Effective as of August 2026
1. Introduction
This privacy policy (“Policy”) provides information about how the Flo Health group of companies (collectively, “Flo,” “we,” or “us”) collect and process your personal data in the context of employee and contractor recruitment. Read this Policy carefully, as it contains important information about the data we process, the purposes and legal basis for processing, recipients of your data, personal data protection rights, and other useful information.
2. What personal data we collect from you
The personal data that we collect from job applicants and prospective contractors may include, where reasonably necessary:
- full name;
- contact information (e.g., email, phone number, address);
- education, skills, and training;
- current workplace and employment history;
- recommendations and references;
- CV, cover letter and any attachments you choose to share;
- location;
- publicly available information (e.g., information from professional social networks);
- interview data (such as test tasks, interview notes and your feedback);
- compensation information and expectations;
- visa and citizenship status;
- verification data, including the results of background checks carried out in relation to you and your employment (such as employment history and identity verification) - the scope of these checks will vary depending on factors such as your location and the role you have applied for;
- information necessary to prepare and administer your employment or service contract; and
- any other information submitted by you.
If you choose to disclose it, we may also collect information relating to your:
- gender;
- veteran status;
- ethnic origin; and/or
- disabilities.
The collection of such data is entirely voluntary, and you are under no obligation to disclose this information. Your decision to provide or withhold such information will not affect your candidacy. When applying, please avoid including any information that is unnecessary for the recruitment process.
Video recording: when and why it may be proposed
If an interviewer is unable to attend your interview, we may record the interview for later review. This helps us make efficient use of your time and avoids the need to reschedule. Any recording will be accessible only to the internal recruiter managing your application, and the relevant interviewer(s) in attendance. Recordings are stored securely and deleted at the end of the recruitment process.
You will always be informed in advance if we intend to record your interview, and you may opt out at any time. Choosing not to be recorded will not affect your application or the outcome of the recruitment process in any way.
3. Why we collect your personal data
We are always looking for talented individuals to help us build a better future for female health. When you apply, or are contacted by us regarding open positions at Flo (either directly or through a recruitment agency), we collect and process your personal data for recruitment purposes which may include to:
- communicate with you;
- verify your information;
- assess your application and suitability for entering into an employment or service agreement with Flo;
- comply with applicable laws, legal processes, or enforceable government requests;
- notify you of future job opportunities where we have your consent;
- monitor diversity, equal opportunities, and your candidate experience;
- carry out background and reference checks as appropriate and in accordance with applicable law; and
- any other activities necessary to administer and manage your application process.
We may instruct our background verification provider to contact you to start your verification process. After you have agreed to proceed, the provider will reach out to you. They will ask for your permission to contact relevant third parties, such as former employers, to verify details like your employment history and dates. Once this verification is completed, this information will then be shared with us.
4. How we process your personal data
We will process your personal data based on one or more of the following legal bases:
- Your consent: For example, if your application is unsuccessful, we will ask for your permission to retain your CV and personal data for consideration in future opportunities within Flo.
- Legal obligation: We may be obligated to process some of your personal data to comply with applicable laws and regulations, for example, to make reasonable adjustments for applicants with disabilities or to conduct checks for eligibility to work in a particular territory, as required by immigration laws.
- Legitimate interest: We may process your personal data to evaluate and improve efficiency in our recruitment process. This includes conducting analytics, forecasting recruitment trends or streamlining processes.
- Contract: We may process your personal data where necessary to take steps prior to entering into an employment or service contract with you, including assessing your suitability for the role and preparing to formalise the employment or contractor relationship.
5. How we collect your data
Generally, we collect your information directly from you. We may also obtain information from:
- other Flo entities within Flo’s corporate group (for example, if you have been referred to another job position at Flo);
- job portals and recruitment & contractor agencies (e.g. Indeed Inc., Glassdoor Inc.);
- recruitment tools (e.g., Greenhouse Inc., Metaview Global Ltd);
- professional social media networks (e.g., LinkedIn);
- Flo employees (e.g., referrals); and
- background-checking service provider (e.g., Veremark Ltd.)
6. Who we share your data with
Your personal data may be shared with other companies within Flo’s corporate group for recruitment purposes, including where we consider your profile may be better suited to other roles within Flo, as described in this Policy.
