Data Processing Agreement
Data Processing Agreement
armenianjobs.com
Effective Date: June 23, 2026
This Data Processing Agreement ("DPA") is entered into between armenianjobs.com ("Platform Operator" or "Processor") and the employer entity accessing the Platform ("Employer" or "Controller") and forms part of the Terms of Service between the parties.
This DPA is required under Article 28 of the EU General Data Protection Regulation (GDPR) and applies where the Employer, acting as a Controller, accesses personal data of job seekers (Data Subjects) through the Platform.
1. Definitions
"Controller" means the Employer who determines the purposes and means of processing job seeker personal data accessed through the Platform.
"Processor" means armenianjobs.com, which processes personal data on behalf of the Controller.
"Data Subject" means the individual job seeker whose personal data is being processed.
"Personal Data" has the meaning given in the GDPR: any information relating to an identified or identifiable natural person.
"Processing" has the meaning given in the GDPR and includes accessing, viewing, storing, using, and deleting personal data.
"GDPR" means the EU General Data Protection Regulation (Regulation 2016/679) and, where applicable, the UK GDPR.
"Sub-processor" means any third party engaged by the Processor to process Personal Data under this DPA.
"Standard Contractual Clauses" or "SCCs" means the standard data protection clauses adopted by the European Commission.
2. Scope and Purpose
This DPA governs the processing of job seeker personal data by the Employer (Controller) through their use of the armenianjobs.com Platform. The subject matter, nature, purpose, duration, and categories of data are set out in Schedule 1 (Description of Processing).
3. Roles of the Parties
The parties acknowledge that:
armenianjobs.com acts as Controller in respect of data it collects from employers and job seekers for its own platform purposes (e.g., account management, billing, platform analytics).
With respect to job seeker personal data made available to Employers through the Platform (e.g., resumes, contact details, application content), the Employer acts as Controller and armenianjobs.com acts as Processor.
Where both parties independently determine purposes and means, each is an independent Controller for their respective processing activities.
4. Obligations of the Processor (armenianjobs.com)
armenianjobs.com shall:
Process job seeker personal data only on documented instructions from the Controller (the Employer), including those set out in this DPA and the Terms of Service
Ensure that persons authorized to process the personal data are bound by confidentiality obligations
Implement appropriate technical and organizational security measures as described in Section 7
Not engage sub-processors without the prior written consent of the Controller, except as set out in Schedule 2
Assist the Controller in fulfilling its obligations to respond to Data Subject requests (see Section 8)
Assist the Controller with its security, breach notification, impact assessment, and consultation obligations under the GDPR
Delete or return all personal data to the Controller upon termination of the service, unless retention is required by applicable law
Make available all information necessary to demonstrate compliance with this DPA and permit audits or inspections by the Controller or a mandated auditor (with reasonable notice and at the Controller's expense)
Notify the Controller without undue delay if, in the Processor's opinion, an instruction infringes the GDPR or other applicable data protection law
5. Obligations of the Controller (Employer)
The Employer shall:
Ensure it has a valid legal basis under the GDPR for processing job seeker personal data
Process job seeker personal data only for the purpose of evaluating candidates for specific, genuine job roles listed on the Platform
Not use job seeker personal data for any other purpose, including marketing, profiling for non-recruitment purposes, or sharing with unauthorized third parties
Comply with all applicable data protection laws, including providing appropriate privacy notices to job seekers where required
Promptly inform armenianjobs.com of any Data Subject requests it receives that relate to data processed through the Platform
Ensure that any staff who access job seeker personal data are bound by appropriate confidentiality obligations
Not transfer job seeker personal data outside the EEA/UK unless appropriate safeguards are in place
Delete or destroy job seeker personal data when it is no longer needed for the recruitment purpose for which it was obtained
6. Permitted Purposes
The Employer may access and use job seeker personal data solely for the following purposes:
Reviewing applications submitted by job seekers for a specific role posted by the Employer on the Platform
Contacting job seekers to arrange interviews or communicate about the specific role
Evaluating candidates and making a hiring decision for that specific role
Any use beyond these purposes — including retaining candidate data for future roles without consent, sharing data with third-party recruiters, or using data for marketing — is strictly prohibited without the explicit written consent of the Data Subject.
7. Security Measures
armenianjobs.com implements the following technical and organizational measures to protect personal data:
Technical Measures
Encryption of personal data in transit using TLS 1.2 or higher
Encryption of personal data at rest
Access controls and role-based permissions limiting access to personal data to authorized personnel only
Regular security testing and vulnerability assessments
Secure deletion procedures for data no longer required
Organizational Measures
Staff training on data protection and information security
Confidentiality obligations for all staff with access to personal data
Data protection policies and procedures
Designated responsibility for data protection compliance
Incident response and breach notification procedures
The Employer is responsible for implementing appropriate security measures on its own systems where job seeker personal data is accessed, stored, or processed.
