About us

Active Search Partners Ltd (“Active Search Partners,” “ASP,” “we,” “us,” or “our”) is a company incorporated in the Republic of Cyprus, licensed as a Private Employment Agency by the Ministry of Labour in the Republic of Cyprus.

As a recruitment agency, we take your privacy seriously and are committed to protecting your personal data. This privacy policy will inform you about how we collect, use, share, and protect your personal data when you interact with us, and about your privacy rights and how the law protects you.

What is the scope of this policy?

This policy applies to the collection of personal data in the context of our activity as a private employment agency and the provision of talent mapping, advisory services, and executive search to our clients. It applies to individuals who may be one or more of the following:

1. a) Candidates, including prospective or placed candidates;
2. b) Prospective or existing clients, or persons holding an office at or representing a client;
3. c) Referees, whose contact details may be provided by candidates;
4. d) Users of our website;
5. e) Suppliers or persons representing a supplier offering services to us.

Please read this privacy policy carefully to understand our practices regarding your personal data.

Who is the Controller of my information?

Active Search Partners Ltd is the controller of your personal information, meaning we decide the purposes and means of processing your personal data.

Our contact details are:

• Email address: info@activesearchpartners.com
• Physical address: Nikolaou Pentadromos Center, Agias Zonis 1, Office 406, Limassol, 3026

 

Data Protection Officer

We have appointed a data privacy officer who is responsible for overseeing questions in relation to this privacy policy. If you have any questions about this policy or our privacy practices, please contact our data privacy officer using the contact details provided above.

What if I am not satisfied by the way you have handled my personal data?

You have the right to lodge a complaint at any time to the data protection commissioner in the Republic of Cyprus, at the following address:

1 Iasonos Street, 1082 Nicosia, Cyprus Tel.: +357 22 818 456 Fax: +357 22 304565 E-mail: commissioner@dataprotection.gov.cy

However, we would appreciate the opportunity to address your concerns before you approach the data protection commissioner, so please contact us in the first instance.

What personal data do we collect?

We only collect personal data in line with applicable laws and to the extent necessary for the legitimate conduct of our business. We collect different types of personal data depending on your relationship with us:

For Candidates:

• Identity Data: first name, last name, title, date of birth, gender, nationality/ies
• Contact Data: email address, telephone numbers, residential address, city, country, social media profile(s)
• Candidate Resume Data: qualifications, educational background (e.g. degrees, certifications, academic history, courses), work experience, skills, employment history, specific industries you would be interested in working in, links to your professional profiles (e.g., LinkedIn), motivational letter etc.
• Candidate Activity Data: applications made, scheduled interviews, outcomes of interviews, logs of contact between you and us
• Financial Data: salary expectations and compensation history (where provided)
• Professional References: name, job title, company, relationship to you, contact details
• Assessment Data: Performance evaluations, skills assessments, psychometric test results

For Clients:

• Identity Data: first name, last name, title
• Contact Data: email address, telephone numbers, business address
• Professional Data: job position, company, business information related to your resourcing needs
• Communication Data: records of our interactions

For Referees:

• Identity Data: name, title
• Contact Data: email address, telephone number
• Professional Data: job position, company, relationship with candidate

For Website Users:

• Technical Data: internet protocol (IP) address, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform, and other technology on the devices you use to access our website
• Usage Data: information about how you use our website

For Suppliers:

• Identity and Contact Data: name, company, email address, telephone number
• Payment Data: bank account details and payment records

Please note that we do not intentionally collect any Special Categories of Personal Data (data revealing racial or ethnic origin, political opinions, religious or philosophical beliefs, trade union membership, genetic data, biometric data, data concerning health, data concerning sex life or sexual orientation) or data relating to criminal convictions or offenses. However, if such data is inadvertently submitted by a candidate (e.g., within a CV or motivational letter), we will take steps to filter and delete it unless we have a lawful basis under Article 9 GDPR. We advise candidates not to include sensitive information unless explicitly requested and justified.

How do we collect your personal data?

We use different methods to collect data from and about you:

Direct interactions with candidates:

• When you submit your CV or application directly to us
• When you register on our website
• When you correspond with us via phone, email, or in-person
• During interviews and recruitment processes
• When you provide feedback

From clients:

• When you engage our services
• When you provide information about your business and recruitment needs
• During meetings and discussions about your resourcing strategies

LinkedIn Recruiter and other professional platforms:

• We search for potential candidates using LinkedIn Recruiter and other professional platforms
• We save candidates to our pipeline in LinkedIn Recruiter
• We use CRM integration to transfer selected candidate data from LinkedIn profiles

Through our website:

• When you visit and navigate our website
• When you fill out contact forms
• When you subscribe to our newsletters or communications

Automated technologies:

• As you interact with our website, we automatically collect Technical Data about your equipment, browsing actions, and patterns using cookies and other similar technologies
• For more information on how we use cookies, please see our Cookie Policy.

Third parties or publicly available sources:

• Referrals from other candidates or clients
• Professional networking platforms
• Public company websites
• Publicly available directories and registers

AI Notetaker:

• During initial calls with candidates and clients, we may use an AI notetaker to document the conversation (with your prior consent obtained via this provider). You may refuse or withdraw consent at any time.
• After the call, we download the conversation script and modify it into a summary

How do we use your personal data?

