1.1.Rules on the Processing of Personal Data of Participants in Personnel Selection (hereinafter referred to as the Rules) establish how UAB “BALTIC AMADEUS” (hereinafter referred to as the Company) processes the personal data of participants in personnel selection (hereinafter referred to as Candidates).

1.2.The Rules are prepared in accordance with Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 on the protection of natural persons concerning the processing of personal data and on the free movement of such data, repealing Directive 95/46/EC (General Data Protection Regulation) (hereinafter referred to as the Regulation), the Law on Personal Data Protection of the Republic of Lithuania and other legal acts regulating the protection and processing of personal data.

1.3.These Rules are intended for Candidates to familiarize themselves with how their personal data is processed by the Company during and after the personnel selection process. They also establish requirements that must be followed by the employees of theCompany’s Human Resources Unitand People Development Managersresponsible for organizing and conducting personnel selections.

1.4.These Rules are published on the Company’s website and in the Company’s job advertisements.


2.1. Candidates submitting their CV and/or other personal data to the Company for participation in the
personnel selection process are provided with the information specified in Articles 13 and 14 of the
Regulation regarding the processing of their personal data. This is done by including a link to these
Rules and the Company’s Privacy Policy in job advertisements.

2.2. If a Candidate is recommended by a friend who is already an employee of the Company, the
recommending employee, in accordance with the Company’s approved recommendation rules, before
providing information to the Company must inform the proposed Candidate that the Candidate’s
personal data (name, surname, phone number, email address, recommended position, additional
information such as a link to a LinkedIn profile, information about work experience, etc.) will be submitted
to the Company and processed in accordance with these Rules and the Candidate’s consent to being
recommended must be obtained.

2.3. In conducting employee recruitment, the Company utilizes a personnel recruitment platform (hereinafter
referred to as the System) managed by external service providers (data processors engaged by the
Company). Candidates can submit their personal data in the System when applying for positions
advertised by the Company or when receiving an invitation from the Company via email or a LinkedIn
message. Before providing their personal data in the System, Candidates must familiarize themselves
with the Privacy Policy and terms of use of the service provider managing the System.

2.4. The Company processes the personal data of Candidates on the basis of consent, expressed when the
Candidate sends his/her CV and/or other data to the Company by email, LinkedIn message, when
participating in a selection process conducted by a personnel search agency, or when the Candidate
agrees to be recommended by a friend or submits data in the System.

2.5. The Company must have and maintain evidence that the Candidates have been informed about the
processing of their personal data.


3.1. For those Candidates who participated in the Company’s publicly announced personnel selection for a specific position but were not selected for employment, CVs, and/or other data may be stored for a period of 3 years after the end of the personnel selection if the Candidates have agreed to it. The possibility to consent to the processing of personal data after the end of the personnel selection is provided by informing the Candidate via email, LinkedIn message, or by providing a consent form via System.

3.2. If the Candidate has not given consent for data storage after the end of personnel selection process, his/her data is either destroyed (including data in paper form, email inbox, or other information storage media) or anonymized in a way that makes it impossible to identify the Candidate’s identity, excluding a case defined in section 3.6.

3.3. The end of the personnel selection is considered to be the date of concluding an employment contract with the selected Candidate for a specific position or the end of the selected Candidate’s probationary period (if specified). The personal data of Candidates who have not given consent for further storage is destroyed or anonymized until the end of the personnel selection.

3.4. Personal data of those Candidates who submitted their CV and/or other data without participating in the Company’s publicly announced personnel selection for a specific position but intending for the Company to contact them in the future if a job opportunity arises, may be stored for a period of 3 years if the Candidates have agreed to it. The possibility to consent to the storage of personal data is provided by responding to the Candidate’s request via email or LinkedIn message, providing a link to the Company’s website where these Rules and Privacy Policy are published, or by providing a consent form via System.

3.5. The Candidate can withdraw the given consent for the storage of personal data at any time by notifying the Company in writing (via e-mail, LinkedIn message).

3.6. Based on legitimate interest as the legal basis for data processing and for the purpose of communication traceability, the Company has the right to retain and process the Candidate’s personal data for 1 year after the end of the personnel selection in individual cases (e.g., if Candidates for the specific position are selected by the recruitment agency and the agency is entitled for compensation if the Company hires such Candidate within the defined period).


4.1. The Company processes only those personal data of Candidates that are related to the Candidate’s qualifications, professional abilities, and job-related characteristics, except as specified by law. Information about the Candidate’s personal life, if not related to qualifications, professional abilities, and job-related characteristics, is not collected.

