Riverflex

Privacy Policy

Riverflex Group Privacy Notice

Job Candidates, Clients, Suppliers, Employees, Consultants & Website Users

1. Summary

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).

2. Purpose of this Notice

This Privacy Notice covers:

  • What personal data we collect
  • How and why we use it
  • Our legal bases for processing
  • Who we share it withs
  • How long we keep it
  • Legal rights in relation to personal data

3. Who we are & who this applies to

Riverflex is an international consulting group. We provide:

  • Managed consultancy and advisory services
  • Talent and recruitment services (permanent, interim, embedded recruitment, freelance, and executive search)
  • Community and open-talent services, including the Riverflex Platform and professional network

Who this Privacy Notice applies to:

  • Job candidates (permanent, interim, freelance, consulting, and network/community members)
  • Clients and prospective clients
  • Suppliers and partners
  • Employees, consultants, and temporary workers receive a separate Employee / Contractor Privacy Notice on onboarding, which covers how we handle their data during their engagement with Riverflex
  • Users of our websites, Applicant Tracking System (ATS), and platforms (including the Riverflex Platform)

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:

  • Candidates and network members
  • Client contacts (prospective and existing)
  • Supplier and partner contacts
  • Employees and consultants
  • Website and platform users

4. Data controlled & contact details

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

5. Personal data we collect

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

  • Name, title, address, email address(es), phone number(s)
  • Links to professional profiles (e.g. LinkedIn, corporate website)

Professional and application information

  • CV/resume, cover letters, portfolios and qualifications
  • Expected salary / day rates, notice period, location preferences


Verification and compliance data

  • Right-to-work documentation (passport, ID card, visa, work permit)
  • Nationality/citizenship or place of birth (where required by law or client requirements)
  • References and referee contact details
  • Background check results (where lawful and required)

Financial and contractual data (network members engaged or previously engaged with Riverflex)

  • Bank or payment details
  • Tax identifiers (e.g. BSN, NI number)
  • Contract terms, assignment details, timesheets, invoices

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

  • Email correspondence, call notes, interview feedback
  • Interview notes, structured summaries, or transcripts generated with the support of AI-enabled tools
  • Recruitment process metadata (e.g. application stage, status changes, timestamps)
  • Participation in talent pools, Riverflex Platform, or community events
  • Consent preferences and records

5.2 Clients and prospective clients

  • Names, roles, business contact details
  • Organisation information
  • Meeting notes, correspondence
  • Contracts, proposals, SoWs, pricing and engagement details
  • Feedback on services, candidates, and consultants

5.3 Suppliers and partners

  • Contact details of supplier representatives
  • Contract, compliance, and invoicing information
  • Communications related to service delivery

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

  • Contact forms, newsletter subscriptions
  • Event registrations, account sign-ups


Technical and usage data

  • IP address, browser type, device information
  • Pages visited, time spent, referring URLs


6. Cookies

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:

  • Apply for roles or register as a candidate or consultant
  • Upload CVs or profiles
  • Get in touch with us
  • Register for events, platforms, or marketing
  • Enter into contracts or negotiations

6.2 From our websites & recruitment platform

When you use our websites, ATS, or recruitment platforms, we may collect data through:

  • Application forms and profiles
  • Interview scheduling and communications
  • Recruitment workflow tools that use automation or AI to structure information, capture notes, or trigger administrative actions

6.3 From other sources

We may also collect data from:

  • Professional networking sites (e.g. LinkedIn)
  • Job boards and CV databases
  • Referrals and introductions
  • Events and business cards
  • Group companies and recruitment partners
  • Background screening and verification providers


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. Special categories of data & criminal records

7.1 Diversity & equal opportunities data

Where voluntarily provided, diversity data is:

  • Optional
  • Only used to support equal opportunities and inclusion reporting, not for any other purpose
  • Processed with appropriate safeguards and consent where required

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:

  • Roles that involve working with vulnerable people or regulated activities
  • Specific client requirements where the client has their own legal or regulatory obligations
  • Situations where right-to-work verification is legally required

Where a background check is carried out, we will:

