MELIOR CAPITAL LTD

Last modified 27 October 2026

MELIOR CAPITAL LTD, referred to in this Policy as “we”, “us”, “our” or “Ergodotisi”, operates a recruitment platform in Cyprus. We connect job seekers with employers through job applications submitted using eApply and through Seek4u, also known as Talent Search.

Seek4u is an optional service that allows participating candidates to make their profiles and CVs available to eligible employers. It includes searchable candidate profiles and, where available, AI-assisted matching that helps employers discover candidates whose professional background corresponds to the requirements of a particular vacancy. Section 12 explains how this matching works.

Job seekers create accounts, upload CVs and apply for vacancies. Employers register, create company profiles, publish job advertisements and purchase access to the services available to them. These activities are referred to in this Policy as our “Services”.

This Privacy Policy explains how we collect and use your personal data, the purposes and legal bases for processing, when we disclose information to others, how long we retain it and your rights. Our processing is governed by the EU General Data Protection Regulation, Regulation (EU) 2016/679 (“GDPR”), and applicable Cyprus data protection legislation, including Law 125(I)/2018.

Please read this Policy and contact us using the details in Section 16 if you have questions about our handling of your personal data.

“Personal data” means information relating to an identified or identifiable natural person. A person may be identifiable directly or indirectly, including by reference to a name, identification number, location data, online identifier or factors relating to their physical, physiological, genetic, mental, economic, cultural or social identity.

“Processing” means an operation or set of operations performed on personal data, whether or not by automated means. It includes collecting, recording, organising, storing, adapting, retrieving, consulting, using, disclosing, combining, restricting, erasing or destroying information.

“Controller” means the person or organisation that determines the purposes and means of processing personal data.

“Processor” means a person or organisation that processes personal data on behalf of a controller.

“Profiling” means automated processing of personal data to evaluate personal aspects of an individual. Seek4u’s AI-assisted comparison of professional information with vacancy requirements is explained in Section 12.

“Pseudonymisation” means processing information so that it cannot be attributed to a particular person without additional information that is kept separately and protected. Pseudonymised information remains personal data where the person can still be identified.

MELIOR CAPITAL LTD acts as the controller for the processing described in this Policy, including operating Seek4u and its AI-assisted matching functionality. We determine the purposes and means of that processing.

Employers act as independent controllers for the recruitment processing they undertake using personal data obtained through Seek4u or eApply. They are responsible for their own use, retention and protection of that information and for providing any privacy information required in connection with their recruitment activities.

We collect personal data in the following ways:

• When you contact us by telephone, social media, email or online chat.
• When you register and create an Ergodotisi account or purchase our Services.
• When you create or edit a profile, upload a CV, submit an application or use other platform features.
• When you provide information or make a choice, including a choice to participate in Seek4u or receive communications.
• Through third parties where this is necessary to provide a service you have requested.
• In providing customer and technical support.
• Through cookies and similar technologies, subject to the applicable consent requirements.

Advertising providers, such as Google, may use cookies to collect information about your activity on our platform. They may combine it with information collected from other websites or applications to build or improve a profile of your interests and display more relevant advertising. Non-essential cookies are subject to your choices in our cookie banner and settings.

The information we process depends on your relationship with us and the Services you use.

All Platform Users

• Contact information, such as your name, telephone number, email address and social media details, and the contents of communications with us.
• Information about use of the website, such as IP addresses, device and browser details, pages accessed, referrer information and behavioural analytics, subject to the applicable consent requirements.

Job Seekers

• Registration information, including your name, email address, optional telephone number, city and country of residence.
• Information in your account or online CV, such as your address, date of birth, LinkedIn page, personal website, education, experience, languages, skills, optional current and preferred salary, job categories and application history.
• Information contained in the CVs and applications you choose to submit, including work history, education, skills, qualifications and certifications.

When you participate in Seek4u, we also process:

• Your participation preferences and records showing when and how you joined, changed your preferences or withdrew.
• Professional information extracted or organised from your profile and CV, such as skills, languages, qualifications, certifications, awards, education and employment history, including relevant institutions, employers, dates and locations, and your job categories, city and country.
• Information generated through AI-assisted matching, including numerical representations of relevant professional information used for comparison, vacancy-specific matching scores, ranking positions and explanations of a match where generated.

These numerical representations and matching results remain personal data where they can be linked to you. They are used for the purposes described in Sections 6 and 12.

