Recruitment Privacy Notice
Last updated: May 2026
At Nova Complex (Finland) Holdco Oy (“we”, “us”, or “our”), we value your privacy and are committed to protecting your personal data. This Recruitment Privacy Notice explains how we collect, process, store, and protect personal data in connection with our employer branding and recruitment activities conducted through our Career Site and recruitment platform, Teamtailor.
This Privacy Notice applies when:
1. You visit our Career Site (“Visitor”);
2. You connect with us or join our Talent Pool (“Connecting Candidate”);
3. You apply for a position with us (“Applying Candidate”);
4. We identify your profile through public professional sources and contact you regarding recruitment opportunities (“Sourced Candidate”);
5. We receive your profile through employee or partner referrals (“Referred Candidate”); or
6. You are listed as a reference by a candidate (“Reference”).
This Privacy Notice complies with the EU General Data Protection Regulation (GDPR) and the Finnish Data Protection Act (Tietosuojalaki 1050/2018).
1. Data Controller
Company Name: Nova Complex (Finland) Holdco Oy Business ID (Y-tunnus): 3482868-2 Registered Address: 26th Floor, Hermannin rantatie 9A, 00580 Helsinki, Finland Contact for Data Protection: HR Team Email: careers@novacomplex.com
Nova Complex (Finland) Holdco Oy acts as the data controller for the personal data processed in connection with recruitment activities. If you have questions regarding data protection, you may contact us at the details above.
2. About Teamtailor
Our Career Site and applicant tracking system are provided through Teamtailor AB (“Teamtailor”), which acts as our data processor and processes personal data on our behalf and in accordance with our instructions.
Our use of Teamtailor enables us to manage applications, communicate with candidates, maintain talent pools, and administer recruitment processes efficiently and securely.
Information regarding Teamtailor’s own privacy practices and cookie-related processing is available through Teamtailor’s privacy and cookie information pages. We have entered into a data processing agreement with Teamtailor in accordance with Article 28 GDPR.
3. Personal Data We Process
A. Visitors
If you visit our Career Site, we may process:
• Device information, including IP address, browser type and version, operating system, language settings and device information;
• Technical and statistical information regarding use of the Career Site;
• Session behaviour and interaction with the site.
B. Candidates
If you connect with us or participate in recruitment activities, we may process:
Contact details
• Name
• Email address
• Telephone number
• Address
• Additional contact information voluntarily provided by you
Application and professional information
• CV or résumé
• Cover letter
• Education
• Work history
• Skills and certifications
• Language proficiencies
• Portfolio or work samples
• Salary expectations
• Professional social media profiles (such as LinkedIn)
Recruitment process information
• Interview notes
• Communication history
• Assessment or recruitment test results
• Interview scheduling and related correspondence
• Internal evaluations and candidate status information created during the recruitment process
Public professional information
We may collect professional information from public sources relevant to recruitment, such as LinkedIn or employer websites.
C. References
If you are listed as a reference, we may process:
• Name
• Contact details
• Communication with us
• Information you provide regarding the candidate.
4. Sources of Personal Data
We primarily collect personal data:
• Directly from you;
• Through Teamtailor and our Career Site;
• From public professional sources;
• From employee or partner referrals;
• From references you provide;
• Through information created during the recruitment process.
Finnish Compliance Note
In accordance with the Finnish Act on the Protection of Privacy in Working Life (759/2004), we primarily collect personal data directly from you.
If we need to collect information from third parties, including references or background information, we will seek your consent where required by applicable law.
Where we obtain personal data from sources other than you, we will provide the required information in accordance with Article 14 GDPR, including at the time of first contact.
5. Purposes of Processing
We process personal data for the following purposes:
• Managing and administering recruitment processes;
• Reviewing and evaluating applications and candidate profiles;
• Communicating with candidates;
• Maintaining and operating our Career Site;
• Improving recruitment and candidate experience;
• Managing our Talent Pool and future recruitment opportunities;
• Conducting sourcing and referral activities;
• Evaluating references;
• Protecting legal rights and responding to legal claims;
• Maintaining security and preventing misuse of systems and services.
6. Legal Basis for Processing
We process personal data under one or more of the following legal bases:
Legitimate Interest
We process personal data where necessary for our legitimate interest in:
• Identifying and recruiting qualified candidates;
• Managing recruitment processes;
• Maintaining an efficient recruitment process;
• Evaluating applications;
• Maintaining recruitment records;
• Ensuring appropriate documentation of hiring decisions;
• Operating and improving recruitment systems.
