Data Protection · Human Power

1. Introduction and Scope

This Privacy and Personal Data Protection Notice (“Privacy Notice”) describes how Human Power LLC (“HumanPower”, “we”, “us”, or “our”), in its capacity as the data controller, collects, uses, stores, discloses, and otherwise processes personal data in the course of its business activities.

HumanPower is committed to ensuring that personal data is processed lawfully, fairly, and transparently, in full compliance with applicable data protection legislation, including the Law on Personal Data Protection of the Republic of Kosovo and relevant international data protection standards.

The purpose of this Privacy Notice is to provide clear and comprehensive information to data subjects regarding:

the categories of personal data processed by HumanPower,
the purposes and legal bases of such processing,
the rights available to data subjects in relation to their personal data, and
the measures implemented to ensure the security and confidentiality of personal data.

This Privacy Notice applies to all individuals whose personal data is processed by HumanPower, including but not limited to:

job candidates and potential candidates,
clients and business partners,
website visitors and users of HumanPower’s digital platforms,
individuals who communicate with HumanPower through electronic or other means.

This Privacy Notice covers personal data processed in any form, whether electronic, written, or otherwise recorded, and applies to processing activities carried out directly by HumanPower or through authorized data processors acting on its behalf.

By accessing HumanPower’s website, using its services, submitting personal data, or otherwise engaging with HumanPower, data subjects acknowledge that they have been informed of and understand the principles and practices described in this Privacy Notice.

2. Data Controller

For the purposes of applicable data protection legislation, Human Power LLC acts as the data controller, meaning that it determines the purposes and means of the processing of personal data. The identification and contact details of the data controller are as follows:

Human Power LLC Registered Address: Qytezja Pejton, Rruga Perandori Justinian, No. 62, Prishtina, Republic of Kosovo Business Registration Number: 71243567 Unique Identification Number: 810857948 Tax Number: 601581061 Email: info@humanpower.info Website: www.humanpower.net

Human Power LLC is legally responsible for ensuring that personal data is processed in accordance with applicable data protection laws and this Privacy Notice. This includes implementing appropriate technical and organizational measures to safeguard personal data against unauthorized access, loss, alteration, or disclosure.

Human Power LLC has designated a Data Protection Officer (DPO) to oversee compliance with personal data protection obligations and to serve as the primary contact point for data protection matters.

Data Protection Officer: Name: Arion Rizaj Email: arion@humanpower.net

Where personal data is processed on behalf of Human Power LLC by third parties, such processing is carried out only by authorized data processors acting under documented instructions and subject to appropriate contractual safeguards, ensuring compliance with applicable data protection requirements.

3. What Personal Data Do We Process?

Human Power LLC processes personal data strictly to the extent necessary for the performance of its business activities, primarily in the field of human resources, recruitment, and related digital services. The categories of personal data processed depend on the nature of the interaction with HumanPower and may include the following:

3.1 Identification and Contact Data

This category includes basic personal information provided by data subjects, such as:

first and last name;
email address.

3.2 Professional and Recruitment-Related Data

In the context of recruitment and talent management services, HumanPower may process:

curriculum vitae (CV);
information on education and professional qualifications;
work experience and employment history;
professional skills and competencies;
information voluntarily provided during the recruitment process.

3.3 Communication Data

HumanPower may process data related to communications with candidates or clients, including:

written correspondence via email or other electronic communication channels;
voice recordings, where applicable, collected as part of specific recruitment processes.

Voice recordings are not used as a standard recruitment tool and are applied only for selected positions and specific recruitment workflows. Where voice recordings are used, data subjects are informed in advance, and such recordings are processed solely for recruitment-related purposes.

3.4 Technical and Usage Data

When individuals visit HumanPower’s website or interact with its digital platforms, certain technical data may be automatically collected, such as:

IP address;
browser type and device information;
usage data related to website interaction.

This data is used primarily to ensure the technical functionality, security, and improvement of HumanPower’s digital services.

3.5 Data Not Processed

HumanPower does not collect or process the following categories of personal data in the ordinary course of its activities:

identity documents, including identity cards or passports;
financial or credit-related data;
special categories of personal data, unless explicitly required by law and subject to additional safeguards.

HumanPower ensures that personal data processed is adequate, relevant, and limited to what is necessary in relation to the purposes for which it is processed.

4. How Do We Collect Personal Data?

Human Power LLC collects personal data through lawful and transparent means, depending on the nature of the interaction between the data subject and HumanPower. Personal data may be collected directly from data subjects or indirectly through authorized channels, as outlined below.

4.1 Data Provided Directly by Data Subjects

HumanPower collects personal data directly when individuals:

submit their CV or professional information for recruitment purposes;
communicate with HumanPower via email or other electronic means;
participate in recruitment processes or interviews;
interact with HumanPower in the context of business or professional engagement.