Please avoid including unnecessary sensitive information in your CV, such as information about your health, racial or ethnic origin, religious or political beliefs, trade union membership, sexual life or sexual orientation, or criminal convictions. We do not request this information for AI-assisted matching. Please also avoid unnecessary identity document numbers, full residential addresses and other people’s personal contact details. The automatic filtering described in Section 7 may not detect all such information in free text.

Employer Representatives

• Registration information, such as your name, telephone number, city, country and language preference.
• Information in your account, including job advertising and payment history.
• Invoice information when you subscribe to or purchase paid Services.

We process personal data for the purposes and on the legal bases set out below. References to a contract apply where processing is necessary to perform a contract with the individual concerned or take requested steps before entering into one. Where an employer representative acts for a company rather than being personally party to the contract, we rely on our legitimate interest in administering that business relationship for the corresponding account and service administration.

Job Seekers

Employers and Their Representatives

Platform Users

Where a support call is recorded, we provide a recording notice before recording takes place. Recording is limited to the support, quality assurance, training or dispute-related purposes described above.

Necessary technical testing may involve limited access to personal data by authorised development and support personnel, for example to check that processing, filtering and deletion work correctly or to resolve a reported fault. Access and copies must be limited to what is necessary for that work. This does not authorise continued matching after withdrawal from Seek4u or the use of candidate information to train general-purpose AI models.

Participation in Seek4u is optional. AI-assisted matching forms part of this service and is controlled through your Seek4u participation setting. You can withdraw your consent at any time as described in Section 11.

An employer’s purchase of Seek4u does not replace the requirement for a candidate to participate in the service. Registering an account, uploading a CV for another purpose or applying for a job does not, by itself, enrol a candidate in Seek4u.

Seek4u participation does not constitute consent to advertising, marketing communications or non-essential analytics cookies. These remain subject to the separate choices and legal bases described in this Policy and our cookie settings.

Where we rely on legitimate interests, we consider the necessity of the processing and balance our interests against the impact on your rights and freedoms. We do not rely on this basis where your interests or fundamental rights override ours. You can request information about the relevant assessment by contacting xx@digitaltree.com.cy.

We disclose personal data to the following categories of recipients where relevant to the purposes described in this Policy.

Affiliates

We share personal data with affiliates, including Digital Tree, where necessary for billing, accounting and marketing services, subject to the applicable legal basis and your marketing choices.

Service Providers

We use providers for the following functions:

• Development, maintenance, technical testing and support — Kufar Tech, SKDO and DNK Technologies, as relevant to the services they provide.
• Software, applications, email, marketing communications, customer relationship management and customer support — Zoho.
• Hosting and infrastructure — FocusNet and Vercel.
• Call centre and telephony services, including call recording where applicable — Cablenet and Yeastar.
• Payment processing — JCC.
• Network protection, security and application monitoring — Cloudflare and Sentry.
• Analytics, advertising, remarketing and audience creation — relevant services provided by Google, Meta, TikTok, LinkedIn and Pinterest, subject to the applicable consent requirements.
• AI processing for Seek4u matching — OpenAI, as explained below.

OpenAI Processing for Seek4u

We use OpenAI’s business API services to analyse and compare professional information for Seek4u’s AI-assisted matching. The information is sent to OpenAI for processing; this part of the service does not run entirely within Ergodotisi’s infrastructure.

For CVs created using our online form, the matching service selects professional fields, such as skills, education and employment history, rather than the separate fields containing your name, email address, telephone number, date of birth, photograph or social media links. Professional fields may nevertheless contain identifying details, including names of employers or educational institutions and information you have entered in descriptions.

For uploaded CVs, text is extracted locally from readable files. Before that text enters the matching index or is sent to OpenAI, including to create numerical representations for comparison, we apply automatic filtering. The filters replace recognised email addresses, telephone numbers and web links, and names matching the candidate’s account details. They also replace personal details in recognised labelled fields in English, Greek and Russian, such as dates and places of birth, age, gender, nationality, marital status, religion, residential addresses and identity document numbers.

This filtering reduces the personal information shared, but does not make the text anonymous. It may miss information that is unlabelled, written differently from account details or presented in an unrecognised format or language. Personal details about other people and sensitive information in free text may also remain. We continue to treat the information used for matching as personal data.

Information sent to OpenAI may include relevant experience, skills, education, qualifications, certifications, languages, professional locations and dates, and vacancy requirements. The matching process uses temporary candidate labels, with the link to your Ergodotisi account kept within our systems. We send extracted text rather than original CV files or photographs. Filtering applies to the copy used for AI matching; eligible employers can still view the profile and original CV you make available through Seek4u.

