Candidate Privacy Policy

  1. What is the purpose of this document?

Firstly, thank you very much for considering a job opportunity at KaFe Rocks Ltd, marketed as Time2play Media (together referred to as “Kafe”, “we”, or “us”).Before applying for a role at Kafe, kindly bear in mind that you will need to provide us with some information (“personal data”) in accordance with the GDPR (General Data Protection Regulation (EU) 2016/679).

The purpose of this Candidate Privacy Policy (“Policy”) is to inform you on how we collect and process your personal data in connection with our hiring process. According to the GDPR we are your Data Controller and as such, we are responsible for taking care of your personal data. By way of this Policy, we also provide you with information about all the rights you can exercise in relation to your personal data.


  1. What are the Data Protection Principles?

Under the GDPR there are some important principles we are required to comply with. In view of this, rest assured that your personal data will be: 

  • based on a legal basis and in accordance with the law;
  • used fairly and in a transparent way;
  • exclusively collected for the purposes of recruitment, selection, and evaluation of candidates for the role you have applied for.
  • maintained for a period not exceeding the necessary for the purposes we have informed you about;
  • Accurate and kept up to date;
  • Kept securely by way of technical and organizational measures.


  1. What personal data may we collect from you?

When you send an application at Kafe, the information we will collect, use and store may be the following:

  • Name and surname
  • Date of birth 
  • Gender
  • Address
  • Ip address 
  • Email address
  • Landline and/or mobile number
  • Other contact details (e.g Skype)
  • Education
  • Qualification
  • Career History
  • Training 
  • Salary
  • Referee and reference details
  • Personal interests
  • Any additional information which is included in your Curriculum Vitae and Covering Letter;
  • Any information you provide us with during your interview/s or test/s which may be part of the hiring process.

We do not request and collect special categories of data (“sensitive personal data”) during the hiring process. 

Sensitive personal data includes information relating to a person’s race or ethnic origin, political opinions or religious or philosophical beliefs, genetic data, physical or mental health or condition, sexual orientation, or details of any criminal convictions. 

If you voluntarily decide to provide us with your sensitive personal data, we will need your clear and explicit consent that will authorize us to collect and use such data.


  1. What are your rights? 

You are entitled to exercise certain rights concerning your personal data that may include:

  • Right of access – you have the right to (i) request access to the personal data we process about you, (ii) obtain a copy of your data in electronic format, and (iii) check that we are lawfully processing it.
  • Right to erasure – you can request that your personal data is deleted.
  • Right to restrict – you have the right to request that we stop processing all or part of your personal data.
  • Right to rectification – if you believe that the personal data we hold about you is not correct, you may request that we amend or update your personal data.
  • Right to object – the right, at any time, to object to us processing your personal data in certain instances.
  • Right to data portability – you have the right to receive your personal data you previously provided us with in a structured, commonly used and machine-readable format, and to request the transfer of your personal data to another party.

If you believe we are not complying with this Policy or any applicable law, you can exercise the right to file a complaint with the Supervisory Authority which is based in your country of residence. 

In order to require any further personal data, exercise any of your rights, or obtain any other information about the way we process your personal data, please feel free to send us a written request to the following email address: 


  1. How do we collect your personal data?

We mainly collect your personal data from you. However, as part of the hiring process, we might collect your personal data from your professional social networks (e.g LinkedIn) and/or your former employers and employees (as a result of a background check).

We do not process any personal data by using automated means.


  1. How will we use your personal data?

We will use your personal data to: 

  • communicate with you regarding the hiring process;
  • assess your qualifications, skills, experience, and suitability for the job you applied for;
  • verify the information you provided us with and carry out background and reference checks;
  • keep records concerning our hiring process;
  • draft an offer letter if you receive a job offer from us; and
  • comply with applicable laws, regulations, legal processes, or enforceable governmental requests.


The legal basis on which we collect and use your personal data is based on our legitimate interest. Our legitimate interest is to hire a candidate with the right skills, experience, background, and qualification that makes him/her the best fit for the actual or future vacancy.

We may also need to process your personal data to respond to and defend against legal claims. 


  1. What if you fail to provide us with your personal data? 

If you will fail to provide personal data when requested, we may not be in the position to consider you for the role you applied for.


  1. How long will we use your personal data for?

If your application will not be successful, we will keep your personal data into our system for a maximum period of twelve (12) months from the end of the recruitment process. 

After the expiration of this period, we will immediately delete your personal data unless we will be required to comply with any applicable law, tax or accounting requirement that requires us to keep the data for a longer period.

As an alternative to the deletion, we may decide to anonymize your personal data. As a result of the anonymization, your personal data will be altered in a way you will not be longer identified, directly or indirectly.


  1. Who will we share your personal data with? 

We will not share your personal data with any third parties.

Where your personal data is transferred to a country outside of the EU/EEA, we will transfer your personal data in accordance with applicable privacy laws. We will also guarantee a level of protection of your personal data by opting for contractual, technical, and organizational measures such as Standard Contractual Clauses approved by the European Commission.


  1. Changes to this Policy 

We may amend or update this Policy from time to time. If we do so, we will change the date and the version at the bottom of this Policy. If we make significant changes, we will provide notification in the form of a visible notice on our website.


This Policy was last amended on the 9th of November 2022.