PRIVACY POLICY

Last updated: 4 February 2026

OZUARA LIMITED places great importance on the protection and respect of personal data.

This privacy policy (the "Privacy Policy") is intended to help you understand how OZUARA LIMITED, acting as the publisher of the CV Elevator Portal, collects and processes your personal data, and what your rights are.

This Privacy Policy applies to:

  • Visitors to our CV Elevator Portal accessible at https://cvelevator.app (the “Portal”), and

  • Visitors using our features for creating CVs, cover letters, and preparing online job applications (the “Features”).

In this Privacy Policy, the term “Personal Data” refers to any information that makes it possible, or may legitimately be used, to identify a natural person.

1. WHO IS RESPONSIBLE FOR PROCESSING YOUR PERSONAL DATA?

OZUARA LIMITED, a company incorporated under Cypriot law (Private Company Limited by Shares), whose registered office is located at RODOU 4, OFFICE 1, 1086 NICOSIA, Cyprus, registered with the Department of Registrar of Companies and Intellectual Property under number HE 443413 (hereinafter the “Company” or “we”), is responsible for processing your Personal Data collected via the Portal and the Features.

2. WHAT PERSONAL DATA DO WE COLLECT, FOR WHAT PURPOSES, AND FOR HOW LONG?

We process your Personal Data in compliance with the applicable data protection regulations, in particular Regulation (EU) 2016/679 of 27 April 2016 on the protection of natural persons with regard to the processing of personal data (the “GDPR”), as well as the Cypriot data protection law (“Law 125(I) of 2018 Providing for the Protection of Natural Persons with regard to the Processing of Personal Data and for the Free Movement of Such Data”).

The data processing operations implemented by the Company pursue specific, explicit, and legitimate purposes. For each of these processing activities, the Company undertakes to process only Personal Data that are adequate, relevant, and limited to what is necessary with regard to the purposes for which they are processed.

We process your personal data only where we have a legal basis to do so:

PurposePersonal dataLegal basisSource
Provision of the Portal and the Features – Management of our contractual relationship with you (providing you with our Features, processing your payments, enabling you to personalize your Personal Interface, your personalized documents, and your profile)• Identity and contact details
• Photograph
• Information contained in your CVs and cover letters
• Login credentials for the Personal Interface
• Payment-related data
Performance of our contract with youData provided by the data subject or automatically collected when using the Features
Management of our Portal, including maintaining its security and resolving issues, and for access, data analysis, assessments, research, surveys, and analytics purposes• Identity and contact details
• Information contained in your CVs and cover letters
• Login credentials for the Personal Interface
• Data relating to your device (type, operating system, settings)
Legitimate interest of the Company in managing its PortalData provided by the data subject or automatically collected when using the Portal and/or the Features
Improving our Portal so that content is presented in the most effective manner• Identity and contact details
• Photograph
• Information contained in your CVs and cover letters
• Login credentials for the Personal Interface
• Data relating to your device
Legitimate interest of the Company in managing its PortalData provided by the data subject or automatically collected
Communication and outreach – Management of contact requests (contact form on the Portal, telephone, and email)• Identity and contact details
• Subject of your request
• Any information or document you share with us
ConsentData provided by the data subject
Sending marketing communications to our Visitors• Identity and contact details
• Data relating to the user journey
Legitimate interest of the Company in developing its businessData provided by the data subject or automatically collected when using the Features
Compliance with data subject rights and regulations – Defending our interests in the event of a dispute• Identity and contact details
• Any information necessary for handling the dispute
Legitimate interest of the Company in defending its interests in the event of a disputeData provided by the data subject, data automatically collected, and data collected from third parties
Management of requests to exercise rights• Identity and contact details
• Any information necessary to process your request to exercise your rights
Legal obligationData provided by the data subject or automatically collected
Compliance with applicable legal or regulatory requirements (accounting, taxation, data protection)• Any information necessary to comply with legal or regulatory requirementsLegal obligationData provided by the data subject or automatically collected

The data required to respond to your requests are marked with an asterisk or an equivalent method on the data collection forms. If these fields are not completed, we will not be able to respond to your requests or provide certain Features.

You must provide us with accurate information that does not infringe the rights of third parties.

3. HOW DO WE SHARE YOUR PERSONAL DATA?

We share the various categories of Personal Data mentioned above with:

  • our authorized staff, who need access to them in the performance of their duties;

  • our processors and service providers who perform various services on our behalf;

  • where applicable, certain of our technical or commercial partners involved in the provision, improvement, or promotion of the Features;

  • our external advisers (lawyers, auditors, etc.) and debt collection agencies;

  • public or judicial authorities, where required by law.

We may also share your Personal Data with third parties in connection with a sale or restructuring of our company.

4. HOW DO WE TRANSFER YOUR PERSONAL DATA?

We may transfer your Personal Data to third-party service providers located outside the European Economic Area. In such cases, we ensure that these transfers are carried out in compliance with applicable regulations and are secured by appropriate safeguards, such as the European Commission’s standard contractual clauses (Articles 46 et seq. of the GDPR).

You may request a copy of these safeguards (excluding confidential clauses) by contacting us using the contact details provided below.

5. HOW LONG ARE YOUR DATA RETAINED?

We retain your Personal Data only for as long as necessary for the purposes described and in accordance with the law.

Data associated with your Personal Interface:

Retained for as long as you use our Features. Deleted if you close your Personal Interface or after 2 years of inactivity.

Data relating to your subscription to our Features:

Retained for 5 years from the end of the contractual relationship.

Data used for marketing purposes:

Until you unsubscribe or 3 years after the last interaction.

6. HOW DO WE PROTECT YOUR PERSONAL DATA?

We implement appropriate technical and organizational measures to prevent unauthorized or unlawful processing of your Personal Data and to avoid any accidental loss, destruction, or damage.

7. WHAT ARE YOUR RIGHTS REGARDING YOUR PERSONAL DATA?

You have several rights with regard to your Personal Data:

RightConditions and exceptions
Withdraw your consent at any timeOnly where the processing is based on your consent. No retroactive effect.
Access your Personal Data and obtain a copyMay be refused if the request is unfounded, excessive, or infringes the rights of a third party
Request the correction of inaccurate or incomplete dataApplicable regardless of the legal basis of the processing.
Request the erasure or restriction of processingApplicable in the cases provided for by the GDPR. Does not apply where there is a legal obligation or a need to defend legal rights.
Request data portabilityOnly for data processed by automated means on the basis of consent or a contract.
Object to processing based on legitimate interestUnless there are compelling legitimate grounds. Objection without justification for direct marketing.
Define instructions regarding your data after your deathYou may appoint a person to carry out these instructions.

To exercise your rights, please contact us using the information provided below. You may also lodge a complaint with the Commissioner for Personal Data Protection of Cyprus or with your national data protection authority.

8. COOKIES

Cookies are placed on our Portal. To learn more, please consult our Cookie Policy.

9. HOW TO CONTACT US?

Contact us via the “Contact Us” section of the Portal or using the contact details indicated in the Terms and Conditions and the General Terms and Conditions of Sale.

10. UPDATES

We reserve the right to modify this Privacy Policy at any time. We will inform you in the event of any material changes.