OpenAI processes information on our behalf under the applicable business data processing terms. Our OpenAI account has optional sharing for model feedback, evaluation and fine-tuning data, and API inputs and outputs disabled. We do not enable optional sharing of candidate information to train OpenAI’s general-purpose models.

OpenAI uses global infrastructure for this service. Matching data may be processed outside the EEA, including in the United States, subject to the international transfer arrangements below. Standard provider retention applies as explained in Section 8.

Employers

Where you participate in Seek4u, your profile and CV may be accessed by employers with an active entitlement to the service, within the job categories in which they have active advertisements. AI-assisted recommendations follow the same access restrictions and do not give an employer access to additional candidates outside those restrictions.

Employers may view your profile and CV and use the available download or contact options for recruitment purposes. If you apply for a vacancy through eApply, we also share your application and the information you submit with the employer advertising that vacancy.

Leaving Seek4u stops future access through that service. It does not automatically recall information that an employer has already downloaded or received. Employers remain responsible for their own lawful processing of those copies.

Authorities

We may disclose personal data to courts, regulatory authorities, law enforcement agencies or other public bodies where required by law or necessary to establish, exercise or defend legal rights.

International Transfers

We use infrastructure and service providers in Cyprus and elsewhere in the European Economic Area (“EEA”). Some providers and their subprocessors may also process personal data, or access it remotely, outside the EEA. Depending on the provider and service, these locations include the United States, Belarus and India. Where you consent to relevant third-party cookies or advertising services, processing may also take place in other countries, including China, as explained in our cookie information.

Where personal data is transferred outside the EEA, we use an applicable transfer mechanism under the GDPR. This may include a European Commission adequacy decision covering the recipient or the European Commission’s Standard Contractual Clauses, together with supplementary safeguards where necessary.

Using an EEA-based contracting entity does not necessarily mean that all processing takes place within the EEA. This also applies to the AI services used for Seek4u.

You can request further information about relevant transfers and a copy of the applicable safeguards by contacting xx@digitaltree.com.cy.

Retention depends on the purpose for which information is processed, the Services you use and any applicable legal requirements. We do not retain all categories of information for the same period.

Account and Contract Records

We retain information needed to operate your account and provide requested Services while you have an active relationship with us. After that relationship ends or following a prolonged period of inactivity, we may retain limited records needed for contractual claims for up to six years, according to the applicable limitation periods. This does not mean that every CV, matching result or other item of account data is retained for that entire period.

We retain payment and accounting records for seven years. Other records are retained for a longer period only where an applicable legal obligation or a specific legal claim requires this.

Processing Based on Consent

Where processing is based on consent, we stop processing for that purpose when you withdraw your consent. We delete the personal data used solely for that purpose without undue delay, unless a separate lawful reason requires us to retain a limited record. Withdrawal does not affect the lawfulness of processing carried out before withdrawal.

Seek4u Profiles and Matching Information

We retain the information needed to provide Seek4u while you participate. The AI matching index contains the professional information used for matching, filtered text from uploaded CVs, numerical representations of that information and identifiers needed to associate it with your account. This index is maintained while your CV remains in the active matching pool described in Section 12 and is refreshed through regular synchronisation. Information is removed when a CV leaves that pool.

Vacancy-specific matching results and reusable copies of those results have a seven-day retention period. They expire after seven days and are removed during the next daily cleanup. They may be replaced or deleted earlier, including when you withdraw from Seek4u. The seven-day period applies to these results and cached copies, not to your main account, stored CV or the matching index while you remain eligible for it.

When you leave Seek4u, we stop making your profile and CV available through its search and recommendation features and stop submitting your information for new AI matching. We remove your existing recommendations from employer access and delete information held solely for matching, including the associated index entries, numerical representations and stored matching results, without undue delay. We also instruct relevant processors to delete data held on our behalf where it is subject to our deletion instructions.

An AI request already in progress when you withdraw may finish processing information that was sent before withdrawal. Any resulting recommendation is excluded from employer access through Seek4u. The deletion requirements in this section also apply to personal data remaining in the stored results of that request. Withdrawal does not retrospectively undo an earlier transmission or override the provider’s limited security and legal retention described below.

Leaving Seek4u does not automatically delete your Ergodotisi account, your own stored CV or records needed for other services you continue to use, such as eApply.

AI Provider Retention

We configure the AI analysis requests so that responses are not stored by OpenAI for later retrieval through the Responses API. This is separate from the matching results we retain within our own service and does not eliminate OpenAI’s standard security and abuse-monitoring retention.

