Privacy Policy

This Privacy Policy (together with other documents referred to therein) describes what personal information we collect from you and how we collect, use, and process it.

1. DATA CONTROLLER DETAILS

THE WISE SEEKER S.L., VAT ID B88209929, Calle Almagro nº1, 2ª izda, 28010 Madrid, Phone 91 9152400, which has appointed a Data Protection Officer whom you can contact regarding any issues related to this Policy: protecciondedatos@thewiseseeker.com

1.1. Applicable Regulation

Our Privacy Policy has been designed in accordance with the General Data Protection Regulation of the EU 2016/679 of the European Parliament and of the Council, of April 27, 2016, regarding the protection of natural persons with regard to the processing of personal data and on the free movement of such data, and repealing Directive 95/46/EC.

The Wise Seeker may modify this Privacy Policy to adapt it to legislative, jurisprudential, or interpretation developments by the competent supervisory authorities. These privacy conditions are complemented by the Legal Notice, Cookie Policy, and Terms of Service.

2. DATA SUBJECT CATEGORIES

Our Privacy Policy applies to you if you belong to any of the following categories:

Users of our website.
Candidates to whom we provide employment services or who apply for a vacant position and contact us through our website, job boards, social media pages, or other channels.
Potential candidates, as well as potential clients and their business contacts with whom we get in touch to present our products and services.
Clients with whom we maintain a business relationship and whom we help fill vacant positions.
Service providers who provide us with various services.

3. PURPOSE OF PROCESSING PERSONAL DATA

The processing of your personal data is carried out for the following purposes:

Tabla

WEB USERS

Purpose	When you visit our website or our application, we process your data for the following purposes: Accessing the website Ensuring that the established connection functions correctly Ensuring and optimizing the performance and accessibility of our website Ensuring and evaluating the security and stability of the system For this, we also use cookies and other technologies. For more information, please refer to our Cookie Policy.
Categories of Personal Data	We process the following data: Website from which access has been made (referrer URL), browser used, and, when necessary, operating system of the device with internet connection Name of your internet service provider For more information, please refer to our Cookie Policy.
Legal Basis	The processing of data is based on the following legal bases: Art. 6.1, b) GDPR - establishment, execution, or termination of our contract with you Art. 6.1, f) GDPR - our legitimate interest in the security, stability, and ease of use of our website Art. 6.1, a) GDPR - your consent
Collection of Your Data	We collect data directly from you.
Recipients of Your Data	No personal data transfers are made, except as legally permitted.