We may also share your data with our contracted service providers (“Processors”) that help us with the recruitment process, such as:
- Crosschq Inc. (TalentWall) – United States; hiring management platform
- Greenhouse Software Inc. – United States; recruitment software provider
- Zoom Inc. – United States; video conferencing platform
- HiBob Inc. – Israel; people management platform
- Remote Technology Services Inc. – United States; hiring management platform and employer of record
- Veremark Ltd – United Kingdom; background verification platform
- Metaview Global Ltd – United Kingdom; AI powered recruitment platform
- Google Cloud EMEA Ltd (Gemini) – Ireland; video conferencing platform and AI powered note-taking solution
- Anthropic Ireland Ltd – Ireland; AI platform provider
We use Processors to support our recruitment processes, including providers of communication platforms, IT infrastructure service, and analytics services. These Processors are carefully selected to ensure they comply with our privacy and security standards. Flo remains responsible for any acts or omissions of our processors and we execute formal data processing agreements with them, as required by applicable law. We do not allow these providers to sell or share your data, and they may not use your data for any other purpose other than what we have contracted them for.
In some cases, your personal data will be processed within the European Union (“EU”) and the European Economic Area (“EEA”). However, where necessary, it may be transferred to and processed in countries outside these territories. When we transfer personal data outside the EEA (for example, to the United States), we ensure that appropriate safeguards are in place to protect your data. These may include reliance on the EU–US Data Privacy Framework, the Swiss–US Data Privacy Framework, and the UK Extension to the EU–US Data Privacy Framework, as well as the use of standard contractual clauses and, where required, supplementary measures.
7. Data Privacy Framework Participation
Flo Health Inc. is certified under the EU–US Data Privacy Framework and the Swiss–US Data Privacy Framework for transfers of personal data from the EU and Switzerland to the United States. You can view our certification here.
8. How long we store your personal data
We retain your personal data for as long as necessary to fulfil the purposes described in this Policy. In general, this means that your personal data will be retained for the duration of the recruitment process. However, we may retain your personal data for longer where required or permitted by applicable law, including in the following circumstances:
- Legal and compliance purposes: where retention is necessary to comply with legal obligations or to establish, exercise, or defend legal claims arising from the recruitment process.
- Future opportunities: where you have consented to us contacting you about future roles, we will retain your data for up to three years following the end of the initial recruitment process.
- Successful applications: if you become an employee or contractor at Flo, your personal data will be retained as part of your employee/contractor record in accordance with our internal employee data retention policies.
- Background checks: information obtained through background verification checks will generally be retained for six months after completion, unless a longer retention period is required by law.
9. Automated decision-making / AI Tooling
As part of our recruitment process, we may use systems that automatically screen applications against predefined criteria (such as location or qualification requirements), which may result in some candidates not progressing. However, decisions regarding your candidacy are not based solely on automated processing. We take additional factors into account and involve human review to ensure a fair and comprehensive assessment of all applicants.
We may also use our vendors to provide AI-powered tools to help streamline administrative aspects of our recruitment process, such as supporting note-taking, sourcing candidates, and improving the overall quality and efficiency of hiring. This processing is subject to human review and does not involve automated decision-making. You can choose to opt-out of these tools, and doing so will not result in any unfavourable treatment. You may also request the deletion of your personal data at any time. While we make every reasonable effort to comply with such requests, certain information may be retained where required or permitted by applicable law.
For more information regarding the use of AI in our recruitment processes, please refer to our Supplementary Privacy Notice (Use of AI in Flo’s Recruitment) which you can find at Annex 1 of this Policy.
10. What happens if you don’t provide us with your personal data
You are not obliged to provide your personal data to Flo. However, as certain information is necessary for us to assess your application and progress the recruitment process, we may be unable to consider you for employment or service contract if you do not provide certain information.
11. Your rights
Under applicable privacy laws, including the General Data Protection Regulation, you have certain rights in relation to your personal data. Subject to any limitations under applicable law, these rights include:
- Right of Access: You have the right to request access to your personal data that Flo processes about you and to request information about what personal data we hold about you, the purposes of the processing, and other related information.