We have assessed that these interests are balanced against candidates’ rights and freedoms.
Consent
We rely on consent where required, including for example:
• Joining our Talent Pool or “Connect” function;
• Interview recording;
• Certain optional assessments;
• Reference checks and any background checks where consent is required under applicable law, including Finnish employment privacy legislation.
You may withdraw consent at any time.
Legal Obligations
We may process personal data where necessary to comply with legal obligations.
7. Career Site Cookies and Tracking Technologies
Our Career Site may use cookies and similar technologies to support functionality, security, analytics, and user experience.
Further information about cookies used on our Career Site, including categories and purposes, is available through our cookie settings or cookie notice
Certain cookies may be provided through Teamtailor or third-party providers.
Information regarding Teamtailor’s own cookie usage and related processing is available through Teamtailor’s cookie policy at https://novacomplex-demo.teamtailor.com/cookie-policy.
Where required by applicable law, non-essential cookies are only activated with your consent through our cookie consent mechanisms.
8. Sharing of Personal Data
We may share personal data with:
Teamtailor and Service Providers
We share information with Teamtailor and other service providers supporting recruitment and related services.
HR Personnel and Hiring Managers
Access is limited to authorised HR personnel and hiring managers involved in recruitment activities.
Group Companies
Where relevant for recruitment purposes and subject to appropriate safeguards, personal data may be shared within our corporate group for recruitment administration. Group companies may act as independent data controllers when participating in recruitment decisions.
Authorities and Legal Recipients
We may disclose personal data:
• To comply with legal obligations;
• To respond to lawful requests;
• To establish, exercise or defend legal claims.
Business Transactions
In connection with mergers, acquisitions or reorganisations, personal data may be disclosed where legally permitted.
We do not sell or rent personal data to third parties.
9. International Transfers and Access Outside the EU/EEA
Personal data is primarily stored and processed within the EU/EEA.
However, international access or transfers may occur:
• Through Teamtailor or authorised sub-processors;
• Through service providers supporting recruitment systems;
• Where authorised HR personnel or hiring managers access Teamtailor or candidate profiles while travelling or working outside the EU/EEA.
Where personal data is transferred or accessed outside the EU/EEA, we implement safeguards recognised under GDPR, including:
• European Commission adequacy decisions;
• Standard Contractual Clauses (SCCs);
• Appropriate technical and organisational security measures.
10. Retention Periods
Applicants
If you apply for a specific position and are not selected, we normally retain your data for 24 months after the recruitment process has concluded. This retention period reflects standard recruitment limitation periods and our need to demonstrate fair and non-discriminatory hiring practices.
This retention period helps us:
• Consider candidates for future vacancies;
• Handle potential legal claims;
• Maintain recruitment records.
Talent Pool / Connect Candidates
If you join our Talent Pool or Connect function, we retain your information until:
• You withdraw consent;
• You remove your profile; or
• The retention period expires following inactivity.
Hired Candidates
If you are hired, recruitment data relevant to employment may become part of employment records and will be governed by our Employee Privacy Notice.
References
Reference information is generally retained for as long as recruitment records relating to the relevant candidate are retained.
11. Your Rights Under GDPR
You have rights regarding your personal data, including:
Right of Access
You may request confirmation of whether we process your data and obtain a copy.
Right to Rectification
You may request correction of inaccurate or incomplete information.
Right to Erasure
You may request deletion of your data where legally applicable.
Right to Restrict Processing
You may request restriction of processing under certain circumstances.
Right to Object
You may object to processing based on legitimate interests.
Right to Data Portability
Where processing is based on consent or contract and carried out automatically, you may request portable data.
Right to Withdraw Consent
Where processing is based on consent, you may withdraw consent at any time.
Right to Lodge a Complaint
You may lodge a complaint with the Finnish Data Protection Ombudsman (Tietosuojavaltuutetun toimisto) or another competent supervisory authority.
12. Exercising Your Rights
Where available, you may exercise certain rights directly through:
• Your Teamtailor profile;
• Teamtailor Data & Privacy settings; or
• By contacting us directly.
Privacy and recruitment requests may be submitted to:
careers@novacomplex.com
13. Changes to this Privacy Notice
We may update this Recruitment Privacy Notice from time to time to reflect changes in legal requirements, recruitment practices, technology, or organisational processes.
The latest version will always be available through our Career Site.
