Privacy Policy

Last Updated: August 15, 2025

On this page, you will find detailed information about our privacy practices, including our Privacy Notice and Privacy Policy. These documents explain how we collect, use, and protect your personal data, as well as your rights regarding your information. We encourage you to review them carefully to understand how we handle your privacy.

PRIVACY POLICY

Who we are. Alcor-Ukraine LLC together with its affiliates, associates and partners (collectively “Alcor” or “we”) has collected your personal data when looking to fill:

Also, we might collect your personal data to fulfill our legal and regulatory obligations, including those related to employment, taxation, and data protection.

Personal data that we process. Apart from the information you directly provided to us (if applicable), the personal data we have collected about you may also include the information found on publicly accessible sources (such as LinkedIn, GitHub, Behance, Hireline, other job-search platforms, and, wherever applicable, Facebook, Instagram and other websites where and to the extent they contain the data directly related to your occupation & professional experience) that normally amounts to the following:

Moreover, during selection process we may gather and process other information about you – for instance, referring to your interests and preferences, as well as any other data that is relevant for evaluation of your professional skills and knowledge, or which is provided by you at your own wish.

In some cases, your personal data may be presented to us by a third party (for example, your former colleague or friend). In this case that person is responsible for receipt of your consent for sharing the data with us.

Automated Decision-Making. We may use your personal data in automated decision-making processes, including profiling, to evaluate and match your skills with job opportunities. You have the right to object to such processing and request human intervention if desired. Please refer to our Privacy Policy for more details.

How we process your data. We will process your data to the extent necessary to fill the role at:

Retention period. We would like to keep your data for 2 years from now (in particular, to be able to offer you future job opportunities), or, as the case may be, until the vacancy for which we are considering you at any given moment is closed, whichever is later.

At the end of the applicable retention period, your data will first be blocked, meaning access will be restricted for any processing except for legal obligations, and then permanently deleted or anonymized, in accordance with applicable law.

Transfer of your personal data. We may share your data only with our customers the list of which is provided herein above (normally based on your explicit consent), or as provided in our Privacy Policy. Additionally, we may share your data with authorized providers to verify your work status and conduct necessary background or reference checks in compliance with applicable law.

You have the right to access the personal data we hold and understand how it is being processed. You may also request the rectification of any data that is incomplete or inaccurate, the cancellation of data when it is no longer necessary for the purposes specified in this notice. Additionally, you can object to the processing of your data for specific purposes. Rights are specified as follows:

Right of Access: You have the right to ask if we are processing your personal data and request a copy of it. However, certain exceptions apply, such as legal privilege or if providing the information would disclose another person’s data.

Right to Rectification: You can request that we update or correct any inaccurate or incomplete personal data we hold about you. We will take reasonable steps to ensure your data is accurate and notify any third parties we have shared your data with, if possible.

Right to Cancellation: You have the right to withdraw your consent or opt-out of data processing at any time by contacting us. This won’t affect the legality of any processing done before you opted out. If we have a separate legitimate reason for processing your data, it may continue even after you withdraw consent.

Right to object. You can ask us to stop processing your personal data and we will abide so as long as we rely on our legitimate interest as described above, except if we can demonstrate other compelling legal grounds for the continued processing.

To exercise any of these rights, you can submit a request to the department responsible (please refer to the specific section for further details). We will provide you with the necessary information and support to facilitate the exercise of your rights regarding your personal data.

Right to file a complaint. If you consider that your personal data is processed in contradiction with the provisions of domestic and/or international law, we ask you to inform us about such a contradiction, and we will resolve it as soon as possible (please see details in Section “Contact us” herein below). In some jurisdictions like Colombia and Mexico, you will be required to provide proof of your identity to exercise your rights to ensure that your personal data is not disclosed to unauthorized persons.

Additionally, you also have the right to file a complaint directly with the respective personal data protection authority, namely:

NOTE: If you are located in countries or regions not mentioned above, you may contact us, and we will provide you with the contact details of the competent authority in your country or region to which you can file a complaint (please see details in Section “Contact us” herein below).

