This privacy policy explains what personal data Armenian Workers collects, why, on what legal basis, who receives it, how long it is kept, how it is protected, and what rights you have. It is written to satisfy the information duties of Articles 13 and 14 of the EU General Data Protection Regulation (GDPR, Regulation (EU) 2016/679) and the Law of the Republic of Armenia on Protection of Personal Data.
The GDPR applies to our processing because we offer recruitment services to employers and agencies established in the European Union and Economic Area, we transfer candidate data to them, and our EU partners, acting as controllers under EU law, exchange data with us. Where this policy says “you”, it means any person whose data we process: candidates, contact persons at employers and agencies, people who report fraud, and website visitors.
1. Controller and contact
Controller: Armenian Workers, a private recruitment and workforce-mobility service registered in the Republic of Armenia. Legal name, registration number and registered address are published on the About page.
Data-protection contact: privacy@armenianworkers.com. Use this address for every request concerning your personal data. We answer within one month; if a request is complex we may extend this by up to two further months and will tell you why (Article 12(3) GDPR).
Representative in the European Union (Article 27 GDPR): if and when our processing of EU residents’ data requires an EU representative, we will appoint one and publish their contact details in this section.
2. Personal data we process, purposes and legal bases
2.1 Candidates
Collected when you submit a profile, apply for a vacancy, sign up for alerts, contact us, or take part in screening.
| Data | Purpose | Legal basis |
|---|---|---|
| Identity and contact: name, year of birth, city, phone, email, preferred contact channel, messaging handles you give us | Creating and managing your candidate profile; contacting you about vacancies | Article 6(1)(b) GDPR: steps at your request before entering into a contract; Article 6(1)(a): your consent given in the form |
| Professional data: languages, experience, skills, certificates, licence categories, previous work abroad, availability, CV and its contents | Assessing suitability for vacancies; presenting you to a verified employer or agency after your agreement | Article 6(1)(b) and 6(1)(a) GDPR |
| Eligibility data: passport validity status, willingness to relocate, availability date | Checking that a legal placement is possible before any partner sees your data | Article 6(1)(b) GDPR |
| Free-text notes you write, including health limitations for physical work if you choose to mention them | Matching you only to work you can safely do | Article 9(2)(a) GDPR: explicit consent, given when you write this information yourself. You are never required to provide health data. |
| Documents requested later for a specific vacancy (passport copy, qualification documents, criminal-record and medical certificates) | Work-authorization and visa procedures of the destination country, as required by the employer and the authorities | Article 6(1)(b) GDPR and, for criminal-record data, Article 10 GDPR applied under the law of the requesting country; requested only through a secure channel and only when a procedure requires them |
| Screening notes, interview outcomes, correspondence | Managing the recruitment process; preventing repeated screening | Article 6(1)(f) GDPR: our legitimate interest in running a reliable recruitment service; balanced against your interests by keeping notes factual and limited |
We do not ask for passport scans, identity-card copies or bank details in the public forms. We do not perform automated decision-making or profiling that produces legal or similarly significant effects (Article 22 GDPR). Every matching decision is made by a person.
2.2 Employers and recruitment agencies
Collected through the workforce-request form, the contact form, email, calls and partnership agreements: company details, contact person’s name, business email and phone, role, and the details of the workforce need.
Purposes: evaluating a partnership, verifying the partner (registration, licences, sample contracts), negotiating and performing service agreements, invoicing, communication. Legal bases: Article 6(1)(b) GDPR (contract and pre-contractual steps), Article 6(1)(c) (accounting and tax obligations), Article 6(1)(f) (our legitimate interest in verifying partners before candidates are approached, which also protects candidates).
2.3 Fraud reports
What you choose to tell us, optionally your name and contact details. Purpose: investigating impersonation and warning candidates. Legal basis: Article 6(1)(f) GDPR, our legitimate interest and the public interest in preventing recruitment fraud. You may report anonymously.
2.4 Website visitors
Our hosting provider records technical server logs (IP address, user agent, requested URL, timestamp) needed to deliver and secure the site: Article 6(1)(f) GDPR. Optional analytics are loaded only after your consent through the cookie banner: Article 6(1)(a) GDPR and Article 5(3) of the ePrivacy Directive as implemented in your country. Details are in the cookie policy.
3. Sources of data
We obtain data directly from you. For candidates we may also receive data from a verified employer or agency about the outcome of an interview or placement, and from public registers when verifying a partner company. We do not buy personal data and do not scrape social networks.
4. Recipients
- Our team, on a need-to-know basis, bound by confidentiality.