4.2 Data Collected Through Digital Platforms

Personal data may be collected when data subjects:

visit or use HumanPower’s website;
interact with online forms or digital tools provided by HumanPower;
communicate through digital recruitment platforms or systems used by HumanPower.

In such cases, certain technical or usage data may be collected automatically to ensure the functionality, security, and performance of HumanPower’s digital services.

4.3 Data Collected Through Authorized Third Parties

In limited cases, HumanPower may receive personal data from authorized third parties, such as:

recruitment partners or intermediaries;
clients providing candidate information for recruitment purposes;
service providers acting on behalf of HumanPower, in accordance with applicable data protection laws.

In all such cases, HumanPower ensures that personal data is obtained lawfully and that appropriate safeguards are in place.

4.4 Voluntary Nature of Data Provision

The provision of personal data to HumanPower is generally voluntary. However, failure to provide certain personal data may limit HumanPower’s ability to offer recruitment or related services or to participate in specific recruitment processes.

5. For What Purposes Do We Process Personal Data?

Human Power LLC processes personal data solely for specific, explicit, and legitimate purposes, in accordance with applicable data protection legislation. Personal data is processed only to the extent necessary to achieve the purposes outlined below.

5.1 Recruitment and Talent Matching

Personal data is processed for the purpose of identifying, assessing, and matching candidates with employment opportunities, including:

managing recruitment and selection processes;
reviewing applications and professional profiles;
presenting suitable candidates to clients or potential employers;
communicating with candidates regarding recruitment opportunities.

5.2 Communication and Relationship Management

HumanPower processes personal data to:

communicate with candidates, clients, and business partners;
respond to inquiries and requests;
coordinate recruitment-related activities and processes.

5.3 Management of Recruitment Processes

Personal data may be processed to:

organize interviews and assessments;
manage recruitment workflows and internal records;
document recruitment-related communications and decisions.

5.4 Legal and Regulatory Compliance

HumanPower may process personal data where necessary to:

comply with applicable legal and regulatory obligations;
respond to lawful requests from public authorities;
establish, exercise, or defend legal claims.

5.5 Service Improvement and Internal Analytics

HumanPower may process personal data, where appropriate, to:

improve the quality and efficiency of its services;
analyze recruitment processes and operational performance;
enhance digital platforms and user experience.

Such processing is conducted using aggregated or anonymized data wherever possible and does not involve automated decision-making with legal or similarly significant effects on data subjects.

6. What is the Legal Basis for Processing Personal Data?

Human Power LLC processes personal data only where there is a valid legal basis, in accordance with applicable data protection legislation. Depending on the specific context and purpose of processing, personal data may be processed on one or more of the following legal bases:

6.1 Consent of the Data Subject

HumanPower processes personal data based on the free, informed, and explicit consent of the data subject, particularly in the context of recruitment and talent management. By submitting personal data, including a CV or professional information, data subjects consent to the processing of such data for the purposes described in this Privacy Notice.

Data subjects have the right to withdraw their consent at any time. Withdrawal of consent does not affect the lawfulness of processing carried out prior to such withdrawal.

6.2 Performance of a Contract or Pre-Contractual Measures

Personal data may be processed where it is necessary for the performance of a contract to which the data subject is a party or in order to take steps at the request of the data subject prior to entering into a contract, including participation in recruitment processes.

6.3 Compliance with Legal Obligations

HumanPower may process personal data where such processing is necessary to comply with legal obligations to which it is subject under applicable laws and regulations.

6.4 Legitimate Interests

In limited cases, HumanPower may process personal data where such processing is necessary for the purposes of its legitimate interests, provided that such interests are not overridden by the rights and freedoms of the data subject. Legitimate interests may include the operation, security, and improvement of recruitment services.

HumanPower ensures that any processing based on legitimate interests is proportionate, transparent, and subject to appropriate safeguards.

7. Voice Recordings and AI-Supported Recruitment

Human Power LLC may, in limited and clearly defined cases, use voice recordings and AI-supported tools as part of specific recruitment processes.

7.1 Use of Voice Recordings

Voice recordings may be collected exclusively in connection with selected recruitment processes and for specific job positions where such an assessment method is considered relevant. Voice recordings are not used as a standard or mandatory recruitment tool.

Data subjects are informed in advance when voice recordings are used, including the purpose and scope of such recordings. Voice recordings are processed solely for recruitment-related purposes and are not used for marketing, profiling, or any unrelated activities.

7.2 AI-Supported Recruitment Tools

HumanPower may use AI-supported tools to assist in organizing, filtering, or managing recruitment processes. Such tools are used to support human decision-making and do not replace human judgment. HumanPower does not apply fully automated decision-making processes that produce legal effects or similarly significant consequences for data subjects. Final recruitment decisions are always subject to human review and assessment.

