Last updated on March 1, 2025.
SPD TECHNOLOGY RO S.R.L.
Bucharest, District 4, 41 George Bacovia Street
LLC “SOFTWARE PRODUCT DEVELOPMENT”
Ukraine, 18002, Cherkasy region, Cherkasy, Shevchenko bldg.
266, office 213
LLC “SPD-GROUP UKRAINE”
Ukraine, 18005, Cherkasy region, Cherkasy city, Kryvalivska str, 7
SOFTWARE PRODUCT DEVELOPMENT GLOBAL LTD
20 Birchin Court, Birchin Lane, London, United Kingdom, EC3V 9DJ
Effective Date: March 1, 2025
1. Introduction
SPD TECHNOLOGY RO S.R.L., LLC “SOFTWARE PRODUCT DEVELOPMENT”, LLC “SPD-GROUP UKRAINE”, SOFTWARE PRODUCT DEVELOPMENT GLOBAL LTD (each of them separately called “Company,” “we,” “us,” or “our”) is committed to protecting and respecting your privacy.
This Privacy Policy explains how we collect, use, and safeguard your personal data in the context of recruitment and employment processes exclusively for individuals applying for positions within SPD TECHNOLOGY RO S.R.L., LLC “SOFTWARE PRODUCT DEVELOPMENT”, LLC “SPD-GROUP UKRAINE”, SOFTWARE PRODUCT DEVELOPMENT GLOBAL LTD.
We process personal data in compliance with the following requirements:
General Data Protection Regulation (GDPR), other applicable Romanian laws for candidates in Romania for hiring on the SPD TECHNOLOGY RO S.R.L.
The Law of Ukraine “On Personal Data Protection” No. 2297-VI for candidates in Ukraine for hiring on the LLC “SOFTWARE PRODUCT DEVELOPMENT” or LLC “SPD-GROUP UKRAINE”.
The UK General Data Protection Regulation (UK GDPR) and the Data Protection Act 2018 for recruitment in the United Kingdom in accordance with the SOFTWARE PRODUCT DEVELOPMENT GLOBAL LTD.
This policy does not apply to data processing activities undertaken by any affiliated entities, third-party recruiters, or individuals hiring outside of SPD TECHNOLOGY RO S.R.L., LLC “SOFTWARE PRODUCT DEVELOPMENT”, LLC “SPD-GROUP UKRAINE”, SOFTWARE PRODUCT DEVELOPMENT GLOBAL LTD.
In all instances where GDPR is referenced in this document, it applies exclusively to recruitment for employment in Romania with SPD TECHNOLOGY RO S.R.L.. We process personal data for recruitment in the United Kingdom in accordance with the UK General Data Protection Regulation (UK GDPR) and the Data Protection Act 2018. These regulations govern the collection, use, and storage of personal data and ensure compliance with privacy and data security standards. For recruitment in Ukraine for LLC “SOFTWARE PRODUCT DEVELOPMENT”, LLC “SPD-GROUP UKRAINE” the applicable legal framework is the Law of Ukraine “On Personal Data Protection”. However, if any provision grants broader rights to the individual under GDPR compared to Ukrainian legislation, the more favorable provision shall apply to the individual being recruited in Ukraine.
We process personal data strictly in accordance with this Privacy Policy, ensuring adherence to the principles of lawfulness, fairness, and transparency. This Privacy Policy details our approach to data retention and protection, outlining the security measures implemented to safeguard personal data from unauthorized access, disclosure, or misuse.
2. Definitions
Personal Data refers to any information related to an identified or identifiable natural person (“data subject”). An identifiable person is one who can be identified, directly or indirectly, by reference to an identifier such as a name, identification number, location data,
online identifier, or other factors specific to the physical, physiological, genetic, mental, economic, cultural, or social identity of that person.
Processing encompasses any operation or set of operations performed on personal data, whether or not by automated means. This includes but is not limited to the collection, recording, organization, structuring, storage, adaptation, modification, retrieval, consultation,
use, disclosure by transmission, dissemination, or otherwise making available, alignment, combination, restriction, erasure, or destruction of personal data.
Other terms used in this Policy have the meanings assigned to them in the General Data Protection Regulation (GDPR), the Law of Ukraine “On Personal Data Protection” No. 2297-VI., UK General Data Protection Regulation (UK GDPR), and the Data Protection Act 2018.
3. Data Controller
SPD TECHNOLOGY RO S.R.L., registered at Bucharest, District 4, 41 George Bacovia Street, is the controller of your personal data if you are hiring in Romania on the SPD TECHNOLOGY RO S.R.L. or making any other legal agreement. If you have any questions about this Privacy Policy or the processing of your personal data, you may contact us at [email protected].
