Privacy Notice for Job Applicants

 

 

Delogue.com ApS

Last updated: October 8, 2025

 

1. Introduction

 

Delogue.com ApS ("Delogue," "we," "us," or "our") is committed to protecting your privacy throughout the recruitment process. This Recruitment Privacy Notice explains how we collect, use, store, and protect your personal data when you apply for a position with us.

This notice applies specifically to job applicants and candidates. For information about how we handle customer, user, and visitor data in connection with our PLM platform and services, please refer to our Privacy Policy.

By submitting an application to Delogue, you acknowledge that you have read and understood this notice.

 

2. Data Controller

 

Delogue.com ApS is the data controller responsible for processing your personal data during the recruitment process.

 

Contact details:

 

Delogue.com ApS
Rosenvængets Allé 16, 4.
2100 København Ø
Denmark
CVR: 34074445

 

Data Protection Officer:


Email: DPO@delogue.com

For any questions about how we handle your personal data, please contact our Data Protection Officer using the details above.

 

 

3. Personal Data We Collect

 

When you apply for a position at Delogue, we may collect and process the following categories of personal data:

 

3.1 Information You Provide

 

When submitting your application, you may provide us with:

 

    • Contact details: Name, email address, phone number, postal address
    • Application materials: CV/resume, cover letter, portfolio, work samples
    • Professional background: Previous employment history, job titles, roles and responsibilities
    • Education and qualifications: Degrees, certifications, professional training
    • References: Contact information for professional referees
    • Additional information: Any other information you voluntarily include in your application, cover letter, or during interviews

 

3.2 Information We Generate

 

During the recruitment process, we may create or collect:

 

    • Assessment data: Interview notes, test results, technical assessments, evaluations from hiring managers
    • Correspondence: Emails, messages, and other communications exchanged during the recruitment process
    • Recruitment decisions: Records of progression through recruitment stages and final hiring decisions

 

3.3 Information from Third Parties

 

With your knowledge and, where required, your consent, we may obtain:

  • References: Information provided by your professional referees
  • Background checks: Where required for specific roles and permitted by applicable law
  • Recruitment agencies: Information provided by recruitment agencies if you applied through one

We will only contact your references or conduct background checks if you progress to the final stages of our recruitment process, and only after informing you in advance.

 

4. Legal Basis for Processing

 

We process your personal data in accordance with the General Data Protection Regulation (GDPR) and applicable Danish data protection laws.

 

4.1 Legitimate Interest

 

Our primary legal basis for processing your personal data is our legitimate interest in recruiting, assessing, and hiring qualified candidates for open positions at Delogue (Article 6(1)(f) GDPR). This includes:

  • Evaluating your qualifications, skills, and experience
  • Communicating with you throughout the recruitment process
  • Making informed hiring decisions
  • Maintaining records of our recruitment activities
  • Defending against potential legal claims related to our recruitment process

We have carefully balanced our legitimate interests against your rights and freedoms and have determined that processing your data for recruitment purposes does not override your interests or fundamental rights.

 

4.2 Consent

 

For processing special categories of personal data (such as health information you may provide to request workplace accommodations), we will obtain your explicit consent prior to processing (Article 9(2)(a) GDPR).

If we need to process your data for purposes beyond the recruitment process (such as adding you to our talent pool for future opportunities), we will seek your specific, informed consent.

 

4.3 Legal Obligations

 

We may process certain personal data to comply with legal obligations, such as employment law requirements, tax regulations, or in response to valid legal requests from authorities (Article 6(1)(c) GDPR).

 

5. How We Use Your Personal Data

 

We process your personal data for the following purposes:

 

5.1 Recruitment and Selection

 

  • To assess your suitability for the role you have applied for
  • To compare your qualifications with other candidates
  • To verify information provided in your application
  • To conduct interviews, assessments, and reference checks
  • To make hiring decisions

5.2 Communication

 

  • To acknowledge receipt of your application
  • To provide updates on your application status
  • To schedule and coordinate interviews or assessments
  • To communicate our hiring decision

5.3 Administration and Record-Keeping

 

  • To maintain records of our recruitment process
  • To respond to queries about recruitment decisions
  • To improve our recruitment processes and candidate experience

5.4 Legal Compliance

 

  • To comply with employment laws and regulations
  • To respond to legal requests or defend against potential claims
  • To fulfill reporting obligations where required by law

5.5 Future Opportunities (with consent)

 

If you provide consent, we may retain your data to consider you for other suitable roles that become available at Delogue within a specified period.

We will not use your personal data for any purpose unrelated to recruitment without obtaining your consent or unless required by law.