Under OpenAI’s standard API arrangements, request and response content may be retained in abuse-monitoring logs for up to 30 days, unless longer retention is required by law or reasonably necessary to protect its services or third parties from harm. These provider records are separate from our seven-day matching results cache. Disabling optional model-training sharing does not disable this security retention.

Restricted Records and Backups

We may retain limited information where required by law or where necessary to establish, exercise or defend legal claims. This may include records demonstrating your participation choices and our handling of withdrawal requests. Such records are restricted to those purposes and are not used to continue Seek4u visibility or AI matching after withdrawal.

Where backup copies are maintained for platform services, restricted copies may remain until overwritten through the applicable backup cycle. They are not used for active matching and must not restore your participation if a backup is recovered.

Copies used for necessary technical support or testing must be restricted to that work and deleted when no longer needed, subject to any specific legal retention requirement. They must not be used to continue matching or employer access after withdrawal.

The retention periods in this section do not authorise continued processing for a purpose for which consent has been withdrawn.

For cookie retention periods, please see our cookie settings. For further information about retention for a particular category of information, contact xx@digitaltree.com.cy.

We use appropriate technical and organisational measures to protect personal data against unauthorised access, unlawful use, disclosure, modification and loss. Access is limited to authorised staff and service-provider personnel who need it for permitted functions, including necessary technical support and testing.

Our measures include staff training, access controls, HTTPS encryption, password hashing, firewall and network security, malware protection, business continuity arrangements and network protection services. We review these measures in light of the nature of the processing and the risks involved.

Our Services are intended for users who meet the age and legal-capacity requirements in our Terms and Conditions: individuals must be at least 18 years old or otherwise legally of age under applicable law and capable of entering into binding agreements.

We do not knowingly collect personal data from children who do not meet those requirements. If we become aware that such a child has provided personal data, we will take appropriate steps to delete it. If you believe this has occurred, please contact xx@digitaltree.com.cy.

You can choose whether to participate in Seek4u when the option is presented during account creation or profile editing. Your choice covers the Seek4u service, including candidate search and AI-assisted matching as described in this Policy.

You can leave Seek4u at any time through your account Settings. You may also contact xx@digitaltree.com.cy for assistance or to request withdrawal.

After you leave, your profile and CV will no longer be available to employers through Seek4u search or AI-assisted recommendations, and your information will no longer be used for new Seek4u matching. The deletion and limited retention arrangements in Section 8 apply.

Leaving Seek4u does not close your account. You can continue browsing vacancies, managing your CV and applying for jobs through eApply. Your previous applications are not automatically withdrawn.

Your right to leave Seek4u continues after any announced launch or policy update date. You may choose to participate again later.

You can manage marketing preferences and non-essential cookies separately from your Seek4u participation. You may also choose not to provide optional information or request closure of your account. Some information is necessary to provide a requested service; we explain this when collecting it.

AI Assisted Matching Within Seek4u

Seek4u uses AI-assisted matching to help employers discover participating candidates whose professional background may be relevant to a vacancy. This involves profiling because automated processing is used to evaluate the correspondence between a candidate’s professional information and job requirements.

The system compares relevant information from your profile and CV, such as experience, skills, education, qualifications, certifications and languages, with the requirements stated in an employer’s advertisement. For example, a qualification or certificate mentioned in your CV may contribute to a match where the vacancy requires it.

The current AI matching process uses a regularly refreshed pool of up to 10,000 of the most active eligible Seek4u candidates, with one CV per candidate. Numerical representations of professional information help identify an initial shortlist of up to 50 relevant CVs for more detailed comparison with a vacancy. The system then scores and ranks that shortlist, subject to the employer’s access restrictions. Activity, inclusion in the current pool and the information the system can read can therefore affect whether a candidate is considered for an AI recommendation.

The comparison can generate a matching score and ranking for that particular vacancy. Employers may see up to ten recommended candidates in a separate AI matching view. The recommendations are drawn from the candidates the employer is already entitled to access through Seek4u.

Employers can also browse the wider eligible candidate database. Not appearing among the AI recommendations does not remove your profile from that database or prevent you from applying directly for a vacancy.

What Matching Means for You

AI matching can help an employer discover your profile, but it may also influence which profiles the employer reviews first. A matching score is an automated assessment of correspondence with a particular advertisement. It is not a verification of your qualifications, a general assessment of your professional ability or a prediction or guarantee of employment.

