Privacy Policy

1. Who we are

This Privacy Policy explains how RECRIMCO CONSULTING S.R.L. collects, uses, stores, shares and protects the personal data of website visitors, candidates, job seekers, representatives of partner companies, employees or prospective employees of client companies, subcontractors, contact persons and other individuals who interact with us.

For processing carried out for its own purposes, the data controller is RECRIMCO CONSULTING S.R.L., with its registered office at 45 Partizanilor Street, Târnăveni, Mureș County, Romania, registered with the Romanian National Trade Register Office (ONRC) under no. J2020000357261, unique tax registration code (CUI) RO42363842, and registered as a foreign employment placement agency under no. 132/02.04.2025 with the Mureș Territorial Labour Inspectorate.

RECRIMCO is a personal data controller within the meaning of the GDPR.

Data protection contact details: info@recrimco.com. Requests may also be sent to the registered office specified above.

RECRIMCO has not appointed a Data Protection Officer (DPO), as it does not consider that it is legally required to do so as at the date this Policy is published. For any data protection enquiry, data subjects may contact RECRIMCO at info@recrimco.com.

2. Scope

This Policy applies to the website www.recrimco.com, contact forms, communications by email, telephone, WhatsApp or other agreed channels, as well as to pre-contractual and contractual interactions relating to RECRIMCO services.

RECRIMCO provides recruitment, selection, information, counselling and employment placement services for work abroad, as well as administrative and operational HR support services, onboarding, document administration, support relating to payroll and timekeeping data, operational support, document audits, application management and related services.

3. RECRIMCO’s roles in personal data processing

Depending on the circumstances, RECRIMCO may act as an independent controller, a joint controller together with another controller, or a processor, in accordance with the GDPR.

For its own marketing activities, website administration, communication with visitors, recruitment, selection, information, counselling and employment placement for work abroad, RECRIMCO generally acts as an independent controller.

In relation to client companies or foreign employers, each party may act as an independent controller for processing carried out for its own purposes. Where RECRIMCO processes data solely on the instructions of a client company, for example in connection with HR administration, timekeeping, payroll support, the creation of operational accounts, employee document management, audits or operational support, RECRIMCO may act as a processor under Article 28 of the GDPR, on the basis of a separate data processing agreement.

When acting as a processor, RECRIMCO does not use the data for its own purposes, implements appropriate security measures and follows the controller’s instructions.

4. Categories of data subjects

We process data relating to the following categories of individuals: website visitors, individuals who contact us, candidates and job seekers, individuals receiving employment placement services for work abroad, employees or prospective employees of client companies, former employees of client companies, representatives and contact persons of partner companies, subcontractors and their employees, suppliers, consultants and other individuals whose data is required for the provision of our services.

5. Categories of personal data processed

Depending on the relationship and the service requested, we may process: first name, surname, Romanian personal identification number (CNP), date and place of birth, nationality, address, identity document details, passport details, driving licence details, photograph, telephone number, email address, CV, professional experience, qualifications, language skills, job title, worksite or warehouse location, start date, contract type, job offer details, employment placement agreement, individual employment contract or equivalent document, travel or relocation data, bank details, payroll and timekeeping data, leave, absences, bonuses, equipment, social security and health insurance data, data relating to the use of operational applications, GPS or telematics data, vehicle usage data, incidents, misconduct, warnings, operational performance and audit data.

Health data, medical fitness certificates and other special categories of personal data are processed only where strictly necessary for the specific offer, the nature of the role, legal obligations or requirements permitted by law, in accordance with the principle of data minimisation. The legal basis for processing health data is Article 9(2)(b) and, respectively, Article 9(2)(h) of the GDPR.

Criminal record data and background checks are processed only to the extent permitted by applicable law and only where necessary to assess eligibility for the relevant role, comply with legal obligations or meet justified operational requirements. Such processing is generally based on a legal obligation or an express requirement of the employer, within the limits of the law, and is not carried out solely on the basis of consent.

With regard to GPS or telematics data and operational monitoring data, where RECRIMCO acts as a processor in connection with such monitoring (for example, for client companies using GPS systems), the controller (the client company) remains primarily responsible for informing employees, while RECRIMCO acts on its written instructions under a data processing agreement pursuant to Article 28 of the GDPR.

