Candidate Privacy Policy

Last updated: 12th July 2021

This notice describes how Nephos collects, uses, discloses, and otherwise processes the personal data (“Candidate Data”) of individuals who apply or are considered for a position with Nephos (“Candidates”).

Scope and Application

This notice governs Nephos processing of Candidate Data anywhere in the world in connection with our recruitment of Candidates for positions at Nephos.

This notice does not apply to Nephos processing of personal data in connection with the use of its products or services. For information on such processing, please see Nephos Privacy Policy.

Collection of Candidate data

We collect the following categories of Candidate Data directly from you:

  • Name, address, email address, telephone number, or other contact information
  • Resumes/CVs, cover letter, academic transcripts, and other statements of experience and education
  • the position(s) for which you wish to be considered, desired salary, willingness to relocate, and other job preferences
  • How you heard about the position
  • Prior employers, dates of employment, positions held and/or job titles
  • Referral names and contact information for referrals
  • Name and contact information for references (it being solely your responsibility to obtain consent from references before providing their personal data)
  • Any other personal data that you provide during the job search, application, or interview process with Nephos, including medical/disability, information submitted in connection with skills assessments, additional information regarding work or educational experiences, information about employment offers from other companies, and reason(s) for acceptance/rejection

We may also receive the following categories of information from other sources:

  • Where permitted by law, background check data, potentially including your criminal history records.
  • Information concerning your prior employment, including (where permitted by applicable law) compensation and your educational and academic degrees, from employment agencies, publicly available sources, social media websites, former employers and/or educational institutions
  • Information provided by references that you provide

In addition, if you apply for a position in the United States, or in another country that permits such voluntary data collections, you will have the opportunity to provide information about your gender, race/ethnic origin and/or veteran status in order for us to conduct equal opportunity monitoring. Where permitted by law, we may also infer some of this information for past Candidates in order to improve our recruitment process

The provision of this information is entirely voluntary, and where required by law (including in the European Economic Area (“EEA”)), we only collect such information with your express consent. If you decline to provide this information, your application(s) will not be affected in any way. If you choose to provide this information, you consent to our using it for equal employment opportunity monitoring purposes. This information will be held and stored anonymously and will not be used to evaluate your application for employment.

Use of Candidate Data

Nephos uses your Candidate Data in connection with our Candidate recruitment process. For example, we use your Candidate Data to:

  • Evaluate and verify your education, skills, experiences and other qualifications and interests in connection with open roles at Nephos
  • Communicate with you regarding the interview process, and inform you of potential career opportunities
  • Prepare offers of employment, including as it relates to compensation
  • Improve our recruitment process, including by generating anonymized data and analysis using Candidate Data
  • Perform pre-employment background checks where permitted by law

If you are hired, Nephos will maintain your Candidate Data as part of your employee records.

If you are not hired for the position for which you were initially considered, we may use your Candidate Data to identify and contact you regarding other positions for which you may want to be considered. If you do not wish for Nephos to use your data for this purpose, you may request that we delete your Candidate Data as explained below.

In addition, if you provide Nephos with the contact information of your references, Nephos may use that information to contact your references (and not for any other purpose). Information provided by such references will be used by to evaluate your candidacy, and will otherwise be treated in accordance with this notice.

Sharing of Candidate Data

We may share your Candidate Data:

  • With Nephos subsidiaries and affiliates.
  • With Nephos employee who has referred you to inform them about the status and outcome of the referral.
  • With vendors, consultants, and other service providers who need access to such information to carry out work relating to the recruitment process on our behalf.
  • In connection with, or during negotiations of, any merger, sale of Nephos assets, consolidation or restructuring, financing, or acquisition of all or a portion of our business by or into another company.
  • With law enforcement officials, government authorities, or other third parties if we believe it is required by applicable law, regulation, operating agreement, legal process such as subpoenas or court orders, or governmental request, if we believe your actions are inconsistent with our policies, or if we believe such sharing is necessary to protect the rights, property, or safety of Nephos or others.
  • In an aggregated and/or anonymized form which cannot reasonably be used to identify you.

