Skip to main content

Legal

Privacy Policy

Last updated: 13 November 2026Version 0.1-draft

This document is a draft and is being finalised.

In short

  • AEONIC TALENT is a recruitment and HR consulting company based in Podgorica, Montenegro. We use personal data to help candidates find work, to help employers find people, and to answer the messages we receive.
  • We ask for your consent before we handle a job application or keep your CV, and you can withdraw it at any time.
  • We send your CV to a client employer only after we have told you who the employer is and you have agreed.
  • Our services are free of charge for candidates.
  • This website does not use cookies, analytics or tracking for visitors. See our Cookie Policy.
  • To ask a question or to use your rights, write to info@aeonictalent.me.

1. Who we are

The controller of your personal data is Društvo sa ograničenom odgovornošću "AEONIC TALENT" - Podgorica (in this policy "Aeonic Talent DOO", "AEONIC TALENT", "we" or "us").

  • Registered seat: Petra Sinanovića Nagiba 4, 81000 Podgorica
  • Registration number in the Central Register of Business Entities of Montenegro (CRPS): 5-0138986/001
  • Tax identification number (PIB): 04429907
  • General enquiries: info@aeonictalent.me
  • Privacy questions and requests: info@aeonictalent.me

[TO BE CONFIRMED: whether a data protection officer has been appointed and, if so, their contact details]

[TO BE CONFIRMED: whether a representative in the European Union is required and, if so, their name and contact details]

2. What this policy covers

This policy explains how we handle personal data when you:

  • visit this website (https://www.aeonictalent.me);
  • apply for a vacancy or send us your CV;
  • send us an employer enquiry or a contact message;
  • are contacted by us about a role.

It applies to candidates, to people who contact us on behalf of an employer, and to visitors to the website.

We handle personal data in line with the Law on Personal Data Protection of Montenegro. A new Law on Personal Data Protection (Official Gazette of Montenegro, no. 133/26) applies from 19 March 2027. We will update this policy where the new law requires it.

[TO BE CONFIRMED by legal counsel: whether the General Data Protection Regulation of the European Union also applies to our services]

3. The data we collect

When you apply for a vacancy

  • Your first name, last name, e-mail address and phone number.
  • Your CV, as a PDF or DOCX file.
  • If you choose to add them: a link to your LinkedIn profile and a cover letter.
  • The vacancy you applied for, the date and time of your application and the language of the form you used.
  • The consents you gave: the exact wording you agreed to, the version of this policy that applied, and the date and time.

When you send us your CV without applying for a specific vacancy

  • Your first name, last name, e-mail address and phone number.
  • Your CV, as a PDF or DOCX file.
  • The area of work you are interested in.
  • If you choose to add them: a link to your LinkedIn profile and a message.
  • The date and time, the language of the form you used and the consents you gave, recorded in the same way as for an application.

During a recruitment process

  • Notes from our conversations and interviews with you.
  • Our assessment of how well your experience matches a role, and the stage and outcome of your application.
  • References, but only from referees whose details you have given us.
  • A record of each time we pass your details to an employer: the employer, the country, the role, the date and how you agreed.

When you send an employer enquiry

Your name, company and work e-mail address and, if you choose to add them, your phone number, the role you are hiring for and your message.

When you send a contact message

Your name, e-mail address and message.

When you visit the website

The public website sets no cookies, stores nothing in your browser and uses no analytics or tracking. We do not build a profile of your visit.

Like every website, ours receives your IP address and basic technical details of each request, such as the type of browser, so that pages can be delivered. To protect our forms against abuse we keep temporary counters of form submissions. The counters are linked to the IP address and, for applications and CVs, also to the e-mail address that was used.

