Recruitment Privacy Notice


Before you provide us with your CV, application form or personal information, please read this Privacy Notice.

This Adaptive Media SIA Recruitment Privacy Notice (the Privacy Notice) describes the type of personal information that Adaptive Media SIA (the Company, we, or us) processes in connection with our online and offline recruitment activities, why we process the information and how this processing may affect you.

We process personal data in accordance with applicable legislation, including the General Data Protection Regulation (GDPR), and the applicable national data protection laws.

The terms used in this Privacy Notice, such as personal data, special category personal data, processing, controller, processor, and others, have the same meaning as the corresponding terms used in the GDPR.


To find top talent to work with us and prepare the necessary documentation in case you are selected as the best candidate, we need to process certain personal information about you. We limit the collection and processing of personal information to achieve one or more purposes as identified in Section 3 of this Privacy Notice. The personal information we collect about you may include:

  • Your first name, last name
  • Contact information, such as your address, telephone number, personal email address
  • Educational background, employment history, certificates, and other details from your CV or application, which are necessary for us to evaluate your compliance with the requirements for the position
  • Information about your personality, competency, ability and suitability for the position based on the details you have provided in your application or shared with us during the interview
  • Your interests and needs regarding employment, including your salary expectations (as well as benefits, and bonuses)
  • Your availability and potential start date
  • Date of birth, place of birth, personal identification number, gender, details of your dependents, if any, your nationality, citizenship, bank details, if you have provided such information to us in your application, correspondence or interviews, or if we agree to sign an employment contract with you
  • Correspondence with you regarding the job position or recruitment process
  • Notes from your answers to questions during the interview stages (including telephone or online interviews)
  • Details on referees’ and information provided by referees about you if you have consented that we may receive information from referees
  • Immigration status (if you need a work permit)
  • IP address
  • Other information that you choose to provide to us during the recruitment process (such as your portfolio, homework materials, links to your projects, your photographs, information about your hobbies, etc.)

Special category personal data

We do not process special category personal data (sensitive personal data), except as set out below.

Special category personal data (sensitive personal data) is information relating to a person’s racial or ethnic origin, political opinions, religious beliefs, trade union membership, health status or sexuality, as well as information on criminal convictions.

Please do not provide any special category personal data to us unless we specifically ask you to, or if providing such data is important for you to receive the support you need from us, for example, health data, where it is necessary to implement special measures for individuals with a disability.

When we have no lawful basis to process special category personal data, we may delete all documents containing special category data.


We usually process personal data about you after obtaining it directly from you in circumstances where you wish to apply for a position with us whether online, through emails, or otherwise. However, there are occasions when we may learn about you through third parties, such as recruitment agencies, your references, or other sources, such as LinkedIn.

If your application is successful, we also collect your personal data from public institutions, if such data is required for us to sign an employment contract with you and start an employment relationship.

This Privacy Notice applies to any recruitment activity whether you have provided your personal information directly to us, or if we have received it from a third party.


Purposes for processing personal data

Personal data may be processed only if the processing has a clear and necessary purpose. We collect your personal data in accordance with this Privacy Notice mainly to consider your application for a job, but there are some other specific purposes for processing your personal data, which are set out in the table below.

Lawful basis for processing personal data

A controller may only process personal information where there is a lawful basis allowing them to do so. When we process personal information during the recruitment process, we rely on the following lawful basis:

  • Contract: when the processing of personal information is necessary to move an application forward before signing an employment contract
  • Legal obligation: when the processing of personal information is required by legal or regulatory obligations, e.g., to provide a safe place of work or to clarify your taxpayer status
  • Legitimate interest: when it is in our or the third parties’ legitimate interest to process your personal data: our or third parties’ legitimate interests lie in continuing, managing, and administering our or third parties’ businesses. Processing personal data is part of managing a business, e.g., when deciding whether to offer employment to a candidate, making decisions about salaries and benefits for employees, assessing training needs for employees, or defending legal claims. Your data will not be processed if your interests, rights, and freedoms related to the processing of your data override our or third parties’ business interests in processing the data in accordance with our or third parties’ legitimate interests
  • Consent: in certain circumstances, such as receiving information about you from referees, storing your data for other positions if your application is not successful in the position you have applied for, we are required to receive your consent. Where we ask for your consent, we will tell you the reasons for processing your data, you will have full control over your decision to give or withhold consent, and there will be no consequences where consent is withheld. Consent, once given, may be withdrawn at any time.