- A verified employer or recruitment agency, only after you have agreed to a specific vacancy, and only the data required for that selection and for the work-authorization procedure. From that point the partner is an independent controller under the law of its country and provides its own privacy information.
- Processors acting on our documented instructions under Article 28 GDPR contracts: website hosting (Vercel), email delivery (Forward Email), email and document storage. A current list is available on request.
- Public authorities (immigration, labour, tax, law enforcement) when a law or a legally binding request requires it.
We never sell personal data, never publish candidate profiles, and never share data for third-party marketing.
5. International transfers
Armenia is not covered by an EU adequacy decision. Two kinds of transfer occur:
- From Armenia to an EU/EEA partner (candidate data for a specific vacancy). The partner processes it under GDPR. We transfer only what is needed, through secure channels, under a written agreement.
- From an EU/EEA partner to us (for example, interview outcomes, contract terms, documents for permit procedures). Because we are in a third country, our EU partners transfer data to us under the Standard Contractual Clauses adopted by the European Commission (Article 46(2)(c) GDPR) or another safeguard in Chapter V GDPR, with the additional measures described in section 8. You may request a copy of the safeguards through privacy@armenianworkers.com.
Data may also be processed on servers of our processors in the EU and the United States under their Article 28 contracts and the transfer mechanisms they provide (Standard Contractual Clauses or the EU-US Data Privacy Framework where applicable).
6. Retention
| Data | Retention |
|---|---|
| Candidate profile and CV | While you wish to be considered. Deleted after 24 months without contact, or earlier at your request. |
| Data of a placed candidate | Duration of the placement plus the period needed to handle warranty, replacement and legal obligations, then deleted or anonymised. |
| Documents collected for a permit procedure | Deleted from our systems once the procedure is complete, unless a law requires longer retention. |
| Employer and partnership records, contracts, invoices | Duration of the relationship plus the statutory retention period for accounting and tax records in Armenia. |
| Fraud reports | As long as needed to investigate and to warn others; then anonymised. |
| Server logs | Short technical period set by the hosting provider, normally days to weeks. |
| Consent records | For as long as the consent is relied on and for the period needed to demonstrate it. |
7. Your rights
Under Articles 15 to 22 GDPR, and under Armenian law, you have the right to:
- access the data we hold about you and obtain a copy;
- rectification of inaccurate or incomplete data;
- erasure (“right to be forgotten”), where no legal obligation requires us to keep the data;
- restriction of processing while a request is examined;
- data portability, receiving the data you provided in a structured, commonly used, machine-readable format;
- object to processing based on our legitimate interests, including to any direct marketing (we do none);
- withdraw consent at any time, without affecting the lawfulness of processing before withdrawal;
- not be subject to automated decision-making with legal or similarly significant effects (we make none);
- lodge a complaint with a supervisory authority: in Armenia, the Personal Data Protection Agency of the Ministry of Justice; in the EU/EEA, the data-protection authority of the country where you live or work, or where the alleged infringement occurred.
To exercise a right, write to privacy@armenianworkers.com. We may ask you to confirm your identity. Exercising your rights is free, unless requests are manifestly unfounded or excessive.
8. Security
We apply technical and organisational measures appropriate to the risk (Article 32 GDPR): HTTPS on every page, secrets kept out of the browser, server-side validation and spam controls on forms, least-privilege access to candidate data, secure channels for sensitive documents, contractual obligations on processors, and regular review of access. No system is perfectly secure. If a personal-data breach is likely to result in a high risk to you, we will inform you without undue delay, and we will notify the competent supervisory authority within 72 hours where Article 33 GDPR applies.
9. Cookies and similar technologies
Only strictly necessary storage is used without consent (your language and cookie choice, security cookies of the hosting provider). Optional analytics cookies are loaded only after you choose “Allow analytics”; refusing is as easy as accepting and does not affect your use of the site. See the cookie policy.
10. Children
Our services are for people aged 18 and over. We do not knowingly process data of anyone younger and delete such data when we become aware of it.
11. Changes to this policy
We review this policy at least annually and whenever our processing changes. The date at the end of the page shows the last review. Material changes are announced on the website and, where they affect candidates in our database, by email.
12. Armenian law
In addition to the GDPR, we comply with the Law of the Republic of Armenia on Protection of Personal Data, including its rules on consent, purpose limitation, security and cross-border transfer. Where the two regimes differ, we apply the stricter standard.
This policy was drafted against the requirements of Articles 12 to 22, 27, 28, 32 to 34 and 44 to 49 GDPR and Armenian data-protection law. The company’s legal counsel should confirm the final text, the EU-representative assessment and the transfer safeguards before it is relied on in contracts with partners.