This policy follows the EU General Data Protection Regulation (GDPR) and Spain's Organic Law 3/2018 on data protection (LOPDGDD). If anything is unclear, use the contact details in section 1.
1. Who we are
The data controller is Assertive Recruiting, a recruitment business run by a self-employed professional (autónoma) established in Spain.
- Business nameAssertive Recruiting
- Based inBarcelona, Spain
- Privacy contactalicia@assertiverecruiting.com
- Websiteassertiverecruiting.com
2. What data we collect and where it comes from
| Who you are | Data we collect | Where it comes from |
|---|---|---|
| Client or prospective client (a company that is hiring) | Name, job title, company, work email, phone, messages, details of the roles you want to fill, billing details | You, through our contact form, email, calls or video meetings |
| Candidate | Name, contact details, CV, work history, skills, salary expectations, interview notes, references you provide | You, through applications or conversations; your public professional profiles (for example LinkedIn); people who refer you to us |
| Business contact we reach out to | Name, job title, company, work email or LinkedIn profile, and the public hiring information that led us to contact you | Public professional sources such as LinkedIn and company websites |
| Website visitor | Technical data such as IP address and browsing data, when you accept cookies | Your browser; you choose which cookies to allow in the cookie banner on our website |
We do not ask for sensitive data, such as health, religion or ethnic origin. Please do not include it in your CV or messages.
3. Why we use your data and the legal basis
| Purpose | Legal basis under the GDPR |
|---|---|
| Reply to your enquiry and prepare a proposal | Steps you asked us to take before a contract (art. 6.1.b) |
| Provide our recruitment service to clients and manage the agreement | Performance of the contract (art. 6.1.b) |
| Assess candidates for roles and keep your profile for future opportunities | Your consent (art. 6.1.a), which you can withdraw at any time |
| Present your profile to a specific employer | Your consent for that employer, given before we share anything |
| Contact business decision-makers about our recruitment services | Our legitimate interest in offering our services to companies that are hiring (art. 6.1.f). You can object at any time, and we will stop |
| Send hiring insights or newsletters by email | Your consent (art. 6.1.a); unsubscribe at any time |
| Invoicing, accounting and tax | Legal obligation under Spanish tax and commercial law (art. 6.1.c) |
| Establishing or defending legal claims | Our legitimate interest (art. 6.1.f) |
Our service is always free for candidates. Only employers pay our fees.
4. AI-assisted screening and human review
We may use AI tools to help search for candidates or summarise CVs. A person always reviews the results, and no decision about you is made by automated means alone. Hiring decisions are always made by the employer, not by us or by any AI tool.
5. Who receives your data
We never sell personal data. We share it only with:
- Employers (our clients): a candidate's profile, and only after the candidate has agreed to be presented to that specific employer.
- Service providers that process data on our behalf, under a data processing agreement:
- Google (Google Workspace and Google Cloud): email, documents and storage;
- our recruitment software (applicant tracking system): candidate and client records;
- Anthropic (Claude): an AI assistant that helps us search for candidates and summarise CVs, always with human review;
- Calendly: scheduling calls and meetings;
- Stripe: payment and invoicing of our fees;
- Hostinger: hosting of our website and contact form;
- LinkedIn: professional networking and messages.
- Our tax advisor (gestoría), for accounting and tax filings.
- Public authorities, when the law requires it.
6. Transfers outside the European Union
Most of our clients are in the United States, and some of our service providers store data there. When we send personal data outside the European Economic Area, we protect it in one of these ways:
- the recipient is certified under the EU-US Data Privacy Framework, which the European Commission recognises as providing adequate protection; or
- we sign the European Commission's Standard Contractual Clauses with the recipient.
You can ask us for a copy of the safeguards that apply to your data at alicia@assertiverecruiting.com.
7. How long we keep your data
| Data | How long we keep it |
|---|---|
| Client contacts and agreements | For the duration of our relationship, then for the period required by Spanish tax and commercial law |
| Candidate profiles | 2 years from our last contact, unless you renew your consent; deleted sooner if you ask |
| Business contacts who never reply | 12 months from our first message |
| Newsletter subscribers | Until you unsubscribe |
| Invoices and accounting records | For the period required by Spanish tax and commercial law |
8. Your rights
You can ask us at any time to:
- access the personal data we hold about you;
- correct data that is wrong or incomplete;
- delete your data;
- restrict how we use it;
- object to our use of it, including for business outreach;
- receive a copy in a portable format;
- withdraw your consent, without affecting anything we did before.
To use any of these rights, email alicia@assertiverecruiting.com with your request. We will reply within one month.
If you think we have not handled your data properly, you can complain to the Spanish Data Protection Agency (Agencia Española de Protección de Datos) at www.aepd.es.
9. Security
We protect your data with multi-factor authentication on all our business accounts, a password manager, encrypted cloud storage, and restricted links when we share candidate documents. CVs are not stored on personal devices.
10. Changes to this policy
We may update this policy when our services or the law change. The date at the top of this page shows the latest version.
Questions about your data?
Write to alicia@assertiverecruiting.com and we will get back to you.
Assertive Recruiting · Barcelona, Spain