7.3 Safeguards and Transparency

Appropriate technical and organizational safeguards are implemented to ensure that voice recordings and AI-supported processes are used in a lawful, transparent, and proportionate manner. Where consent is required, personal data related to voice recordings or AI-supported assessments is processed only after the data subject has provided explicit consent and may be withdrawn at any time.

8. Where and for How Long Do We Store Personal Data?

Human Power LLC stores and retains personal data only for as long as it is necessary to fulfill the purposes for which the data was collected and processed, in accordance with applicable data protection legislation and internal data retention principles.

8.1 Data Storage Location

Personal data processed by HumanPower is stored on secure servers operated by authorized third-party service providers. As a general rule, personal data is hosted on servers located within the European Union, ensuring an adequate level of data protection consistent with applicable legal standards.

HumanPower takes reasonable steps to ensure that all hosting and infrastructure providers implement appropriate technical and organizational measures to protect personal data against unauthorized access, loss, alteration, or disclosure.

8.2 Retention Periods

Personal data is retained based on the following criteria:

for as long as the recruitment process is ongoing or the data subject remains active in HumanPower’s recruitment database;
until the data subject requests deletion of their personal data or withdraws consent;
for longer periods only where retention is required by applicable law or necessary for the establishment, exercise, or defense of legal claims.

Voice recordings and other assessment-related data are retained only for the duration strictly necessary to complete the relevant recruitment process, unless a longer retention period is required by law or explicitly agreed with the data subject.

8.3 Deletion and Anonymization

Once the applicable retention period expires, personal data is securely deleted, anonymized, or otherwise rendered inaccessible, unless further retention is legally required. HumanPower ensures that data deletion and anonymization processes are carried out in a manner that prevents unauthorized recovery or use of personal data.

9. Do We Transfer Personal Data Outside Our Primary Place of Operations?

Human Power LLC may transfer personal data outside its primary place of operations where such transfer is necessary for the technical operation of its services and in accordance with applicable data protection laws. Personal data is primarily processed and stored on servers located within the European Union, where an adequate level of personal data protection is ensured. Any cross-border transfer of personal data is conducted only to entities that implement appropriate technical and organizational safeguards to protect personal data.

Where personal data is transferred to third parties acting on behalf of HumanPower, such transfers are governed by contractual arrangements that ensure:

personal data is processed solely in accordance with HumanPower’s documented instructions;
confidentiality and security obligations are maintained;
personal data is not used for purposes other than those described in this Privacy Notice.

HumanPower does not transfer personal data for external marketing or unrelated commercial purposes without a valid legal basis or the explicit consent of the data subject.

Human Power LLC shares personal data only where necessary for the performance of its services and strictly in accordance with applicable data protection requirements.

10.1 Clients and Business Partners

In the context of recruitment and talent placement services, personal data may be shared with HumanPower’s clients or business partners for the sole purpose of evaluating candidates for employment opportunities. Such sharing is limited to relevant recruitment-related information and takes place only within the scope of the recruitment process.

10.2 Authorized Data Processors

HumanPower may share personal data with authorized third-party service providers that act as data processors on its behalf, including:

hosting and infrastructure providers;
IT and technical support providers;
providers of recruitment-related digital tools.

These data processors are contractually bound to process personal data only in accordance with HumanPower’s instructions and to implement appropriate technical and organizational security measures.

10.3 Legal and Regulatory Authorities

Personal data may be disclosed where required by law or in response to lawful requests from competent public authorities, courts, or regulatory bodies.

10.4 No Unauthorized Disclosure

HumanPower does not sell, rent, or otherwise disclose personal data to third parties for marketing or unrelated commercial purposes.

11. How Do We Protect Personal Data?

Human Power LLC implements appropriate technical and organizational measures to ensure a level of security appropriate to the risk associated with the processing of personal data.

Such measures are designed to protect personal data against unauthorized or unlawful access, loss, alteration, disclosure, or destruction and are continuously reviewed to reflect technological developments and operational requirements.

Security measures implemented by HumanPower include, among others:

access controls limiting personal data access to authorized personnel only;
technical safeguards to protect systems and digital infrastructure;
organizational policies governing the handling and confidentiality of personal data;
contractual confidentiality and data protection obligations imposed on authorized data processors.

HumanPower adopts a risk-based approach to personal data protection and ensures that personal data is processed in a manner that preserves its integrity and confidentiality.

While HumanPower takes reasonable steps to protect personal data, no system can guarantee absolute security. Accordingly, data subjects acknowledge that the transmission and processing of personal data inherently involves certain risks.

12. Limitation of Liability

Human Power LLC takes reasonable and appropriate measures to protect personal data in accordance with applicable data protection laws and this Privacy Notice. However, data subjects acknowledge that no system, technology, or security measure can guarantee absolute protection against all risks.