Use of Cookies. Our website uses cookies to enhance your user experience. For detailed information about how we use cookies and how you can manage your preferences, please refer to our Privacy Policy.

Security measures. We take appropriate technical and organizational measures to protect your personal data from unauthorized access, alteration, loss, or destruction, as required by law. These measures include secure data storage, encryption, and restricted access to personal data by authorized personnel only.

Additionally, all persons involved in processing your data, including employees, contractors, and service providers, are bound by confidentiality obligations that remain effective even after the termination of their relationship with us.

Lastly, we regularly review and update our security practices to ensure compliance with the latest regulatory requirements and industry standards.

Data Minimization. We only collect the minimum amount of personal data necessary to achieve the purposes outlined in this Privacy Notice. We ensure that the data collected is relevant and not excessive for the purposes for which it is processed.

Changes to this Privacy Notice. We may update this Privacy Notice from time to time to reflect changes in our practices, legal requirements, or other necessary updates. We will notify you of any significant changes by updating the “Last Revised” date at the top of this notice and, where required by law, provide a more prominent notice or obtain your consent.

Breach Notification. In the event of a data breach that compromises your personal data, we will notify you and the relevant data protection authorities promptly, detailing the nature of the breach, the affected data, and the measures being taken to mitigate its impact.

Responsible Department. The department responsible for managing and protecting your personal data is the Legal Department. This department ensures that your data is processed in compliance with applicable laws and regulations. You can reach the DPO for any inquiries or concerns regarding your personal data at the email address specified in the “Contact us” section.

Our privacy practices. This Privacy Notice should be read together with our Privacy Policy which describes how we process your personal data and lists your data subject rights in this respect.

Contact us. If you want us to delete your data and stop contacting you, you may ask us to do so by one of the following means:

E–mail: dpo@alcor-bpo.com

Telephone: +380-44-359-13-60

Postal address (physical address): 01033, Ukraine, Kyiv, Simi Prakhovykh str., 58/10.


PRIVACY POLICY

Alcor-Ukraine LLC, together with its affiliates, associates, and partners (“Alcor”, “we” or “us”) is a company specializing in rendering tech recruitment services as well as providing other operational (back-office) solutions. In the course of its business, Alcor collects some information that could be used to identify you.

We call this information “personal data”. We control the collection and processing personal data relating to individuals who interact with us (“data subjects” or “you”). The data subjects may include (without limitation): visitors and users of our website alcor-bpo.com (collectively “users”); candidates for current or future roles at our companies or at our customers’ companies (“candidates”); as well as our existing or potential customers (collectively “customers”).

Please read this Policy that explains:

Alcor ensures that this Policy is in compliance with the following Laws:

As we operate in many countries around the world, our privacy practices may vary among the regions to reflect local practices and laws. However, in no case will they be less strict than those provided in this Policy.

Additionally, we assume that in the course of our normal business activities, we may unintentionally receive, store, process, and transfer the personal data of individuals who are located in countries or regions not mentioned in this Policy. However, we guarantee for these people a level of personal data protection and security no lower than that required by the legislation of the aforementioned countries.

Please note that some Alcor activities may be performed in conjunction with other companies (for instance: our customers), in which case respective companies сan also receive your personal data which will be used according to their terms of use and privacy policies and, if applicable, other agreements between Alcor and such companies. You may find more details in Section “Sharing and transferring personal data”.

PERSONAL DATA THAT WE COLLECT

The personal data we receive in the course of our business may include the following:

Please note that the specific range of personal data we collect varies on a case-by-case basis, and, among other things, depends on how you interact with us and for which purpose.

Moreover, we can collect some amount of information about you (such as your language preferences, operating system, device settings, etc.) using the cookies and other similar technologies on this website (please see details in our Cookie Policy).

