Privacy Policy
How ATRO Recruitment collects, uses and protects personal data — of the people who visit this site, the companies who contact us, and the candidates we work with.
Last updated: 22 August 2026 · Version 1.0
1. Who is responsible for your data
The controller of the personal data described in this policy is:
Anastasiia Trotska, trading as ATRO Recruitment (Ukraine)
Email: anastasiia@atrorecruitment.com
Phone: +38 067 485 77 11 · Telegram: @anastasiia_atro
“Controller” means we decide why and how your personal data is processed. We do not have a statutory Data Protection Officer; privacy questions are handled personally by Anastasiia Trotska using the contact details above.
2. What this policy covers
This policy applies to atrorecruitment.com and to the recruitment services delivered through it. It covers three groups of people:
- Visitors — anyone who opens this website.
- Clients and prospective clients — companies and their representatives who send us an enquiry or engage us for a search.
- Candidates — professionals whose details we receive, review or present in the course of a search.
We process personal data in line with the EU General Data Protection Regulation (GDPR) where it applies, and with the Law of Ukraine “On Personal Data Protection”.
3. What we collect, and why
3.1 Website visitors
The site itself asks for nothing. If — and only if — you accept analytics cookies, Google Analytics 4 records anonymised, aggregated usage data: pages viewed, time on page, approximate region derived from a truncated IP address, device and browser type, and the source that referred you. This tells us which parts of the site are useful. It is never used to identify you, and we run no advertising or cross-site tracking.
If you decline, no analytics cookies are set and no measurement data leaves your browser. Technical server logs kept by our hosting provider (IP address, timestamp, requested file) exist for security and are outside the scope of consent.
3.2 Enquiries from companies
When you submit the contact form or write to us, we receive the details you choose to give: name, company, email, phone, the role you are hiring for, and anything in your message. We use them to answer you, to prepare a proposal, and — if we work together — to run the assignment.
3.3 Candidates
In the course of a search we collect and process: name and contact details; CV and career history; education and qualifications; salary expectations; notes from our conversations and assessment; references, where you have agreed to them; and, where relevant to a role, the right to work in a given country.
Candidate data reaches us in three ways — you send it to us directly, a mutual contact refers you, or we find your professional profile in public sources such as LinkedIn or a company website. If we contacted you first, we will say where we found you the first time we write.
We share a candidate profile with a client only after we have told the candidate which company it is and they have agreed. We do not sell, publish or exchange candidate data.
Please do not send us special category data — health, religious or political views, trade-union membership, ethnic origin, sexual orientation, biometric or genetic data. We do not need it and do not ask for it. Photographs, dates of birth and marital status are equally unnecessary; please leave them out of your CV. If such data reaches us unsolicited, we delete it.
4. Legal basis for each purpose
Under the GDPR we must have a lawful basis for every processing activity. Ours are:
| Purpose | Legal basis |
|---|---|
| Analytics cookies and measurement | Your consent — Art. 6(1)(a). Withdrawable at any time. |
| Answering an enquiry, preparing a proposal | Steps taken at your request before a contract — Art. 6(1)(b). |
| Delivering a search for a client | Performance of a contract — Art. 6(1)(b). |
| Assessing and presenting a candidate | Steps prior to an employment contract — Art. 6(1)(b) — and our legitimate interest in operating a recruitment practice — Art. 6(1)(f). |
| Keeping a candidate on file for future roles | Your consent — Art. 6(1)(a). |
| Sourcing a professional profile from public sources | Our legitimate interest in matching people to roles — Art. 6(1)(f). You may object at any time. |
| Accounting, tax and record-keeping | Legal obligation — Art. 6(1)(c). |
| Site security and abuse prevention | Our legitimate interest in keeping the service available — Art. 6(1)(f). |
Where we rely on legitimate interest, we have weighed it against your rights and freedoms, and we will stop if you object and we have no overriding ground to continue.
5. Cookies and similar technologies
We use as little as the site can function on. Nothing that requires consent is set before you give it: Google Consent Mode v2 holds all analytics and advertising storage in a denied state from the first byte of the page.
| Name | Type · Purpose | Duration |
|---|---|---|
atro.consent | Essential · Browser local storage. Remembers your cookie choice so we do not ask again. | 12 months |
_ga | Analytics · Google Analytics. Distinguishes one visitor from another. Set only after you accept. | 24 months |
_ga_6M4HHT5TFC | Analytics · Google Analytics. Maintains session state. Set only after you accept. | 24 months |
You can change your mind at any time: select Cookies in the footer of any page to reopen the choice. Declining removes our consent record and stops further measurement; you can also clear cookies and site data through your browser settings.
