1. General information
This notice explains how YCO SAM and the Y.CO Group handle your personal data when you apply through our online recruitment platform (Personio). YCO SAM acts as lead data controller for all group recruitment. The Y.CO Group comprises YCO SAM (Monaco), YCO 3 LLP (United Kingdom), YCO Inc. (United States), and YCO NZ Ltd (New Zealand), all ultimately controlled by YCO 2 SAM.

Our recruitment process involves multiple rounds with HR (YCO SAM), line managers and the Managing Director (who may be employed by any group entity), and the co-founders (YCO SAM). Your data is therefore shared within the group on a need-to-know basis as described in Section 3.

2. The Data Controller
The controller under data protection law is:
YCO SAM (Société Anonyme Monégasque)
17 Avenue Albert II, L'Albu, 98000 Monaco
Phone: +377 93 50 12 12
Data Protection Officer: DPO@Y.CO

3. Group-Wide Recruitment — How Your Data Is Shared

Round	Who is involved	Y.CO entity
Round 1 — HR interview	HR team	YCO SAM (Monaco)
Round 2 — Line manager	Line manager	YCO SAM / YCO 3 LLP / YCO Inc. / YCO NZ Ltd (depends on role)
Round 3 — Managing Director	MD	YCO SAM or local entity
Round 4 — Co-founders	Co-founders	YCO SAM (Monaco)

Your data is shared within the Y.CO Group only on a need-to-know basis with the relevant interviewers at each stage. It is not shared outside the group during the recruitment process. All group entities handling your data are bound by the Y.CO Group Intra-Group Data Sharing Agreement.

4. Personal Data Collected

4.1 Application form data

Name, email address, telephone number
LinkedIn profile URL (optional)
How you found the vacancy
Location / position applied for

4.2 Documents you upload

Cover letter, CV, certificates, references — may contain date of birth, address, qualifications, employment history.

4.3 Data generated during the process

Interview notes, assessment records, and internal communications created by Y.CO staff involved in your application.

4.4 Special category data

We do not request special category data as part of the application process. If any is included in your documents, it will be treated with enhanced protection and accessed only by authorised HR staff.

5. Why We Process Your Data

Purpose	Legal basis
Assessing your application and conducting interviews	Pre-contractual steps — Law 1.565 Art. 5 / GDPR Art. 6(1)(b) / UK GDPR Art. 6(1)(b) / NZ Privacy Act Principle 1
Communicating with you about your application	Pre-contractual steps / Legitimate interest
Sharing your data within the Y.CO Group with relevant interviewers	Legitimate interest in conducting group recruitment — Law 1.565 Art. 5 / GDPR Art. 6(1)(f)
Legal compliance (right-to-work checks etc.)	Legal obligation — Law 1.565 Art. 5 / GDPR Art. 6(1)(c)
Talent pool — future vacancies (consent only)	Consent — Law 1.565 Art. 5 / GDPR Art. 6(1)(a) — see Section 7
Successful application: transition to employee HR file	Contract performance / Legal obligation

6. Our Recruitment Platform and Data Storage

We use Personio SE & Co. KG (Munich, Germany) as our recruitment platform. All application data is stored on Personio's EU-based servers (Frankfurt) using TLS encryption. Data remains within the EU at all times.

Personio acts as our data processor under Article 26 of Law No. 1.565 / Article 28 GDPR. A Data Processing Addendum governs how Personio handles your data on our behalf.

Intra-group data access during recruitment

Your data is stored in Personio's EU servers regardless of which country the position is based in.

During recruitment, your data may be accessed by Y.CO staff in Monaco, UK, USA and New Zealand as part of the multi-round process.

Access by YCO Inc. (USA) staff is governed by the Y.CO Group Intra-Group Data Sharing Agreement as the contractual transfer safeguard.

No data is shared outside the Y.CO Group during recruitment.

7. Retention Periods

7.1 Unsuccessful applications

Personal data is retained for 24 months from the end of the recruitment process, then permanently deleted or anonymised. Anonymised data may be retained for statistical analysis only.

7.2 Successful applications

Your application data is transferred to your employee HR file and retained for the duration of employment and applicable statutory retention periods. A separate Employee Privacy Notice will be provided at onboarding.

8. Your Data Protection Rights

Right	What it means	Applicable framework
Information	To be informed — this notice serves that purpose	All
Access	Copy of your personal data	All
Rectification	Correction of inaccurate data	All
Erasure	Deletion where no longer necessary or consent withdrawn	Law 1.565 / GDPR / UK GDPR
Restriction	Limit processing in certain circumstances	Law 1.565 / GDPR / UK GDPR
Portability	Data in portable format (consent/contract processing)	Law 1.565 / GDPR / UK GDPR
Object	Object to legitimate interest processing	Law 1.565 / GDPR / UK GDPR
Withdraw consent	At any time without affecting prior processing	All

To exercise any right: contact the DPO at DPO@Y.CO. Response within one month.

9. Supervisory Authorities

Position applied for / your residence	Supervisory authority	Contact
Monaco positions / Monaco residents	APDP (Autorité de Protection des Données Personnelles)	apdp.mc
UK positions / UK residents	ICO (Information Commissioner's Office)	ico.org.uk
New Zealand positions / NZ residents	OPC (Office of the Privacy Commissioner)	privacy.org.nz
US positions / US residents	Relevant state AG (e.g. California AG for CA residents under CPRA)	Varies by state
EU/EEA residents	Local EU supervisory authority	ec.europa.eu/justice/data-protection/bodies/authorities

10. Updates to This Notice

YCO SAM may update this notice to reflect changes in law, the recruitment process, or the group structure. The current version is always available on our recruitment platform. Material changes will be communicated to active applicants by email

Head of Client Management

We are looking forward to hearing from you!

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