Privacy Policy

Last updated: September 2026

1. About this Privacy Policy

Rubino Rekrytering AB (”Rubino”, ”we”, ”us”) provides recruitment and executive search services.

This Privacy Policy describes how we process personal data as part of our business activities and when you come into contact with us.

This Policy applies, among other things, when you:

contact us via our website, email or telephone,
are a client, prospective client, supplier, business partner or other business contact,
receive information or marketing from us,
apply for a position through us,
register with Rubino Connect,
are identified by us as a potential candidate through search,
are recommended or referred to us,
provide a reference for a candidate, or
otherwise participate in or come into contact with a recruitment process that we conduct.

When you use our candidate services, you may also receive information about the processing of personal data in connection with our recruitment system.

Rubino Rekrytering AB, company registration number 556641-9098, is the data controller for the processing described in this Policy.

Information about how we use cookies and similar technologies on rubino.se can be found in our separate Cookie Policy.

2. Clients, Prospective Clients and Other Business Contacts

What Personal Data Do We Process?

When you contact us, for example through a form on rubino.se, by email or by telephone, we may process information such as:

name,
job title and employer,
email address and telephone number,
information that you provide in your enquiry,
communications and information arising in connection with our contact, and
other relevant information necessary to manage an existing or potential business relationship.

We may also process corresponding professional contact details relating to existing and prospective clients, suppliers, business partners and other business contacts that we obtain from, for example, company websites, professional networks or other publicly available professional sources.

Why Do We Process the Data and What Is Our Legal Basis?

We process personal data relating to clients, prospective clients and other business contacts in order to:

respond to and follow up on enquiries,
communicate about ongoing and potential assignments,
administer and develop our client and business relationships,
follow up on previous contacts and enquiries,
provide information about and market our services,
send relevant information and newsletters, and
conduct and develop Rubino’s business.

The processing is based on legitimate interests in that it is necessary to take steps prior to or perform a contract, or to conduct and develop our business, maintain professional business relationships and market our services.

Direct Marketing

Contact details relating to existing and prospective clients and other professional contacts may be used for relevant B2B marketing and newsletters. You can unsubscribe from such communications at any time by using the unsubscribe link in the communication or by contacting us.

You always have the right to object to the processing of your personal data for direct marketing purposes. If you do so, we will no longer use your personal data for this purpose.

3. Candidates and Potential Candidates

What Personal Data Do We Process?

The data we process depends on how you come into contact with us and whether you participate in a recruitment process.

We may, for example, process:

contact details, such as name, email address, telephone number and place of residence,
application and professional information, such as CV, education, work experience, skills, language skills, positions held and other professional qualifications,
information from the recruitment process, such as interview responses, our professional assessments and notes, as well as results from tests and other assessment tools,
reference information, such as information provided by referees about your experience, performance and other circumstances relevant to the recruitment in question,
communications between you and Rubino,
publicly available professional information, for example information from LinkedIn, company websites and other professional sources, and
technical data generated when you use our digital services.

We only process personal data that is relevant and necessary for the purpose in question. We ask you not to provide sensitive personal data or data relating to criminal offences unless we have expressly requested it and there is a legal basis for the processing.

Where Do We Obtain Candidates’ Personal Data?

Personal data may come:

directly from you, for example through an application, CV, interview or other contact with us,
from you when you register with Rubino Connect,
from publicly available professional sources, such as LinkedIn and company websites,
from people who recommend or refer you to us,
from referees whom you have named or approved for us to contact, and
from information generated as part of a recruitment process, such as interviews, tests and professional assessments.

As part of our executive search activities, we also identify and map potential candidates based on publicly available professional information within the scope of specific recruitment assignments.

If we contact you after identifying you through search or receiving your information from someone else, we will inform you about our processing of personal data and provide you with access to this Privacy Policy in accordance with applicable data protection rules.

Why Do We Process Candidates’ Personal Data?

We process personal data in order to:

receive and administer applications,
conduct recruitment processes,
assess candidates’ experience, skills and suitability for current positions,
identify and map potential candidates within the scope of specific recruitment assignments,
contact relevant individuals about current opportunities,
communicate with candidates,
conduct interviews, tests, assessments, reference checks and, where relevant to the position in question, background checks,
present relevant candidates to our clients,
administer Rubino Connect and, where you have chosen this, contact you about relevant future job opportunities,
administer and develop our recruitment services and the systems and tools used in our business, and
comply with legal obligations and establish, exercise or defend legal claims.

What Is Our Legal Basis for Processing Candidate Data?