[TO BE CONFIRMED: whether the hosting provider keeps server logs that contain IP addresses and, if so, for how long]

Data our forms do not ask for

Our forms do not ask for a photograph, your date of birth, national identification number (JMBG), nationality, marital or family status, or your current or previous pay. Please do not include these details in your CV or messages. Please also leave out information about your health, religion, ethnic origin, political views, trade union membership or criminal record. If your CV contains such information, we do not take it into account.

Data from other sources

If we approach you about a role ourselves, we may have found your professional details in public sources, such as professional networking sites, or received them from someone who recommended you. When we first contact you, we tell you where we obtained your details and point you to this policy.

4. Why we use your data, and on what basis

  • To handle your application for a vacancy. We assess your suitability for the role and manage the recruitment process. We do this on the basis of your consent, which you give on the application form for that specific vacancy.
  • To keep your profile for future roles. If you agree, we keep your CV and details in our talent database so that we can consider you for other positions and contact you about them. This is a separate consent. It is optional when you apply for a vacancy, and it is the purpose of the form for sending us your CV.
  • To introduce you to an employer. We send your CV or profile to a client employer only after we have told you who the employer is and where it is based, and you have agreed.
  • To answer enquiries and messages. We use the details in an employer enquiry or a contact message only to reply to it and to take the steps you ask for.
  • To keep the website and our records secure. We limit repeated form submissions and keep a log of staff sign-ins, of downloads of CVs and of changes to candidate records.
  • To meet our legal obligations and to deal with legal claims. For example, we keep a record of the consents you gave for as long as we keep the data they are about, and a record of each disclosure of your data to an employer (see section 8).

We do not sell personal data and we do not use it for advertising.

[TO BE CONFIRMED by legal counsel: the legal basis for each purpose under the law in force, including any reliance on legitimate interest from 19 March 2027]

5. Your consent and how to withdraw it

  • The consent boxes on our forms are never ticked in advance. Consent for a vacancy and consent for the talent database are separate.
  • We record each consent with its exact wording, the version of this policy that applied, and the date and time.
  • After you apply or send us your CV, we send you an e-mail that confirms receipt, gives you a reference number and lists the consents you gave and the version of this policy.
  • You can withdraw a consent at any time by writing to info@aeonictalent.me. You do not need to give a reason.
  • If you withdraw your consent for a vacancy, your application for that vacancy ends. If you withdraw your consent for the talent database, we remove your profile from it. An application that is in progress is not affected.
  • Withdrawing consent does not affect what we did on the basis of your consent before you withdrew it.

6. Who receives your data

  • Our staff. Only members of staff who need candidate data for their work can see it. Each has a personal account. Staff who only edit website content have no access to candidate data.
  • Client employers. Only with your agreement for that employer, as described in section 4. We keep a record of every disclosure.
  • Service providers. Companies that host the website, the database and the stored files, and that deliver our e-mail, handle data on our behalf and under our instructions. [TO BE CONFIRMED: hosting provider and location; database and file storage provider and location; e-mail delivery provider and location]
  • Public authorities. Where the law requires us to disclose data.

[TO BE CONFIRMED: whether candidate data is shared with any related company and, if so, with which company and on what basis]

7. Transfers outside Montenegro

Client employers may be based outside Montenegro. We send your data to an employer in another country only after you have agreed to that employer and that country.

[TO BE CONFIRMED: the countries in which our service providers store or access personal data, the legal mechanism for each transfer, and how to obtain a copy of the safeguards]

8. How long we keep your data

Each record is given a deletion date when we receive it. When that date has passed, the record and the files that belong to it are deleted or anonymised. Each record keeps the period that was in force when we received it, even if we change that period later. The record of the consents you gave is deleted together with the rest of your data.

