Privacy Policy

1. Introduction

At Nova Trust Holding BV, we are committed to safeguarding the personal data of all individuals who engage with us for recruitment purposes. This Privacy Policy explains how we process your personal data in accordance with the General Data Protection Regulation (EU) 2016/679 (“GDPR”).

2. Data Controller

The data controller responsible for your personal data under this policy is:

Nova Trust Holding BV
Graaf Willemlaan 12, 1181EG Amstelveen, The Netherlands
Email: contact@novatrusthold.com

3. Purpose and Legal Basis for Processing

We process your personal data solely for recruitment and selection purposes. The legal bases under GDPR for our processing include:

• Article 3(1)(a) – Consent: You voluntarily provide us with your personal data.
• Article 3(1)(b) – Contract: Processing is necessary to take steps at your request prior to entering into an employment contract.
• Article 3(1)(f) – Legitimate Interests: To evaluate your application and qualifications.
• Article 3(1)(c) – Legal Obligation: To comply with applicable labor and employment laws, where relevant.

4. Categories of Personal Data We Process

We may collect and process the following categories of data:

• Identification: Full name, nationality, date of birth (if applicable)
• Contact information: Email address, phone number, mailing address
• Professional background: CV, education, work experience, qualifications
• Recruitment materials: Cover letters, application forms, references
• Interview and assessment results
• Other data you choose to provide during the hiring process

We do not collect special categories of personal data (e.g., health, ethnicity, etc.) unless legally required or provided voluntarily and explicitly by you.

5. How We Use Your Data

We use your personal data for:

• Reviewing applications and assessing qualifications
• Communicating with you about the recruitment process
• Organizing interviews and evaluations
• Conducting background or reference checks (where applicable and lawful)
• Keeping records for legal or regulatory compliance

We will not use your data for marketing or unrelated purposes.

6. Data Recipients

We only share your data when necessary and in compliance with GDPR. Recipients may include:

• Internal hiring personnel and management
• Subsidiaries or affiliated entities within the same corporate group
• Third-party service providers assisting with recruitment (e.g., applicant tracking systems, background screening)
• Legal authorities where required by law

All third parties are bound by confidentiality and data protection obligations.

7. International Transfers

Your data will generally be processed within the European Economic Area (EEA). If we transfer your personal data outside the EEA, we will ensure adequate safeguards are in place (e.g., standard contractual clauses approved by the European Commission).

8. Data Retention

We will retain your data only as long as necessary for the purposes described:

• For unsuccessful applicants: your data will be retained for up to 12 Months after the recruitment process, unless you request deletion earlier.
• For successful applicants: your data will be incorporated into your employment records and retained in accordance with our HR data policy.

You may request earlier deletion at any time, subject to legal or regulatory requirements.

9. Your GDPR Rights

You have the following rights under the GDPR:

• Access: Request access to your personal data
• Rectification: Request correction of inaccurate data
• Erasure: Request deletion of your data (“right to be forgotten”)
• Restriction: Request restriction of processing
• Portability: Request transfer of your data to another controller
• Objection: Object to processing based on legitimate interests
• Withdraw consent: Where processing is based on consent, you may withdraw it at any time

To exercise these rights, contact us at contact@novatrusthold.com. You also have the right to lodge a complaint with a supervisory authority in your country of residence or workplace.

10. Data Security

We implement appropriate technical and organizational measures to protect your data, including encryption, access controls, and secure storage, in accordance with GDPR requirements.

11. Updates to This Privacy Policy

We may update this Privacy Policy from time to time. The latest version will always be available on our website or upon request, with the “Effective Date” noted at the top.