For website visitors, we may process technical data such as IP address, online identifiers, device data, browser, operating system, pages accessed, date and time of access, cookie preferences and other data generated through use of the website.

6. Purposes of processing

We process personal data for the following purposes: website administration; responding to enquiries; pre-contractual and contractual communications; marketing RECRIMCO services; recruitment, selection, information, counselling and employment placement for work abroad; presenting candidates to foreign employers; preparing employment placement files; issuing firm job offers and individual annexes; organising interviews; providing support with employment and travel; submitting notifications and reports to the competent authorities; statutory record keeping; providing operational HR services to client companies; onboarding; personnel file administration; payroll and timekeeping support; creating and administering accounts on operational platforms; document audits; operational monitoring within the limits of the law; handling data subject requests; protecting legal rights and legitimate interests; and ensuring tax, accounting and legal compliance.

RECRIMCO does not sell the personal data of candidates, clients or website visitors.

As a foreign employment placement agency, RECRIMCO processes the personal data of job seekers and individuals receiving employment placement services for work abroad in accordance with Article 7 of Law no. 156/2000, the GDPR and the applicable national implementing legislation.

7. Lawful bases for processing

Depending on the circumstances, processing is based on: the performance of a contract or steps taken prior to entering into a contract; compliance with legal obligations applicable to RECRIMCO, including obligations relating to foreign employment placement, reporting to the Territorial Labour Inspectorate and document retention; the legitimate interest in organising, evidencing and protecting recruitment, placement and communication activities, security and the defence of legal rights; the data subject’s consent where the law requires or permits this basis; the protection of vital interests in exceptional circumstances; and compliance with applicable legal requirements in the fields of employment, social security, health and occupational safety, where relevant.

Where we rely on legitimate interests, the data subject has the right to object to the processing under the conditions described in the section entitled “Data subject rights”.

The purposes of processing are linked to the relevant lawful bases as follows: for recruitment, selection, employment placement and presenting candidates to employers, the lawful basis is the performance of the employment placement agreement or steps taken prior to entering into a contract and, where applicable, legitimate interests; for reporting to the Territorial Labour Inspectorate and other authorities, the lawful basis is compliance with legal obligations (including Law no. 156/2000 and applicable employment and tax legislation).

For promotional and marketing communications, the lawful basis is consent where consent is required.

8. Sources of personal data

As a rule, we collect personal data directly from the data subject. In certain circumstances, we may also receive data from client companies, foreign employers, operational partners, subcontractors, dispatch teams, accounting providers, operational platform providers or public authorities, to the extent necessary for recruitment, employment placement, HR administration, operational support, audits, timekeeping, payroll or compliance with legal obligations.

9. Employment placement services for candidates and free services for job seekers

For Romanian citizens seeking employment abroad, RECRIMCO provides information, counselling and employment placement services in accordance with Law no. 156/2000 and the applicable implementing rules.

Employment placement services are provided free of charge to the job seeker. RECRIMCO does not and will not charge candidates any commission, fee, charge, security deposit, advance payment, penalty or other cost for information, counselling, recruitment, selection or employment placement activities relating to work abroad.

Any personal expenses incurred by a candidate, such as travel costs, the cost of obtaining personal documents or other expenses that are not employment placement costs, will be borne by the candidate only to the extent permitted by law and separately communicated in writing in the individual offer or employment contract or equivalent document.

10. Recipients of personal data

Where necessary, personal data may be disclosed to foreign employers or client companies, affiliated companies or operational partners designated by the client company, competent public authorities, territorial labour inspectorates, IT and communications providers, storage and electronic signature service providers, operational platforms used by client companies, consultants, translators, accountants, lawyers, auditors, training providers, authorised transport providers, banks or other recipients authorised by law or required for the purposes described above.

Access to personal data is limited to individuals who genuinely need the data to perform their duties or provide the relevant services.

An up-to-date list of the principal categories of recipients is available upon request.

11. International transfers

Personal data is generally processed in Romania, Germany and within the European Economic Area. Where data is transferred to employers or recipients located in the European Union or European Economic Area, the transfer is made for the purposes of assessment, selection, employment, service provision or compliance with legal obligations.

