DATA RETENTION POLICY

Effective date: 1 July 2026
Last updated: 28 July 2026

1. Purpose

MOBILIZE Talent Acquisition Kft. is committed to processing personal data responsibly and in accordance with the General Data Protection Regulation (EU) 2016/679, referred to as the “GDPR”, and applicable Hungarian data-protection legislation.

This Data Retention Policy explains how we retain, review, delete and anonymise personal data collected in connection with our executive search, recruitment, consulting and related business activities.

The data controller is:

MOBILIZE Talent Acquisition Kft.
Registered office: 1051 Budapest, Széchenyi István tér 7-8., Hungary
Company registration number: 01-09-458415
Tax number: HU33086804

Private Employment Agency Registration No.: BP/0701/029960-2/2026-1478
Represented by: Zoltan Zorkoczi, Managing Director
Email: info@mobilize-talent.com
Website: https://mobilize-talent.com

MOBILIZE Talent Acquisition Kft. is referred to in this Policy as “MOBILIZE”, “we”, “us” or “our”.

2. Retention Principles

Executive search is relationship-driven and often involves long-term engagement with candidates and clients. Relevant professional opportunities may arise several years after an individual’s initial contact with MOBILIZE.

We nevertheless retain personal data only for as long as it remains necessary and relevant for the purposes for which it was collected or for another compatible and lawful purpose.

Our retention decisions take account of:

• the nature and sensitivity of the information;
• the purpose for which it is processed;
• the date of the most recent meaningful interaction;
• whether the information remains accurate and professionally relevant;
• the reasonable expectations of the individual;
• ongoing or potential recruitment assignments;
• contractual and legal obligations;
• applicable limitation periods;
• the need to establish, exercise or defend legal claims; and
• any objection, deletion request or withdrawal of consent.

Personal data will not be retained indefinitely merely because storage is technically possible.

3. Candidate Information

3.1 Specific recruitment assignments

Candidate information processed in connection with a specific recruitment assignment may be retained for the duration of that assignment and for up to five years following the conclusion of the recruitment process.

This period allows MOBILIZE to:

• maintain an appropriate record of the recruitment process;
• respond to candidate or client enquiries;
• demonstrate how the assignment was managed;
• comply with legal and contractual obligations; and
• establish, exercise or defend legal claims.

Information may be retained for a longer period where required by law, where a dispute or legal claim is ongoing, or where the candidate remains part of MOBILIZE’s professional talent network.

3.2 Professional talent database

Where a candidate submits a CV, engages with MOBILIZE, agrees to remain in contact, or is lawfully identified as a potentially relevant professional, we may retain appropriate professional information within our talent database for current and future opportunities.

Candidate records retained for talent-network purposes will be reviewed at least every three years from the most recent meaningful interaction, update or verification.

A meaningful interaction may include:

• submission of a CV or application;
• confirmation or updating of professional information;
• discussion of a career opportunity;
• participation in an interview or recruitment process;
• an indication that the candidate wishes to remain in contact;
• a response to a professional communication; or
• another interaction demonstrating that continued retention remains relevant.

Following a review, we may:

• retain the record where continued retention remains necessary and justified;
• contact the candidate to verify or update the information;
• restrict the record from active recruitment use;
• delete unnecessary or outdated information; or
• anonymise or delete the record where continued retention can no longer be justified.

A candidate record may be retained beyond an individual three-year review point where MOBILIZE determines that the information remains accurate, relevant and necessary for legitimate executive-search purposes. Each continuation must remain subject to periodic review.

3.3 Old and duplicate CVs

Where several versions of a candidate’s CV are held, MOBILIZE may retain the most recent relevant version and delete outdated duplicates unless an earlier version is necessary to maintain an appropriate record of a recruitment process.

CVs and profiles that are materially outdated, cannot be verified or no longer support a legitimate recruitment purpose will be deleted, restricted or anonymised.

3.4 Candidate objections and deletion requests

Candidates may object to processing or request deletion of their information at any time.

Where a valid deletion request applies, the relevant personal data will be deleted or anonymised unless continued retention is required or permitted by law.

Where a candidate asks not to be contacted again, MOBILIZE may retain limited information on a suppression list. This information will be used only to ensure that the individual’s communication preference is respected across the MOBILIZE network.

4. Client and Business Information

Client, prospective-client, supplier, adviser and business-contact information may be retained:

• for the duration of the relevant business relationship;
• while there is a reasonable prospect of a professional relationship;
• for the period necessary to administer services and contractual obligations; and
• following the end of the relationship for the applicable legal, accounting, tax and limitation periods.

Contractual and assignment records may generally be retained for up to five years after completion or termination, unless a longer period is required by law or necessary for an ongoing matter.