Recruitment Processes

When you apply for a position or participate in a recruitment process, we process your personal data on the basis of legitimate interests. Our legitimate interest is to be able to carry out recruitment assignments and assess candidates for current positions, as well as to contact you in connection with a recruitment process.

When you submit an application, you confirm that you have read the information about how we process your personal data. This confirmation does not constitute consent for us to retain your data for future recruitment processes.

Search and Referred Candidates

As a recruitment and executive search company, we identify and map individuals whom we believe may be relevant to specific recruitment assignments.

When we identify a potential candidate, we normally contact the person to provide information about the position in question and determine whether there is interest in continuing the dialogue. If the person is interested, we may then ask for, for example, a CV or other relevant information and, where appropriate, add the person to the specific recruitment process in our recruitment system.

When we process publicly available professional information for this purpose, we do so on the basis of our legitimate interest in collecting and processing information about potential candidates and contacting you in connection with a recruitment process. This interest outweighs the interest in the information not being used for these purposes. The same may apply when someone recommends or refers a potential candidate to us.

We limit the processing to information that is relevant to the professional context and the specific recruitment assignment.

Rubino Connect and Future Job Opportunities

If you register with Rubino Connect or choose to allow us to retain your information for relevant future job opportunities, this processing is based on your consent.

Providing consent is voluntary and does not affect your ability to apply for or participate in a current recruitment process.

You may withdraw your consent at any time.

Tests in the Recruitment Process

In some recruitment processes, we use occupational psychological tests, such as personality and ability tests, as supplementary assessment material for final-stage candidates. In connection with these tests, we may process personal data such as your name and contact details, as well as the test results generated by the tests.

The purpose is to supplement other information in the recruitment process and contribute to a structured and quality-assured basis for decision-making. Test results constitute only one part of the overall assessment and are not used as the sole basis for decisions in the recruitment process.

The processing is based on our legitimate interest in conducting a structured and quality-assured recruitment process. Inklistrad text

Legal Obligations

In certain cases, we process personal data in order to comply with a legal obligation, for example where certain information must be retained under accounting rules.

4. Who May Have Access to Candidates’ Personal Data?

Our Clients

Within the scope of a specific recruitment assignment, limited professional information about potential candidates may be used in discussions with the client to whom the assignment relates.

When you are being considered as a candidate in a recruitment process, relevant parts of your candidate material may be shared with the client.

We limit the information to what is relevant to the specific recruitment assignment. Our clients may be located in Sweden or in other countries.

Depending on the circumstances, the client may be an independent data controller for the processing that takes place after the client has received personal data.

Service Providers and Digital Tools

We use external service providers and digital tools to support our recruitment work, for example for:

managing candidate data,
tests and assessments,
recording and transcription of interviews,
communication and administration, and
AI-based processing, structuring and summarisation of candidate material.

When service providers process personal data on our behalf, we take appropriate contractual, technical and organisational measures to ensure that personal data is processed securely and lawfully and only for relevant purposes.

We may also disclose personal data to public authorities or other recipients where required by law.

5. Referees

It is the candidate’s own responsibility to inform you, as a referee, that your contact details are being provided to us.

When you provide a reference for a candidate, we may process personal data about you such as:

name,
contact details,
job title and employer,
your professional relationship with the candidate, and
information about when and how the reference was provided.

We process this information in order to conduct and document reference checks as part of our recruitment assignments.

The processing is normally based on our and our client’s legitimate interest in being able to conduct and quality-assure recruitment processes. The balancing of interests is based on the fact that the interest in being able to assist candidates in their career development outweighs the interest in not processing the personal data.

Information you provide about the candidate is processed as part of the candidate’s recruitment process.

6. Suppliers and Business Partners

We may process names, contact details, job titles, employers and other relevant professional information relating to contact persons at suppliers and business partners.

The processing takes place in order to administer and develop our business relationships, communicate, manage contracts and services, and conduct our business.

Depending on the circumstances, the processing is based on a contract or our legitimate interest in administering and developing our professional business relationships.

7. Transfers of Personal Data to Other Countries

In connection with our business activities, personal data may be processed in other countries, for example when we work with international clients or use external service providers and digital tools.

Where processing takes place within the EU/EEA, EU data protection rules apply.

If personal data is transferred to a country outside the EU/EEA, we ensure that there is a valid basis for the transfer and appropriate safeguards in accordance with the GDPR, for example an adequacy decision by the European Commission or the European Commission’s Standard Contractual Clauses.

8. How Long Do We Retain Personal Data?

General

We do not retain personal data for longer than is necessary for the purposes described in this Privacy Policy.