If personal data is transferred to countries outside the European Economic Area, the transfer will take place only in compliance with the GDPR, including on the basis of an adequacy decision, Standard Contractual Clauses or other applicable legal safeguards, and the data subject will be informed where required.

In the absence of an adequacy decision, the transfer will be based on appropriate safeguards, such as Standard Contractual Clauses, in accordance with Article 46 of the GDPR.

12. Communication channels

Communications with data subjects may take place through the website, email, telephone, WhatsApp, electronic signature platforms, operational applications or other agreed means. Documents sent through messaging applications will, where possible, be transferred to internal systems or systems approved by the client company and deleted from the messaging applications when they are no longer required, to the extent technically and legally possible.

13. Cookies and similar technologies

The website may use cookies that are strictly necessary for its operation and security. Analytics, marketing, remarketing and social media cookies, as well as other non-essential technologies, will be used only if they are actually enabled on the website and only after the user’s consent has been obtained where required by law. Until a valid consent mechanism has been implemented, such cookies must remain disabled.

Before publication, the actual list of cookies, providers, retention periods and purposes must be confirmed with the website developer and included in the cookie banner or Cookie Policy.

14. Data retention

We retain personal data only for as long as necessary to fulfil the purposes for which it was collected and for the applicable statutory retention periods. Employment placement agreements, individual offer annexes, copies of documents relating to placement services and documents that must be retained under Law no. 156/2000 are generally kept for the statutory period of three years, unless a longer period is required by law.

Communication data and commercial documents may be retained for the duration of the contractual relationship and thereafter for the applicable limitation, tax and accounting periods or for the establishment, exercise or defence of legal claims. Personal data processed in the capacity of processor is returned or deleted in accordance with the controller’s instructions, except where retention is required by law.

Personal data used for marketing communications is retained until consent is withdrawn or the right to object is exercised, as applicable.

15. Security measures

We implement appropriate technical and organisational measures, including restricting access to personal data, using individual accounts and passwords, protecting access credentials, storing documents in approved systems, organising and archiving documents, transmitting data through reasonably secure channels, training authorised personnel, monitoring incidents, returning or deleting data when it is no longer required, and applying other measures proportionate to the relevant risks.

No method of transmission or storage is entirely risk-free. If we become aware of a personal data breach, we will act in accordance with the GDPR, including by notifying the competent authority and/or affected data subjects where required.

16. Data subject rights

Subject to the conditions set out in the GDPR, you have the right of access, rectification, erasure, restriction of processing, objection and data portability; the right not to be subject to a decision based solely on automated processing; the right to withdraw consent where processing is based on consent; and the right to lodge a complaint with the Romanian National Supervisory Authority for Personal Data Processing (ANSPDCP), whose registered office is at 28-30 Gheorghe Magheru Boulevard, District 1, Bucharest, website: www.dataprotection.ro, email: anspdcp@dataprotection.ro.

To exercise your rights, you may contact us at info@recrimco.com or at our registered office. We will respond within the time limits set by the GDPR. Before responding, we may request reasonable additional information to verify your identity.

17. Automated decision-making

RECRIMCO does not make decisions that produce legal effects concerning data subjects, or similarly significantly affect them, solely by automated means. Digital tools may be used to organise information, perform administrative filtering, maintain records, prepare reports or provide operational support; however, relevant decisions concerning selection, employment placement, hiring or the continuation of a business relationship involve human intervention and/or a decision by the relevant employer or client company.

18. Provision of personal data

Providing the personal data required for recruitment, employment placement, preparation of employment documents, statutory reporting or the provision of HR services may be necessary in order for the process to continue. Refusal to provide strictly necessary data may make it impossible to continue the placement process, present the candidate to an employer, prepare the documents or provide the requested services.

Certain personal data is mandatory in order to comply with legal or contractual obligations (for example, identification data and data required for the employment placement agreement and employment contract), while other data may be optional (for example, certain communication or marketing preferences). At the time of collection, RECRIMCO will indicate which data is mandatory and which is optional.

19. Updates to this Policy

We may update this Privacy Policy to reflect legislative, technical or operational changes. The version published on the website is the version applicable at the time it is accessed.