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Candidate Privacy Policy

Last Update : December 15, 2025



1. Introduction


This Candidate Privacy Notice (“Notice”) describes how Mytona Limited and its affiliated companies (“Mytona”, “we”, “us” or “our”) collect, use, disclose, store, and otherwise process your Personal Data in connection with our recruitment and hiring activities, and how we comply with applicable data protection laws in the jurisdictions where we operate, including Thailand, Singapore, New Zealand, Kazakhstan, Armenia, Georgia, and Serbia.


Your privacy is important to us, and we are committed to processing your Personal Data lawfully, fairly, transparently, and securely.


For the purpose of this Notice, “Candidates” or “you” means individuals who apply to an open position with Mytona, or who are contacted for or express interest in employment with us, or who attend a recruitment event or undergo an interview or assessment with us. This includes prospective employees, interns and contractors.


Mytona means Mytona Limited, having its registered address at Level 5, 129 Hurstmere Road, Takapuna, Auckland 0622, New Zealand, together with its affiliated companies (“Mytona Group”). For the purposes of applicable data protection laws, Mytona Limited and/or the relevant Mytona Group entity acts as the data controller (or equivalent concept under local law), determining the purposes and means of processing your Personal Data.



2. The Personal Data We Collect and Receive


Personal Data

We may collect and receive your Personal Data about you, including but not limited to:

  • identification information (such as name and nationality);
  • contact details;
  • eligibility to work and immigration status;
  • date of birth;
  • education, qualifications, employment history, skills, and preferences;
  • information you provide during interviews or assessments;
  • test results or work samples (where applicable);
  • referee details (you confirm that you have informed your referees that their information has been shared with us);
  • where an offer is made, payroll-related information required by law, such as tax, social security, or statutory benefit information.
  • where required by local law or business necessity, we may also process next-of-kin or emergency contact details for insurance, medical coverage, or emergency purposes.


Sensitive Personal Data

In limited circumstance, and only where permitted or required by applicable law, we may collect and process sensitive personal data (or equivalent concepts under local laws), such as:

  • information about disabilities or health conditions solely for the purpose of providing reasonable accommodations;
  • diversity-related information (such as racial or ethnic origin), where legally permitted and usually on a voluntary basis;
  • information required to verify your right to work, including visa, immigration, government identification numbers, or proof of vaccination where mandated by law.


You are not required to provide sensitive or special categories of personal data as part of your application unless we expressly request it and where such collection is permitted or required by law. Candidates are responsible for ensuring that sensitive personal data is not included in CVs, cover letters, portfolios, or other materials submitted to Mytona unless strictly necessary. You may black out, redact, or delete any sensitive information before submitting your application.


If you voluntarily choose to provide sensitive personal data to Mytona without being requested to do so, or fail to remove such information from your application materials, you acknowledge and agree that you have provided such data of your own initiative. Where Mytona unintentionally receives sensitive personal data that was voluntarily disclosed by you, such disclosure will be deemed as your explicit consent for Mytona to collect, use, and process such data for recruitment-related purposes, to the extent permitted by applicable law.



3. What are our Purposes and Legal Bases for Processing


We process your Personal Data for the following purposes:

  • assess your skills, qualifications, and suitability for the role; 
  • communicate with you about the recruitment process; 
  • conduct interviews and assessments;
  • carry out background and reference checks;
  • make hiring decisions and, where applicable, prepare an employment or offer letter;
  • maintain recruitment records;
  • comply with legal or regulatory requirements.


Our lawful bases for processing depend on the applicable jurisdiction and may include one or more of the following:

  • your consent;
  • the necessity to take steps prior to entering into a contract;
  • compliance with legal obligations;
  • legitimate business interests, such as operating an effective recruitment process, provided such interests are not overridden by your rights.


Failure to provide required Personal Data may result in Mytona being unable to progress your application or comply with legal requirements.



4. Automated decision-making


We do not make decisions solely based on automated decision making tools (a decision made solely by the creation and application of technologies without any human intervention) or profiling (processing of personal information with a range of technologies that reduce human intervention to evaluate certain conditions about an individual) that produces a legal effect or similarly significant effect.


We may use artificial intelligence or generative AI tools to support recruitment activities, but all hiring decisions involve meaningful human review and judgement.



5. Data sharing 


5.1 We share your Personal Data within Mytona Group


Your Personal Data may be shared within the Mytona Group with HR and recruitment teams, interviewers and hiring managers, operational and compliance teams to evaluate your profile. We restrict access to Personal Data to people who need to know that information and who are subject to contractual confidentiality requirements. 


5.2 We Share Your Personal Data with Third-Party Service Providers


We will only share your Personal Data with third-party service providers for the purposes of processing your application where appropriate, for example, with recruiting software and applicant tracking systems, candidate assessment platforms, interview scheduling platforms and hiring analytics platforms. 


All such  providers are contractually required to ii) only process your data as instructed by Mytona Group and (ii) implement appropriate security measures to safeguard your Personal Data; and (iii) store your Personal Data within the terms of the agreement (iv) comply with applicable data protection laws.


5.3 Additional Disclosure Recipient


We may also disclose your Personal Data to:

  • law enforcement, government agencies, and other recipients for legal, security, and safety purposes where required by law;
  • professional advisors (e.g. lawyers, accountants, auditors)
  • Any other party with your consent or at your direction. 



6. Cross-border transfers


Your Personal Data may be transferred to, stored, or processed in countries outside your home jurisdiction. Where cross-border transfers occur, we implement appropriate safeguards as required by applicable laws, such as contractual protections, adequacy mechanisms, comparable protection standards, or your explicit consent where required.



7. Data Security


Mytona uses appropriate administrative, technical, organizational measures to protect your Personal Data against unauthorized access, loss, misuse, or disclosure. All electronic data are kept secure on corporate drives with only select authorized individuals having access to the information. Your Personal Data are also protected through confidentiality undertakings entered into by all persons processing your personal data.



8. How long we may keep your data for


We will retain your Personal Data for no longer than is necessary for achieving the purposes for which it was collected. 


8.1 Non-hired candidates: 


If you are unsuccessful in your application, your Personal Data will generally be retained for up to three (3) years from the date we notify you of our recruitment decision. We retain such data on the basis of our legitimate interests, including to manage and improve our recruitment processes, provide candidate feedback, consider you for future employment opportunities, and establish, exercise, or defend legal claims. You may request that we delete your Personal Data earlier or update your information at any time. To exercise your rights, please contact us using the details provided in section 10. 


8.2 Hired candidates: 


If you are successful in your application, a separate employee Data Protection Policy will apply which outlines the retention periods for employee personal information.‍



9. Your Legal Rights


Under applicable data protection laws, you have the following rights:

  • Right to access and obtain a copy of your Personal Data;
  • Right to correct your Personal Data;
  • Right to be forgotten or to delete your Personal Data;
  • Right to restrict or object to the processing of your Personal Data;
  • Right to withdraw consent ; 
  • Other rights, depending on the local law of the jurisdiction in which you are located, you may have additional rights in relation to your Personal Data.


To exercise any of your rights, we may need to request specific information to help us confirm your identity and ensure your right to access your Personal Data. This is a security measure to ensure that Personal Data is not disclosed to any person who has no right to receive it.



10. How to Contact Us


If you have any questions or concerns about this Notice or how we handle your personal information, or wish to exercise your legal rights, please contact us at dpo@mytona.com 



11. Changes to this Privacy Notice


We reserve the right to update this Notice at any time. Each version of this Notice is identified at the top of the page by its version date.