To the maximum extent permitted by applicable law, HumanPower shall not be held liable for:

indirect, incidental, consequential, or special damages arising from the processing of personal data;
loss of data, loss of business opportunities, or reputational damage resulting from unauthorized access, cyberattacks, or technical failures beyond HumanPower’s reasonable control;
actions or omissions of third parties, including clients or authorized data processors, who process personal data independently or in violation of applicable obligations;
damages arising from the use of digital platforms, electronic communications, or recruitment tools, where HumanPower has implemented reasonable security measures.

HumanPower shall not be responsible for the misuse of personal data by clients or third parties who receive such data in the context of recruitment processes and act as independent data controllers.

13. What Rights Do Data Subjects Have?

Human Power LLC respects and ensures the exercise of all rights granted to data subjects under applicable data protection legislation. Data subjects may exercise the following rights in relation to their personal data:

13.1 Right to Information

Data subjects have the right to be informed about the collection and processing of their personal data in a clear, transparent, and understandable manner.

13.2 Right of Access

Data subjects have the right to request confirmation as to whether their personal data is being processed and, where applicable, to obtain access to such data.

13.3 Right to Rectification

Data subjects have the right to request the correction of inaccurate or incomplete personal data without undue delay.

13.4 Right to Erasure

Data subjects have the right to request the deletion of their personal data where:

the data is no longer necessary for the purposes for which it was collected;
consent has been withdrawn and there is no other legal basis for processing;
the data has been unlawfully processed.

This right may be limited where retention of the data is required by law or necessary for the establishment, exercise, or defense of legal claims.

13.5 Right to Restriction of Processing

Data subjects have the right to request the restriction of processing of their personal data in certain circumstances, including where the accuracy of the data is contested or the processing is unlawful.

13.6 Right to Object

Data subjects have the right to object to the processing of their personal data where such processing is based on legitimate interests, unless HumanPower demonstrates compelling legitimate grounds that override the interests, rights, and freedoms of the data subject.

13.7 Right to Withdraw Consent

Where processing is based on consent, data subjects have the right to withdraw their consent at any time. Withdrawal of consent does not affect the lawfulness of processing carried out prior to the withdrawal.

13.8 Right to Lodge a Complaint

Data subjects have the right to lodge a complaint with the competent supervisory authority if they believe that their personal data has been processed in violation of applicable data protection laws.

To exercise any of the rights described above, data subjects are required to submit a request to Human Power LLC’s Data Protection Officer using the contact details provided in this Privacy Notice. Requests will be reviewed and handled in accordance with applicable data protection laws and within the legally prescribed timeframes.

Human Power LLC may request additional information where necessary to verify the identity of the data subject submitting the request, in order to ensure the security and confidentiality of personal data.

14. Cookies and Website Technologies

Human Power LLC uses cookies and similar technologies on its website to ensure proper functionality, improve user experience, and analyze the performance of its digital services.

14.1 What Are Cookies?

Cookies are small text files stored on a user’s device when visiting a website. They help the website recognize the user’s device and store certain information related to website usage.

14.2 Types of Cookies Used

HumanPower may use the following categories of cookies:

Strictly necessary cookies, which are essential for the basic operation and security of the website;
Performance and analytics cookies, which help understand how visitors interact with the website and allow HumanPower to improve its services;
Preference cookies, which store user settings and preferences to enhance the user experience.

HumanPower does not use cookies for external marketing purposes without obtaining the user’s prior consent, where such consent is required.

14.3 Managing Cookies

Users may manage or disable cookies through their browser settings. Please note that disabling certain cookies may affect the functionality or availability of some features of the website.

15. Contact Details and Complaints

For any questions, requests, or concerns related to the processing of personal data, data subjects may contact Human Power LLC using the contact details below: Human Power LLC Address: Qytezja Pejton, Rruga Perandori Justinian, No. 62, Prishtina Email: info@humanpower.info Website: www.humanpower.net

Requests relating to the exercise of data subject rights should be addressed to the Data Protection Officer, using the contact details specified in this Privacy Notice.

Human Power LLC is committed to handling all data protection requests and complaints in a timely, transparent, and lawful manner. Where a data subject believes that their personal data has been processed in violation of applicable data protection laws, they have the right to lodge a complaint with the competent supervisory authority.

16. Updates and Entry into Force

Human Power LLC reserves the right to update or amend this Privacy Notice from time to time in order to reflect changes in applicable laws, regulatory requirements, technological developments, or business practices. Any updates to this Privacy Notice will be published on HumanPower’s official website and will become effective as of the date of publication, unless stated otherwise.

Continued use of HumanPower’s services or continued interaction with HumanPower after the publication of an updated Privacy Notice shall be deemed as acknowledgment of, and agreement with, the revised terms. This Privacy Notice enters into force on the date of its publication and replaces any previous privacy or data protection notices issued by Human Power LLC.

Data Protection Policy