;
Object to processing based on legitimate interests;
Receive personal data in a structured, commonly used, and machine-readable
format where applicable;
Withdraw consent at any time where processing is based on consent;

Lodge a complaint with the Agencia Española de Protección de Datos (AEPD) or another competent supervisory authority. Requests may be submitted to the Company using the contact details provided in this Notice.

11) Automated Decision-Making

The Company does not make decisions producing legal or similarly significant effects based solely on automated processing, including profiling, within the meaning of Article 22 GDPR.

12) Amendments

The Company reserves the right to amend this Notice from time to time in order to reflect changes in legal requirements, regulatory guidance, or recruitment practices. The most current version shall be made available through the recruitment platform or other suitable communication channels.