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, 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 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)
- 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