  • Tell you in advance what type of check is being conducted and why
  • Only use accredited and compliant screening providers
  • Obtain your explicit consent, except where we are legally required to conduct the check without it
  • Retain results only for as long as necessary and in line with our retention schedule

8. Why we use your personal data & legal bases

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:

  • Assessing your suitability for roles
  • Introducing candidates to clients
  • Managing contracts, payments, and compliance
  • Improving the fairness, consistency, and quality of our hiring

Legal bases

  • Legitimate interests (such as evaluating suitability for a role, conducting background/reference checks, and maintaining a talent pool for future vacancies)
  • Contract / pre-contractual steps
  • Legal obligations
  • Consent (where applicable)

8.2 Clients & prospective clients

We use your data for service delivery, account management, billing, and communications.

Legal bases

  • Legitimate interests (delivering contracted services, managing the client relationship, onboarding and offboarding clients)
  • Contractual necessity
  • Legal obligations

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.

9. Our use of AI & automation tools

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:

  • Transcribe or produce structured summaries of interviews
  • Review and organise CV and candidate profile information
  • Support note-taking during the recruitment process
  • Trigger administrative workflow actions

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

  • AI tools process personal data only on Riverflex's instructions, under GDPR-compliant Data Processing Agreements
  • Outputs are always reviewed by a human before use
  • We take steps to monitor for and mitigate bias in AI-assisted processes

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.


10. Sharing your personal data

We may share your data with:

  • Riverflex group companies
  • Clients (with candidate consent)
  • Data processors & third-party-service providers

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.

11. Internal data transfers

Where data is transferred outside the UK/EEA, we apply:

  • Adequacy decisions, or
  • Standard Contractual Clauses (SCCs), or
  • Transfer Impact Assessments (TIAs) where required

12. How we store & protect your data

Riverflex operates an ISO 27001-certified Information Security Management System (ISMS), covering:

  • Access controls
  • Encryption and monitoring
  • Supplier security reviews
  • Incident response

13. How long we store & protect your data

13.1 Candidate & network members

Candidates for permanent roles at Riverflex or with our clients are those whose data is:

  • Kept for 3 years (1,095 days) after last meaningful contact
  • Subject to consent renewal 30 days before expiry
  • Automatically deleted if no renewal response is received
  • Available for deletion on request, actioned within 1 month


The 3-year retention period applies to all candidates regardless of how far they progressed in the recruitment process. 

Last meaningful contact means:

  • Application submitted, interview attended, or direct communication from the candidate
  • This does not include: recruiter profile views, automated emails, or system-generated notifications

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.

14. Your rights 

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:

  • Access a copy of your personal data
  • Correct inaccurate data or incomplete data
  • Request erasure of your data (the ‘right to be forgotten’)
  • Restrict or object how we process your data
  • Request human review of any automated decision
  • Withdraw consent at any time, without affecting the lawfulness of prior processing


To exercise any of these rights, contact us at privacy@riverflex.com.

15. Cookies

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

  • Authentication: to identify you when you visit and as you navigate our site
  • Status: to determine whether you're logged in
  • Analysis: to understand usage and performance of our website and services (via Google Analytics and Hotjar)
  • Cookie consent: to store your cookie preferences


Third-party cookies

Some of our service providers also set cookies. In particular:

  • Google Analytics : used to analyse website use. Google's privacy policy is available at policies.google.com/privacy
  • Hotjar: used to analyse website usage and improve user experience


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.

16. Contact

📧 privacy@riverflex.com

Riverflex AI Hiring Manifesto

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:

  • Complies fully with GDPR and applicable data protection regulations, including data minimization, purpose limitation, and security principles
  • Is guided by a strong commitment to fairness, inclusion, and bias reduction. Our recruiters are supported in recognizing and mitigating bias, and AI outputs are used to inform decisions - never to make them.
  • Is transparent to candidates. We let candidates know when AI or automation is used at any stage of the hiring process and explain what it's for.
  • Respects candidate rights and choice. Candidates can ask questions about how we use AI at any stage of the process

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.