CANDIDATE PRIVACY POLICY

Effective as of December 11th, 2025


By applying for a position at Uney GmbH (“Uney”, “we”, “us”, or “our”), you understand that your personal data is processed according to the following privacy policy and agree with it. This policy states (i) what data we collect during the application and recruitment process, (ii) the use we make of such data, (iii) the safeguards we put in place to protect your data and (iv) your rights as data subject.


This Privacy Policy is complementary to our general Privacy Policy to the extent applicable when visiting our website.


This Policy applies to the personal information about you that you or anyone else may provide (on your or our behalf) to Uney during the application and recruitment process (“Candidate Data”) including through our jobs sites and recruitment platforms. This Policy is made public at the corporate website of Uney (https://uney.com).


  1. Legal Framework


Uney GmbH is a company formed under Swiss law and whose headquarters are located at Grafenaustrasse 13, 6300 Zug, Switzerland. For all questions, you can reach us at [email protected].


We are subject to the Swiss Federal Act on Data Protection (“FADP”). We are also Regulation (EU) 2016/679 (General Data Protection Regulation, “GDPR”) compliant. The designated representative of Uney in the European Union (notably for the purpose of art. 27 GDPR) is Roger Daniel Wehrli.


  1. Types of Candidate Data We Collect


The types of Candidate Data that you share with us and/or that we may obtain from third parties, such as your former employers, references, employment screening agencies, recruiters, and recruiting and other websites, include: 


  • Name, address, email address, telephone number, and other personal information;


  • Resume, CV, cover letter, previous work experience, professional licenses and certifications, job skills and qualifications, and education information;


  • Compensation history and requests, willingness to relocate, and other job preferences;


  • Reference information, candidate’s former employer feedback, and information received from background checks;


  • Scoring and analytical results produced by AI tools used in our recruitment process;


  • Online questionnaire results and information from interviews; and


  • Any additional information provided or revealed during the application and recruitment process (e.g., language preference). 


Any information that you submit during the application and recruitment process must be true and correct and you must have the lawful right to provide it. If not, this may lead to rejection of your application or disciplinary action, including termination of any subsequent employment.


Uney does not request sensitive personal information, such as race, ethnic origin or health information, unless permitted or required by labor regulations of Switzerland, such as for the employment engagement purposes.


    1. Application via our Career page


When applying for a position at Proton, you provide us with your Candidate Data which we save in our Recruiting Database (“Database”, see below) and process according to this Policy.


    1. Application via third-party sourcing or recommendation


If you are sourced by us and added manually to our Database, the personal data is obtained from public sources, such as LinkedIn. If you are referring to us by a third party for potential employment, the personal data added to our Database is provided by said third party, and/or data available publicly.


In all cases, upon inclusion in our Database, you will receive an email informing you of your inclusion and of the processing of your personal data.


  1. Use of Candidate Data


Uney may collect, use, and otherwise process your Candidate Data for human resources and business management purposes, including:


  1. to evaluate your skills and qualifications for positions at Uney; 


  1. to communicate with you;


  1. to maintain appropriate record-keeping related to recruitment and hiring practices and processes;


  1. to conduct tests and collection results, including your answers, score, or ranking, and measures to prevent cheating by using AI and turning your webcam on;


  1. to use AI tools to support efficient, transparent, and fair recruitment: Summarize and structure CVs and application documents, generate candidate scores, compare your profile with the requirements of the position;


  1. to analyze and improve recruitment processes and outcomes; and


  1. to verify your information and conduct reference and background checks, where permitted. 


Uney also may collect, use and otherwise process your Candidate Data to comply with the law of Switzerland.


Such processing is also legally permissible under Art. 6(1)(f) of GDPR as necessary for the purposes of the legitimate interests pursued by us, which are the solicitation, evaluation, and selection of applicants for entering a contractual relationship.


  1. Use of AI tools


As part of the recruitment process, we use AI-based tools that may involve profiling within the meaning of Article 4(4) GDPR. Profiling includes the automated analysis of your application materials, prior applications, and publicly available professional data to generate structured summaries, match your qualifications to job requirements, and assign candidate scores.