CANDIDATES
	Purpose 1	Purpose 2
Purposes	We process your data when you register with us to provide you with employment and selection services or to carry out a selection process with you in order to establish an employment relationship with you. In this context, we may use your data to communicate with you, respond to your inquiries, analyze your CV and find a suitable position for you, create a candidate profile for you, arrange interviews, conduct aptitude tests, or send your application documents to the employer of your choice.	We process your data when you register with us and provide your application data to us, and, if applicable, to potential employers.
Categories of Personal Data	For this purpose, we may process the following data: Name and address Phone number Email address Information present in your CV Information about your educational background Professional experience Work references Salary expectations Professional aspirations Nationality Residence and work permit Photos Language skills Results of assessment center tests In certain cases, special categories of data such as, for example, disability.	For this, we may process the following data: Name and address Phone number Email address Information present in your CV Information about your educational background Professional experience Work references Salary expectations Professional aspirations In certain cases, special categories of data such as, for example, disability.
Legal Basis	The legal basis for data processing is as follows: Art. 6.1, b) GDPR - establishment, execution, or termination of our contract with you Art. 6.1, c) GDPR - compliance with legal obligations of a labor and social nature Art. 6.1, f) GDPR - our legitimate interest in maintaining our client relationship with you We only process your special category data with your consent, in accordance with Art. 6.1, a) GDPR, and to the extent that we are obligated to do so for reasons of labor and social law and, finally, for reasons of equal opportunities. In these cases, we base the processing of your data on Art. 9.2, b), g), and h) GDPR.	For this, we may process the following data: Name and address Phone number Email address Information present in your CV Information about your educational background Professional experience Work references Salary expectations Professional aspirations In certain cases, special categories of data such as, for example, disability.
Collection of Your Data	We collect data directly from you. Additionally, we may also collect your data from third parties, specifically from: References, for example, former employers or past clients of yours to confirm your credentials and qualifications Publicly accessible professional networks, such as LinkedIn, to expand the information we already have about you We will only contact the references you have indicated to us during the application process and our services.	We collect data directly from you.
Recipients of Your Data	In order to provide our employment services, we may share personal information about you with potential employers offering job opportunities that you are interested in. Within the data processing described here, it's also possible for both internal and external service providers to have access to your data. These may include data processors, such as the following: IT support Web hosting, IT service IT solutions to improve service quality Data analysis Hiring support Sales Telecommunications providers Professional networking providers Providers of psychometric assessments or aptitude tests Our providers are contractually obligated by us to maintain confidentiality and comply with data protection standards and regulations. If you apply for a specific position, we will transmit your candidate data to the potential employer who has requested it. In the context of the data processing described here, it's also possible for the internal and external service providers described above to have access to your data.	In order to provide our employment services, we may share personal information about you with potential employers offering job opportunities that you are interested in. Within the data processing described here, it's also possible for both internal and external service providers to have access to your data. These may include data processors, as well as our data controllers responsible for the following areas: IT support Web hosting, IT service IT solutions to improve service quality Data analysis Hiring support Sales Telecommunications providers Professional networking providers Providers of psychometric assessments or aptitude tests Our providers are contractually obligated by us to maintain confidentiality and comply with data protection standards and regulations. If you apply for a specific position, we will transmit your candidate data to the potential employer that has requested it. In the context of the data processing described here, it's also possible for the internal and external service providers described above to have access to your data.

POTENTIAL CANDIDATES AND POTENTIAL CLIENTS

Purpose	We process your personal data to present you with our services and to be able to contact you and respond to your inquiries. We process the personal data you provide to us when you contact us and make an inquiry. Additionally, we may process data about you obtained from publicly accessible sources and professional and social networks, such as LinkedIn, the company, or other job portals, in order to contact you if we believe you may be interested in our employment services. Furthermore, we may have become aware of you through a recommendation from another candidate or client and may contact you accordingly. If you act as a business contact on behalf of a company, we will process your professional contact details.
Categories of Personal Data	For this purpose, we may process the following data: Name and address Job title Phone number Email address Professional data Company name Information in your CV, professional profile, company profile Information about your educational background References Work experience Employment references Salary expectations Career aspirations Open job postings Nationality Photos Language skills Status on your professional networks, for example, if you are open to job offers
Legal Basis	The processing of data is based on the following legal bases: Art. 6.1, a) GDPR - your consent Art. 6.1, b) GDPR - establishment, execution, or termination of our contract with you Art. 6.1, f) GDPR - our legitimate interest in direct marketing measures and distribution of our recruitment and employment services, as well as our legitimate interest in finding new commercial contacts, clients, and potential candidates
Collection of Your Data	We collect data directly from you. Additionally, we may also collect your data from third parties, namely: Professional networks like LinkedIn Other candidates or clients
Recipients of Your Data	In the context of the data processing described here, providers of internal and external services from the following areas may have access to your data: Marketing Sales IT Solutions IT Support Postal and Shipping Services Telecommunications Data Analysis

CUSTOMERS (B2B) AND CONTACT DATA

Purpose	We process your data to provide you with our services. To do this, we handle your data to communicate with you and find suitable candidates for your vacancies.
Categories of Personal Data	For this purpose, we may process the following data: Company name Address Company contact information Phone number Information about vacancies and profile requirements
Legal Basis	The processing of data is based on the following legal basis: Art. 6.1, b) GDPR - establishment, execution, or termination of our contract with you
Collection of Your Data	We collect data directly from you. Additionally, we may also collect your data from third parties, namely: Professional networks like LinkedIn Other clients and candidates
Recipients of Your Data	In the context of the data processing described here, providers of internal and external services from the following areas may have access to your data: Marketing Sales IT Solutions IT Support Postal and Shipping Services Telecommunications Data Analysis Accounting Administration Banking

