Privacy policy - Avant Advisors

PRIVACY POLICY FOR JOB APPLICANTS / CANDIDATES & CLIENT / POTENTIAL CLIENT CONTACT PERSONS

Effective on April 8, 2026

This Privacy Policy sets out the terms of personal data processing relating to job applicants and candidates and to representatives and other contact persons of Avant’s clients and potential clients according to the EU’s General Data Protection Regulation (GDPR), as well as the Finnish Data Protection Act and the Act on the Protection of Privacy in Working Life.

Avant’s Responsible AI Commitment is included at the end of this document for convenience, but it is separate from this Privacy Policy.

Content

1. Controller of the filing system

2. Definitions

3. For what purposes do we process your data and on what grounds?

4. What types of information may we collect about you?

5. From which sources do we gather your personal data?

6. To whom may we transfer and assign your personal data?

7. Is your data transferred to countries outside the European Union?

8. How long do we process your data?

9. What are our principles for securing your personal data?

10. How can you exercise the different types of rights you have?

10.1 Right of access to your personal data.

10.2 Right to rectification.

10.3 Right to erasure ('right to be forgotten').

10.4 Right to restriction of processing.

10.5 Right to object.

10.6 Right to data portability.

11. Do we make decisions affecting you based on automated means?

12. Do we process your personal data in order to profile you?

13. How can you exercise your right to lodge a complaint with the supervisory authority?

14. Which law do we apply for processing personal data?

15. How can we update this Privacy Policy?

Separate document included: Avant Responsible AI Commitment

1. Controller of the filing system

The controller of this filing system is the Finnish company Avant Advisors Ltd (business registration number: 3183730-5), hereinafter referred to as ”Avant”.

Avant’s contact details for related privacy matters are:

Avant Advisors Ltd / privacy

Pohjoinen Rautatiekatu 15, 00100 Helsinki

Tel: +358 40 587 1429

Please do not hesitate to contact us if you have any questions, concerns or ideas related to Avant’s personal data procedures.

2. Definitions

In the following the most essential terms used in this privacy policy are explained:

'Applicant' means any person who has sent a specific or general job application to any of the positions promoted by Avant on behalf of its corporate clients or on behalf of Avant itself, and any person who is a candidate for such position based on Avant’s suggestion.
'Client / Potential Client Contact Person' means a representative, employee, consultant, beneficial owner or other contact person of an actual or prospective corporate client of Avant, or any other natural person who contacts Avant or is contacted by Avant in relation to Avant’s services.
'Personal data' means any information relating to an identified or identifiable natural person ('data subject'); an identifiable natural person is one who can be identified, directly or indirectly.
'Consent' of the data subject means any freely given, specific, informed and unambiguous indication of the data subject's wishes by which he or she, by a statement or by a clear affirmative action, signifies agreement to the processing of personal data relating to him or her.
'Profiling' means any form of automated processing of personal data consisting of the use of personal data to evaluate certain personal aspects relating to a natural person, in particular to analyse or predict aspects concerning that natural person's performance at work, economic situation, health, personal preferences, interests, reliability, behaviour, location or movements.
'AI Tool' or 'Artificial Intelligence Tool' means any software or system that uses machine learning, natural language processing, or other automated techniques to analyse, process, or generate information, used by Avant solely as a supportive tool to assist human executive search and recruitment professionals.

3. For what purposes do we process your data and on what grounds?

When you visit Avant’s websites, we process data about your browser, operating system, IP address, location and related technical data in order to ensure the functionality of the website, the safety of the connection and a good user experience.

For applicants and candidates, Avant may process your personal data where this is directly necessary for recruitment processes, candidate research, assessments, possible employment relationships and related communications. This includes processing relating to managing the rights and obligations of the parties, providing benefits that may be offered by Avant or its corporate client, and requirements arising from the special nature of the work concerned.

For client and potential client contact persons, Avant may process your personal data in order to communicate about Avant’s services, respond to inquiries and requests, prepare proposals, manage and perform client assignments and contracts, maintain the client relationship, arrange meetings and events, and develop its business relationships.

Avant may also process your personal data for communication and marketing purposes, for example to inform you of possible new job openings, relevant services and to invite you to Avant’s and/or its corporate clients’ events, where permitted by applicable law.

Avant may also process your personal data where this is necessary for security purposes, to comply with legal obligations, and for the establishment, exercise or defence of legal claims.