PERSONAL DATA THAT WE DO NOT INTENTIONALLY COLLECT

Of course, you are free to decide which information to share with us. However, we ask you to consider the following warnings:

HOW WE COLLECT THE PERSONAL DATA

We receive personal data directly from you when you interact with us, especially when:

In general, you are not obliged to provide your personal data to us. However, most probably we will not manage to fulfil your requests or provide you with the services (wholly or partially) unless you do so. If you ask, we will advise you whether the provision of your personal data is mandatory in that particular case (and of possible consequences if you do not provide us with it).

Please note that we may combine personal data about you collected from different sources.

If you are a candidate for current or future roles at our companies or customers’ companies, we may:

You may be assured that when any portion of your personal data is not collected directly from you (for instance, if we find your profile online and add your personal data to our database in order to contact you with a proposal to participate in the selection for open vacancy), we will always notify you at the point of collecting personal data in such a manner or, at the latest, within a month from the moment of collection of that data. We will process such personal data for the purpose for which it was gathered until you ask that we remove it. However, in such a case Alcor will have the right to keep some personal data to the extent required by the provisions of domestic and/or international law.

HOW WE USE THE PERSONAL DATA

Alcor may use your personal data for the purposes described below.

This list is not exhaustive, and we may seek to process your personal data for any other purpose as disclosed to you, to which you specifically agreed, or as required or permitted by the provisions of domestic and/or international law.

LEGAL BASIS FOR THE PROCESSING OF YOUR PERSONAL DATA

The legal basis upon which we collect, use, store, and otherwise process your personal data will depend on the personal data concerned and the specific purpose for which it is needed.

In general, we rely on one of the following grounds:

You may be assured that we use your personal data in ways that you would reasonably expect, and our legitimate interest serves as a legal basis for collection and processing your personal data only if, and to, the extent it does not interfere with your rights and freedoms.

You have the right to object to these grounds of processing your personal data by contacting us (please see details in Section “Contacts”), upon which we will delete your personal data without further delay (unless we have a separate legitimate ground for further processing).

NOTE: you are free to withdraw your consent at any time by contacting us (please see details in Section “Contacts”), upon which we will delete your personal data without further delay (unless we have a separate legitimate ground for further processing). If you withdraw your consent, it will not affect the lawfulness of prior processing your personal data based on your consent before you withdrew it.

Please be assured we will handle and process your personal data only in line with the purpose for which it was collected. If at any moment we intend to process your personal data for any other purpose, we will not do this without sending you respective notification / your prior explicit consent (subject to the exclusions and limitations which may be provided in the provisions of domestic and/or international law).

NOTE! If you share personal data of any third person with us, you ensure that you have received freely given, specific, informed and unambiguous consent of that person to such transfer and further processing respective data by us, and you may present appropriate evidence of it upon request.

If you have any questions or need more information concerning the legal basis on which we collect your personal data, please contact us to clarify further details (please see details in Section “Contacts”).

HOW LONG WE KEEP YOUR PERSONAL DATA

To determine the appropriate retention period for your personal data, we consider (1) the amount, nature, and sensitivity of the personal data in question; (2) the potential risk of harm from unauthorised use or disclosure of your personal data; (3) the purposes for which we process your personal data; (4) whether we can achieve those purposes through any other means; and (5) the applicable legal requirements.

We do not keep your personal data for any longer than is necessary (a) to fulfill the purpose for which we collected it (you may find more details in Section “How we use the personal data”); (b) to comply with domestic and/or international law, or other regulatory obligations (for instance, accounting or reporting requirements) that apply to our business and services we provide; or (c) to assert and/or defend against legal claims.

Where personal data is subject to Mexican law, and the applicable retention period has ended, the data will be first blocked, meaning access and further processing will be restricted; and only then securely deleted, in accordance with applicable law.