Clients, Prospective Clients and Business Contacts

Information provided through contact forms, email or other contact is retained for as long as necessary to manage and follow up on the contact.

If the contact leads to or is relevant to a client relationship, potential business relationship or other ongoing professional contact, relevant information may continue to be processed for as long as necessary for these purposes.

Personal data relating to clients, prospective clients and other business contacts may be retained for as long as the business relationship continues and thereafter for as long as the information remains relevant to our legitimate business purposes.

If you object to direct marketing, we will no longer use your personal data for this purpose. We may need to retain limited information about your objection to ensure that you do not receive further marketing.

Candidates

A candidate profile is retained for as long as it is needed for an ongoing recruitment process, or for as long as you:

are registered with Rubino Connect, or
have valid consent for us to retain your information for relevant future job opportunities.

When a recruitment process is completed and archived, the current recruitment process ceases to constitute a purpose for continued retention. If you have not consented to remain as a future candidate in our Rubino Connect candidate network, our automatic deletion process is activated and the candidate profile is deleted or anonymised without undue delay in accordance with our retention and deletion procedures.

Information about potential candidates processed as part of search and mapping activities is not retained for longer than necessary for the specific recruitment assignment.

Personal data processed in external tools, for example for tests, interview recordings, transcription or AI-based support, is not retained for longer than necessary for the relevant purpose and is deleted in accordance with our procedures.

Rubino Connect and Future Job Opportunities

If you register with Rubino Connect or otherwise consent to us retaining your information for future job opportunities, your consent is valid for 24 months.

When this period expires, we will ask you to actively renew your consent if you wish to remain part of our candidate network. If you renew your consent, a new 24-month period begins.

Consent is not renewed automatically and you may withdraw it at any time. If your consent expires or is withdrawn and there is no other current purpose for the processing, the candidate profile will be deleted as described above.

Information That Needs to Be Retained for Longer

Certain limited personal data may need to be retained for longer in order for us to comply with legal obligations or to establish, exercise or defend legal claims.

For example, the name of a candidate who has been employed through a recruitment assignment may appear in our accounting records and be retained in accordance with applicable accounting rules. Such information is not used for continued recruitment purposes.

When personal data is no longer required for any of the purposes applicable to the processing, it is deleted or anonymised.

9. How Do We Protect Personal Data?

We take appropriate technical and organisational security measures to protect personal data against unauthorised access, loss, alteration or other unlawful processing.

Access to personal data is restricted to individuals and service providers who need the information for their work or in order to provide relevant services to us.

10. AI and Automated Decision-Making

We may use AI-based tools to support our recruitment work, for example to structure information, summarise CVs, interviews and other candidate material, and make administrative parts of the recruitment process more efficient.

AI is used as a support tool for our recruitment consultants. We do not use AI to automatically make decisions about candidates, screen out candidates or determine who proceeds in a recruitment process. Assessments and decisions in our recruitment processes are always made by humans.

We do not use solely automated decision-making that produces legal effects or similarly significantly affects candidates. Inklistrad text

11. Your Rights

Depending on the circumstances, under the GDPR you have the right to:

receive information about how we process your personal data,
request access to the personal data we process about you,
request correction of inaccurate or incomplete information,
request deletion of your personal data,
request restriction of processing,
object to processing based on legitimate interests,
object at any time to processing for direct marketing purposes,
receive certain personal data in a structured, commonly used and machine-readable format where the right to data portability applies, and
where processing is based on consent, withdraw your consent at any time.

If you withdraw your consent, this does not affect the lawfulness of processing carried out before the consent was withdrawn.

You also have the right to lodge a complaint with the Swedish Authority for Privacy Protection (Integritetsskyddsmyndigheten, IMY) if you believe that our processing of your personal data is contrary to applicable data protection rules.

12. Contact and Data Protection Questions

Rubino Rekrytering AB is the data controller for the processing covered by this Privacy Policy.

Hanne Rubino is the contact person for data protection and privacy matters at Rubino Rekrytering AB.

Rubino Rekrytering AB
Company registration number: 556641-9098
Email: [email protected]
Telephone: +46 (0)8-411 60 80

You may contact us if you have questions about how we process your personal data or if you wish to exercise any of your rights under the GDPR.

To protect your personal data, we may need to verify your identity before providing information or fulfilling certain requests.

13. Changes to this Privacy Policy

We may update this Privacy Policy when our working methods, services or legal requirements change.

The current version is always available via rubino.se and our candidate services. The date of the latest update is stated at the top of this Policy.