Privacy Policy
Job Candidates, Clients, Suppliers, Employees, Consultants & Website Users
This Privacy Notice explains how Riverflex Trading International Limited, Riverflex Trading NL B.V., and Riverflex Trading UK Limited (together, "Riverflex", "we", "us", or "our") collect, use, store, and protect personal data. We process personal data in accordance with the General Data Protection Regulation (GDPR), as implemented in the Netherlands under the Uitvoeringswet Algemene verordening gegevenssbescherming (UAVG).
This Privacy Notice covers:
Riverflex is an international consulting group. We provide:
Who this Privacy Notice applies to:
If you join Riverflex as an employee or contractor, you'll receive a separate Employee / Contractor Privacy Notice with more detail on how we handle your data during your engagement.
We collect personal data about:
Riverflex Trading International Limited, Riverflex Trading NL B.V., and Riverflex Trading UK Limited act as joint data controllers for the personal data described in this notice. All three entities share responsibility for how your data is collected, used, and protected and that your data may be accessible across the Riverflex group as part of our shared systems and operations.
For any privacy or data protection questions, contact us at: privacy@riverflex.com
Depending on your relationship with us, we may collect and process the following categories of personal data.
5.1 Job candidates, freelancers & network members
Identification and contact details
Professional and application information
Verification and compliance data
Financial and contractual data (network members engaged or previously engaged with Riverflex)
Note: This data is retained for 7 years after the end of an engagement for tax and legal compliance purposes (see Section 12).
Communication, assessment & process data
5.2 Clients and prospective clients
5.3 Suppliers and partners
5.4 Employees, consultants & temporary workers
Additional HR-related personal data is handled under a separate Employee / Contractor Privacy Notice, provided during onboarding.
5.5 Website & platform users
When you visit our websites or platforms, we may collect:
Information you provide
Technical and usage data
We use cookies on our website. See Section 15 for full details.
How we collect your data
6.1 Directly from you
You provide data when you:
6.2 From our websites & recruitment platform
When you use our websites, ATS, or recruitment platforms, we may collect data through:
6.3 From other sources
We may also collect data from:
Sourcing from Public Professional Profiles
We may identify candidates through professional networking sites (e.g., LinkedIn via Recruiter System Connect) and contact them about relevant opportunities.
When you respond positively to our outreach, we export your profile to our Applicant Tracking System (Recruitee) on the same day and notify you within 30 days.
We only use publicly available career information (job titles, skills, experience, education), target relevant roles, and rely on legitimate interests as our legal basis.
You can opt out or request deletion at any time. All requests are acknowledged within 10 business days and completed within 1 month, in line with GDPR Article 12. We will notify you if an extension is required.
7.1 Diversity & equal opportunities data
Where voluntarily provided, diversity data is:
7.2 Background checks
Background checks (including criminal record checks, identity verification, and reference checks) are only carried out where there is a clear and legitimate reason to do so. This is typically limited to:
Where a background check is carried out, we will:
We only process personal data where we have a lawful basis to do so.
8.1 Candidates, freelancers & network members
We use your data for:
Legal bases
8.2 Clients & prospective clients
We use your data for service delivery, account management, billing, and communications.
Legal bases
8.3 Suppliers & partners
We use your data for onboarding, management, billing, and compliance.
8.4 Marketing
We only send marketing communications where you've given consent or where legitimate interests apply. You can opt out at any time.
We use AI-enabled tools to support parts of our recruitment and talent processes. This section explains how those tools interact with your personal data.
9.1 What we use AI tools for
We may use AI-enabled tools to:
9.2 Legal basis
Our use of AI tools in recruitment is based on legitimate interests, specifically, improving the consistency, efficiency, and fairness of our hiring process, and, where required, consent.
9.3 Automated decision-making
We do not make solely automated decisions that have legal or similarly significant effects on candidates. A human recruiter reviews all AI-generated outputs before any decision is made or communicated. You have the right to request human review of any decision under Article 22 of UK/EU GDPR.
9.4 Safeguards
For more on Riverflex's broader approach to AI in hiring, including our commitments on fairness, transparency, and candidate rights, see our AI Hiring Manifesto below.
We may share your data with:
10.1 Data processors & third-party-service providers
Riverflex works with carefully selected third-party service providers who act as data processors. They process personal data only on our instructions and cannot use it for their own purposes.
We use third-party processors to assist in delivering our services. For a complete list of our authorized sub-processors, please view our Sub-processor List.
All processors are bound by GDPR-compliant Data Processing Agreements (DPAs) requiring them to process data only on Riverflex's behalf, implement appropriate technical and organizational security measures, and assist Riverflex in meeting its data protection obligations.
Riverflex remains the Data Controller in all cases.
10.2 Legal & regulatory authorities
We may share data with regulators or authorities where required by law.
10.3 Business transactions
In the event of a merger, acquisition, or similar transaction, appropriate safeguards will always apply.
Where data is transferred outside the UK/EEA, we apply:
Riverflex operates an ISO 27001-certified Information Security Management System (ISMS), covering:
13.1 Candidate & network members
Candidates for permanent roles at Riverflex or with our clients are those whose data is:
The 3-year retention period applies to all candidates regardless of how far they progressed in the recruitment process.
Last meaningful contact means:
13.2 Contractors & temporary workers
Data is kept for 7 years after assignment ends.
13.3 Clients & suppliers
Data is kept for 7 years after the relationship ends.
13.4 Archiving & pseudonymization
Where appropriate, we archive or pseudonymize data to meet legal and compliance requirements.
Depending on your country of residence, you have rights under UK GDPR and the Data Protection Act 2018 (if you are based in the UK), or EU GDPR (if you are based in the EEA). These include the rights to:
To exercise any of these rights, contact us at privacy@riverflex.com.
We use cookies on our website to make it work properly and to understand how it's being used. Here's what we use them for:
Cookies we use
Third-party cookies
Some of our service providers also set cookies. In particular:
Managing your cookies
You can control or delete cookies at any time through your browser settings. Most browsers allow you to block or delete cookies via their privacy or security preferences. Note that disabling cookies may affect how parts of our website function.
Note: blocking all cookies may affect how some parts of our website work.
At Riverflex, we use automation and artificial intelligence responsibly - to support a fair, inclusive, efficient, and human-centred hiring experience. AI and automation are there to support our people, not replace them. Every hiring decision is ultimately made by our recruiters and hiring managers, who are fully accountable throughout.
We use AI tools to streamline our workflows (for example, taking interview notes, generating structured summaries, reviewing CVs and candidate profiles, and supporting recruitment documentation), improve consistency, and reduce admin - while keeping human judgment, context, and empathy at the heart of how we assess people. We use AI assistance to summarize interview notes. All summaries are reviewed by human recruiters and final decisions are made by people, not AI.
Our use of AI in hirings:
AI outputs are used to inform decisions, never to make them. At Riverflex, technology serves people, not the other way around.
For more detail on how we handle your data, see our Privacy Notice above.