- Right to Rectification: If you believe that we hold any incomplete or inaccurate data about you, you have the right to ask us to correct and/or complete the information.
- Right to Erasure: You also have the right to request the erasure of your personal data or to restrict processing in accordance with the data protection laws.
- Right of Data Portability: You have the right to request a copy of your personal data in electronic format and to transmit that personal data to another party.
- Right to Withdraw Consent: Where we rely on your consent to process your personal data, you have the right to withdraw that consent at any time. Withdrawal of consent does not affect the lawfulness of any processing carried out prior to its withdrawal.
- Right to Object to Processing: If your personal data is processed based on our legitimate interests (as outlined above), you have the right to object. We will carefully consider your request and stop processing for the specified purposes unless we can demonstrate a legitimate ground to override your objection, such as the defense of a legal claim.
Right to Complain if you based in the UK
If you are based in the UK, you have the right to lodge a complaint with the Information Commissioner’s Office (ICO) if you believe your data protection rights have been infringed. When you raise a complaint with us, we will:
- facilitate the submission of your complaint, which can be done using the contact details below;
- acknowledge receipt of the complaint within the statutory timeframe of 30 days from the date it is received;
- take appropriate and proportionate steps in response to the complaint, including conducting reasonable enquiries and investigations as necessary; and
- keep you informed of the progress and outcome of the complaint in a timely and transparent manner.
12. Contact us
If you apply or are referred for a role at one of our locations in the UK or Lithuania, the Flo entity responsible for that location is responsible for supporting the hiring process. Contact details for the relevant entities are set out below.
- Flo Health UK Limited (United Kingdom)
Address: Fourth Floor South, International House, 1 St. Katharine’s Way, London, E1W 1UN, United Kingdom - Flo Health LTU UAB (Lithuania)
Address: Saltoniškių st. 2-1, 08126 Vilnius, The Republic of Lithuania
We only process your personal information in compliance with this Policy and in accordance with the relevant data protection laws. If, however, you wish to raise a complaint regarding the processing of your personal data or are unsatisfied with how we have handled your information, please email our data protection officer at dpo@flo.health.
You can also complain to your local data protection authority or other local regulatory body responsible for ensuring protection of your rights relating to the handling of personal data. Without prejudicing your rights, we kindly request that you contact us first so we can work together to resolve the issue.
If you have any questions regarding this Policy or your privacy, please email us at hr@flo.health, or you can email Flo’s data protection officer at dpo@flo.health.
Annex 1: Supplementary Privacy Policy (AI)
1. Introduction
This Supplementary Privacy Policy (“Policy”) describes how the Flo Health group of companies (collectively, “Flo”, “we” or “us”) uses artificial intelligence (“AI”) when collecting and processing personal data as part of the hiring process. It should be read together with Flo’s Job Applicant Privacy Policy above (the “Main Policy”).
2. AI Providers
The third party data processors we engage with for this purpose are:
- Google Cloud EMEA Ltd (Gemini) - Ireland; AI powered note-taking solution
- Metaview Global Ltd - United Kingdom ; AI powered recruitment platform
- Greenhouse Software Inc. - United States; recruitment software provider, with AI features
- Anthropic Ireland Ltd - Ireland; AI software platform
Collectively (“AI Providers”).
We carry out appropriate due diligence on our AI Providers before using their tools, including assessing their approach to safety, fairness, and non-discrimination. This includes reviewing their controls, testing outputs where appropriate, and ensuring they meet our internal standards and applicable legal requirements.
3. How do we use AI Providers ?
Our AI providers support our hiring process by improving efficiency and the overall quality of recruitment. These tools may be used to:
- transcribe interviews to ensure accuracy and completeness;
- provide feedback to interviewers to strengthen their skills and support Flo in delivering a consistently high-quality, fair, and objective interview process;
- generate structured, objective summaries of candidates based on the information you provide;
- identify potential candidates in line with our specified job requirements;
- ensure adherence to Flo’s standards on fairness and non-discrimination.
These tools are used solely to support administrative aspects of the recruitment process. Any AI-generated outputs relating to your candidacy are used only as a reference point to assist our team in recalling objective information when forming their own assessments. All hiring decisions are made by humans, who consider relevant factors and apply independent judgment to ensure a fair and comprehensive evaluation of every candidate.
