PRIVACY POLICY

Company Name: Apollon Hospitality Ltd (“the Company”)
Contact: Data Protection Lead – info@apollonhospitality.com
Address: 124 City Road, London EC1V 2NX, United Kingdom
Document: Privacy Policy
Last updated: March 2026

Contents
1. Introduction
2. Scope of Services
3. Collection of Personal Data
4. Types of Personal Data
5. Purpose of Processing
6. Legal Basis for Processing
7. Special Category Data
8. Data Accuracy and Minimisation
9. Recruitment Disclaimer and Limitation of Responsibility
10. Data Sharing
11. International Transfers
12. Data Retention
13. Your Rights
14. Automated Decision-Making
15. Cookies
16. Log Files
17. External Links
18. Business Transfers
19. Data Security
20. Changes to This Notice
21. Complaints

1. Introduction
Apollon Hospitality Ltd is a recruitment and staffing company registered in the United Kingdom, providing hospitality talent sourcing, advisory, and introduction services to business clients internationally, including within the European Union.

For the purposes of applicable data protection laws, including the UK GDPR and the Data Protection Act 2018, the Company acts as a data controller in relation to personal data processed in connection with its services.

This Privacy Notice explains how we collect, use, and protect your personal data.

We process personal data lawfully, fairly, and in a transparent manner in accordance with applicable data protection laws.

2. Scope of Services
The Company operates strictly as an independent recruitment intermediary.
We:

identify and assess candidates
match candidates with relevant opportunities
facilitate introductions between candidates and employers

We do not:

employ candidates
act as an employer
guarantee job offers or employment outcomes

All hiring decisions are made solely by the relevant employer.

3. Collection of Personal Data
We may collect personal data directly from you, including when you:

submit your CV or application
contact us via email or website
engage with us professionally

We may also collect data from third-party sources such as:

professional platforms (e.g. LinkedIn, Indeed, Hosco, Reed)
publicly available professional profiles
referrals or business partners

4. Types of Personal Data

We may process:

identification data (name, contact details)
professional data (CV, experience, qualifications)
communication records
technical data (IP address, website usage).

Where relevant and necessary, this may include special category data, processed strictly in accordance with applicable law.

5. Purpose of Processing
We process personal data for the following purposes:

assessing candidate suitability
matching candidates with opportunities
facilitating recruitment processes
communicating with candidates and clients
maintaining internal databases
complying with legal and regulatory obligations.

We do not process personal data for unrelated purposes.

6. Legal Basis for Processing
We process personal data only where we have a lawful basis under UK GDPR:

Legitimate Interests (Primary Basis)
Processing is necessary to provide recruitment and talent sourcing services to our business clients.

Contract
Processing necessary to take steps prior to entering into a contract or to fulfil contractual obligations.

Legal Obligation
Processing required to comply with legal or regulatory requirements.

Consent (Limited Use)
Consent is relied upon only where required, including:

marketing communications
processing of special category data where applicable.

Where required under applicable electronic marketing laws (including PECR), we will obtain your consent before sending marketing communications. You may opt out at any time by using the unsubscribe link or contacting us directly.

You may withdraw consent at any time.

7. Special Category Data
Where special categories of personal data are processed, this is done only:

where necessary for recruitment purposes and
in accordance with Article 9 UK GDPR

including where:

explicit consent has been obtained or
processing is necessary for employment-related purposes.

8. Data Accuracy and Minimisation
We ensure that personal data processed is:

adequate
relevant
limited to what is necessary

We rely on individuals to provide accurate and up-to-date information and do not independently verify all data provided.

9. Recruitment Disclaimer and Limitation of Responsibility
The Company acts solely as an intermediary between candidates and employers.
Accordingly:

We do not guarantee employment or job offers
We are not responsible for hiring decisions made by employers
We are not liable for outcomes of recruitment processes
We rely on information provided by candidates and do not verify all details

The Company shall not be liable for:

inaccuracies or omissions in candidate-provided data
decisions made by employers or candidates
any loss arising from recruitment outcomes

10. Data Sharing
We may share personal data with:

Business Clients
For the purpose of recruitment and candidate evaluation.
Service Providers
Including CRM systems, cloud providers, and IT services, under strict confidentiality agreements.
Professional Advisers
Legal, financial, or compliance advisers.
Regulatory Authorities
Where required by law.

All third-party service providers act as data processors and are contractually bound to process personal data only on our instructions and in accordance with applicable data protection laws.

We do not sell or rent personal data.

11. International Transfers
Where personal data is transferred outside the UK or EEA, we implement appropriate safeguards, including:

Standard Contractual Clauses (SCCs)
or equivalent legal mechanisms

12. Data Retention
We retain personal data only for as long as necessary for the purposes set out in the Private Policy. Candidate data is typically retained for up to 12 months from last meaningful interaction. Data may be retained longer where required by law. You may request deletion at any time.

13. Your Rights
You have the following rights under data protection law:

Right to be informed
Right of access
Right to rectification
Right to erasure
Right to restrict processing
Right to data portability
Right to object
Right to withdraw consent
Right not to be subject to automated decision-making

To exercise your rights: info@apollonhospitality.com
We respond within one month.

14. Automated Decision-Making
The Company does not carry out automated decision-making or profiling that produces legal or similarly significant effects.

15. Cookies
Our website uses cookies to improve functionality and user experience. Please refer to our Cookie Policy for further details.

16. Log Files
We may collect technical data such as IP addresses for analytics and website administration. This data is not used to directly identify individuals.

17. External Links
Our website may contain links to third-party websites. We are not responsible for their privacy practices.

18. Business Transfers
In the event of a sale, merger, or restructuring, personal data may be transferred to new owners or advisers.
You will be notified where required by law.

19. Data Security
We implement appropriate technical and organisational measures, including:

secure systems,
access controls,
encryption where appropriate.

Access is limited to authorised personnel.

20. Changes to This Policy
We may update this Privacy Policy from time to time.
Updates will be published on our website.

21. Complaints
If you have concerns, contact us at:
info@apollonhospitality.com

We encourage you to contact us first so that we can address your concerns and attempt to resolve any issues before you approach the UK Information Commissioner's Office (ICO).

You also have the right to lodge a complaint with the UK Information Commissioner’s Office (ICO).