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Privacy Policy

Cobania Labs SRL (doing business as IT Smart Recruiters)
Last updated: 01.01.2025

Cobania Labs SRL, operating under the brand IT Smart Recruiters (“we”, “us”, “our”), is committed to protecting your personal data and ensuring transparency in how we process it. This Privacy Policy explains what information we collect, how we use it, who we share it with, and what rights you have under the General Data Protection Regulation (GDPR – EU 2016/679) and applicable national laws.

By using our website, submitting your CV, applying for roles, or communicating with us, you agree to the terms outlined in this Privacy Policy.

1. DATA CONTROLLER INFORMATION

Cobania Labs SRL
Operating under the brand IT Smart Recruiters
CUI: 46629204
Registered Address: Balta Pasărea 10B, Tunari, Ilfov, Romania
Email: diana@itsmartrecruiters.com
Website: itsmartrecruiters.com

Cobania Labs SRL acts as the Data Controller for all personal data processed through this website and in connection with recruitment activities.

2. PERSONAL DATA WE COLLECT

We collect and process different types of personal data depending on how you interact with our services:

2.1 Data You Provide Directly

  • Name, email address, phone number, country/city
     
  • CV/resume, LinkedIn URL, portfolio, cover letter
     
  • Work history, education, skills, certifications
     
  • Job preferences, salary expectations, availability
     
  • Communication content (emails, messages, interview details)
     

2.2 Automatically Collected Data

  • IP address
     
  • Browser type, device type, operating system
     
  • Website usage data (pages visited, time spent, interactions)
     
  • Cookies (see Cookie Policy)
     

2.3 Sensitive Personal Data

We do not intentionally request sensitive data (e.g., ethnicity, health information, religious beliefs).
If you provide such information voluntarily, we will process it only as necessary and with enhanced confidentiality.

3. PURPOSES OF PROCESSING

We process personal data for the following purposes:

3.1 Recruitment & Talent Placement

  • Evaluating candidate profiles
     
  • Matching candidates to job opportunities
     
  • Presenting profiles to clients (only with explicit consent)
     
  • Scheduling and managing interviews
     
  • Providing feedback and updates throughout recruitment stages
     

3.2 Service Management & Improvement

  • Improving website functionality
     
  • Enhancing candidate experience
     
  • Analyzing website traffic and performance
     

3.3 Legal & Compliance

  • Fulfilling GDPR obligations
     
  • Preventing misuse or fraudulent activity
     
  • Protecting our legitimate business interests
     

4. LEGAL BASES FOR PROCESSING (GDPR Article 6)

We process your data based on:

4.1 Consent

When you submit your CV or agree to be considered for roles.

4.2 Contractual necessity

When actions are needed to enter into or fulfill a recruitment-related arrangement.

4.3 Legitimate interest

Including:

  • Identifying and matching talent
     
  • Communicating with candidates
     
  • Improving services and website experience
     

4.4 Legal obligation

Compliance with statutory requirements.

You may withdraw consent at any time by emailing diana@itsmartrecruiters.com.

5. HOW WE SHARE YOUR DATA

Your personal data may be shared with:

5.1 Clients & Hiring Companies

Only with your prior approval.

5.2 Recruitment Partners

Other agencies assisting in the recruitment process, under GDPR-compliant agreements.

5.3 Service Providers

Such as:

  • Website hosting providers
     
  • Email and communication platforms
     
  • CRM/ATS recruitment software
     
  • Analytics tools
     

5.4 Authorities

Only when required by law or legal request.

We never sell personal data.

6. INTERNATIONAL DATA TRANSFERS

Some service providers or clients may be located outside the EU/EEA.
In such cases, data transfers are protected through:

  • Standard Contractual Clauses (SCCs)
     
  • Adequacy decisions
     
  • GDPR-compliant Data Processing Agreements
     

7. DATA RETENTION

We retain personal data only for as long as necessary:

  • Candidate data: up to 24 months from last interaction
     
  • Client data: for the duration of cooperation + required legal periods
     
  • Website analytics/cookies: as described in the Cookie Policy
     

You may request earlier deletion at any time.

8. YOUR GDPR RIGHTS

Under GDPR, you have the right to:

8.1 Access

Obtain a copy of your personal data.

8.2 Rectification

Correct inaccurate or incomplete data.

8.3 Erasure

Request deletion (“right to be forgotten”).

8.4 Restriction

Limit how we process your data.

8.5 Portability

Receive your data in a structured, machine-readable format.

8.6 Objection

Object to processing based on legitimate interests.

8.7 Withdraw consent

Stop processing based on consent.

8.8 No automated decisions

We do not conduct automated profiling or decision-making.

To exercise rights, contact:
📩 diana@itsmartrecruiters.com

We will respond within 30 days.

9. SECURITY MEASURES

We implement strong technical and organizational security measures, including:

  • Encrypted data storage
     
  • Secure servers
     
  • Access control based on job roles
     
  • Firewalls and intrusion monitoring
     
  • GDPR-compliant third-party tools
     

Despite this, no system is 100% secure.

10. COOKIES & TRACKING TECHNOLOGIES

We use cookies to enhance user experience and analyze site performance.
Please refer to our Cookie Policy for full details.

11. THIRD-PARTY LINKS

Our website may contain links to external websites.
We are not responsible for their content or privacy practices.

12. CHILDREN’S PRIVACY

Our services are intended for users aged 18 years and older.
We do not knowingly collect personal data from children.

13. CHANGES TO THIS POLICY

We may update this policy at any time to reflect legal or operational changes.
The updated version will always be available on this page.

14. CONTACT INFORMATION

For questions, requests, or concerns regarding data privacy, contact:

📌 Cobania Labs SRL (IT Smart Recruiters)
📍 Balta Pasărea 10B, Tunari, Ilfov, Romania
📩 diana@itsmartrecruiters.com

You may also lodge a complaint with the Romanian National Data Protection Authority (ANSPDCP).

Privacy Policy coming soon
  • Privacy Policy

IT Smart Recruiters

Bucharest, Romania

+40727343836

Copyright © 2023 IT Smart Recruiters - All Rights Reserved.

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