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Privacy Policy

BlueLabs Software Ltd, a limited liability company incorporated in terms of Maltese laws, bearing registration number C 88567 and having its registered office at Tipico Tower, Level 11, Vjal Portomaso, St. Julians STJ 4011, Malta (“we”, “us”, “our“) are committed to protecting and respecting your privacy. This Privacy Policy (together with any other documents referred to herein) sets out the basis on which the personal data collected from you, or that you provide to us, will be processed by us in connection with our recruitment processes. Please read the following carefully to understand our views and practices regarding your personal data and how we will treat it. For the purpose of the General Data Protection Regulation (“GDPR”) the Data Controller is BlueLabs Software Ltd.

We use Recruitee, an online application provided by Recruitee B.V., to assist with our recruitment process. We use Recruitee to process personal information as a data processor on our behalf. Recruitee is only entitled to process your personal data in accordance with our instructions.

Your Personal Information

Information we collect from you

We collect and process some or all of the following types of information from you:

  • Information that you provide when you apply for a role. This includes information provided through an online job site, via email, in person at interviews and/or by any other method.

  • In particular, we process personal details such as name, email address, phone number, address, date of birth, qualifications, experience, information relating to your employment history, skills and experience that you provide to us as well as recorded videos of yourself that you provide to us during one-way video interviews.

  • If you contact us, we may keep a record of that correspondence.

  • A record of your progress through any hiring process that we may conduct.

  • Details of your visits to our and our service providers‘ websites including, but not limited to, traffic data, location data, weblogs and other communication data, the site that referred you to such website and the resources that you access.

Information we collect from other sources

Recruitee provides us with the facility to link the data you provide to us, with other publicly available information about you that you have published on the internet – this may include sources such as LinkedIn and other social media profiles.

Recruitee's technology allows us to search various databases – some publicly available and others not, which may include your personal data (including your CV), to find possible candidates to fill our job openings. Where we find you in this way we will obtain your personal data from these sources.

We may receive your personal data from a third party who recommends you as a candidate for a specific job opening or for our business more generally.

Uses Made Of Your Information

Lawful basis for processing

We rely on legitimate interest as the lawful basis on which we collect and use your personal data. Our legitimate interest is the recruitment of staff for our business.

Purposes of processing

We use information held about you in the following ways:

  • To consider your application in respect of a role for which you have applied.

  • To consider your application in respect of other roles.

  • To communicate with you in respect of the recruitment process.

  • To enhance any information that we receive from you with information obtained from third party data providers.

  • To find appropriate candidates to fill our job openings.

  • To help our service providers (such as Recruitee and its processors and data providers) and partners (such as the job sites through which you may apply) improve their services.

Automated decision making/profiling

We may use Recruitee’s technology to select appropriate candidates for us to consider based on criteria expressly identified by us, or typical in relation to the role for which you have applied. The process of finding suitable candidates may be automatic, however, any decision as to who we will engage to fill the job opening will be made by our staff.

Disclosure Of Your Information

As set out above, we may pass your information to our third party service providers, including Recruitee, who use it only in accordance with our instructions and as otherwise required by law.

How We Store Your Personal Data


We take appropriate measures to ensure that all personal data is kept secure including security measures to prevent personal data from being accidentally lost, or used or accessed in an unauthorised way. We limit access to your personal data to those who have a genuine business need to know it. Those processing your information will do so only in an authorised manner and are subject to a duty of confidentiality.

We also have procedures in place to deal with any suspected data security breach. We will notify you and any applicable regulator of a suspected data security breach where we are legally required to do so.

Unfortunately, the transmission of information via the internet is not completely secure. Although we will do our best to protect your personal data, we cannot guarantee the security of your data transmitted through any online means, therefore any transmission remains at your own risk.

Where we store your personal data

The data that we collect from you and process using Recruitee’s services may be transferred to, and stored at, a destination outside the European Economic Area ("EEA"). It may also be processed by staff operating outside the EEA who work for us or for one of our suppliers. By submitting your personal data, you agree to this transfer, storing and processing.

In particular, your data may be accessible to our service providers‘ staff in the USA, Australia as well as other locations worldwide and may be stored on servers in the USA, Australia as well as in the EU. The USA and Australia do not have the same data protection laws as Malta and the EEA.

A Data Processing Agreement has been signed between BlueLabs Software Limited and each of its data processors. These data processor agreements are designed to help safeguard your privacy rights and give you remedies in the unlikely event of a misuse of your personal data.

How long we keep your personal data

We will hold all the data for a period of 180 days from the moment of the last amendment of your stored data. Prior to that your personal information will be deleted without undue delay on receipt of a written request by you (or another person engaged by you) to us.

Your Rights

Under the General Data Protection Regulation you have a number of important rights free of charge. In summary, those include rights to:

  • access to your personal data and to certain other supplementary information that this Privacy Policy is already designed to address;

  • require us to correct any mistakes in your information which we hold;

  • require the erasure of personal data concerning you in certain situations;

  • receive the personal data concerning you which you have provided to us, in a structured, commonly used and machine-readable format and have the right to transmit those data to a third party in certain situations;

  • object at any time to processing of personal data concerning you for direct marketing;

  • object to decisions being taken by automated means which produce legal effects concerning you or similarly significantly affect you;

  • object in certain other situations to our continued processing of your personal data;

  • otherwise restrict our processing of your personal data in certain circumstances; and

  • claim compensation for damages caused by our breach of any data protection laws.

For further information on each of those rights, including the circumstances in which they apply, see the guidance from the Office of the Information and Data Protection Commissioner Malta on individuals rights under the General Data Protection Regulation.

If you would like to exercise any of those rights, please:

  • contact us using our Contact details below;

  • let us have enough information to identify you;

  • let us have proof of your identity and address; and

  • let us know the information to which your request relates.

How to Complain

We hope that we can resolve any query or concern you raise about our use of your information. The General Data Protection Regulation also gives you right to lodge a complaint with a supervisory authority, in particular in the European Union (or European Economic Area) state where you work, normally live or where any alleged infringement of data protection laws occurred. The supervisory authority in Malta is the Information Commissioner who may be contacted at


All questions, comments and requests regarding this Privacy Policy should be addressed to