Privacy Policy

Last updated: August 2026

At Easter Hay ApS, we take the protection of your personal data seriously. This Privacy Policy explains how we collect, use, store and protect personal data in connection with our recruitment and consultancy services and when you visit our website.

1. Data controller

Easter Hay ApS is the data controller responsible for the processing of your personal data.

Easter Hay ApS
Hyttekrogen 12
2665 Vallensbæk Strand
Denmark
Company registration no. (CVR): 42739456

Phone: +45 41 22 00 32
Email: kimi@easterhay.dk

If you have any questions about how we process your personal data, you are always welcome to contact us.

2. What personal data do we process?

The personal data we process depends on your relationship with Easter Hay.

Candidates and freelance consultants

In connection with recruitment and the placement of freelance consultants, we may process information including:

• Name and contact details
• Address and geographical location
• CV and educational information
• Employment history and professional experience
• Skills and professional qualifications
• Experience with Microsoft Dynamics 365, Power Platform and related technologies
• Job preferences and career interests
• Salary expectations or expected hourly rate
• Availability
• Information from interviews and other communication with you
• References, where relevant and agreed with you
• Other information you choose to provide in connection with a recruitment or consultancy process

Clients and business contacts

If you are a client, prospective client or contact person at a company, we may process information including:

• Name
• Job title and company
• Telephone number and email address
• Information about the company's recruitment or consultancy requirements
• Correspondence and information relating to our business relationship

3. Where do we obtain your data?

We primarily obtain personal data:

• Directly from you
• From your CV
• From LinkedIn and other professional, publicly available sources
• Through telephone calls, email, LinkedIn or meetings
• From clients or other professional contacts
• Through forms and functions on our website
• Through skills questionnaires that you voluntarily choose to complete

If we find your profile through LinkedIn or another professional source and consider your background relevant to our specialist recruitment area, we may contact you regarding a potential job or consultancy opportunity.

4. Skills information via Microsoft Forms

As part of our work with candidates, we may ask you to voluntarily complete a skills questionnaire using Microsoft Forms.

The purpose is to obtain a more detailed understanding of your experience and expertise within Microsoft Dynamics 365, Power Platform and related professional areas.

Your responses may subsequently be recorded on your candidate profile in our recruitment system, Manatal, and form part of our overall assessment of your profile.

The information may be used when assessing your suitability for specific permanent positions or freelance assignments. Relevant skills information may also be included in a presentation to a client when, by agreement with you, we present your profile to that client.

Completing a skills questionnaire is voluntary. Choosing not to complete one does not prevent you from being considered as a candidate by Easter Hay.

5. Purposes of processing

We process personal data in order to, among other things:

• Assess candidates' skills and experience
• Match candidates and freelance consultants with relevant opportunities
• Contact candidates about current and future permanent positions or freelance assignments
• Present relevant candidates to clients by prior agreement with the candidate
• Carry out recruitment and consultancy processes
• Communicate with clients, candidates and business partners
• Administer agreements and business relationships
• Document completed recruitment and consultancy processes
• Comply with applicable legislation

6. Legal basis for processing

Depending on the circumstances, we process ordinary personal data on one or more of the following legal bases.

Legitimate interests

We may process personal data under Article 6(1)(f) of the GDPR where processing is necessary for our legitimate interest in operating a specialised recruitment and consultancy business. This may include identifying and contacting relevant candidates and facilitating contact between candidates and companies.

Steps prior to entering into a contract and performance of a contract

We may process personal data under Article 6(1)(b) of the GDPR where processing is necessary to perform a contract with you or to take steps at your request before entering into a contract.

Legal obligation

In certain circumstances, we process personal data under Article 6(1)(c) of the GDPR where processing is necessary to comply with a legal obligation.

Consent

Where a specific type of processing requires your consent, we will obtain it separately. In such cases, processing will be based on Article 6(1)(a) of the GDPR.

These are recognised legal bases under Article 6 of the GDPR; consent is only one of several possible grounds for lawful processing.