Processing of your personal data is based on the following grounds under the EU’s General Data Protection Regulation (one or more grounds may apply simultaneously):

Processing is necessary in order to take steps at your request prior to entering into a contract or to enter into and perform a contract.
Processing is necessary for the purposes of the legitimate interests pursued by Avant and, where relevant, its corporate clients.
You have given consent to the processing of your personal data.
Processing is necessary for compliance with a legal obligation to which Avant is subject.

The legitimate interests of Avant or a third party referred to above may include amongst others the following matters:

maintaining a candidate pool for possible new recruitment needs
business development
managing and developing client and business relationships, including communicating about services, preparing proposals and performing assignments
contractual base with our corporate clients
direct marketing and professional networking to the extent permitted by law
network and information security, fraud prevention and the establishment, exercise or defence of legal claims

In addition to the above, Avant may use your data where this is necessary for security purposes or for investigating possible fraud or other suspected violations of our agreements or this Privacy Policy.

4. What types of information may we collect about you?

The content of Avant’s filing system may include the following types of data, as well as records of updates or changes to such data:

Personal information

last name, all first names, previous last name
home or work address, e-mail address and other contact details
phone number(s)
date of birth
national identification code
gender
nationality
photo and video clips
languages
medical and drug test data (where applicable)
use of your rights related to your personal data (such as the right to access your personal data)

2. Employment-related information for applicants and candidates

work history and interests in the future
education, trainings and certificates you have completed
knowledge, skills and expertise (e.g. language and ICT skills)
cover letter and CV
salary and benefit data and requests
examples of previous work or presentations
personality and aptitude and competence assessment results (e.g. via recruitment consultants)
other information during recruitment interviews and reference checking
credit rating (where applicable)
extract from criminal records (where applicable)
work permit (where applicable)
information obtained from publicly available sources, including professional networking platforms such as LinkedIn, where you have made such information publicly accessible
AI-generated support information (such as extracted skills or keyword matches) used only to assist human recruiters

3. Client and potential client contact information

employer, title, role and other professional identification details
work contact details and preferred methods of communication
information relating to inquiries, proposals, assignments, services purchased or discussed, contracts and invoicing where relevant to the individual contact persons
records of meetings, calls, e-mail correspondence, event participation and other communications with Avant
information concerning your professional interests, service needs and marketing or event preferences
publicly available professional information, including company websites and professional networking platforms such as LinkedIn

5. From which sources do we gather your personal data?

Avant gathers personal data directly from you, whether you are an applicant, candidate, client or potential client contact person, for example from:

website forms
physical forms
telephone conversations during which you provide personal data to Avant
e-mail correspondence in which you provide personal data to Avant
personal discussions, meetings and networking events
job application videos
public social media profiles and company websites
networking platforms (such as LinkedIn)

Avant may gather personal data from third parties based on your consent, for example from:

persons you have indicated as a reference
companies offering recruitment consultancy and personality and aptitude assessment tests to Avant or to its corporate clients

Avant may gather personal data from third parties without your consent where permitted by law, for example when:

we collect personal data within our candidate research work in order to add a person to our candidate pool and/or to add a person to our corporate client’s shortlist
a corporate client proposes a candidate for an open position and shares personal data on a sufficient legal basis
an authority discloses information to enable Avant or its client to fulfil a statutory duty
the employer acquires personal credit data or information from the criminal record in order to establish the employee's reliability, where permitted by law

Avant may also obtain and update personal data from authorities and service providers that are legally entitled to provide such data.

Avant may also collect certain technical data from the device you use to communicate with us (such as IP address and log information) in connection with your use of our online services.

6. To whom may we transfer and assign your personal data?

Avant does not sell, lease or otherwise disclose your personal data to third parties outside of Avant unless otherwise stated below.

As part of our business operations and to provide certain services, we use service providers. Avant may share your personal data with authorized third parties that perform services for Avant for the purposes described in this Privacy Policy within the limits of applicable legislation. This may include, for example, software providers (such as Invenias and Bullhorn International Limited) and providers conducting research or assessments (such as Hogan and Summit A/S). Where AI Tools are used by such service providers, Avant ensures that: (a) your data is processed only for recruitment purposes and only as necessary (data minimisation principle), (b) your data is not used to train or improve third-party AI models, (c) AI service providers act as data processors and follow Avant’s instructions, (d) appropriate security measures are in place, and (e) AI service providers are bound by data processing agreements in accordance with Article 28 of the GDPR.

Because Avant takes the responsibility to safeguard your personal data seriously, Avant does not allow those companies to use the data for any purpose other than to perform those services, and Avant requires them to protect your personal data in a way consistent with this Privacy Policy.