LLC “SOFTWARE PRODUCT DEVELOPMENT”, registered at Ukraine, 18002, Cherkasy region, Cherkasy, Shevchenko bldg. 266, office 213 or LLC “SPD-GROUP UKRAINE”, registered at Ukraine, 18005, Cherkasy region, Cherkasy city, Kryvalivska str, 7, is the controller of your personal data if you are hiring in Ukraine on the LLC “SOFTWARE PRODUCT DEVELOPMENT” or LLC “SPD-GROUP UKRAINE” or making any other legal agreement. If you have any questions about this Privacy Policy or the processing of your personal data, you may contact us at [email protected].
SOFTWARE PRODUCT DEVELOPMENT GLOBAL LTD, registered at 20 Birchin Court, Birchin Lane, London, United Kingdom, EC3V 9DJ is the controller of your personal data if you are hiring in the UK on the SOFTWARE PRODUCT DEVELOPMENT GLOBAL LTD or making any other legal agreement. If you have any questions about this Privacy Policy or the processing of your personal data, you may contact us at [email protected].
4. What Personal Data We Collect
We collect and process personal data in the context of recruitment and employment. We collect data that you provide to us at the recruitment stage, ensuring transparency and compliance with applicable legal requirements. Access to your personal data may include filling in a box with a check mark when using our website with job ads. We adhere to the principle of transparency, which requires that any information and notices regarding the processing of personal data are accessible and understandable, using clear and simple wording so that the person is aware of the facts and limits of consent.
The categories of data we process include:
4.1 Recruitment Stage
Basic Identification and Contact Information:
Full name
Email
Phone number
Address (optional unless required for the position)
Job Application Information:
Curriculum Vitae (CV) or resume
Cover letter
Employment history and professional experience
Educational qualifications and certifications
References (with consent from the candidate to contact them)
Work permits, visa details, and temporary defense status (for Ukrainian candidates)
4.2 Employment Stage
Upon hiring, we may collect additional data, including:
Passport, national ID, work permit, visa
Tax identification number
Bank account details: Bank account details: Full name of the account holder (as registered with the bank): Bank account number (IBAN); Bank name; Bank branch (if applicable); SWIFT/BIC code (for international transactions); Currency of the account; Tax identification number (if required by local regulations); Bank address (if required for compliance purposes)
Date of birth
Gender
Current Address (Street, Number, City, County, Postal Code)
Phone Number
Email Address
IP address (if applying through an online platform)
Medical certificates (only when legally required)
5. Legal Basis for Processing
We process personal data based on the following legal grounds:
GDPR Article 6(1)(b) and Article 11 of the Law of Ukraine “On Personal Data Protection” – Processing necessary for taking steps prior to entering into an employment contract (recruitment) and the performance of an employment contract.
GDPR Article 6(1)(c) and Article 6 of the Law of Ukraine “On Personal Data Protection” – Processing necessary for compliance with legal obligations, including labor, tax, and social security laws.
GDPR Article 6(1)(f) and Article 11 of the Law of Ukraine “On Personal Data Protection” – Processing based on legitimate interests, such as evaluating candidates and maintaining recruitment records.
We do not process special category data under GDPR Article 9, such as health data, except where legally required (e.g., medical certificates).
We process personal data for recruitment and hiring in the UK based on the following legal grounds:
Article 6(1)(b) UK GDPR – Processing is necessary for pre-contractual measures and entering into an employment contract.
Article 6(1)(c) UK GDPR – Compliance with legal obligations, including tax, employment, and immigration laws.
Article 6(1)(f) UK GDPR – Legitimate interests, such as evaluating candidates and maintaining recruitment records.
6. Data Processing Activities
We collect, store, and process your personal data for the following purposes:
Managing job applications and recruitment procedures.
Evaluating candidates for potential employment.
Communicating with candidates about job opportunities.
Entering into and managing employment contracts.
Complying with labor laws, tax regulations, and social security requirements.
Storing recruitment data for potential future job openings (with candidate consent if beyond 12 months).
We collect data that you provide to us at the recruitment stage, ensuring transparency and compliance with applicable legal requirements. Additionally, we may use your personal data to contact you regarding other suitable job vacancies within SPD TECHNOLOGY RO S.R.L., LLC “SOFTWARE PRODUCT DEVELOPMENT”, LLC “SPD-GROUP UKRAINE”, SOFTWARE PRODUCT DEVELOPMENT GLOBAL LTD provided that such processing aligns with our legitimate interests and applicable legal requirements.
7. Data Sharing & Transfers
We share personal data only as necessary and in compliance with legal requirements:
Third-Party service providers: We use third-party providers for accounting and payroll services. Upon the transfer of your personal data to the Third-Party service providers, these entities become the data controllers with respect to the personal data they receive. As data controllers, they are responsible for the processing and protection of your personal data in accordance with their own internal policies and the requirements of the GDPR. We ensure that all third-party service providers we collaborate with are bound by contractual agreements to process your personal data in compliance with GDPR standards, including the implementation of appropriate technical and organizational measures to safeguard your data. You retain all rights under the GDPR, including the right to access, rectify, or request the deletion of your personal data. If you have concerns regarding the processing of your personal data by the Third-Party service providers, you should contact them directly as the data controller.