SERVICES PROVIDERS AND CONTACT INFORMATION
	Purpose 1	Purpose 2
Purposes	We process your personal data to assess your suitability as our supplier. Only in very limited cases and to the extent that we are legally obliged to do so, we compare your data with sanctions lists and other public lists and registers, including terrorist and embargo lists, and PEP (Politically Exposed Persons) lists.	We process your personal data to assess your suitability as our supplier. Only in very limited cases and to the extent that we are legally obliged to do so, we compare your data with sanctions lists and other public lists and registers, including terrorist and embargo lists, and PEP (Politically Exposed Persons) lists.
categories of Personal Data	For this purpose, we may process the following data: Company name Name and address Contact person details Phone number Summary of services provided Contractual and accounting data	For this purpose, we may process the following data: Company name Name and address Contact person details Phone number References
Legal Basis	The processing of data is based on the following legal basis: Art. 6.1, b) GDPR - establishment, execution, or termination of our contract with you	The processing of data is based on the following legal bases: Art. 6.1, c) GDPR - our legal obligation to conduct background checks Art. 6.1, b) GDPR - establishment, execution, or termination of our contract with you Art. 6.1, f) GDPR - our legitimate interest in conducting assessments to evaluate your suitability
Collection of Your Data	We collect data directly from you.	We collect data directly from you. We also may use data from public records and sanctions lists.
Recipients of Your Data	In the context of the data processing described here, it is possible that providers of internal and external services from the following areas may have access to your data: Marketing Sales IT solutions IT Support Postal and Shipping Services Telecommunications Data Analysis Accounting Administration Banking	In addition, in the context of the data processing described here, it is possible that providers of internal and external services from the following areas may have access to your data: Hiring IT Solutions IT Support Postal and Shipping Services Telecommunications Administration

4. DATA RETENTION PERIOD

We will retain the personal data of users only for the time necessary to fulfill the purposes for which they were collected, which may sometimes be an ongoing purpose until consent is revoked. Subsequently, if necessary, the information will be kept blocked for the periods legally established.

In the case of data provided in relation to job offers that you wish to subscribe to, they will be kept for two years from the date of the last update. After this period, if they have not been updated, the data will be deleted unless you indicate otherwise.

5. CONSENT TO PROCESS YOUR DATA IN OUR FORMS

When filling out the forms, checking the box "I Accept the Privacy Policy" and clicking to submit the data, the User expressly states that they have read and expressly accepted this privacy policy and gives their unequivocal and express consent to the processing of their personal data in accordance with the stated purposes.

The personal data requested are mandatory, so refusal to provide them will make it impossible to provide the contracted services.

The user guarantees that the provided data are true, accurate, complete, and up-to-date, being responsible for any direct or indirect damage or harm that may arise as a result of non-compliance with this obligation. If the user provides third-party data, they declare that they have their consent and undertake to transfer the information contained in this clause to them, exempting us from any liability in this regard. However, we may carry out verifications to verify this fact, adopting the due diligence measures that correspond, in accordance with data protection regulations.

6. SECURITY MEASURES

As part of our commitment to ensuring the security and confidentiality of your personal data, we inform you that the technical and organizational measures necessary to ensure the security of personal data and prevent its alteration, loss, treatment, or unauthorized access have been adopted, taking into account the state of technology, the nature of the stored data, and the risks they are exposed to, as provided in Art. 32 of the GDPR EU 679/2016.

7. DATA TRANSFER

No data transfers are foreseen, except those authorized by tax, commercial, and telecommunications legislation, as well as in cases where a judicial authority requires it.

Without prejudice to the foregoing, we may share your information in the cases established in the purposes table of clause 3 of this document.