Avant may share applicant and candidate personal data with the corporate clients who engage Avant to assist with their recruiting processes. Avant takes the minimisation and transparency principle into consideration in connection with any data sharing.

Avant may share your personal data as part of any merger, acquisition, sale of company assets or transition of service to another provider. This also applies in the unlikely event of an insolvency, bankruptcy or receivership in which your personal data would be transferred to another entity as a result of such a proceeding.

Avant may share your personal data based on a valid order from a court or other official body with sufficient authority.

7. Is your data transferred to countries outside the European Union?

Avant’s services may be provided using resources and servers located in various countries around the world. Avant’s primary aim is to use resources located within the EU.

Avant may sometimes transfer your personal data outside the country where you use our services. In such cases Avant ensures that a legal basis for such a transfer exists and that adequate protection for your personal data is provided as required by applicable law, for example, by relying on EU adequacy decision or alike, using standard agreements approved by relevant authorities in accordance with Article 46 of the GDPR (where necessary) and by requiring the use of other appropriate technical and organizational information security measures.

8. How long do we process your data?

Avant may process applicant and candidate data in its job applicant system at maximum until the end of the second year following the application year (for example: application 1 May 2026 => 31 December 2028).

Avant may process personal data relating to client and potential client contact persons for as long as necessary to manage the client relationship, prepare proposals, communicate regarding services, perform contracts and assignments, and maintain business relationships, and thereafter for as long as necessary to comply with legal obligations or for the establishment, exercise or defence of legal claims.

Where processing is based on your consent, Avant may process your personal data for the period specified in the consent or until you withdraw your consent.

AI-generated support information is retained only for as long as necessary for the relevant recruitment process and otherwise in line with the retention periods described in this Privacy Policy.

Avant may process your personal data based on legal requirements for as long as the applicable legislation allows.

9. What are our principles for securing your personal data?

Avant has established electronic and administrative safeguards designed to make the information processed secure.

Only appointed personnel of Avant and of organizations operating under Avant’s assignment or on behalf of Avant are entitled to use the personal data filing system. All persons processing the system have a personal right of use granted by Avant or its co-operation partner. Different levels of access have been created based on the data a person needs according to his/her job description. We implement appropriate technical and organisational security measures designed to protect personal data against unauthorised access, disclosure, alteration, or destruction. These measures include network security controls (such as firewalls), access controls, encryption where appropriate, and regular monitoring of our systems.

Manually processed documents containing personal data are protected against unauthorized access.

All personnel of Avant and its subcontractors are obliged to keep the information about the personal data which they obtain in their work confidential.

10. How can you exercise the different types of rights you have?

All rights can be exercised by contacting Avant’s privacy team by using the contact details issued in section 1 above. The team will then give further instructions on how to exercise a specific right. Where Avant has reasonable doubts concerning the identity of the person making the request, Avant may request the provision of additional information necessary to confirm your identity.

Avant will provide information on action taken on a request to you within one month of receipt of the request. That period may be extended by two further months where necessary, taking into account the complexity and number of the requests.

10.1 Right of access to your personal data

You have the right to obtain from Avant confirmation as to whether or not personal data concerning you are being processed, and, where that is the case, receive information about your personal data.

10.2 Right to rectification

You have the right to obtain from Avant without undue delay the rectification of inaccurate personal data concerning you.

10.3 Right to erasure ('right to be forgotten')

You have the right to obtain from Avant the erasure of personal data concerning you without undue delay where one of the following grounds applies:

your personal data are no longer necessary in relation to the purposes for which they were collected or otherwise processed;
you withdraw consent on which the processing is based and where there is no other legal ground for the processing;
you object to the processing and there are no overriding legitimate grounds for the processing;
your personal data have been unlawfully processed;
your personal data have to be erased for compliance with a legal obligation in Union or member state law to which Avant is subject;
the personal data have been collected in relation to the offer of information society services (Article 8(1) GDPR).

However, you do not have the right to erasure if the processing is necessary:

for exercising the right of freedom of expression and information;
for compliance with a legal obligation which requires processing by Union or member state law to which Avant is subject; or
for the establishment, exercise or defence of legal claims.

10.4 Right to restriction of processing

You have the right to obtain from Avant restriction of processing where one of the following applies:

the accuracy of the personal data is contested by you, for a period enabling Avant to verify the accuracy of the personal data;
the processing is unlawful and you oppose the erasure of the personal data and request the restriction of their use instead;
Avant no longer needs the personal data for the purposes of the processing, but they are required by you for the establishment, exercise or defence of legal claims;
you have objected to processing pending the verification whether the legitimate grounds of Avant override those of you.

