Privacy Policy

This Privacy Policy explains how Scrubs Group collects, uses, and protects personal data submitted through our platform for recruitment and workforce engagement at construction sites across Europe.

1. Data Controller

GRĀU STUDIOS
Viale IV Novembre 78b, 31100 Treviso (TV), Italy
VAT No. 05127460268
Sole proprietorship of Francesco Tiberi

Contact: info@graustudios.com

We have not appointed a Data Protection Officer. For privacy matters, please contact Francesco Tiberi at the email address above.

2. What data we collect

We collect personal data directly from you through online forms, including:

• Identification and contact information: first name, last name, email address, phone number, date of birth
• Professional information: CV/resume and the qualifications, experience, and skills contained in it
• Identity documents: photos or scans of identity documents you upload
• Bank details: bank account information (IBAN or equivalent) collected in a subsequent step when needed for payment setup

Please do not include sensitive personal data (e.g., health information, trade union membership) in your CV or uploads unless strictly necessary.

3. Why we use your data

We process your personal data solely for recruitment and workforce engagement purposes, including to:

• Evaluate your profile and match you to work opportunities at construction sites
• Contact you about roles, availability, and onboarding
• Verify identity and eligibility where reasonably necessary for onboarding and site access
• Set up administrative and payment arrangements when a working arrangement is established
• Maintain an internal candidate pool to manage current and future staffing needs

We do not use your data for marketing, advertising, profiling for unrelated commercial purposes, or selling personal data.

4. Legal basis for processing

Depending on the context, we rely on one or more of the following legal bases under the GDPR:

• Contract / pre-contractual measures: to assess your application and take steps at your request before entering into a working arrangement
• Legitimate interests: to operate our recruitment and workforce management activities while respecting your rights and expectations
• Legal obligations: to comply with applicable employment, tax, social security, workplace safety, and other legal requirements
• Consent: where required by law for specific processing activities; you may withdraw consent at any time without affecting prior processing

5. Who we share your data with

We share personal data only when necessary for the purposes described above:

• Authorized personnel of GRĀU STUDIOS (recruitment, operations, administration)
• Service providers acting on our behalf (e.g., IT, hosting, database management) under appropriate contractual safeguards
• Construction site clients/companies only when necessary for you to work at a specific site (e.g., for onboarding, access authorization, assignment coordination). These companies act as independent controllers and are responsible for their own use of your data under their privacy policies.
• Professional advisers (legal, accounting) when needed
• Public authorities where required by law

We do not share your personal data with third parties for their independent marketing purposes.

6. International transfers

Work opportunities may involve construction sites in different European countries. If personal data is transferred outside the European Economic Area (EEA), we will use lawful transfer mechanisms and appropriate safeguards as required by data protection law (for example, Standard Contractual Clauses or adequacy decisions).

7. How long we keep your data

We retain personal data only for as long as necessary for the purposes described in this Policy and in compliance with applicable law.

• Candidate profile data (contact details, CV): retained while you remain in our active candidate pool. We periodically review records (at least every 24 months) and delete or anonymize data that is no longer needed, unless retention is required by law or for the establishment, exercise, or defense of legal claims.
• Identity document images: retained only as long as reasonably necessary for verification, onboarding, site access, and compliance, then securely deleted or restricted.
• Bank details: retained only as long as needed for payment setup/administration and any mandatory legal retention periods.

You can request deletion of your data at any time (see Section 9).

8. Security

We implement appropriate technical and organizational measures to protect personal data against unauthorized access, loss, alteration, or disclosure, including access controls, secure authentication, encryption, and regular security reviews.

While we take data protection seriously, no system can be guaranteed 100% secure.

9. Your rights

Subject to applicable law (including the GDPR), you have the right to:

• Access your personal data
• Rectify inaccurate or incomplete data
• Request erasure of your data (in certain circumstances)
• Restrict processing (in certain circumstances)
• Object to processing based on legitimate interests
• Data portability (where applicable)
• Withdraw consent at any time where processing is based on consent
• Lodge a complaint with the competent supervisory authority (in Italy: Garante per la Protezione dei Dati Personali – www.gpdp.it)

How to exercise your rights: Email info@graustudios.com. We may request information to verify your identity before fulfilling requests, especially those involving identity documents or bank details.

10. Automated decision-making

We do not make decisions based solely on automated processing (including profiling) that produce legal effects concerning you or similarly significantly affect you.

11. Children

Scrubs Group is not intended for individuals under the age of 18. If you believe a minor has submitted personal data, please contact us so we can take appropriate action.

12. Changes to this Policy

We may update this Privacy Policy from time to time. We will publish the updated version on our platform and update the “Last updated” date at the top of this page.

13. Contact

GRĀU STUDIOS
Viale IV Novembre 78b, 31100 Treviso (TV), Italy
VAT No. 05127460268
Email: info@graustudios.com