We will only use your personal data when the law allows us to. Most commonly, we will use your personal data in the following circumstances:

• Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests
• Where we need to perform the contract we are about to enter into or have entered into with you
• Where we need to comply with a legal obligation
• Where we have obtained your consent for specific processing activities

 

 

For Candidates:

Purpose/Activity	Types of Data	Lawful Basis
To register you as a candidate and maintain our candidate database	Identity, Contact, Resume Data	Legitimate interests: to support candidates in finding suitable job positions, develop our business, and maintain a talent database
To assess your skills, qualifications, and suitability for job positions	Resume Data, Candidate Activity Data	Legitimate interests: to match suitable candidates with job opportunities
To introduce you to potential employers	Identity, Contact, Resume Data	Legitimate interests: as a recruitment agency, our core business is connecting suitable candidates with employers
To communicate with you about potential job opportunities	Identity, Contact, Resume Data	Legitimate interests: to provide recruitment services and career opportunities
To use AI notetaker during initial calls	Identity, Contact, Voice Data	Consent: we will obtain your consent before using AI notetaking technology
To conduct reference checks	Identity, Contact, Reference Data	Legitimate interests: to verify candidate information for potential employers

For Clients:

Purpose/Activity	Types of Data	Lawful Basis
To register you as a client	Identity, Contact, Professional Data	Performance of a contract with you
To provide recruitment services, talent mapping, and executive search	Identity, Contact, Professional Data	Performance of a contract with you
To manage our relationship with you	Identity, Contact, Professional Data	Legitimate interests: to maintain and develop our business relationship
To send you suitable candidate profiles	Identity, Contact	Legitimate interests: to provide our recruitment services
To use AI notetaker during meetings	Identity, Contact, Voice Data	Consent: we will obtain your consent before using AI notetaking technology

For Website Users:

Purpose/Activity	Types of Data	Lawful Basis
To administer and protect our website	Technical Data	Legitimate interests: for running our business, provision of administration and IT services, network security
To deliver relevant website content and improve user experience	Technical Data, Usage Data	Legitimate interests: to grow our business and inform our marketing strategy

Marketing communications:

We may use your Identity and Contact Data to send you information about our services that may be of interest to you. You will receive marketing communications from us if you have requested information from us, used our services, or if you provided us with your details when registering for a promotion, and you have not opted out of receiving marketing communications.

We rely on our legitimate interest to send marketing messages to individuals who have engaged with our services, in line with Recital 47 GDPR. We have conducted a Legitimate Interests Assessment (LIA) to ensure this does not override your fundamental rights. You can unsubscribe at any time via the opt-out link or by contacting us.

How long will we keep your personal data?

We will only retain your personal data for as long as necessary to fulfill the purposes we collected it for, including for the purposes of satisfying any legal, regulatory, tax, accounting, or reporting requirements.

To determine the appropriate retention period for personal data, we consider:

• The amount, nature, and sensitivity of the personal data
• The potential risk of harm from unauthorized use or disclosure
• The purposes for which we process the data and whether we can achieve those purposes through other means
• The applicable legal, regulatory, tax, accounting, or other requirements

For candidates, we typically maintain your data for 24 months after our last meaningful contact with you. After this period, we will contact you to determine if you would like us to continue storing your information or if you prefer us to delete your data.

For clients, we retain your data for the duration of our business relationship and for a period afterward as required by applicable laws.

Who do we share your personal data with?

We may share your personal data with the following parties:

For Candidates:

• Potential employers
• Our CRM service provider (to store and manage your data)
• IT service providers (who help maintain our systems)
• Some clients may request that we save candidate CVs in their own CRMs

For Clients:

• Candidates who match your requirements (we only share relevant business contact information)
• Our CRM service provider
• IT service providers

All Users:

• Professional advisers including lawyers, bankers, auditors, and insurers
• Regulatory authorities, when required by law
• Third parties in connection with a business reorganization, sale, or merger

We require all third parties to respect the security of your personal data and to treat it in accordance with the law. We do not allow our third-party service providers to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our instructions.

International transfers

We store your data inside the European Economic Area (EEA).

If we need to transfer your personal data outside the EEA (for example, if we use service providers based outside the EEA), we ensure a similar degree of protection is afforded to your data by implementing appropriate safeguards:

• We aim to transfer data only to countries that have been deemed to provide an adequate level of protection for personal data by the European Commission. However, where this is not possible, we will ensure that appropriate safeguards will be put in place subject to our transfer impact assessment, such as Standard Contractual Clauses.

How do we protect your personal data?

We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used, or accessed in an unauthorized way, altered, or disclosed. These include:

• Limiting access to your personal data to those employees, agents, contractors, and other third parties who have a business need to know
• Implementing procedures to deal with any suspected personal data breach
• Technical measures such as encryption and secure IT systems

Your legal rights

Under certain circumstances, you have rights under data protection laws in relation to your personal data:

• Request access to your personal data
• Request correction of your personal data
• Request erasure of your personal data
• Object to processing of your personal data
• Request restriction of processing your personal data
• Request transfer of your personal data
• Right to withdraw consent where we rely on consent for processing

If you wish to exercise any of these rights, please contact our data privacy officer.

You will not have to pay a fee to access your personal data or to exercise any of the other rights. However, we may charge a reasonable fee if your request is clearly unfounded, repetitive, or excessive. We may also refuse to comply with your request in these circumstances.

We try to respond to all legitimate requests within one month. Occasionally it may take us longer if your request is particularly complex or you have made a number of requests.

Changes to this privacy policy

We keep our privacy policy under regular review. This version was last updated on 29 March 2025. Historic versions can be obtained by contacting us.

Cookie Policy

Our website uses cookies to distinguish you from other users of our website. This helps us to provide you with a good experience when you browse our website and also allows us to improve our site.

For detailed information on the cookies we use and the purposes for which we use them, see our Cookie Policy.

Contact us

If you have any questions about this privacy policy or our privacy practices, please contact us at:

Email address: info@activesearchpartners.com