8. Data Subject Rights
Where a Data Subject (job seeker) exercises a right under the GDPR (e.g., access, rectification, erasure, restriction, portability, objection) that relates to personal data processed by the Employer:
The party receiving the request shall promptly notify the other party
armenianjobs.com shall provide reasonable assistance to the Employer to enable it to fulfill the request
The Employer, as Controller, is responsible for responding to the Data Subject within the statutory timeframe (generally 30 days under GDPR)
Neither party shall respond to a Data Subject request in a way that is inconsistent with their obligations under applicable data protection law
9. Personal Data Breaches
In the event of a personal data breach affecting job seeker data:
armenianjobs.com shall notify the Employer without undue delay and, where feasible, within 72 hours of becoming aware of the breach
The notification shall include: the nature of the breach; the categories and approximate number of Data Subjects affected; the categories and approximate number of records affected; the likely consequences of the breach; and measures taken or proposed to address the breach
The Employer, as Controller, is responsible for notifying the relevant supervisory authority and, where required, affected Data Subjects, in accordance with Articles 33 and 34 of the GDPR
Each party shall cooperate with the other in investigating and mitigating any breach
10. Sub-processors
The Employer provides general authorization for armenianjobs.com to engage sub-processors listed in Schedule 2. armenianjobs.com shall:
Impose data protection obligations on sub-processors equivalent to those in this DPA
Notify the Employer of any intended changes to sub-processors (additions or replacements) with at least 14 days' notice
Remain liable to the Controller for the acts and omissions of sub-processors
The Employer may object to a new sub-processor within 14 days of notification by providing written reasons. If the parties cannot resolve the objection, the Employer may terminate the relevant services on written notice.
11. International Data Transfers
armenianjobs.com shall not transfer job seeker personal data to a country outside the EEA or UK that does not provide an adequate level of protection unless:
The transfer is subject to Standard Contractual Clauses (SCCs) as approved by the European Commission or the UK ICO
Another appropriate safeguard under Article 46 of the GDPR applies
The transfer falls within a derogation under Article 49 of the GDPR
Where SCCs apply, they are incorporated into this DPA by reference. The applicable module shall be Module Two (Controller to Processor) or Module Three (Processor to Processor) as appropriate.
12. Term and Termination
This DPA shall remain in force for as long as the Employer uses the armenianjobs.com Platform or for as long as armenianjobs.com processes personal data on behalf of the Employer, whichever is longer.
Upon termination, armenianjobs.com shall, at the Employer's election, delete or return all job seeker personal data processed under this DPA within 30 days, unless retention is required by applicable law.
13. Liability
Each party's liability under this DPA shall be subject to the limitations and exclusions set out in the Terms of Service, to the extent permitted by applicable data protection law.
Where both parties are responsible for damage caused by processing in breach of the GDPR, each shall be held liable for the damage attributable to them.
14. Governing Law
This DPA shall be governed by the same law as the Terms of Service, subject to any mandatory requirements of the GDPR and applicable national data protection laws.
15. Order of Precedence
In the event of a conflict between this DPA and the Terms of Service on matters relating to personal data processing, this DPA shall prevail.
16. Contact and Data Protection Enquiries
For all data protection enquiries relating to this DPA:
Email: legal@armenianjobs.com
Website: https://armenianjobs.com
Schedule 1 — Description of Processing Activities
Subject Matter
Access by Employers to job seeker personal data submitted through the armenianjobs.com Platform for the purpose of recruitment.
Nature of Processing
Viewing, downloading, storing, and using job seeker personal data for candidate evaluation.
Purpose of Processing
To enable Employers to evaluate job seekers who have applied to specific roles posted on the Platform and to facilitate the recruitment process.
Duration of Processing
For the duration of the Employer's active use of the Platform and for as long as necessary to conclude the relevant recruitment process, subject to the Employer's own retention obligations.
Categories of Data Subjects
Job seekers who have created accounts on armenianjobs.com
Job seekers who have applied to a role posted by the Employer
Categories of Personal Data
Identity data: name, photograph (if provided)
Contact data: email address, phone number, location/address
Professional data: resume/CV, work history, skills, education, qualifications, references
Application data: cover letters, responses to screening questions, application status
Communication data: messages exchanged between the job seeker and the Employer through the Platform
Special Categories of Personal Data
Job seekers may voluntarily include special category data (e.g., disability status, nationality) in their resumes. Employers must treat any such data with heightened care and must only process it where they have a valid legal basis under Article 9 of the GDPR. Employers must not solicit or require special category data as part of the application process unless strictly necessary and lawful.
Schedule 2 — Approved Sub-processors
armenianjobs.com may engage the following categories of sub-processors in connection with the Platform. Specific sub-processor names and locations will be provided on request or via our sub-processor list page.
Cloud hosting and infrastructure providers (e.g., servers, databases, file storage)
Email delivery service providers
Payment processing providers
Analytics and performance monitoring tools
Customer support software providers
Security and fraud detection services
A current list of named sub-processors is available upon request at legal@armenianjobs.com. armenianjobs.com will provide at least 14 days' notice of any changes to sub-processors that may affect the processing of job seeker personal data.
Execution
By using the armenianjobs.com Platform as an Employer, you acknowledge that you have read, understood, and agree to be bound by this Data Processing Agreement. If you are entering into this DPA on behalf of a company or other legal entity, you represent that you have authority to bind that entity.
If you require a separately executed copy of this DPA (e.g., for your own compliance records), please contact us at legal@armenianjobs.com.