 

6. Who Has Access to Your Data

 

We limit access to your personal data to those who need it for legitimate recruitment purposes. Your data may be shared with or accessed by:

 

6.1 Internal Personnel

 

  • Hiring managers responsible for the role you applied for
  • Human Resources personnel managing the recruitment process
  • Relevant team members involved in interviews or assessments
  • Senior leadership involved in final hiring decisions

All internal personnel with access to your data are bound by confidentiality obligations.

 

6.2 External Third Parties

 

We may share your personal data with the following third parties where necessary:

 

  • Recruitment agencies: If you applied through an external recruiter, we may share information with that agency as part of our contractual arrangement
  • Reference providers: Your professional referees, if you progress in the recruitment process and have provided their contact information
  • Service providers: Third-party providers who support our recruitment process, such as:
    • Applicant tracking system providers
    • Assessment and testing platforms
    • Video interviewing services
    • Background check providers (where applicable and lawful)

All third-party service providers are carefully selected and are contractually bound to process your data only on our instructions and in compliance with applicable data protection laws. Where providers are located outside the EU/EEA, we ensure appropriate safeguards are in place as described in Section 10.

We will not sell, rent, or otherwise share your personal data with any other third parties without your explicit consent, unless required by law.

 

7. Data Retention

 

We retain your personal data only for as long as necessary to fulfill the purposes for which it was collected, or as required by law.

 

7.1 Unsuccessful Candidates

 

If your application is unsuccessful, we will retain your personal data for 6 months following the conclusion of the recruitment process. This retention period allows us to:

 

  • Respond to any queries you may have about our recruitment decision
  • Defend against potential legal claims related to our recruitment process
  • Consider you for similar positions that may become available during this period
  •  

After 6 months, your personal data will be securely deleted from our systems, unless you have provided consent for longer retention (see Section 7.3 below).

 

7.2 Successful Candidates

 

If you are offered and accept a position with Delogue, your application data will become part of your employee personnel file. This data will be retained in accordance with our employee data retention policies and Danish employment law requirements.

Specifically:

 

  • During employment: Your data will be retained for the duration of your employment
  • After employment ends: Your personnel file will be retained for 5 years following the end of your employment, in compliance with the Danish Bookkeeping Act and general limitation periods under Danish law

7.3 Talent Pool (Optional)

 

If you wish to be considered for future opportunities at Delogue, you may consent to join our talent pool. If you opt in:

 

  • We will retain your application data for up to 12 months from the date of your application
  • You will be considered for relevant positions that become available during this period
  • You may withdraw your consent and request deletion of your data at any time by contacting DPO@delogue.com

7.4 Backup and Archival Data

 

Please note that your data may remain in backup systems for up to 3 months after deletion from our active systems. Backup data is stored securely and is isolated from further processing until permanent deletion is completed.

 

8. Your Rights Under GDPR

 

As a data subject under the GDPR, you have the following rights regarding your personal data:

 

8.1 Right of Access

 

You have the right to request confirmation of whether we are processing your personal data and, if so, to obtain a copy of that data along with information about how it is being used (Article 15 GDPR).

 

8.2 Right to Rectification

 

You have the right to request that we correct any inaccurate or incomplete personal data we hold about you (Article 16 GDPR).

 

8.3 Right to Erasure ("Right to be Forgotten")

 

You have the right to request deletion of your personal data in certain circumstances, such as when:

 

  • The data is no longer necessary for the purposes for which it was collected
  • You withdraw consent (where consent was the legal basis for processing)
  • You object to processing based on legitimate interests and there are no overriding legitimate grounds for continued processing
  • The data has been unlawfully processed
  •  

This right is subject to certain exceptions, such as where we need to retain data to comply with legal obligations or to establish, exercise, or defend legal claims (Article 17 GDPR).

 

8.4 Right to Restriction of Processing

 

You have the right to request that we temporarily restrict processing of your personal data in certain situations, such as when:

 

  • You contest the accuracy of the data
  • Processing is unlawful but you prefer restriction over deletion
  • We no longer need the data, but you need it for legal claims
  • You have objected to processing, and we are verifying whether our legitimate grounds override yours (Article 18 GDPR)

8.5 Right to Object

 

You have the right to object to processing of your personal data where we are relying on legitimate interests as the legal basis. We will stop processing unless we can demonstrate compelling legitimate grounds that override your interests, rights, and freedoms, or where processing is necessary for the establishment, exercise, or defense of legal claims (Article 21 GDPR).

 

8.6 Right to Data Portability

 

You have the right to receive your personal data in a structured, commonly used, and machine-readable format and to transmit that data to another controller, where technically feasible. This right applies where processing is based on consent or contract and is carried out by automated means (Article 20 GDPR).

 

8.7 Right to Withdraw Consent

 

Where we process your data based on your consent (such as for special categories of data or for inclusion in our talent pool), you have the right to withdraw that consent at any time. Withdrawal of consent will not affect the lawfulness of processing carried out before the withdrawal (Article 7(3) GDPR).