Accounting, invoicing and tax records will be retained for the period required under applicable Hungarian law.

5. Website Enquiries and Communications

General enquiries, contact-form submissions and related correspondence may be retained for up to two years after the last meaningful communication.

Correspondence connected with a recruitment assignment, client relationship, contract, complaint, dispute or legal obligation may be retained for the longer period applicable to that category.

Technical security logs may be retained for up to twelve months unless a longer period is necessary to investigate a security incident, prevent misuse or comply with a legal obligation.

Website analytics and cookie-related information will be retained according to the periods described in the Cookie Policy and the settings of the applicable service provider.

6. Marketing and Subscription Information

Information used for newsletters, job alerts and other consent-based communications will be retained until:

• consent is withdrawn;
• the individual unsubscribes;
• the relevant communication service is discontinued; or
• MOBILIZE determines that the information is no longer accurate or relevant.

MOBILIZE may periodically review inactive subscription records.

Where a person unsubscribes, limited suppression information may be retained to ensure that no further communications are sent contrary to their request.

7. Recruitment Partner and International Network Records

Information relating to MOBILIZE franchise partners, recruitment partners and authorised professional contacts may be retained for the duration of the relationship and for the applicable legal, contractual and limitation periods following its conclusion.

Candidate information accessed or processed through the MOBILIZE international network remains subject to the retention rules described in this Policy.

Each authorised partner must:

• comply with the applicable retention instructions;
• keep information accurate and relevant;
• communicate objections and deletion requests promptly;
• refrain from maintaining unauthorised duplicate databases; and
• securely delete information when required.

8. Legal, Financial and Compliance Records

Personal data may be retained for longer than the standard periods described in this 

Policy where necessary to:

• comply with a legal, regulatory, accounting or tax obligation;
• respond to an investigation or lawful authority request;
• establish, exercise or defend a legal claim;
• manage an ongoing complaint or dispute;
• investigate fraud, misconduct or a security incident; or
• protect the rights and legitimate interests of MOBILIZE or another person.

Where a legal hold applies, deletion will be suspended only for the information and period necessary for the relevant matter.

9. Secure Storage, Deletion and Anonymisation

Personal data is protected using appropriate technical and organisational measures designed to prevent unauthorised access, loss, alteration, misuse or disclosure.

When a retention period expires or continued retention can no longer be justified, personal data will be:

• securely deleted;
• irreversibly anonymised; or
• restricted from active use pending secure deletion.

Deletion from operational systems may not result in immediate deletion from encrypted backup systems. Backup copies will remain protected, will not be returned to active use except where necessary for disaster recovery, and will be overwritten or deleted according to the applicable backup cycle.

Where anonymised information can no longer be linked to an identifiable individual, it may be retained for statistical, analytical or business-planning purposes.

10. Responsibilities Within the MOBILIZE Network

MOBILIZE operates through an international network of independently owned and operated franchise partners.

Unless otherwise stated, this website and MOBILIZE’s central data-processing activities are operated by MOBILIZE Talent Acquisition Kft., Hungary.

Where services are delivered by an authorised MOBILIZE franchise partner, that partner may act as an independent controller, joint controller or data processor, depending on the circumstances and applicable contractual arrangements.

MOBILIZE and its authorised partners must coordinate where necessary to ensure that:

• retention rules are applied consistently;
• information is not retained without a continuing lawful purpose;
• candidate rights are respected throughout the relevant network;
• deletion and objection requests are communicated appropriately; and
• access is withdrawn when no longer required.

11. Your Rights

Subject to applicable law, you may request:

• access to your personal data;
• correction of inaccurate or incomplete information;
• deletion of your personal data;
• restriction of processing;
• objection to processing based on legitimate interests;
• withdrawal of consent where processing is based on consent; and
• further information about the applicable retention period.

Requests should be sent to:

Email: info@mobilize-talent.com

We may request information necessary to verify your identity before acting on a request.

12. Policy Review

MOBILIZE will review this Data Retention Policy periodically and update it where necessary to reflect:

• changes in applicable law or regulatory guidance;
• changes in business activities;
• the introduction of new systems or technology;
• changes to recruitment processes; or
• identified data-protection or security risks.

The latest version will be published on the MOBILIZE website with the applicable effective and last-updated dates.

13. Contact

For questions about this Data Retention Policy or the retention and deletion of personal data, please contact:

MOBILIZE Talent Acquisition Kft.
Registered office: 1051 Budapest, Széchenyi István tér 7-8., Hungary
Company registration number: 01-09-458415
Tax number: HU33086804
Represented by: Zoltan Zorkoczi, Managing Director
Email: info@mobilize-talent.com
Website: https://mobilize-talent.com

© 2026 MOBILIZE Talent Acquisition Kft. All rights reserved.