  • Applications for a vacancy: 6 months after the advertised closing date of the vacancy or, if no closing date was advertised, after the date of your application.
  • Talent database, including CVs sent without a specific vacancy: 24 months from the date you last gave your consent. If we change this period later, the period that applied when you gave your consent still applies to you. Before the period ends we may ask whether you would like to stay in the database. If you do not give a new consent, your profile and CV are deleted.
  • Employer enquiries: 24 months from the date we receive them.
  • Contact messages: 12 months from the date we receive them.
  • Record of disclosures to employers: 120 months from each time we pass your details to an employer. The record holds your name and e-mail address, the employer and its country, the role, the date and how you agreed. It is kept for this period also after the rest of your data has been deleted or made anonymous, because we must be able to show who received your data.

If you applied for a vacancy and also agreed to join the talent database, your profile is kept for the talent database period.

We may keep data for longer where we need it to establish, exercise or defend a legal claim, or where the law requires us to keep it. If you are placed with an employer through us, we keep the records we need for our agreement with that employer and for our accounting obligations.

[TO BE CONFIRMED by legal counsel: the period for the record of disclosures to employers; how long records of consent are kept after the rest of your data is deleted; whether a minimal record of an application is kept as evidence in case of a legal claim, and for how long; how long placement records, accounting records and backups are kept]

9. Your rights

You can ask us to:

  • Access: confirm whether we hold data about you and give you a copy of it.
  • Rectification: correct data that is wrong and complete data that is incomplete. If you ask, we correct your name, your phone number and the link to your LinkedIn profile. The record of what we sent to an employer keeps your details as they were sent.
  • Erasure: delete your data. What we keep for statistics or as evidence, such as the outcome of an application and the record of your consents, no longer contains anything that identifies you. One record is the exception: the record of disclosures to employers (see section 8) keeps your name and e-mail address, the employer, its country, the role, the date and how you agreed, for 120 months from each disclosure. An application whose details we passed to an employer is deleted in full.
  • Restriction: limit the use of your data while a question about it is being resolved. We mark your data so that it is not deleted in the meantime, and a member of our staff handles your request by hand.
  • Portability: give you the data you provided to us in a commonly used electronic format.
  • Objection: consider your objection to a particular use of your data.
  • Withdrawal of consent: stop any use of your data that is based on your consent, as described in section 5.

To use any of these rights, write to info@aeonictalent.me. We may ask you for information that confirms your identity, so that we do not give your data to someone else. Using your rights is free of charge. We reply as soon as we can, and no later than 15 days after we receive your request.

10. Automated decisions

We do not make decisions about you by automated means and we do not profile you. Every application is read and assessed by a member of our staff.

11. How we protect your data

  • The website is served over an encrypted connection (HTTPS).
  • CVs are kept in private storage that cannot be reached from the public internet. Only signed-in members of staff with the right permissions can open them.
  • Staff sign in with personal accounts, which can be protected with a second sign-in step. They are signed out automatically after a period of inactivity.
  • Staff sign-ins, downloads of CVs and changes to candidate records are logged.
  • The forms accept CVs only as PDF or DOCX files, and the type of each file is checked when it is uploaded.

No system is completely secure. If a personal data breach puts you at risk, we will inform you and the supervisory authority as the law requires.

12. Children

Our services are intended for adults. Our application forms ask you to confirm that you are at least 18 years old. If you believe that someone under 18 has sent us personal data, please write to us and we will delete it.

13. Complaints

If you are unhappy with how we have handled your data, please write to us first at info@aeonictalent.me so that we can put it right.

You also have the right to complain to the supervisory authority of Montenegro:

  • Agency for Personal Data Protection and Free Access to Information (Agencija za zaštitu ličnih podataka i slobodan pristup informacijama, AZLP)
  • Address: Bulevar Revolucije 11, Podgorica, Montenegro
  • E-mail: azlp@azlp.me
  • Website: www.azlp.me

You can also ask a court to protect your rights.

14. Changes to this policy

We update this policy when the way we handle data changes or when the law changes. The date of the latest version is shown at the top of this page. Every consent we record is linked to the version that applied when it was given. If a change significantly affects how we use data that you have already given us, we will tell you and, where the law requires it, ask for your consent again.