 

8.8 Exercising Your Rights

 

To exercise any of these rights, please contact our Data Protection Officer at DPO@delogue.com. We may need to verify your identity before fulfilling your request to protect your personal data from unauthorized access.

We aim to respond to all legitimate requests within 30 days. If your request is particularly complex or you have made multiple requests, we may extend this period by a further 60 days and will inform you of any such extension.

 

9. Data Security

 

We take the security of your personal data seriously and implement appropriate technical and organizational measures to protect it from unauthorized access, accidental loss, alteration, disclosure, or misuse.

Delogue follows generally accepted industry standards to ensure the security of data both in transit and at rest. These safeguards include, but are not limited to:

 

  • Encryption: Data is encrypted during transmission over public networks using SSL/TLS protocols
  • Access controls: Strict role-based access controls ensure that only authorized personnel can access applicant data
  • Authentication: Multi-factor authentication and strong password policies for all systems
  • Secure infrastructure: Use of secure data centers with physical and digital security measures, firewalls, and intrusion detection systems
  • Monitoring: Regular monitoring and logging of system access and activities
  • Internal policies: Comprehensive data protection policies, confidentiality agreements, and staff training on data handling practices
  • Incident response: Documented procedures for detecting, responding to, and recovering from security incidents

Despite our best efforts, no system can be guaranteed to be 100% secure. We cannot absolutely guarantee the security of information transmitted to us or stored in our systems. If you suspect that your personal data has been compromised or misused, please contact us immediately at DPO@delogue.com.

In the event of a personal data breach that is likely to result in a risk to your rights and freedoms, we will notify you and the relevant supervisory authority in accordance with applicable law.

 

10. International Data Transfers

 

Your personal data will generally be processed and stored within the European Economic Area (EEA). Our primary systems are hosted in Ireland.

However, some of our service providers may process data in countries outside the EU/EEA that may not offer the same level of data protection as the EEA (for example, certain applicant tracking systems or assessment tools may be hosted in the United States).

When we transfer your personal data outside the EU/EEA, we ensure that appropriate safeguards are in place to protect your data in accordance with GDPR requirements. These safeguards include:

 

  • Adequacy decisions: Transfers to countries recognized by the European Commission as providing an adequate level of data protection
  • Standard Contractual Clauses (SCCs): We enter into European Commission-approved Standard Contractual Clauses with recipients in third countries
  • Supplementary measures: Where required, we implement additional safeguards such as encryption, access controls, and data minimization

For more information about the safeguards we use for international transfers, or to request a copy of the Standard Contractual Clauses, please contact us at DPO@delogue.com.

 

11. Automated Decision-Making and Profiling

 

We do not use automated decision-making or profiling in our recruitment process.

All hiring decisions are made by our recruitment team based on a holistic and human review of your application, qualifications, interview performance, and overall suitability for the role. No decisions that produce legal or similarly significant effects are made solely on the basis of automated processing.

If our recruitment practices change in the future to include any form of automated decision-making, we will update this notice and inform candidates accordingly.

 

12. Changes to This Notice

 

We may update this Recruitment Privacy Notice from time to time to reflect changes in our practices, technologies, legal requirements, or for other operational, legal, or regulatory reasons.

When we make changes to this notice, we will revise the "Last updated" date at the top of this document and publish the updated version on our website.

Where required by applicable law, we will notify you in advance of material changes. We encourage you to review this notice periodically to stay informed about how we collect, use, and protect your personal data during the recruitment process.

Your continued participation in our recruitment process following the posting of any revised notice constitutes your acknowledgment and agreement to be bound by the updated terms.

 

13. Right to Lodge a Complaint

 

If you have concerns about how we handle your personal data or believe that we have not complied with applicable data protection laws, you have the right to lodge a complaint with the relevant supervisory authority.

 

In Denmark, the supervisory authority is

 

Datatilsynet (Danish Data Protection Agency)
Website: www.datatilsynet.dk

 

You also have the right to lodge a complaint with the supervisory authority in the EU/EEA country where you live, work, or where an alleged infringement of data protection law occurred.

Before lodging a formal complaint, we encourage you to contact us directly at DPO@delogue.com so that we can address your concerns.

 

14. Contact Us

 

If you have any questions about this Recruitment Privacy Notice, how we process your personal data, or wish to exercise your data protection rights, please contact us:

 

Data Protection Officer
Email: DPO@delogue.com

 

General Recruitment Inquiries
Email: career@delogue.com

We aim to respond to all inquiries within a reasonable timeframe and in accordance with applicable data protection laws.

 

Thank you for your interest in joining Delogue. We appreciate the time you have taken to apply and look forward to reviewing your application.