Policy

Privacy Policy

and personal data processing on HIRE by Stafflow

Updated September 24, 2026

This English text is a courtesy translation. The Russian version of this document is the legally binding one and prevails in case of any discrepancy.

This Privacy and Personal Data Processing Policy (the “Policy”) sets out how the Limited Liability Company “CatLogic” processes and protects personal data when granting the right to use the Hire by Stafflow platform and operating the websites https://hirevision.by and https://hire.stafflow.by, including the Licensees' career sites created with the Platform. The Policy has been prepared in accordance with the Law of the Republic of Belarus of May 7, 2021 No. 99-Z “On Personal Data Protection” (the “Law”) and other acts of the legislation of the Republic of Belarus.

01

General provisions

1.1. The Limited Liability Company “CatLogic” (UNP 193743532; 220073, Republic of Belarus, Minsk, Kharkovskaya St. 15, office 311; e-mail: support@stafflow.by) (the “Licensor”) is the rights holder of the Hire by Stafflow platform (the “Platform”).

1.2. The terms “Licensee”, “User”, “Candidate”, “Account”, “Partner”, “Third-Party Services” and others are used in the meaning set out in the Hire by Stafflow User Agreement published at https://hirevision.by/en/user-agreement (the “Agreement”).

1.3. The Licensor processes personal data in two capacities:

  • as an operator — for data that the Licensor collects itself for registration on the Platform, for concluding and performing the Agreement and the license agreement, and for support and operation of the websites (section 2 of the Policy);
  • as an authorized person — for data processed in the Licensee's Account on its instruction, including the data of Candidates and Account Users (section 3 of the Policy). The operator of such data is the relevant Licensee.

1.4. The Policy applies regardless of how the right to use the Platform was acquired (directly from the Licensor or through a Partner Channel).

02

Processing of personal data by the Licensor as an operator

2.1. Data subjects: persons who register on the Platform and create an Account; representatives of Licensees who deal with the Licensor on the conclusion and performance of the Agreement and the license agreement; persons who contact the support service; visitors to the websites.

2.2. Data processed: surname, first name and patronymic; e-mail address; telephone number; job title; the name and details of the organization on whose behalf the subject acts; the content of inquiries and correspondence; technical data (IP address, browser and device information, cookie data).

2.3. Purposes of processing:

  • registration on the Platform, creating and maintaining the Account;
  • concluding and performing the Agreement and the license agreement, including issuing Invoices and primary accounting documents;
  • providing technical support and sending notices related to the operation of the Platform and changes to the documents;
  • ensuring the security of the Platform;
  • web analytics of the website https://hirevision.by — in the manner provided by the Cookie Notice.

2.4. Legal grounds: the consent of the personal data subject; the conclusion and performance of contracts; performance of obligations provided for by legislation (including in the field of accounting); other grounds provided for by the Law.

2.5. Processing periods: for the term of the Agreement (license agreement) or until consent is withdrawn, and, for information contained in primary accounting and other documents, for the retention periods established by legislation.

03

Processing of personal data on the instruction of Licensees

3.1. For personal data processed in a Licensee's Account, the operator is the Licensee and the Licensor is the authorized person. The processing instruction is contained in section 7 of the Agreement, which the Licensee accepts when registering on the Platform, including when acquiring the right of use through a Partner Channel.

3.2. Data subjects: Candidates; Account Users (Recruiters, Internal and External Clients); other persons whose data is entered by the Licensee.

3.3. Data processed:

  • of Candidates: surname, first name and patronymic; date of birth; contact details; information on education, employment history, qualifications, professional skills and work experience; resumes and cover materials; applications to vacancies; interview and assessment results; information on offers; Users' comments;
  • of Account Users: surname, first name and patronymic; e-mail address; telephone number; job title; role in the Platform; information on actions in the Platform.

3.4. Purposes of processing: publishing and managing vacancies, including on the Licensee's career site; selecting and assessing Candidates; organizing interviews; preparing offers; interacting with Third-Party Services for personnel search; analytics on the hiring pipeline; ensuring the operation of other Platform functionality to the extent necessary for the relevant function.

3.5. Actions with personal data: collection, systematization, storage, modification, use, anonymization, blocking, provision, deletion. Processing is carried out using automation tools.

3.6. The legal basis for processing is determined by the Licensee as the operator. The Platform provides the Licensee with means of obtaining consent: when a User logs in to the Account and when a Candidate applies to a vacancy through the Licensee's career site. The Licensee ensures that a legal basis exists for processing data it enters into the Platform in any other way (manually, by import, from Third-Party Services).

3.7. The processing period is determined by the Licensee within the term of the contractual relationship. After it ends, the data is stored for 30 (thirty) calendar days so that it can be exported, and is then deleted, unless the Agreement or legislation provides otherwise.

04

Transfer of personal data

4.1. The Licensor does not transfer personal data to third parties, except for:

  • disclosure of a Candidate's data to an External Client and other Account Users within their access rights;
  • transfer of data to Third-Party Services at the Licensee's initiative when the relevant integrations are used;
  • engaging contractors who ensure the operation of the Platform (hosting, mailings, payment services) on terms of confidentiality and personal data protection. By accepting the Agreement, the Licensee agrees to the engagement of such persons to process data processed on its instruction;
  • cases provided for by legislation.

4.2. Personal data processed in the Platform is stored on servers located in the territory of the Republic of Belarus.

4.3. Cross-border transfer of personal data is carried out only in the cases and in the manner provided for by Article 9 of the Law. The cross-border transfer of data collected by analytics cookies on the website https://hirevision.by is described in the Cookie Notice.

05

Rights of personal data subjects

5.1. A personal data subject has the right to: withdraw consent at any time without giving reasons; receive information about the processing of their personal data; demand changes to their personal data if it is incomplete, outdated or inaccurate; receive information on the disclosure of their personal data to third parties; demand that processing be stopped and/or their personal data be deleted; appeal against the actions (inaction) and decisions of the operator to the authority protecting the rights of personal data subjects in the manner established by legislation.

5.2. For the data referred to in section 2 of the Policy, the request is sent to the Licensor at support@stafflow.by or to the postal address given in clause 1.1 of the Policy.

5.3. For the data referred to in section 3 of the Policy, the request is sent to the Licensee (the organization carrying out the recruiting). A request received by the Licensor is passed to the relevant Licensee without undue delay; the Licensor carries out instructions received from the Licensee.

5.4. The request must contain the information provided for by Article 14 of the Law.

06

Personal data protection measures

6.1. The Licensor takes legal, organizational and technical measures to ensure the protection of personal data, including: encryption of data in transit, separation of access rights, backups, monitoring of security events, and appointing a person responsible for internal control over the processing of personal data.

6.2. Licensor employees who have access to personal data undertake non-disclosure obligations.

6.3. In the event of a breach of personal data protection systems, the Licensor immediately notifies the relevant Licensees with respect to data processed on their instruction, and, with respect to data processed as an operator, the authority protecting the rights of personal data subjects, in the manner and within the periods established by legislation.

07

Final provisions

7.1. The Policy is publicly available at https://hirevision.by/en/privacy-policy.

7.2. The User Agreement (https://hirevision.by/en/user-agreement) and the Cookie Notice (https://hirevision.by/en/cookies) are integral parts of the Platform's document package.

7.3. The Licensor may amend the Policy. The new version takes effect when it is published, unless the new version provides otherwise.

Limited Liability Company “CatLogic”, UNP 193743532, 220073, Republic of Belarus, Minsk, Kharkovskaya St. 15, office 311, support@stafflow.by

Last updated: September 24, 2026

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