4.2. The Company processes the following personal data of Candidates:

4.2.1.Name, surname, email address, phone number, desired job position, information about education and work experience, qualifications, CV, content of the motivational letter, comments provided by the Candidate, other information submitted by the Candidate, e.g., links to social
media accounts, Candidate profiles and examples of work on the internet, etc.;

4.2.2.Recommendations, feedback from previous employers, contact persons’ personal data, their
contacts, and the content of the feedback are identified;

4.2.3.Candidate evaluation information, i.e., insights and opinions of the person(s) conducting the
selection, results of Candidate testing, answers to questions, task solutions, etc.

4.3. The Company does not process special categories of personal data (sensitive data) or data about criminal convictions of Candidates, except when such data is necessary to verify whether a person meets the legal requirements applicable for the specific position or work, and except in other cases
provided by legislation.

4.4. Special (sensitive) personal data, which cannot be processed without the legal basis specified in the applicable law, includes data revealing racial or ethnic origin, political opinions, religious or philosophical beliefs, or membership in trade unions, as well as genetic data, biometric data for the purpose of
uniquely identifying a person, health data, or data about a person’s sexual life and sexual orientation.

4.5. The Company may check the Candidate’s profile on the professional social network LinkedIn and the information published there. To ensure the Candidate’s privacy and objectivity of evaluation during the personnel selection, the Company does not proactively check data on the Candidate’s Facebook,
Twitter, and other personal social media accounts unless the Candidates provide links to their profiles in specific social networks.

4.6. The personal data of Candidates defined in point 4.2 of the Rules can be processed by the Company for the following purposes: to identify the Candidate, communicate with the Candidate through communication channels, assess the Candidate’s qualifications, experience and suitability for a specific job position.

4.7. The Company receives Candidates’ personal data, such as CVs, Candidate questionnaires, and/or other application documents (motivational letters, etc.), directly from Candidates through the following channels: e-mail and/or LinkedIn messages, through the System.

4.8. The Company may also obtain information about the Candidate, including their CV and/or other application documents, from the System, as well as from entities providing job search, recruitment, and/or intermediary services, such as recruitment agencies, online job search portals, specialized career social networks and recommendations.

4.9. The Company may collect Candidates’ personal data related to qualifications, professional abilities, and job-related characteristics from the Candidate’s current employer, having obtained the Candidate’s consent beforehand. Consent may be obtained via e-mail, LinkedIn message, or any other method allowing for the preservation of evidence of consent.

4.10. The Company has the right to collect Candidates’ personal data related to qualifications, professional abilities, and job-related characteristics from the Candidate’s previous employers without the Candidate’s consent, only by informing the Candidate about this source of information.


5.1. The Company may disclose the Candidate’s data to third parties (for example, the Company’s clients in
whose projects the potential Candidates might be involved) only after informing the Candidate in advance.

5.2. Following the requirements of data protection laws, the Company enters into data processing or transfer
agreements with all third parties that the Company may utilize to conduct personnel selections and to
which access to Candidates’ personal data may be granted (e.g., managers of personnel management
platforms, recruitment agencies, etc.). This includes signing standard terms for the processing of
personal data or applying other measures specified in Chapter V of the Regulation if personal data are
to be transferred to data recipients or processors in third countries outside the European Economic

5.3. Data processing agreements are also concluded with any other service providers who would have
access to Candidates’ personal data, such as IT or server service providers, system administrators and
other assisting service providers managing personal data according to the Company’s instructions.

5.4. Candidate personal data may also be disclosed to competent authorities or law enforcement agencies
(e.g., law enforcement institutions or supervisory authorities) but only upon their legal request justified
by applicable laws, or in cases provided by laws and following the procedures required to ensure the
rights of the Company, the security of clients, employees, and resources, or to assert legal claims and
defend legitimate interests of the Company.


6.1. The Rules are reviewed and, if necessary, updated in accordance with changes in data protection laws or their implementation practices, as well as changes in the Company’s data processing practices, but no less frequently than once a year.

6.2. These Rules and their amendments are approved by the order of the Chief Executive Officer of the Company.

6.3. All employees of the Company’s Human Resources Unit and People Development Managers are formally familiarized with these Rules in writing.

6.4. For any questions related to the processing of Candidates’ personal data, it is recommended to contact the Company in writing at the email address