10.5 Right to object

You have the right to object, on grounds relating to your particular situation, at any time to processing of personal data concerning you which is based on legitimate interests pursued by Avant, including profiling. Avant shall no longer process the personal data unless Avant demonstrates compelling legitimate grounds for the processing which override your interests, rights and freedoms for the establishment, exercise or defence of legal claims.

Where personal data are processed for direct marketing purposes, you have the right to object at any time to the processing of personal data concerning you for such marketing, which includes profiling to the extent that it is related to such direct marketing.

Please be aware that you cannot opt out of receiving service messages from Avant, including but not limited to security and legal notices.

10.6 Right to data portability

You have the right to receive the personal data concerning you, which you have provided to Avant, in a structured, commonly used and machine-readable format and have the right to transmit those data to another controller where: (a) the processing is based on consent or on a contract; and (b) the processing is carried out by automated means.

11. Do we make decisions affecting you based on automated means?

In connection with recruitment, Avant does not make any decisions based solely on automated processing, including profiling. All decisions, such as whether to invite an applicant to an interview, proceed to the next stage or make a job offer, are made by human recruitment professionals. Further information on our use of AI Tools and human oversight is set out in Avant’s separate Responsible AI Commitment included at the end of this document.

12. Do we process your personal data in order to profile you?

In connection with recruitment, we may use tools such as AI Tools to analyse application data in order to support our human recruitment professionals. These tools never replace human judgment. We do not rely on solely automated processing, including profiling, to make recruitment decisions that produce legal effects concerning you or similarly significantly affect you. Further information on our use of AI Tools is set out in Avant’s separate Responsible AI Commitment included at the end of this document.

13. How can you exercise your right to lodge a complaint with the supervisory authority?

You have the right to lodge a complaint with the Finnish Data Protection Ombudsman (or another competent supervisory authority, in particular in the EU/EEA country of your habitual residence, place of work or alleged infringement). You may also first contact Avant’s privacy team (see section 1) to seek an amicable solution. Contact information of the competent authority can be found here.

14. Which law do we apply for processing personal data?

The processing of personal data in Avant’s filing system is governed by the European Union’s applicable data protection legislation as well as the national laws of Finland.

15. How can we update this Privacy Policy?

Avant may modify this Privacy Policy, and if we make material changes to it, we will provide notice on our website or by other means.

The following Avant Responsible AI Commitment is provided together with this Privacy Policy for convenience, but it is separate from and does not form part of this Privacy Policy.

AVANT RESPONSIBLE AI COMMITMENT

Avant is committed to using AI Tools in recruitment in a responsible, transparent, fair, and legally compliant manner. We recognize that recruitment decisions significantly affect people's lives and careers, and we ensure that AI Tools are used only as supportive tools while humans remain in control of all decision-making.

Avant may use AI Tools to assist in various stages of the recruitment process, for example to analyse and summarize CVs, cover letters and interview notes to identify relevant skills, experience and qualifications, to compare candidate profiles against position requirements, to suggest relevant interview questions based on job requirements and candidate background, to extract and categorise skills, competencies and experience from application materials, and to support communication and scheduling (such as drafting messages or coordinating interview times, always with human review).
Automated analysis of application and interview data (for example identifying skills from your CV or matching your profile to a role) is used only to support our human recruitment professionals and never replaces human judgment.
Avant does not make any recruitment decisions based solely on automated processing, including profiling, that produce legal effects concerning you or similarly significantly affect you. AI Tools do not make final hiring decisions. All applications, recommendations and AI-generated outputs are reviewed by human recruitment professionals, who make independent professional judgments.
When AI Tools are used, we follow the data minimisation principle. AI processes only the information necessary for the recruitment task. We do not collect additional data for AI purposes. AI analyses the information you provide in your application and, where relevant, work related information that you have made publicly available on professional networking platforms (such as LinkedIn) or interview notes. AI-generated support information is stored only as long as necessary for the recruitment process.
Where we use third-party AI providers, they act as data processors and may process your personal data only for recruitment purposes and only as necessary, in accordance with our instructions and data processing agreements. Your data is not used to train or improve third-party AI models, and appropriate security measures are applied.

You have the right to request information about whether AI Tools have been used in processing your application. You may also request that your application be reviewed without AI assistance. You can exercise these rights by contacting Avant’s privacy team using the contact details in section 1 and the general instructions in section 10.