8. INTERNATIONAL DATA TRANSFERS

When we share your personal data, it may be transferred both within and outside the European Economic Area (EEA). In the event that we transfer your personal data internationally, we will do so only in accordance with applicable law and will require an adequate level of protection for them, as well as the application of appropriate security measures. Your personal data may be transferred from countries located in the EEA to countries located outside it. In such cases, we will require the following safeguards to be respected:

That the laws of the country to which your personal data are transferred guarantee an adequate level of data protection. Click here to see the list of non-EEA countries that, according to the European Commission, offer an adequate level of data protection; or
That the transfer is subject to standard data protection clauses approved by the European Commission. You can find more information about such data protection clauses here; or
Any other appropriate safeguards applicable under Article 46 of the EU General Data Protection Regulation (2016/679).

The safeguards we apply are as follows:

Country or international organization declared to have an adequate level of protection by the European Commission:
Switzerland. Decision 2000/518/CE of the Commission, of July 26, 2000
Canada. Decision 2002/2/CE of the Commission, of December 20, 2001, regarding entities subject to the scope of Canadian data protection law
Argentina. Decision 2003/490/CE of the Commission, of June 3, 2003
Guernsey. Decision 2003/821/CE of the Commission, of November 21, 2003
Isle of Man. Decision 2004/411/CE of the Commission, of April 28, 2004
Jersey. Decision 2008/393/CE of the Commission, de 8 de mayo 2008
Faroe Islands. Decision 2010/146/UE of the Commission, of March 5, 2010
Andorra. Decision 2010/625/UE of the Commission, of October 19, 2010
Israel. Decision 2011/61/UE of the Commission, of January 31, 2011
Uruguay. Decision 2012/484/UE of the Commission, of August 21, 2012
New Zealand. Decision 2013/65/UE of the Commission, of December 19, 2012
Japan. Decision of January 23, 2019
United Kingdom. Decision of June 28, 2021 (English version)
Republic of Korea. Decision of December 17, 2021 (English version)
EU-USA Data Privacy Framework Decision of July 10, 2023 (English version)
In the absence of an adequacy decision, adequate safeguards shall apply:

Commission Implementing Decision (EU) 2021/914 of June 4, 2021 concerning standard contractual clauses for the transfer of personal data to third countries pursuant to Regulation (EU) 2016/679 of the European Parliament and of the Council.

Therefore, before carrying out the transfer, we will ensure that it is legally authorized and that there are sufficient guarantees to ensure an adequate level of data protection with respect to the data transfer (for example, through contractual guarantees, officially recognized regulations, or binding internal data protection regulations at the recipient) or that you have given us your consent for that data transfer.

9. USER RIGHTS

Any individual has the right to obtain confirmation as to whether or not we are processing personal data concerning them. Interested parties have the right to access their personal data, as well as to request the rectification of inaccurate data or, where appropriate, to request their deletion when, among other reasons, the data are no longer necessary for the purposes for which they were collected. Under certain circumstances, interested parties may request the restriction of the processing of their data, in which case we will only retain them for the exercise or defense of claims. For reasons related to their particular situation, interested parties may object to the processing of their data. The data controller will cease processing the data, except for compelling legitimate reasons, or the exercise or defense of potential claims.

De acuerdo con la legislación vigente tiene los siguientes derechos: derecho a solicitar el acceso a sus datos personales, derecho a solicitar su rectificación o supresión, derecho a solicitar la limitación de su tratamiento, derecho a oponerse al tratamiento, derecho a la portabilidad de los datos y así mismo, a revocar el consentimiento otorgado.

9.1. How do I exercise my rights?

To exercise your rights, you must contact the data controller, requesting the corresponding form for exercising the chosen right. You can exercise your rights by writing to us at the following email address: protecciondedatos@thewiseseeker.com. Remember to accompany a copy of a document that allows us to identify you.

Finally, you are informed of your right to file a complaint with the competent data protection authority (in Spain, www.aepd.es) if you become aware of or believe that an act may constitute a breach of the applicable data protection regulations.

Last update 26/04/2024.