In particular, we may use our own-developed AI tool to select appropriate candidates for us to consider based on criteria expressly identified by us, or typical in relation to the role for which you have applied. The process of finding suitable candidates is automatic, however, any decision as to who we will engage to fill the job opening will be made by our staff.


However, no decision with legal or similarly significant effects is based solely on automated processing. All AI-generated summaries and scores are reviewed and interpreted by human recruiters and hiring managers. The final hiring decision is always made by humans and not by an algorithm.


If you participate in an assessment, test, or interview, we may use our own-developed AI tool or machine learning to capture your facial image taken from your webcam or device at intervals during your participation and analyze those images for the purpose of detecting changes to the facial images, or to analyze patterns of your coding and interactions and behavior within an assessment, test, or interview to indicate whether answers may be copied from or generated or assisted by using another unauthorized source.


  1. Retention of Candidate Data  


If you are hired, your Candidate Data may be transferred to an employee personnel file and used and retained for as long as necessary in connection with your employment for human resources and business management purposes in accordance with applicable law and the internal personal data privacy of Uney (if any, from time to time).


If you are not hired, you will also agree to give explicit consent to us to retain your Candidate Data for a further fixed period of 120 days to consider you for other job opportunities at Uney. If you do not wish to retain your Candidate Data, please contact us at [email protected].


  1. Disclosure of Candidate Data 


Uney may share your Candidate Data internally and with service providers and other third parties that have been engaged to perform recruitment and employment-related services on behalf of Uney. These third parties are required to use appropriate measures to protect the confidentiality and security of your Candidate Data.


Uney may also be required to disclose certain Candidate Data to third parties as required by law or regulation (e.g., to tax and social security authorities) or in response to legal process or lawful requests by public authorities, including to meet national security or law enforcement requirements.


We will also share your Candidate Data with third parties if we have your consent to this Policy, or (1) to detect, investigate and help prevent fraud, security, or technical issues; (2) to protect the rights, property, or safety of Uney and our users, applicants, candidates, employees, and others; and (3) as part of a corporate transaction, such as a transfer of assets or an acquisition by or merger with another company.


  1. Security and Confidentiality


Uney is committed to using appropriate technical and organizational measures designed to protect the security and confidentiality of your Candidate Data.


  1. Your Rights


As a company that is complying with the Swiss FADP and the EU GDPR, your privacy is important to us, and we are committed to protecting and safeguarding your data privacy rights.

You have the right to access, restrict, rectify, or delete your Candidate Data. You also have the right to withdraw your consent at any time.


In addition, you may lodge a complaint to the Swiss Federal Data Protection and Information Commissioner. We remain available via email to [email protected] for any inquiry.


Please note, however, that certain personal data may be exempt from certain requests due to restrictions under applicable laws.


  1. Grounds for Processing


We collect and use Candidate Data under the following legal bases:


  • Where necessary to perform an employment or other contract with you or at your request prior to entering a contract;


  • Where necessary for our compliance with employment law or other legal obligations;


  • Where applicable, with your consent; and/or


  • As necessary to carry out the application and recruitment process, protect the security of our systems and candidates, detect or prevent fraud, enable candidates to comply with legal obligations, or fulfill our other legitimate interests as described above, except where our interests are overridden by your privacy rights.


Where we rely on your consent to process Candidate Data, you have the right to withdraw your consent at any time without affecting the lawfulness of processing based on consent before its withdrawal, and where we rely on legitimate interests, you may have the right to object to that processing.


  1. Changes to this Policy


We will update this Policy from time to time. We will post the revised Policy with an updated revision date on our corporate site and link it to it from our jobs site and recruitment platform. If we make any material changes, we will provide notice through these sites or by other means.


  1. Contact


The controller of your Candidate Data is Uney GmbH, while our Database is operated by Smart Artificial Intelligence L.L.C and your personal data is thus shared with this entity located on Floor 3, H Office Tower, Dubai, UAE. The transfer is subject to appropriate additional safeguards, including the Standard Contractual Clauses, as issued by the European Commission.


If you have any questions, comments, complaints, or requests regarding this Policy or our processing of your information, please contact: Uney GmbH, Grafenaustrasse 13, 6300 Zug, Switzerland - [email protected].