Results depend on the information available and may be incomplete or inaccurate. Matching uses selected information and limited extracts rather than necessarily assessing every part of a CV. Scanned images and text that cannot be extracted may not be included. Missing, unreadable or outdated information can affect a score or whether a profile appears among the recommendations. Keeping your profile and CV up to date and using a readable text-based CV helps the system work with current information.

Matching is intended to assess relevant professional requirements. The selection and filtering described in Section 7 reduce unnecessary personal information but cannot guarantee that all sensitive or irrelevant information is removed. You can ask us to review inaccurate information or raise a concern about an inappropriate matching result using the contact details below.

Human Involvement

Ergodotisi’s matching feature generates recommendations; it does not itself make hiring decisions, reject applications or submit applications on your behalf. Employers are responsible for reviewing relevant candidate information and making their own recruitment decisions in accordance with applicable law. A recommendation or score should not be treated as a substitute for that review.

You can contact xx@digitaltree.com.cy to request information about the personal data used in matching, raise a concern about a result or ask us to investigate inaccurate information. We will review the concern and take appropriate corrective action where necessary.

Other Profiling

Where you have consented to relevant job alerts or marketing communications, we may also use information such as your selected job categories or location to make those communications more relevant. Advertising and non-essential analytics remain subject to their separate consent arrangements.

You can withdraw the relevant consent at any time. For direct marketing, you also have the right to object at any time, including to profiling associated with that marketing.

Subject to the conditions and exceptions in the GDPR, you have the following rights in relation to your personal data:

• Withdrawal of consent: you can withdraw consent at any time. Withdrawal does not affect the lawfulness of processing based on consent before withdrawal.
• Access: you can request confirmation that we process your personal data, information about that processing and a copy of the personal data we hold about you.
• Rectification: you can request correction of inaccurate personal data and completion of incomplete information.
• Erasure: you can request deletion where the information is no longer necessary, you withdraw consent and no other legal basis applies, an objection requires processing to stop, processing was unlawful, deletion is required by law, or another GDPR ground for erasure applies.
• Objection: where processing relies on legitimate interests, you can object for reasons relating to your particular situation. We must stop unless we demonstrate overriding compelling legitimate grounds or need the information for legal claims. You can object to direct marketing at any time, including related profiling, without that balancing test.
• Restriction: you can request that we limit processing where the GDPR conditions apply, for example while we assess the accuracy of disputed information.
• Portability: where processing is automated and based on consent or a contract, you can request the personal data you provided in a structured, commonly used, machine-readable format and, where technically feasible, transmission to another controller.

Your rights also apply to personal data generated through Seek4u matching, including scores and other matching information that we hold about you. Subject to applicable legal conditions, you may request access to that information, correction of inaccurate personal data, restriction of processing or deletion.

Nothing in this Policy limits your protections under Article 22 GDPR concerning decisions based solely on automated processing that produce legal or similarly significant effects. Where its safeguards apply, these include the right to obtain human intervention, express your point of view and contest the decision.

To exercise your rights, contact xx@digitaltree.com.cy. We may request information reasonably needed to verify your identity. We will respond without undue delay and normally within one month. Where the GDPR permits an extension because of complexity or the number of requests, we will explain the extension within that first month. If we cannot comply with a request, we will explain the reason and your right to complain or seek a remedy.

We may update this Privacy Policy to reflect changes to our Services, processing activities or legal obligations. The date of the latest update appears at the beginning of this Policy.

For material changes affecting how we use your personal data, we will provide an appropriate notice, such as an email or an account notification, before the relevant change takes effect where required by law.

Publishing an updated Policy, your continued use of the platform or your failure to respond to a notification does not, by itself, constitute consent to new processing. Where a change requires fresh consent, we will obtain it before carrying out the processing concerned.

You can review and change your Seek4u participation and other privacy preferences at any time.

We are responsible for complying with applicable data protection law and for taking appropriate measures to protect personal data. If we identify a failure affecting our processing of personal data, we will investigate and take appropriate corrective action.

Nothing in this Policy excludes or limits your statutory data protection rights, including your right to complain to a supervisory authority or seek a remedy where provided by law.

For questions about this Policy, our handling of personal data or the exercise of your rights, please contact MELIOR CAPITAL LTD using the following privacy contact details.

Email: xx@digitaltree.com.cy

Telephone: +357 22 285238

Complaints

You may contact us to raise a concern or complaint about our processing of your personal data. You also have the right to complain directly to a competent supervisory authority, including the Office of the Commissioner for Personal Data Protection in Cyprus. You do not have to contact us first.

Cyprus Commissioner: www.dataprotection.gov.cy