Government authorities: Data is shared with tax authorities, labor offices, and other relevant regulatory bodies as required by law.
International data transfers:we do not transfer personal data outside the EU/EEA. LLC “SOFTWARE PRODUCT DEVELOPMENT”, LLC “SPD-GROUP UKRAINE”, does not transfer personal data outside Ukraine unless required by law.SOFTWARE PRODUCT DEVELOPMENT GLOBAL LTD does not transfer personal data outside UK unless required by law.
8. Data Retention
Unsuccessful job applications: Retained for 12 months, after which data is deleted unless consent is obtained for longer storage.
Employees: Personal data is retained for the duration of employment and as required by local labor and tax laws.
9. Data Subject Rights
9.1. If your personal data is processed by SPD TECHNOLOGY RO S.R.L., you have the following rights:
The right to receive information about your personal data processed by us, the purposes of their processing, if possible, the period during which personal data is processed (if this is not possible, the criteria for determining such a period), the logic that conditions any automated processing of personal data, and receipt of confirmation and notification of those personal data that concern you and are subject to processing, the consequences of such processing, categories of relevant personal data.
The right to receive a copy of personal data that is in the process of processing. We will provide you with information in a concise, transparent, comprehensible and easily accessible form, using clear and simple wording, without unreasonable delay and in any case within one month from the date of receipt of the request.
The right to limit the processing of your personal data at any time. Withdrawal of consent does not affect the lawfulness of processing that was based on consent before its withdrawal.
The right to limit the processing of your personal data or to object to processing, as well as the right to data portability. You have the right to receive your personal data in a structured, generally accepted, machine-readable format and the right to transfer such data to another controller.
The right to send a request for correction or erasure of your personal data;
The “right to be forgotten” if there is no longer a need for personal data for the purposes for which they were collected or otherwise processed; if the retention of such data violates the General Data Protection Regulation (GDPR or Union or Member State legislation that applies to you. You have the right to withdraw your consent on which the processing is based.
The right to file a complaint with a supervisory authority.
The right to know what personal information is being collected and to correct inaccurate information (if any). You may review, edit, or change your personal data by email at address [email protected].
The right to delete your personal data. You can request the erasure of your personal data by email us at the address [email protected]. In some cases, we may be legally required to keep some of the data for a certain time; in which case we will fulfill your request after we have complied with our obligations.
Depending on where you are geographically located, the relevant laws of your location may give you certain rights with respect to your personal data.
To exercise these rights, contact us at:
SPD TECHNOLOGY RO S.R.L.
Bucharest, District 4, 41 George Bacovia Street
[email protected]
9.2. If your personal data is processed by LLC “SOFTWARE PRODUCT DEVELOPMENT”, LLC “SPD-GROUP UKRAINE”, you have the following rights under Article 9 of the Law of Ukraine “On Personal Data Protection”:
Right to information – – to know the sources of collection, location of your personal data, the purpose of processing, and the location or residence of the data controller or processor. You may also authorize a representative to obtain this information unless restricted by law.
Right to access Conditions – to receive information about the conditions for granting access to your personal data, including details on third parties to whom your data has been disclosed.
Right to access – to request and obtain access to your personal data processed by the company.
Right to confirmation and content – to receive a response within 30 calendar days regarding whether your personal data is being processed and obtain a copy of the data, unless otherwise provided by law.
Right to object – to submit a reasoned request objecting to the processing of your personal data by the data controller.
Right to rectification and deletion – to request correction or deletion of your personal data if it is unlawfully processed or inaccurate.
Right to data protection – to protect your personal data from unlawful processing, accidental loss, destruction, damage, or unauthorized disclosure, including protection against false or defamatory information.
Right to file complaints – to submit complaints regarding the processing of your personal data to the Commissioner for Human Rights or to the court.
Right to legal remedies – to seek legal remedies in case of violations of data protection laws.
Right to restriction – to place reservations on the extent of data processing when providing consent.
Right to withdraw consent – to withdraw your consent for data processing at any time.
Right to understand automated processing – to be informed about the mechanisms of automated data processing used in relation to your personal data.
Right to protection from automated decisions – to be safeguarded against automated decision-making that has legal consequences for you.
To exercise these rights, contact us at
LLC “SOFTWARE PRODUCT DEVELOPMENT”
Ukraine, 18002, Cherkasy region, Cherkasy, Shevchenko bldg. 266, office 213
[email protected]
LLC “SPD-GROUP UKRAINE”
Ukraine, 18005, Cherkasy region, Cherkasy city, Kryvalivska str, 7
[email protected]
9.3. As a data subject under UK GDPR, you have the following rights:
Right to be informed – Receive clear information about how your data is processed.
