PRIVACY POLICY

Effective Date: July 24, 2026

This privacy policy (hereinafter – Privacy Policy) establishes and defines the terms and conditions for the collection, processing, storage, and protection of personal data applied by data controller Peopable UAB when conducting executive recruitment, headhunting, candidate representation, paid career acceleration services, and administering the website peopable.lt.

We deeply value the trust placed in us by every candidate, client, and website visitor. We are committed to ensuring the highest standard of personal data protection in strict compliance with Regulation (EU) 2016/679 of the European Parliament and of the Council (GDPR), the Law on Legal Protection of Personal Data of the Republic of Lithuania, and other applicable European Union and Lithuanian legislation.

1. DATA CONTROLLER DETAILS & CONTACTS

1.1. The controller of your personal data is:

2. KEY DEFINITIONS

2.1. Personal Data – any information relating to an identified or identifiable natural person (Data Subject).

2.2. Data Processing – any operation performed on personal data (collection, recording, storage, adaptation, disclosure, transmission, erasure, anonymization, etc.).

2.3. Candidate – a natural person who submits a CV, completes a representation request, or participates in recruitment projects conducted by Peopable UAB or is included in the talent database.

2.4. Client (Employer) – a legal entity or organization commissioning recruitment, executive search, RPO, or related talent acquisition services from Peopable UAB.

2.5. Career Services Purchaser – an individual purchasing paid personal career services (CV rewrite, LinkedIn makeover, interview prep, career growth bundle).

3. CORE PRINCIPLES OF DATA PROCESSING

3.1. In processing personal data, Peopable UAB strictly adheres to the core GDPR principles:

• Lawfulness, fairness, and transparency: data is processed lawfully, fairly, and in a transparent manner.
• Purpose limitation: personal data is collected for specified, explicit, and legitimate purposes.
• Data minimization: data collected is strictly necessary for the designated processing purposes.
• Accuracy: reasonable steps are taken to ensure inaccurate data is rectified or erased immediately.
• Storage limitation: data is retained no longer than necessary for processing purposes or legal compliance.
• Integrity and confidentiality: high organizational and technical security measures are maintained at all times.

4. CATEGORIES OF PERSONAL DATA PROCESSED

4.1. We process the following categories of personal data:

A) Candidate Data (Recruitment, Headhunting, Representation & Talent Database):

• Identification & Contact Details: Full name, date of birth, email address, telephone number, city/country of residence, photo (if voluntarily included in CV), LinkedIn profile URL.
• Qualifications & Professional History: Resume (CV), cover letter, education, academic institutions, certifications, languages spoken, software/technical proficiencies, professional achievements.
• Career History & Aspirations: Employment experience, current & former employers, titles, responsibilities, target compensation, target work mode (remote, hybrid, on-site), relocation readiness.
• Recruitment Assessment Data: Recruiter interview evaluation notes, competency assessment summaries, skill test results.
• Reference Check Data: Employer feedback from previous managers (processed strictly upon prior explicit candidate consent).

B) Career Services Purchaser Data:

• Client full name, email address, phone number, ordered service package, billing details, and payment status (processed securely via Stripe gateway).

C) Client (Employer) & Business Partner Contact Data:

• Representative name, position, company name, corporate email, phone, correspondence history, contract execution records.

D) Website Visitor & Inquirer Data:

• IP address, timestamp, browsing session logs, browser type, device details, cookie preferences, contact form text content.

5. LEGAL GROUNDS FOR DATA PROCESSING

5.1. Peopable UAB processes personal data strictly under at least one of the following legal bases under GDPR:

• Consent of the Data Subject (Art. 6(1)(a) GDPR): candidate talent database inclusion, presenting CVs to prospective employers, conducting reference checks, direct marketing.
• Contract Performance or Pre-Contractual Measures (Art. 6(1)(b) GDPR): executing paid career service orders and candidate representation requests.
• Compliance with Legal Obligations (Art. 6(1)(c) GDPR): statutory financial accounting, taxation, and regulatory reporting.
• Legitimate Interests (Art. 6(1)(f) GDPR): website security, service optimization, legal claim defense, business continuity.

6. DATA RETENTION PERIODS

6.1. Personal data is retained no longer than necessary for the defined processing purposes or statutory retention laws:

6.2. Upon expiration of retention periods, data is permanently and securely destroyed or anonymized.

7. CANDIDATE CONFIDENTIALITY & REFERENCE CHECKS

7.1. Strict Confidentiality: Peopable UAB maintains absolute candidate privacy standards. Your resume, personal details, and employment search status are never presented to any prospective employer without your explicit prior consent for a specific job position.

7.2. Reference Checking: Reference checks with former employers or managers are performed strictly upon prior explicit written consent from the candidate.

8. DATA DISCLOSURE & THIRD-PARTY RECIPIENTS

8.1. Personal data may be shared only with the following categories of recipients:

• Clients (Potential Employers): during recruitment processes, strictly following candidate consent.
• Data Processors: IT infrastructure, database hosting, email, and payment processors (e.g. Stripe Payments Europe Ltd, FormSubmit, Google Ireland Ltd) acting strictly under contract and GDPR obligations.
• Statutory Authorities: law enforcement, courts, or regulatory bodies where required by law.

8.2. Personal data is stored and processed within the EU/EEA. Data transfers outside the EEA are performed strictly using European Commission Standard Contractual Clauses (SCCs).

9. COOKIE POLICY & CONSENT MANAGEMENT

9.1. Our website integrates the international "Cookiebot" consent platform (Usercentrics A/S). Essential cookies enable core site functions, while non-essential analytics and marketing cookies remain blocked until explicit consent is given.

9.2. Essential website cookies:

9.3. You can review, modify, or revoke your cookie choices at any time via the website consent widget or your browser settings.

10. YOUR RIGHTS AS A DATA SUBJECT

10.1. Under the GDPR, you possess the following rights:

• Right to be Informed: receive transparent information regarding data processing.
• Right to Access: request access to and copies of your personal data.
• Right to Rectification: request correction of inaccurate or incomplete data.
• Right to Erasure ("Right to be Forgotten"): request deletion of your personal data.
• Right to Restrict Processing: request temporary suspension of data processing.
• Right to Data Portability: receive your data in a structured, machine-readable format.
• Right to Object: object to processing based on legitimate interest or direct marketing.
• Right to Withdraw Consent: withdraw consent at any time without affecting past processing lawfulness.

10.2. To exercise your rights, submit a written request to info [at] peopable.lt. We will respond within 1 calendar month.

11. COMPLAINTS & SUPERVISORY AUTHORITY

11.1. If you believe your data processing violates GDPR, please contact us first at info [at] peopable.lt so we can address your inquiry promptly and amicably.

11.2. You also hold the right to lodge a formal complaint with the supervisory authority:

12. AMENDMENTS TO PRIVACY POLICY

12.1. Peopable UAB reserves the right to update this policy at any time. The current version is published at peopable.lt/privacy-policy.