4. Information collected
Our AI Providers may transcribe your interview, which involves capturing information shared during the conversation. Before any relevant details are added to your candidate profile, the interviewer will review and approve the transcript to ensure accuracy. We may also collect relevant information from publicly available professional profiles.
For details of the specific categories of data that may be collected during the interview process, please refer to our Main Policy.
5. How we process your personal data
We process your personal data in connection with AI Providers on the basis of our legitimate interests. We have carried out appropriate assessments, as required by applicable law, and have carefully ensured that this processing does not override your fundamental rights and freedoms.
For a comprehensive overview of how we process your personal data for other purposes, please refer to the Main Policy.
We do not use AI Providers to intentionally collect special category data. However, given the nature of interviews and conversations, such data may be incidentally disclosed. Where this information is relevant to your candidacy (for example, where you discuss legal requirements relating to your entitlement to work), it may be reviewed and recorded on your candidate profile. In such cases, we will process this information in accordance with the relevant special category purposes outlined in the Main Policy.
6. Your Rights
You can opt out of the use of AI Providers at any stage of the hiring process without any impact on your application or final hiring decision. Your interviews will proceed as scheduled, and the tools will not be used. To opt out, please follow the link in your interview invite or contact us at hr@flo.health.
To opt-out, please follow the link in your interview invite or contact us at: hr@flo.health
This opt-out applies only to our use of AI Providers. Personal data collected and processed on other legal bases may continue to be retained and used as outlined in the Main Policy. For more information about your rights, please refer to the Main Policy.
7. Who will access your personal data
We may share information collected by our AI Providers with our Processors outlined in our Main Policy.
Your interview transcripts are generally accessible only to those who participated in the interview. Only in rare and exceptional circumstances may a limited number of authorised Flo employees access transcripts despite not having been present. This may occur for purposes such as:
- addressing disputes or complaints related to the hiring process;
- where strictly necessary to review and improve our interview practices, where we reasonably consider this appropriate; and
- supporting senior hiring managers where a final decision cannot be reached.
If a decision is influenced by an interview where the decision-maker was not present, they are required to consult with attendees to ensure appropriate context is understood before any final employment decision is made.
8. Automated Decision-Making
The AI Providers are not used for automated decision-making. Specifically:
- Transcript: All transcript data is subject to human review before being imported into a candidate profile, and is only used to support interviewers’ recall before they make their own decisions.
- Objective Candidate Summaries: The AI Summaries are only capable of providing objective information, and any information extracted is verified by a human. The system has been programmed to reject any question that is considered subjective. For example, an error message will occur if a question such as ‘Should I hire this candidate?’ is entered.
- Insights: The insights data is used solely to evaluate and improve our hiring processes and related practices. Identifiable information is used only where necessary and only in relation to Flo employees, for the purpose of developing interview skills and supporting adherence to our standards of fairness and non-discrimination. Information relating to candidates is aggregated so that no individual candidate can be identified.
- Sourcing: AI sourcing tools are configured in accordance with Flo’s role-specific requirements and hiring criteria. These tools generate candidate suggestions based on those predefined specifications. All suggestions are subject to human review, and any decisions regarding candidate selection or outreach are made solely by our team, applying independent judgment in line with our standards of fairness and non-discrimination.
9. Data Retention
Personal data collected through AI Providers as part of your recruitment process will be retained in accordance with our Main Privacy Policy. Any information collected by AI Providers that is not required for the retention purposes set out in the Main Policy will be deleted at the end of the recruitment process. This applies regardless of your application outcome or any consent to retain your information for future opportunities. Where personal data is used to improve or streamline our internal recruitment processes, it will be de-identified or aggregated so that it can no longer reasonably be used to identify you.
10. Contact or Complaints
If you have any questions relating to the use of AI in our recruitment process, please contact hr@flo.health. Or you can email Flo’s data protection officer at dpo@flo.health.
For data protection concerns, contact our Data Protection Officer at dpo@flo.health. You may also raise complaints with your local data protection authority or regulatory body, as detailed in the Main Policy