For example:

Below you may find out how long we keep your personal data in some specific cases (please note that the list is not exhaustive):

CASE DESCRIPTION

RETENTION PERIOD

(starting from the moment of

personal data collection)

Filling in ‘Contact us’ form on our website

1 year

Contacting us through live chat

(lower right corner of the pages on our website)

1 year

Sending us your CV and other personal data to be considered for specific IT vacancy

2 years

Sending us your CV and other personal data to be considered for current and future available IT vacancies

2 years

Normally, the retention period will not exceed 2 years. However, we are legally required to hold some types of personal data to fulfill our statutory obligations (for instance, taxation, accounting, or reporting purposes) – then we will hold your personal data in our systems for as long as necessary for the relevant activity. Moreover, in some cases, we may anonymize your personal data (in such a manner that you are not or no longer identifiable) for research or statistical purposes, in the event of which we may use this information indefinitely without further notice to you.

We review our personal data retention periods on a regular basis. If you have any questions about how long we keep your personal data, you may contact us (please see details in Section “Contacts”) to clarify all the questions you have.

YOUR RIGHTS WITH RESPECT TO PERSONAL DATA

As a data subject, you have certain rights under domestic and/or international law in relation to the personal data we hold about you. The processing of your personal data may be subject to:

Where the processing of your personal data is subject to the mentioned data protection Laws, at a minimum you have the set of data subject rights provided below.

NOTE: If you are located in countries or regions with legislation that is not mentioned above, we guarantee you a level of personal data protection and security no lower than that required by the legislation of the aforementioned countries.

Right of access

If you ask us, we will confirm whether we are processing your personal data and, if necessary, provide you with a copy of such personal data (along with other details). There are some limitations and exceptions concerning this right: for example, where information is legally privileged, or if providing you with the information would reveal any personal data of another person.

Right to data portability

In certain circumstances, you have the right to receive your personal data provided by you to us and reuse it elsewhere, or send such data to another organization (or ask us to do so if technically feasible); this is regarding where (1) our lawful basis for processing the personal data is consent or necessity for the performance of our contract with you, and (2) the processing is carried out by automated means.

This right allows you to request that we transfer your personal data directly to another organization, where technically feasible.

Right to rectification

You may require us to update or correct any inaccurate personal data or complete any incomplete personal data concerning you. If you do, we will take reasonable steps to check the accuracy and correct your personal data. Please let us know if any of your personal data changes so that we can keep it accurate and up-to-date. If you are entitled to rectification and if we have shared your personal data with others, we will let them know about the rectification where possible. If you ask us, where it is possible and lawful for us to do so, we will also tell you who we have shared your personal data with, so that you can contact them directly. Also note that Alcor is not required to notify third parties to whom your personal data has been disclosed of any rectification when such notification involves an unreasonable burden or disproportionate effort.

You also have the right to request the correction of your data directly through our online portal or by contacting us using the details provided in this Policy.

Withdrawal of consent (right to opt-out)

If we rely on your explicit consent as our legal basis or any other legal basis mentioned in this Policy for processing your personal data, you have the right to withdraw that consent or to opt out of data processing (unless we have a separate legitimate ground for further processing) at any time by contacting us (please see details in Section “Contacts” herein below). It will not affect the lawfulness of processing before you decide to opt-out or withdraw your consent.

Right to object

You can ask us to stop processing your personal data and we will abide so, if we are:

Right to erasure

You can ask us to delete your personal data in some circumstances, for instance if you withdraw your consent (where applicable). For situations where, in accordance with the provisions of domestic and/or international law, we fulfil your request, Alcor will delete your personal data without undue delay. If you are entitled to erasure and if we have shared your personal data with others, we will let them know about the erasure where possible. If you ask us, where it is possible and lawful for us to do so, we will also tell you who we have shared your personal data with, so that you can contact them directly. Also note that Alcor is not required to notify third parties to whom your personal data has been disclosed of any deletion when such notification involves a disproportionate effort or unreasonable burden.

You can request the deletion of your personal data when it is no longer necessary for the purposes for which it was collected, or if you withdraw your consent and there is no other legal basis for processing. In such cases, we will erase your personal data without undue delay, unless legal obligations require us to retain it.

Right to restriction of processing

You can ask us to ‘block’ or suppress the processing your personal data in certain circumstances (such as where you contest the accuracy of that data or you object to us), so that we no longer process that personal data until that restriction is lifted. If you are entitled to restriction and if we have shared your personal data with others, we will let them know about the restriction where it is possible for us to do so. If you ask us, where it is possible and lawful for us to do so, we will also tell you who we have shared your personal data with, so that you can contact them directly.

