1. Introduction
At The Proper Agency (the Agency), your privacy matters. This Privacy Notice explains how we collect, use, and protect your personal data, whether you’re a client, partner, or job applicant. We comply with the General Data Protection Regulation (the GDPR) and other relevant laws.

2. How We Collect Your Data
We collect your personal data in three main ways:

• Directly from you: when you contact us via email, phone or chats on our social media accounts, use our services, apply for a job, fill out an inquiry forms or surveys, etc.
• Automatically: when you interact with our digital platforms, through our website and social media. This may include your IP address, device info, browsing behaviour, cookies.
• From third persons: when we collect certain information from public sources, recruitment platforms, referrals, or third-party partners helping us deliver services.

3. Why We Use Your Data and On What Legal Grounds
We collect and process your personal data to ensure that we can provide our services to you effectively and to comply with our legal obligations. In the case of processing data from job applicants, we do so to evaluate your suitability for employment at the Agency and meet any legal requirements related to the recruitment process.

We only process your data when we have a valid ground under GDPR. This may include your consent, fulfilling a contract, meeting legal obligations, or pursuing our legitimate interests.

Detailed information on data processing purposes, legal grounds, specific data categories and retention periods is provided in Annex to this Privacy Notice.

4. Sharing Your Data
We may share your data with other persons for purposes consistent with this Privacy Notice:

• Service providers: these may include companies providing data storage, server and/or communication services, software development and maintenance, advertising and marketing services, online traffic and website analysis, statistics services, accounting, recruitment service providers and other service providers.
• Our business partners: with whom we collaborate to provide specific services. These partners may be involved in jointly delivering or enhancing the services we offer to our clients and may include entities working with us on projects.
• Third parties such as courts, state authorities, legal or audit service providers, etc. in compliance with legal requirements.

As a general rule, we do not transfer personal data outside the European Economic Area. However, in certain cases where our activities require it (e.g., if our service provider is located outside the European Economic Area), we will ensure that the necessary security measures are implemented for such data transfers.

5. Automated Decisions
In some cases, we may employ automated decision-making processes (also referred to as profiling) concerning you. This entails utilizing technology to assess your personal circumstances and other factors to anticipate outcomes. For example, automated processes may be used in areas such as screening job applications and conducting preliminary assessments in recruitment process. In cases where we reach automated decisions concerning you, you retain the right to request a manual review conducted by a human being.

6. Your Rights
You have specific rights under the GDPR, including:

• Right to be informed about how and why your personal data is processed.
• Right of access to the personal data we hold about you.
• Right to rectification of inaccurate or incomplete data.
• Right to erasure (“right to be forgotten”) in certain cases, such as when data is no longer needed, or processing is unlawful.
• Right to restrict processing in cases such as data inaccuracy, objection, or pending legal claims.
• Right to data portability, allowing you to receive and transfer your data when processing is based on consent or contract and done automatically.
• Right to object to processing based on legitimate or public interest, including direct marketing and profiling.
• Right not to be subject to automated decisions, including profiling, that significantly affect you.
• Right to be informed about international data transfers and the safeguards applied.

To exercise your rights, please send us a written request using the contact details in this Privacy Notice. We will respond as soon as possible, and no later than within 1 month. In complex cases, this period may be extended by up to 2 additional months. Requests are generally handled free of charge, unless they are clearly unfounded or excessive. You also have the right to file a complaint with the State Data Protection Inspectorate.

7. How We Protect Your Data
We take the security of your personal data seriously and apply appropriate technical and organizational measures to ensure its confidentiality, integrity, and availability. These measures include internal policies and access controls, staff responsibilities, secure IT infrastructure, regular backups, incident response procedures, and establishment of proper legal arrangements when engaging third-party data processors. We aim to prevent unauthorized access, loss, or misuse of your data at all stages of processing.

8. Data Retention
We keep your data only as long as necessary for the purposes stated in this Privacy Norice. Once the retention period expires, the data is no longer processed. At the end of the retention period, we either securely destroy or anonymize the data. Our retention periods are specified in Annex to this Privacy Notice.

9. Notice Updates
We may update this Privacy Notice from time to time – especially if we start or cease processing of certain categories of data. When we do, we’ll post the latest version in our website. We recommend checking this page occasionally to stay informed.

10. If You Have Questions
If you have any questions or concerns about your data processing, just contact us at:

• Email: vitalij@theproper.agency
• Phone: +37065572655

1. Data of clients, business partners, service providers and other third persons

2. Data of job applicants