Last Updated: August 2025
Version: 2.0
1. Introduction and Data Controller Information
LUX SEARCH LTD ("we," "us," "our," or the "Company") operates as a specialized recruitment consultancy connecting professionals with employers across Europe. We are committed to protecting your personal data and respecting your privacy rights under the General Data Protection Regulation (EU) 2016/679 ("GDPR") and Cyprus Law 125(I)/2018.
Data Controller:
LUX SEARCH LTD
Company Registration Number: ΗΕ 464568
30 Pireos Street, 1st floor, Office 1
Strovolos, Nicosia 2023, Cyprus
Email: vincent@luxsearch.eu (primary contact method)
VAT Number: CY60092221M
Data Protection Contact:
Vincent Lüders
Email: vincent@luxsearch.eu
We aim to respond promptly to all inquiries
2. Personal Data We Collect
2.1 Information You Provide Directly
When you submit your application or CV through our website, we collect:
- Identity Data: Full name, title, date of birth (if included in CV)
- Contact Data: Email address, telephone numbers, postal address
- Professional Data: Employment history, educational qualifications, professional certifications, skills, languages
- Application Data: CV/resume, cover letter, portfolio links, references
- Preference Data: Job preferences, desired salary range, location preferences, availability
- Communication Data: Records of our correspondence and interactions
2.2 Information Collected Automatically
When you visit our website, we automatically collect:
- Technical Data: IP address (anonymized), browser type and version, time zone setting, browser plug-in types
- Usage Data: Information about how you use our website, including pages visited and links clicked
- Form Submission Data: Timestamp of when you submitted your application
2.3 Cookies and Analytics
We use Google Analytics 4 (GA4) to understand how visitors use our website. GA4 uses first-party cookies to distinguish unique users and sessions.
Analytics cookies are only set after you give explicit consent via the cookie banner shown on your first visit. No analytics data is collected or sent to Google before you accept. If you decline, no analytics cookies are set and no usage data is shared with Google.
Cookies used after consent:
- _ga — Distinguishes unique visitors. Expires after 2 years.
- _ga_[ID] — Maintains session state. Expires after 2 years.
Google processes this data on our behalf under a Data Processing Agreement. IP addresses are anonymized before storage. You can withdraw consent at any time by clicking "Cookie Settings" in the website footer.
For more information, see Google's Privacy Policy.
2.4 Information from Third Parties
We may receive information about you from:
- Public Sources: LinkedIn profiles, professional websites, public directories
- Referrals: Information provided by colleagues or other professionals who recommend you
- Background Check Providers: Only with your explicit consent and where legally required
3. How We Use Your Personal Data
We only use your personal data where we have a lawful basis. Here's specifically how and why we process your information:
3.1 For Job Seekers/Candidates
- Process your application for specific vacancies - All categories listed in Section 2 - Legitimate interest (matching candidates to roles)
- Assess your suitability for current and future positions - Professional and application data - Legitimate interest
- Communicate with you about job opportunities - Contact data - Legitimate interest for initial contact; consent for ongoing communications
- Maintain our talent pool for future opportunities - All categories - Consent (you must opt-in)
- Conduct reference and background checks - Identity and professional data - Legitimate interest or legal obligation
- Comply with legal obligations - All categories as required - Legal obligation
- Defend against legal claims - All categories as necessary - Legitimate interest
4. Who We Share Your Data With
We share your personal data only when necessary and with appropriate safeguards:
4.1 Categories of Recipients
Service Providers (Data Processors):
- Netlify Inc. (USA) - Website hosting and form processing
- Google Ireland Limited - Document storage (Google Drive) and website analytics (Google Analytics 4, with your consent)
- Notion Labs Inc. (USA) - Internal documentation and candidate tracking
Business Partners:
- Client Companies: We share candidate profiles with prospective employers only after informing you and confirming your interest in the specific opportunity
- Partner Recruitment Firms: Located in EU and non-EU countries, operating under strict confidentiality agreements
5. Data Retention
We retain your personal data only as long as necessary for the purposes described:
- Unsuccessful applications: 6 months from final decision
- Talent pool profiles: 24 months from last update (with consent)
- Successful placements: Duration of employment + 6 years
- Client records: 6 years from last interaction
- Email correspondence: 3 years
- Website usage data: 12 months
6. Your Rights
Under GDPR, you have the following rights:
- Access: Request a copy of your personal data we hold
- Rectification: Correct inaccurate or incomplete data
- Erasure: Request deletion of your data (in certain circumstances)
- Restriction: Limit how we use your data
- Portability: Receive your data in a machine-readable format
- Object: Object to processing based on legitimate interests
- Withdraw Consent: Where we rely on consent, withdraw it at any time
- Complain: Lodge a complaint with the supervisory authority
To exercise any right, email vincent@luxsearch.eu. We'll respond within 30 days and never charge a fee unless requests are manifestly unfounded or excessive.
7. Contact and Complaints
Data Protection Contact:
Vincent Lüders
LUX SEARCH LTD
Email: vincent@luxsearch.eu (primary contact method)
Supervisory Authority:
Commissioner for Personal Data Protection
1 Iasonos Street, 1082 Nicosia, Cyprus
Phone: +357 22 818 456
Email: commissioner@dataprotection.gov.cy