7. Sharing personal data

We do not share your CV or candidate profile with a prospective employer or client without prior agreement with you.

When you are being considered for a specific permanent position or freelance assignment, relevant information may be shared with the company seeking an employee or consultant.

This may include:

• CV
• Professional experience
• Skills and professional qualifications
• Relevant information from our communication with you
• Salary expectations or hourly rate, where relevant
• Information from skills assessments

We also use external IT and system providers that may process personal data on our behalf. These include providers of recruitment systems, Microsoft services, hosting and other IT services.

Where a supplier processes personal data on our behalf, this is done in accordance with applicable data protection rules and relevant data processing agreements.

8. Manatal

Easter Hay uses Manatal as its recruitment and candidate database.

Information about candidates and freelance consultants may be registered in Manatal for the purpose of managing candidate relationships, skills, communication and current or future recruitment and consultancy opportunities.

Easter Hay is the data controller for the personal data we enter into Manatal, while Manatal processes that information on our behalf as a data processor. Manatal's current Data Processing Addendum confirms this controller/processor relationship.

Our current Danish Privacy Policy states that Manatal's servers are located in the United States. Personal data may therefore be transferred to and processed outside the EU/EEA. Where such a transfer takes place, it must be based on a valid transfer mechanism and appropriate safeguards in accordance with applicable data protection legislation, including, where relevant, the European Commission's Standard Contractual Clauses or another approved transfer mechanism. Manatal's current DPA expressly provides for the EU Standard Contractual Clauses where its services involve relevant transfers outside the EEA.

9. How long do we retain your personal data?

Candidate information in Manatal is generally retained for up to 24 months.

After this period, the information is deleted or, where relevant and lawful, the need and legal basis for continued retention is reassessed.

If you are involved in a specific recruitment process, consultancy agreement or other business relationship, certain information may need to be retained for a longer period for purposes such as documentation, accounting requirements or potential legal claims.

You may contact us at any time if you no longer wish to remain registered in our candidate database.

10. Special categories of personal data

As a general rule, we do not need special categories of personal data, such as information concerning health, religion, political opinions, sexual matters or other sensitive personal data.

We therefore recommend that you do not include such information in your CV or other material unless it is relevant and necessary in the specific circumstances.

If we exceptionally need to process such data, we will do so in accordance with applicable data protection legislation and on the basis of a valid legal ground.

11. Security

We implement appropriate technical and organisational security measures designed to protect personal data against accidental or unlawful destruction, loss, alteration, unauthorised disclosure or access.

Access to personal data is limited to persons and suppliers who have a legitimate need to access the information.

12. Your rights

When we process personal data about you, you have a number of rights under data protection legislation.

Depending on the circumstances, you may have the right to:

• Access the personal data we process about you
• Have inaccurate personal data corrected
• Have personal data deleted
• Restrict the processing of your personal data
• Object to our processing
• Receive certain personal data in a structured, commonly used and machine-readable format
• Withdraw your consent where processing is based on your consent

Your rights depend on the specific legal basis for the processing, and not every right therefore applies in every situation.

If you wish to exercise any of your rights, please contact us at kimi@easterhay.dk. The Danish Data Protection Agency also describes the applicable rights and the circumstances in which they apply.

13. Complaints to the Danish Data Protection Agency

If you are dissatisfied with the way we process your personal data, you are welcome to contact us first.

You also have the right to lodge a complaint with the Danish Data Protection Agency (Datatilsynet).

Further information about your rights and how to lodge a complaint is available on the Danish Data Protection Agency's website.

14. Cookies and the website

When you visit Easter Hay's website, necessary cookies are used. Depending on the functions used on the website and the choices you make, other cookies or similar technologies may also be used.

Cookies and similar technologies requiring consent are only used once the necessary consent has been provided.

You can find more information about our use of cookies and manage your choices through the website's cookie settings.

15. Changes to this Privacy Policy

We may update this Privacy Policy from time to time, for example if the way we process personal data changes or if applicable legislation changes.

The latest version will always be available on the Easter Hay website.

Last updated: August 2026