6. Who else sees your data
We are a small practice and we keep the list of recipients short. Personal data is disclosed only to:
- Clients — a candidate profile is shared with the hiring company, and only with the candidate's prior agreement.
- Google Ireland Limited — Google Analytics 4, as our processor, if you have accepted analytics cookies.
- Hostinger International Ltd. — hosting of this website, of our mailbox, and of the script that receives the contact form. Enquiries and server logs are stored on their infrastructure.
- Telegram FZ-LLC — a copy of each enquiry is delivered to our private team chat so that we can respond quickly. Only what you typed into the form is sent; the chat is closed and visible to us alone.
- Professional advisers — accountants and, if ever needed, legal counsel, bound by confidentiality.
- Public authorities — where disclosure is required by law.
Each processor acts on our documented instructions under a data processing agreement. We never sell personal data and we do not share it for advertising.
7. International transfers
ATRO Recruitment operates from Ukraine, and our clients and candidates are located across Europe and beyond. Personal data may therefore be transferred outside the European Economic Area, including to Ukraine, to Lithuania and Cyprus (our hosting provider), and to the United Arab Emirates (Telegram).
Where that happens, the transfer is protected by the European Commission's Standard Contractual Clauses together with supplementary technical measures, or by another mechanism permitted under Chapter V of the GDPR. You may request a copy of the safeguards that apply to a particular transfer using the contact details in section 1.
8. How long we keep it
| Data | Retention |
|---|---|
| Analytics events in Google Analytics | 2 months (property default), then automatically deleted |
| Enquiries that do not lead to work | 12 months from the last message |
| Client records and correspondence | 3 years after the end of the engagement |
| Candidate file during an active search | Until the search closes, then as below |
| Candidate file held for future roles | 24 months from our last contact — we ask again before extending |
| Accounting and tax records | As required by Ukrainian law |
| Server logs | Up to 12 months |
When a period ends, data is deleted or irreversibly anonymised. A candidate can ask to be removed sooner at any point, and we act on it.
9. Your rights
Wherever the GDPR applies to you, you have the right to:
- Access — obtain a copy of the personal data we hold about you.
- Rectification — have inaccurate or incomplete data corrected.
- Erasure — have your data deleted where we have no overriding reason to keep it.
- Restriction — have processing paused while a dispute is resolved.
- Portability — receive the data you gave us in a structured, machine-readable format.
- Object — to processing based on legitimate interest, including being sourced from public profiles.
- Withdraw consent — at any time, without affecting what was lawful before the withdrawal.
- Complain — to a supervisory authority.
Write to anastasiia@atrorecruitment.com and we will respond within one month. There is no charge; we may ask for proof of identity before releasing data, so that we do not disclose it to the wrong person.
If you believe we have handled your data badly, please tell us first — we would rather fix it. You are equally entitled to go straight to a regulator: in the EU, the data protection authority of the country where you live or work; in Ukraine, the Ukrainian Parliament Commissioner for Human Rights (Уповноважений Верховної Ради України з прав людини).
10. How we protect it
The site is served over HTTPS. Access to candidate and client files is limited to Anastasiia Trotska and, where a search requires it, to a named collaborator under a confidentiality agreement. Accounts are protected by strong, unique passwords and two-factor authentication; devices are encrypted. We collect the minimum we need and delete on schedule.
No system is absolutely secure. If a breach ever puts your rights and freedoms at risk, we will notify the competent supervisory authority within 72 hours and inform you without undue delay.
11. Automated decisions and children
We make no decisions about you by automated means, and we do not profile you. Every shortlist is the judgement of a person.
This site and our services are intended for professional adults. We do not knowingly collect data about anyone under 18. If you believe we hold such data, tell us and we will delete it.
12. Changes to this policy
If our processing changes, we update this page and move the version and date at the top. Material changes affecting consent will be raised with you again through the cookie banner or by email, as appropriate. Earlier versions are available on request.
13. Contact
Any question about this policy, or any request concerning your data:
Anastasiia Trotska — ATRO Recruitment
anastasiia@atrorecruitment.com
+38 067 485 77 11 · @anastasiia_atro