Rights in relation to automated individual decision-making, including profiling

You have the right to be free from decisions based solely on automated processing your personal data, including profiling, unless these are necessary for entering into, or the performance of, a contract between you and us, or unless we do so based on your explicit consent (still such consent can be withdrawn as described in Subsection “Withdrawal of consent”).

This is why we normally request your consent before analyzing your personal data (on our own or via our providers) to build individual profiles. These profiles may be used to discover your interests and display targeted advertisements online. The aim is to provide you with offers that are relevant and interesting for you. The profiling is based on interaction with our website, e-mails, and content. As we will not collect your name and other important personal data, such as your addresses or bank details, in the course of such profiling, we expect that such profiling will have no further impact, other than providing you with a more pleasant user experience when surfing the Internet. We will make no automated decisions that would result in legal effects or similarly significantly affect you.

You have the right to request human intervention in cases where automated decision-making is used, particularly if such decisions have legal consequences or otherwise significantly affect you. This right includes the ability to express your point of view and contest the decision.

Right to file a complaint

If you have a concern with respect to the way we process your personal data, you can report it to the relevant supervisory authority (please see details in Section “Complaints” herein below).

Please note that these rights are not absolute and in certain cases are subject to conditions as specified in the provisions of domestic and/or internationals law. For instance, it may happen if we have an overriding interest or legal obligation to continue to process your personal data.

You can exercise the above rights, where applicable, by contacting us directly (please see details in Section “Contacts”). We will respond to your request within the statutory period and typically seek to resolve the matter within one month. We will require you to provide satisfactory proof of your identity in order to ensure that your personal data is disclosed only to you.

In some jurisdictions like Colombia and Mexico, you will be required to provide proof of your identity to exercise your rights to ensure that your personal data is not disclosed to unauthorized persons.

While we will make reasonable efforts to accommodate your request, we reserve the right to reject such access requests, or to impose restrictions or requirements upon such requests if required or permitted by provisions of domestic and/or internationals law but will explain “why” if we do so.

SHARING AND TRANSFERRING PERSONAL DATA

Please note that your personal data may be processed outside of the European Economic Area, US, Argentina, Brazil, Chile, Colombia, Mexico, or Uruguay, particularly in Ukraine. Please be informed that Ukraine is not determined by some countries as a country that offers an adequate level of data protection, which entails certain risks of losing the protection provided under the applicable legislation, when your personal data is transferred outside of the mentioned countries, US, or European Union/ European Economic Area. Moreover, we may transfer your personal data to other countries (such as the United Kingdom, etc.).

If it’s required under the applicable legislation, we have in place appropriate contractual clauses or arrangements implemented in the agreements executed with our customers and third-party service providers, in order to provide adequate protection for the transfer of your personal data.

Alcor may exchange your personal data with its affiliates, associates and partners. Moreover, we may share your personal data with our customers and third-party service providers (as described below) where and to the extent necessary in connection with the purposes described in this Policy. Anyway, you may be assured that we do not share personal data with third parties, except as (a) necessary for our legitimate professional and business needs; (b) necessary to carry out your requests; (c) necessary to provide our services to you; (d) pursuant to your explicit consent; (e) required or permitted by law; and/or (f) as otherwise described in this Policy. Alcor will only transfer personal data to such persons when they meet our strict standards on the processing personal data and security and pass those same standards down to their sub-processors.Where we believe that processing or other business activities on our behalf or in our interest are better performed by third parties (“third party service providers”), we may outsource respective operations to them and, consequently, transfer your personal data to those entities, such as our IT systems providers, background check providers, website hosting providers, data analysis, data backup, security and cloud storage services, consultants and other providers. We only share personal data that they reasonably need to provide their services and will not transfer your personal data to any third parties for their own direct marketing purposes. We ensure that third party service providers are authorized to use your personal data only as necessary to provide services on our behalf or in our interest.