Right of access – Request a copy of your personal data.
Right to rectification – Correct inaccurate or incomplete data.
Right to erasure (“right to be forgotten”) – Request deletion of data under certain conditions.
Right to restrict processing – Limit how data is processed.
Right to data portability – Receive data in a structured, machine-readable format.
Right to object – Object to processing based on legitimate interests.
Rights related to automated decision-making and profiling – Request human intervention if automated decisions affect you.
To exercise these rights, contact us at:
SOFTWARE PRODUCT DEVELOPMENT GLOBAL LTD
20 Birchin Court, Birchin Lane, London, United Kingdom, EC3V 9DJ
Do we update your personal data?
We take all reasonable steps to update your data to ensure that inaccurate personal data, having regard to the purposes for which it was processed, is deleted or corrected without delay. You have the right to contact us to correct your personal data and the right to fill in incomplete personal data, including by submitting an additional statement.
You have the right to delete your personal data and stop processing it (“right to be forgotten”) if:
the personal data is no longer necessary for the purposes for which we collect it or otherwise process it
you had withdrawn your consent or objected against the processing of your personal data, and if there is no other lawful basis for the processing, or if the processing of your personal data otherwise does not comply with the General Data Protection Regulation (GDPR).
In the event of receiving a request for erasure of personal data and in the event of providing your personal data to third parties (in accordance with Section 6), we take appropriate measures, including technical measures, to inform such third parties that process personal data that you have requested the erasure of any references to, copies of, or reproductions of such personal data.
We will only retain your personal data for as long as is necessary for the purposes set out in this Privacy Policy, unless a longer retention period is required or permitted by law (for example, tax, accounting or other legal requirements).
We may be required to erase your personal data to comply with a statutory obligation set out in the legislation that applies to us.
Unless we have an ongoing legitimate business need for the processing of your personal data, we will delete or anonymize such information (data).
10. Security Measures
We store your personal data exclusively in compliance with the requirements for their safety, integrity, and a special regime of access to them, which excludes the possibility of familiarization, distribution, and access to personal data directly or indirectly by third parties. We process personal data exclusively in a way that ensures an appropriate level of security and confidentiality of personal data, including to prevent unauthorized access or use of personal data, as well as equipment necessary for processing and against accidental loss, destruction, or damage, using appropriate technical and organizational tools.
We implement appropriate technical and organizational measures to protect personal data, including:
Secure storage and access controls. Access to your personal data is restricted to authorized personnel only.
Encryption of data where applicable.
Regular Security Audits and Penetration Testing. We conduct regular security audits and penetration testing to identify and address potential vulnerabilities in our systems. These assessments are performed by qualified security professionals to ensure that our security measures are effective and up-to-date.
Data Minimization and Anonymization. We adhere to the principle of data minimization, collecting and processing only the personal data necessary for the specified purposes. Where possible, personal data is anonymized to further protect your privacy.
Incident Response and Breach Notification. In the event of a data breach, we have a comprehensive incident response plan in place. We will notify the relevant supervisory authorities and affected individuals without undue delay, and within the timeframes required by the GDPR, should a breach pose a high risk to your rights and freedoms.
Data Retention and Disposal. We retain your personal data only for as long as necessary to fulfill the purposes for which it was collected, in accordance with our Data Retention Policy. When your data is no longer needed, it is securely deleted or anonymized.
Third-Party Service Providers. Where we engage third-party service providers to process personal data on our behalf, we ensure that they are bound by contractual obligations to implement appropriate technical and organizational measures to protect your data in compliance with the GDPR.
Your Rights and Our Responsibilities. We respect your rights under the GDPR, including your rights to access, rectify, erase, and restrict the processing of your personal data. Our responsibilities include ensuring that your data is processed lawfully, fairly, and transparently, and that your privacy is protected at all times.
For the purposes of this Policy and other requirements, this section is considered the Data Protection Policy and Data Retention Policy.
11. Updates to This Privacy Policy
We may update this Privacy Policy from time to time to comply with legal requirements. Any updates will be published on our website, and we encourage you to review the policy periodically.
12. Contact Us
If you have any questions about this Privacy Policy or our data processing practices, you may contact us at:
SPD TECHNOLOGY RO S.R.L.
Bucharest, District 4, 41 George Bacovia Street
[email protected]
LLC “SOFTWARE PRODUCT DEVELOPMENT”
Ukraine, 18002, Cherkasy region, Cherkasy, Shevchenko bldg. 266, office 213
[email protected]
LLC “SPD-GROUP UKRAINE”
Ukraine, 18005, Cherkasy region, Cherkasy city, Kryvalivska str, 7
[email protected]