The table below outlines the lawful basis we rely on when processing your personal data for various purposes. 

PurposeExamples of personal data that may be processedLawful basis for processing
RecruitmentData related to your identity (e.g., your first name and last name, personal identification number, or date of birth, place of birth, nationality), contact information (e.g., your phone number, address, email address), information about your professional experience (including current and previous employment details), educational background (including university degrees, academic records, professional licenses, memberships and certifications, awards and achievements, language skills), and any other personal data that you provide to us during the recruitment process.

Information concerning your application and our assessment of it, references, any checks we may make to verify the information provided or background checks, and any information related to your right to work. Some of the above processing activities can only be performed with your consent.

If necessary, information concerning your health and any disability to allow us to adjust working arrangements for you.


Legal obligation

Legitimate interests


Administering the recruitment processCommunicating with you in connection with the recruitment process, and providing you with information about our onboarding process.


Legal obligation

Legitimate interests

Signing an employment contract with you (if the working conditions have been agreed upon)Your bank account, information about the terms and conditions of employment, including working hours, salary, benefits, and bonuses, if any.

Information about your dependents, information relating to your status as a taxpayer, including information obtained from public institutions, to allow us to calculate tax obligations and inform public authorities about the commencement of an employment relationship with you.


Legal obligation

Legitimate interests

Financial planning and budgetingInformation, such as your proposed salary, and (if applicable) prospective bonuses.Legitimate interests
Disputes and legal proceedingsAny information relevant or potentially relevant to a dispute or legal proceedings affecting us.

Legitimate interests

Legal obligation

The examples in the table above are not exclusive.

Changes in the purposes or lawful basis of the processing of personal data

In case of substantial changes in the personal data we collect, or the purposes for which we process it, we will include such changes in an amendment to this Privacy Notice. The most up-to-date version of this Privacy Notice is available on our website.



Internally we disclose your personal data to our employees who are responsible for the recruitment process in the Company and other employees involved in the relevant recruitment process, e.g., the direct manager of the position we are hiring for and/or the management of the Company. Other members of staff may have access to personal information where such access is required for their functions, e.g., members of the IT team or Accountancy Department.

Employees who access personal information are aware of their obligations to only process personal data in accordance with applicable legislation, including the GDPR.

Employees who access personal information are aware of their obligations to only process personal data in accordance with applicable legislation, including the GDPR.


Externally we may disclose your personal data, if it is in our legitimate interests, to third-party recruitment consultants and similar businesses (including online recruitment portals) as a part of the recruitment process.

Where you have applied through a recruitment agency, we may share your personal information with them.

We may also disclose your personal data to persons and organizations that process data on our behalf, such as our external consultants and professional advisers (lawyers, auditors, accountants, technical support providers, and IT consultants), payroll service, insurers, and other benefit providers, our bank, the organization hosting our IT systems, and software providers.

If you have been selected to work with us, we share your personal data with tax, audit, or other authorities, where it is necessary to comply with the requirements of laws and regulations.

When disclosing your personal data to third parties, we ensure that an appropriate and GDPR-compliant data processing agreement (or similar protection) is in place, except where disclosure is required by law.


Your personal data may be stored at our premises, and on the hardware of our employees, service providers or their employees, as well as on the platforms of cloud-based storage service providers, such as Google or Microsoft.


Our processors may be located outside of the European Economic Area (EEA), so your personal data may be transferred and stored outside the EEA.

Where personal data is transferred or stored outside of the EEA, we ensure that appropriate measures are in place to provide adequate protection of the data through a mechanism approved by the European Commission.


We have appropriate security measures in place to prevent the accidental loss or use of, or unauthorized access to personal data

We limit access to your personal data to those who need to know it. Your data will only be processed in an authorized manner, and the processing is subject to confidentiality obligations.