Please note that the storage of your personal data on servers and/or on software made available or hosted by third party service providers shall not be considered a disclosure of your personal data to third parties as far as third-party service providers do not have direct access to it. In all events, we shall ensure by contract that our third-party service providers protect your personal data that is shared with them.

In an ongoing effort to better understand users of our website, we may analyze anonymous and aggregate information in order to operate, maintain, manage, and improve our website and/or services that we render. This aggregate information does not identify you personally. We may share this aggregate data with our customers, third party service providers and other persons. We may also disclose aggregated user statistics in order to describe Alcor services (or pursuing other lawful purposes) to current and prospective business partners, customers and other persons.

In certain situations, we may be required to disclose your personal data where we have a legal necessity or obligation to do so, including to meet the requirements set forth by domestic and/or international law. For instance, we may disclose your personal data to assert and/or defend against legal claims.

In the event of a sale, merger, receivership or transfer of all assets of Alcor, we reserve the right to assign or share your personal data with such third parties and their advisors. Please be assured that you will be sent notice of such an event should it occur with the ability to opt-out of such a transfer unless Alcor and/or such third parties have a separate legitimate ground for such transfer and further processing your personal data.

PERSONAL DATA SECURITY

Alcor has security measures in place to protect information we process (including your personal data), which involve preventing, detecting, investigating, and resolving security threats, both during transmission and once we receive it.

We do our best to protect your personal data, whether in electronic or tangible form (e.g., hard copy), by sticking to appropriate internal policies and using state-of-the-art technical and organizational measures that follow the applicable requirements for the safe and lawful processing personal data.

Moreover, we restrict access to your personal data to authorized individuals among internal personnel, agents, or contractors of Alcor who need to access your personal data to perform specific tasks. Your personal data is contained behind secured networks and is only accessible by a limited number of persons who are required to keep the information confidential.

Although we use industry-standard precautions to safeguard your personal data, the transmission of data over the Internet (including by e-mail) is never completely secure. We endeavor to protect personal data, but 100% complete security does not presently exist anywhere online or offline. For this reason, you should take care in deciding what information you send to us, especially when you do so at your own initiative.

In the event of a data breach that compromises your personal data, we will notify you and the relevant data protection authorities promptly, detailing the nature of the breach, the affected data, and the measures being taken to mitigate its impact.

If you have any questions about security, you may direct them to us (please see details in Section “Contacts”).

LINKS TO OTHER WEBSITES

Our website (including this Privacy Policy) may contain links to other websites and you should review the privacy policies on those sites. We have no responsibility for the policies and practices of those sites.

CHANGES TO THIS PRIVACY POLICY

We may from time to time, modify this Privacy Policy, upon which we will also update the ‘Last Revised’ date stated herein above. Even though we may inform you about any changes hereof (especially by sending you an electronic notice if you provided us with your e-mail address), you are still advised to visit this page regularly for the latest information on our privacy practices with regard to our privacy practices.

COMPLAINTS

If you consider that your personal data is processed in contradiction with the provisions of domestic and/or international law, we ask you to inform us about such a contradiction, and we will resolve it as soon as possible (please see details in Section “Contacts” herein below). Additionally, you also have the right to file a complaint directly with the respective personal data protection authority, namely:

NOTE: If you are located in countries or regions not mentioned above, you may contact us, and we will provide you with the contact details of the competent authority in your country or region to which you can file a complaint (please see details in Section “Contacts” herein below).

CONTACTS

If you (a) have any questions or complaints regarding this Policy or the way your personal data is processed; (b) would like to report any suspicious activity, including automated messages or calls from parties you cannot identify; or (c) would like to exercise a legal right in relation to your personal data, please contact us via the address below.

EU representative according to article 27 of General Data Protection Regulation (GDPR): “MyLo” Pogoda Gładki Grzesiek sp.k.

Postal address: Jana Sobieskiego str., 1/2, 31-136 Kraków, Poland.

Email: dpo@alcor-bpo.com