Legal/Candidate Privacy Notice

Candidate Privacy Notice

Last updated: April 2026

This Candidate Privacy Notice explains how Next Gate Tech processes personal data about individuals who apply for roles with us, are referred to us, are contacted about potential roles, or otherwise participate in our recruitment process.

This notice applies to candidates for employment, contractor, internship, temporary, advisory, or similar roles.

1. Who We Are

Next Gate Tech is responsible for the processing of personal data described in this notice.

If you have questions about this notice or how we process your personal data, you can contact us at:

Email: privacy@nextgatetech.com

Address: Next Gate Tech S.A., 26A Boulevard Royal, L-2449 Luxembourg

2. Personal Data We Collect

We may collect and process the following categories of personal data during the recruitment process:

  • identification and contact details, such as your name, email address, phone number, address, and professional profile links;
  • application materials, such as your CV or résumé, cover letter, portfolio, work samples, certifications, and other documents you provide;
  • professional and educational information, such as your employment history, education history, qualifications, skills, languages, professional licenses, and references;
  • recruitment process information, such as interview notes, assessment results, screening outcomes, evaluation feedback, role preferences, availability, compensation expectations, and communications with us;
  • eligibility and compliance information, such as work authorization, visa status, right-to-work information, and other information required to comply with employment, immigration, or legal obligations;
  • reference and verification information, where applicable and permitted by law;
  • technical and usage information if you use our recruitment platforms, websites, forms, scheduling tools, or communication systems.

We ask that you do not provide sensitive personal data unless it is specifically requested, legally required, or relevant to an accommodation request or another recruitment-related purpose.

3. Sources of Personal Data

We may collect personal data from:

  • you directly;
  • recruitment agencies, search firms, or sourcing partners;
  • employees or other individuals who refer you;
  • publicly available professional sources, such as company websites, professional directories, or professional networking platforms;
  • referees, former employers, educational institutions, or verification providers, where applicable and permitted by law;
  • service providers that support our recruitment process.

4. How We Use Personal Data

We may process your personal data for the following purposes:

  • managing and administering our recruitment process;
  • receiving, reviewing, and evaluating applications;
  • assessing your qualifications, experience, skills, and suitability for a role;
  • conducting candidate screening, interviews, assessments, and evaluations;
  • communicating with you about your application, interviews, assessments, offers, and related recruitment matters;
  • verifying information you provide, including references, qualifications, employment history, or eligibility to work, where applicable and permitted by law;
  • preparing, making, and managing employment, contractor, or similar offers;
  • maintaining recruitment records;
  • complying with employment, immigration, equality, tax, social security, and other legal or regulatory obligations;
  • establishing, exercising, or defending legal claims;
  • improving our recruitment processes, candidate experience, and hiring practices;
  • considering you for future opportunities, where we have an appropriate legal basis to do so.

5. Legal Bases for Processing

Where applicable data protection law requires us to identify a legal basis, we rely on one or more of the following:

  • Steps prior to entering into a contract: to assess your application and decide whether to offer you a role.
  • Legal obligation: to comply with employment, immigration, tax, social security, equality, recordkeeping, or other legal requirements.
  • Legitimate interests: to manage recruitment, assess candidates, select suitable individuals, communicate with candidates, maintain recruitment records, improve hiring processes, and protect our legal rights.
  • Consent: where required by law, such as for certain background checks, retaining your details in a talent pool, or processing certain optional information.
  • Vital interests or public interest: only where applicable and permitted by law.

6. Sensitive Personal Data

In limited cases, we may process sensitive personal data or special categories of personal data, such as health information, disability or accommodation information, diversity or equal-opportunity information, or information relating to criminal convictions or offences.

We will only process this type of information where permitted by law and where relevant to the recruitment process, such as to provide reasonable accommodations, comply with legal obligations, monitor equality and diversity where lawful, conduct legally permitted background checks, or establish, exercise, or defend legal claims.

7. Candidate Screening and Checks

As part of the recruitment process, we may carry out candidate screening. This may include reviewing your application materials, assessing your qualifications and experience, conducting interviews, evaluating work samples or assessments, checking references, and verifying information you have provided.

Where applicable and permitted by law, we may also conduct background checks, right-to-work checks, identity verification, qualification checks, employment history checks, or other role-relevant checks. The type and scope of checks may depend on the role, location, legal requirements, and business needs.

We will only conduct checks that are relevant, proportionate, and lawful.

8. Automated Decision-Making

We do not make recruitment decisions based solely on automated processing that produces legal or similarly significant effects on candidates, unless we notify you separately and such processing is permitted by applicable law.

We may use recruitment tools to help organize, screen, or manage applications, but hiring decisions involve human review.

9. Who We Share Personal Data With

We may share your personal data with:

  • our personnel involved in recruitment, including HR, hiring managers, interviewers, management, legal, finance, IT, and security personnel;
  • group companies, affiliates, or related entities involved in recruitment or hiring decisions;
  • recruitment agencies, search firms, referral providers, or sourcing partners;
  • applicant tracking system providers, HR software providers, communication tools, scheduling tools, document management providers, and other service providers supporting recruitment;
  • background-check, reference-check, assessment, testing, or verification providers, where applicable and permitted by law;
  • professional advisers, such as legal, tax, accounting, immigration, or audit advisers;
  • public authorities, regulators, courts, law enforcement, immigration authorities, or other third parties where required by law or necessary to protect our legal rights.

We require service providers that process personal data on our behalf to handle such data in accordance with appropriate confidentiality, security, and data protection obligations.

10. International Transfers

Your personal data may be processed in countries other than the country where you are located, including by our group companies, recruitment service providers, and technology providers.

Where required by applicable law, we use appropriate safeguards for international transfers of personal data, such as standard contractual clauses or other lawful transfer mechanisms.

11. Data Retention

We retain recruitment-related personal data for as long as necessary to manage the recruitment process, assess and decide on applications, communicate with candidates, make and manage offers, comply with legal obligations, resolve disputes, and establish, exercise, or defend legal claims.

If your application is successful, relevant recruitment data may become part of your employment, contractor, or personnel record and will be retained in accordance with our applicable employee, contractor, or personnel data retention practices.

If your application is unsuccessful, we retain your recruitment-related personal data only for as long as reasonably necessary for recruitment administration, legal compliance, dispute resolution, and recordkeeping purposes.

Where we wish to retain your information for future opportunities, we will do so only where we have an appropriate legal basis, such as your consent where required by applicable law.

12. Your Rights

Depending on your location and applicable law, you may have rights in relation to your personal data, including the right to:

  • request access to your personal data;
  • request correction of inaccurate or incomplete personal data;
  • request deletion of your personal data;
  • request restriction of processing;
  • object to processing based on legitimate interests;
  • withdraw consent where processing is based on consent;
  • request portability of your personal data;
  • lodge a complaint with a data protection authority.

These rights may be subject to legal limits or exceptions.

To exercise your rights, contact us at privacy@nextgatetech.com.

13. Accuracy of Information

You are responsible for ensuring that the information you provide during the recruitment process is accurate and up to date. Please inform us if your information changes during the recruitment process.

14. Changes to This Notice

We may update this Candidate Privacy Notice from time to time. If we make material changes, we will provide notice where required by applicable law.