Nephos does not sell Candidate personal data.

Cookies and Third Party Technologies

We may allow others to provide online audience measurement and analytics services for us, to serve advertisements on our behalf across the Internet, and to track and report on the performance of those advertisements. These entities may use cookies, web beacons, SDKs, and other technologies to identify your device when you visit our site, including Nephos Careers page. For more information about these technologies and service providers, please refer to our Cookie Policy.

Candidate Data Retention and Deletion

Nephos retains your Candidate Data for as long as you are under consideration for a position with Nephos. Thereafter, Nephos retains your data in accordance with the laws in the countries where you live. These laws may require Nephos to retain your information for periods defined in such laws, or to delete it after periods defined in those laws. Unless otherwise required by such laws, Nephos will retain your Candidate Data for 3 years after it ceases to consider you for a position with Nephos, and will thereafter delete your Candidate Data except for historical information regarding the positions for which you were considered (e.g., the position(s) for which you applied and the dates of your application(s)), and the decisions made by Nephos with respect to your candidacy (which may include the grounds for the decision). In some cases, we may ask for your consent to retain your Candidate Data for longer than the period otherwise permitted under applicable laws.

You may also request deletion of your Candidate Data at any time. Unless otherwise required by law, or where Nephos may have a legitimate interest that justifies continued retention, Nephos will delete your Candidate Data after receiving such request, except for historical information regarding the positions for which you were considered, and the decisions made by Nephos with respect to your candidacy.

Your Rights

You have the following rights with respect to Nephos handling of your Candidate Data:

  • Access your personal data
  • Correct any errors regarding your personal data
  • Erase or delete your Candidate Data under the terms above
  • Object to or restrict certain processing of your Candidate Data
  • Receive your Candidate Data in a usable electronic format and transmit it (data portability)
  • Withdraw your consent to the processing of your Candidate Data 

To exercise these rights, please see below or submit your request via email to Please note that in certain instances, exercising your rights to object to or restrict processing of your Candidate Data, or to withdraw consent relating to the processing of your Candidate Data, may impact our ability to consider you for a position with Nephos. However, candidates will not be discriminated against for exercising these rights.

In addition, if you are a resident of the EEA, you also have the right to lodge a complaint with your local data protection authority or regulatory body relating to Nephos handling of your Candidate Data.

Information for Candidates in the European Economic Area

Nephos processes your personal data pursuant to one or more of the following legal bases:

  • The processing is necessary to take steps, at your request, relating to potentially entering into an employment contract with you.
  • The processing is necessary to comply with our legal obligations, such as retaining records relating to the recruitment process for periods required under applicable laws.
  • The processing is necessary in connection with Nephos legitimate interests in recruiting and hiring the best candidates. For example, we process your Candidate Data to measure and improve the effectiveness of our recruitment process, or maintain historical records of the recruitment process and the outcomes of that process.
  • We may also seek your consent to process or retain your Candidate Data in certain circumstances. For example, we may ask for your consent to retain your data so that you may be considered for future employment opportunities with Nephos.

International Transfer of Candidate Data

If you are applying for a position with us, the Candidate Data that we collect about you in the recruitment process may be transferred to, and stored on, our servers, located in the EU. Authorized employees of Nephos and/or affiliated companies at locations in/outside the United States may have access to your Candidate Data as part of the recruitment process.

If you live outside the United States, including in the EEA, we transfer your Candidate Data on the basis of Standard Contractual Clauses, or other mechanisms approved by the European Commission.

Updates to The Notice

We may change this notice from time to time. Any changes to this notice go into effect upon the effective date of the revised notice.

Questions and Comments

You may submit questions and comments about this notice to:

Nephos d.o.o.
Attn: Data Protection Officer
Antuna Bauera 25
Zagreb, Croatia