We keep the personal data that we obtain about you during the recruitment process for no longer than necessary to achieve the purposes for which it was obtained and processed. How long we keep your personal data depends on whether your application is successful, as well as the nature of the data and the purpose for which it was obtained and processed.

If your application is unsuccessful, we will retain your personal data for 6 months from the date we last contacted you, unless we are bound by legal obligations to retain the data for a longer period of time. In this case, any information obtained in the recruitment process will be kept for as long as necessary in accordance with legal obligations.

Even if you are not selected for the position you have applied for, we may keep your data for a longer period, up to 3 years, in case of other suitable positions, provided we have received your consent for that.

If your application is successful, your personal data will be processed for the purpose of your employment relationship with us, and in accordance with our employment Privacy Notice.


You as the data subject have certain rights over your personal data and we as the controller are responsible for fulfilling these rights. Please see further information below about these rights, when they are available and how to exercise them.

Your right of access to personal data

You have the right to obtain a copy of your personal data, as well as other supplementary information. It may help you understand how and why we are using your data, what kind of personal data we have on you, and make sure that we are processing your data in a lawful manner.

Your right to rectification / amendment of personal data

You have the right to request for your personal data to be amended or rectified where it is inaccurate (for example, if you change your name or address), and to have incomplete personal data completed.

Your right to erasure / right to be forgotten

You have the right to have your personal data erased, but this right is not absolute and only applies in certain circumstances.

You have the right to have your personal data erased if:

  • the personal data is no longer necessary for the purpose we originally collected or processed it for
  • we are relying on your consent as the lawful basis for holding the data, and you withdraw your consent
  • we are relying on our legitimate interests as the legal basis for processing your data, but you object to the processing of your data, and there is no overriding legitimate interest to continue this processing
  • your personal data has been processed unlawfully
  • your personal data must be erased to comply with a legal obligation we are subject to.

Your right to restrict the processing of your data

You have the right to restrict the processing of your personal data, that is, to limit the way that we use your data, in the following circumstances:

  • for a period enabling us to verify the accuracy of your personal data where you have contested the accuracy of the personal data
  • the data has been unlawfully processed and you request restriction instead of erasure
  • when your personal data is no longer necessary in connection with the purpose it was collected and processed for, you can request restriction of the processing of your personal data to establish, exercise, or defend legal claims
  • for a period enabling us to verify whether the legitimate interests relied on by us override your interests where you have objected to the processing of your personal data based on legitimate interest

Your right to object to the processing of your data

The right to object to the processing of your personal data allows you to ask us to stop processing your personal data.

You have the right to object to the processing of your personal data when there are legitimate interests, and your interests override the legitimate interests relied on by us.

Your right to data portability

The right to data portability gives you the right to receive your personal data you have provided to us in a structured, commonly used and machine-readable format. It also gives you the right to request that we transmit this data directly to another controller.

The right to data portability only applies when:

  • the legal basis for the processing of your personal data is consent or the performance of a contract
  • we are carrying out the processing by automated means.

Your right to withdraw consent

Where we process personal data based on your consent, you have the right to withdraw consent at any time.

Your right to lodge a complaint

If you have a complaint about how we use your personal data, please contact us using the information provided in Section 10 of this Privacy Notice.

You also have the right to lodge a complaint with the supervisory authority in your country of residence, place of work, or the country in which an alleged infringement of data protection law has occurred. The data protection supervisory authority in the Republic of Latvia is the Data State Inspectorate, contact information:

Datu valsts inspekcija
Address: Blaumaņa iela 11/13-11, Riga, LV-1011
Phone number: +371 67 223 131


If you have any questions about this Privacy Notice, or you would like to exercise any of your rights described above, please contact us at:

Adaptive Media, SIA
Cēsu iela 19, Valmiera, LV-4201


This Privacy Notice is effective from February 1, 2021.

The Privacy Notice may change from time to time to comply with legal requirements or to meet our changing business needs, so please check the Privacy Notice regularly to be aware of the latest updates. The most up-to-date version of the Privacy Notice is available on our website.

This Privacy Notice does not form part of any employment contract you may enter into, nor does it create any contractual rights or obligations. We may amend this Privacy Notice at any time.

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