Privacy Policy

At nineDots, we take the privacy and protection of personal data seriously. This Privacy Policy explains how we collect, use, store and share personal data when providing our recruitment services, working with candidates and clients, engaging contractors and other professional contacts, and operating our website.

We process personal data in accordance with the General Data Protection Regulation (GDPR), the Irish Data Protection Act 2018 and other applicable data protection laws.

1. Who we are

nineDots provides recruitment and related talent services.

Nine Dots Recruitment Limited is the data controller responsible for personal data processed in connection with our Irish recruitment business and ninedots.io, unless we tell you otherwise.

nineDots also operates through nineDots W.L.L. in Bahrain, which is responsible for personal data processed in connection with its own recruitment activities. Both companies use a shared recruitment database, and authorised personnel in either business may access candidate information held within it. Depending on the processing activity, the companies may act as independent or joint data controllers.

This policy applies to candidates and prospective candidates, contractors and consultants, clients and prospective clients, suppliers and other professional contacts, and visitors to our website.

It applies whether you provide your personal data to us directly or we obtain it from another source, such as LinkedIn, another professional platform or a referral.

2. What personal data we collect and where it comes from

The information we collect depends on your relationship with us.

For candidates and contractors, this may include your contact details, CV, employment history, education, skills and qualifications, professional experience, salary or rate expectations, availability and location preferences, information provided during applications or interviews, and records of roles you have applied for, been considered for or been introduced to.

Where required for a particular role or assignment, we may also process information necessary for references, identity, right-to-work or other appropriate pre-employment checks.

We do not routinely request or collect special category personal data, such as information about health, disability, ethnicity or religious beliefs. However, you may choose to share certain information with us, for example where you require adjustments during a recruitment process. Where we process this information, we will do so only where necessary and where an appropriate legal basis and additional condition under data protection law apply.

We may receive this information directly from you, including through applications and CV submissions on our website, or through sources including LinkedIn and other professional platforms, job boards, referrals, clients and previous interactions with nineDots.

For clients, prospective clients, suppliers and other business contacts, we may process your name, job title, company, business contact details and information relating to our communications and professional relationship with you.

Our website may also collect technical information through cookies and similar technologies.

3. How and why we use your personal data

We use personal data to provide and manage our recruitment services and operate our business. This includes:

• identifying and assessing candidates for job and contract opportunities;
• matching and contacting candidates about current and future relevant opportunities;
• managing applications, introductions, interviews and recruitment processes;
• carrying out appropriate checks where required;
• managing contractor assignments;
• providing services to and communicating with clients;
• maintaining client, candidate and professional relationships;
• managing contracts, invoicing and business administration;
• contacting prospective clients and other professional contacts about our services where appropriate; and
• meeting our legal, regulatory and contractual obligations and protecting our legal rights.

We may use AI-enabled tools to assist with recruitment activities, including searching for candidates, reviewing and organising information, preparing notes and supporting administrative tasks. These tools support our team rather than replace human judgement. We do not use solely automated decision-making to determine whether candidates are successful or unsuccessful in a recruitment process.

4. Our legal basis for processing

We process personal data on the following lawful bases, depending on the purpose and circumstances:

• Legitimate interests: To identify, assess and contact candidates about relevant opportunities, manage recruitment processes, maintain our candidate database for future opportunities, develop client relationships and operate our business, where those interests are not overridden by individuals' rights and interests.
• Contract: Where processing is necessary to enter into or perform a contract with you, including managing contractor engagements and related contractual arrangements.
• Legal obligations: Where processing is necessary to comply with applicable legal or regulatory requirements.
• Consent: Where consent is required for a particular activity, such as certain marketing communications or non-essential website cookies.

Where we rely on legitimate interests, we consider the impact of the processing on your rights and interests. Where we rely on consent, you can withdraw it at any time.

5. How we share your personal data

We only share personal data where necessary for our recruitment services, business operations or legal obligations.

This may include sharing candidate information with clients and prospective employers in connection with recruitment processes, including by email or through their applicant tracking and recruitment systems. We may also share personal data with service providers supporting our technology and business operations, providers carrying out appropriate checks, professional advisers, and regulators or public authorities where required by law.

Personal data may also be accessible to authorised personnel across our Irish and Bahrain businesses through our shared recruitment database.

Where third parties process personal data on our behalf, we require them to handle that information appropriately.

We do not sell personal data.

6. International transfers

Personal data may be processed or accessed outside the European Economic Area (EEA) where this is necessary to provide our services or where our service providers or other nineDots operations are located internationally.

Where personal data subject to GDPR is transferred outside the EEA, we assess the applicable data protection requirements and the safeguards needed for that transfer. Depending on the circumstances, these may include recognised transfer mechanisms, contractual protections and appropriate technical and organisational measures.

You can contact us if you would like further information about the safeguards applicable to your personal data.

7. How long we keep your personal data

We retain personal data only for as long as necessary for the purposes for which it was collected, including providing recruitment services, considering candidates for future opportunities, maintaining professional relationships and meeting applicable legal, regulatory, accounting or contractual requirements.

Candidate records are reviewed periodically, with review periods depending on the individual's recruitment status and our ongoing relationship with them. A review does not automatically result in deletion. We assess whether there remains a legitimate purpose for retaining the information and whether it is still relevant and necessary.

Where personal data is no longer required for a legitimate purpose, we will delete or anonymise it as appropriate. Certain placement, contractual and financial records may be retained for longer where necessary to meet legal obligations or protect our legitimate business interests.

8. Data security

We use appropriate technical and organisational measures to protect personal data against unauthorised access, loss, misuse, alteration or disclosure.

Access to personal data is restricted to authorised employees and other authorised individuals, and we take appropriate measures to protect personal data against unauthorised access or use.

9. Your data protection rights

Depending on the circumstances, you may have the right to access your personal data, have inaccurate information corrected, request deletion or restriction of processing, object to processing based on legitimate interests, request data portability, and withdraw consent where we rely on it.

You have the right to object at any time to the use of your personal data for direct marketing.

These rights are not absolute and may not apply in every circumstance.

To exercise your rights, contact us at privacy@ninedots.io.

You also have the right to complain to the relevant data protection authority. For matters relating to Nine Dots Recruitment Limited, you can contact the Irish Data Protection Commission at www.dataprotection.ie.

10. Cookies and website analytics

Our website uses cookies and similar technologies to operate the site and, where applicable, understand how visitors use it.

Where consent is required for non-essential cookies or tracking technologies, we will ask for your consent before using them.

You can manage your cookie preferences using the cookie consent options provided on our website.

11. Business communications

We may use professional contact information to communicate with clients, prospective clients and other business contacts about our recruitment services, where we have an appropriate lawful basis and the communication is permitted under applicable electronic marketing rules. Where consent is required, we will obtain it before sending marketing communications.

You can ask us to stop receiving marketing or business development communications at any time by contacting us at privacy@ninedots.io or using an unsubscribe option where available.

12. Contact us

If you have questions about this Privacy Policy, how we use your personal data or your data protection rights, contact:

privacy@ninedots.io

13. Changes to this Privacy Policy

We may update this Privacy Policy where our services, data-processing activities or legal requirements change.

The latest version will be available on our website and will show the date it was last updated.