Web Privacy Policy

At Circular we care about your privacy. We have prepared this policy to inform you about what, who and why we collect and process your personal data, how we protect it and how you can contact us.

In this sense, the present document regulates the privacy policy of the website (hereinafter the "Website") owned by Circular Talent, S.L. (hereinafter "Circular"). We are an entity dedicated primarily to connect candidates and companies to explore potential professional collaborations. Below, we indicate our identification data:

Company name: Circular Talent, S.L.

TAX ID: B88203641

Address: C/ Alcalá 155, 3ºI 28009 - Madrid

E-mail of the Data Protection Delegate: dpo@circular.io.

1 For what purpose and on what legitimate basis do we process your personal data?

We inform you that all the information that we request or may request is necessary for the purposes described in this privacy policy and if you do not provide it, we will not be able to contact you or provide you with a response to any request you make. For this reason, we reserve the right not to respond or process any type of request if you do not provide us with the aforementioned data.

It is important that you ensure the accuracy of the personal data you provide us, and we may periodically ask you to review and update them, so that such personal data are as accurate and truthful as possible.

In this Web Site you can find information that may be useful in order to inform you about the services offered by Circular, as well as how to make the most of the platform. In this sense, Circular will only process the data necessary to process the consultation made, provide the contracted service or to initiate and maintain a commercial, contractual and/or pre-contractual relationship with you.

Below, we describe the different purposes for which your personal data will be processed, i.e. we explain why we will process your personal data. We also - by means of the following headings - indicate the legal basis on which we legitimize such processing. For ease of reference, the purposes, together with their corresponding legitimate bases, are structured according to the condition in which you visit the Website:

1.1 In case you are a Recruiter we will process your personal data for the following purposes:

Management and development of your interactions with candidates and/or other users through the Circular Web Site.

Circular may carry out the processing of your personal data for:

  1. Management of your registration on the Website, as well as the creation, development and publication of your user profile, which will be available to all users of the Web Site without registration.
  2. Management, development and publication of your references of candidates sent by (i) making available to the candidate a reference link; or (ii) sending the reference email on your behalf.
  3. Design and publication of job offers and/or creation of groups for the dissemination of offers of interest to your members.
  4. Support in the management and selection of candidates proposed by the Website based on the requirements of the offer by sending an invitation to interview or discarding the profile.
  5. Management and forwarding of satisfaction surveys to the candidates with whom you carried out the selection processes and the elaboration of statistics based on the feedback received. For clarification purposes, the statistics, together with the comments made by the candidates on the selection process in which they have participated, will be published only in relation to the company you represent and not in relation to you as an individual.
  6. Management and development of conversations with other Recruiters and candidates registered on Circular's website.

Legitimate base: Management, development and maintenance of the contractual relationship subscribed with Circular through registration on the Website.

Management and development of the Circular Web site rewards system.

Circular may process your personal data to award you recognition points based on your interactions with candidates on the Website, specifically: (i) for new candidates referred to Circular; and (iii) for the hiring of candidates referred by you. You can find more detailed information about our rewards system at the following link: Circular Rewards System.

Legitimate base: Management, development and maintenance of the contractual relationship subscribed with Circular through registration on the Website.

Keep you informed of Circular's main news.

Circular may carry out the processing of your personal data to keep you informed of the main news related to Circular, the Website or the products and services we provide, similar to those contracted. You may oppose the receipt of such communications at any time by clicking on the "Unsubscribe" link provided in the footer of the e-mails or through the channels referred to in section "5. What rights do you have? How can you exercise them?”

Legitimate base: Circular's legitimate interest in keeping you informed about products or services similar to those contracted, and that may be of interest to you, allowing you to learn about all the features of the Website, and if necessary, modify or extend the contracted services.

1.2. In case you are an applicant we will process your personal data for the following purposes:

Management and development of your interactions with candidates and/or other users through the Circular Web Site.

Circular may carry out the processing of your personal data for:

  1. Management of your registration on the Website, as well as the creation, development and publication of your user profile, which will be available to all users of the Web Site without registration.
  2. Management, development and publication of your references of candidates sent by (i) making available to the candidate a reference link; or (ii) sending the reference email on your behalf.
  3. Design and publication of job offers and/or creation of groups for the dissemination of offers of interest to your members.
  4. Support in the management and selection of candidates proposed by the Website based on the requirements of the offer by sending an invitation to interview or discarding the profile.
  5. Management and forwarding of satisfaction surveys to the candidates with whom you carried out the selection processes and the elaboration of statistics based on the feedback received. For clarification purposes, the statistics, together with the comments made by the candidates on the selection process in which they have participated, will be published only in relation to the company you represent and not in relation to you as an individual.
  6. Management and development of conversations with other Recruiters and candidates registered on Circular's website.

Legitimate base: Management, development and maintenance of the contractual relationship subscribed with Circular through registration on the Website.

Management and development of the Circular Web site rewards system.

Circular may process your personal data to award you recognition points based on your interactions with candidates on the Website, specifically: (i) for new candidates referred to Circular; and (iii) for the hiring of candidates referred by you. You can find more detailed information about our rewards system at the following link: Circular Rewards System.

Legitimate base: Management, development and maintenance of the contractual relationship subscribed with Circular through registration on the Website.

Keep you informed of Circular's main news.

Circular may carry out the processing of your personal data to keep you informed of the main news related to Circular, the Website or the products and services we provide, similar to those contracted. You may oppose the receipt of such communications at any time by clicking on the "Unsubscribe" link provided in the footer of the e-mails or through the channels referred to in section "5. What rights do you have? How can you exercise them?”

Legitimate base: Circular's legitimate interest in keeping you informed about products or services similar to those contracted, and that may be of interest to you, allowing you to learn about all the features of the Website, and if necessary, modify or extend the contracted services.

1.3. If you are a user of the Website, and regardless of your status as a Recruiter or Candidate, we will process your personal data for the following purposes:

Manage your contact requests, as well as requests for information through the means provided on the Website.

Circular may process your personal data in order to attend your contact and/or information requests sent through any of the channels provided for this purpose.



Legitimate base: Circular's legitimate interest in correctly fulfilling your request and providing you with the information you need in order to enjoy all the functionalities of our Website.

Carrying out statistics, studies and analysis of visitors to the Web Site.

Circular may process your personal data to carry out statistics, studies and analysis of visitors to the Website, for which we will carry out a commercial profile based on your browsing habits, consumption and preferences shown during your use of our services. This analysis will be carried out with the use of cookies and similar tracking technologies. You can obtain more information about the specific cookies used on the Website, as well as how to manage them in our Cookies Policy.

Legitimate base: *Circular's legitimate interest in obtaining a better understanding of the business and/or user profile of the Website. In particular, gathering information about the most used functionalities or the most frequent visitors allows us to continue developing the Website according to the tastes and preferences of our users.

*We inform you that your privacy is important to Circular and, in this regard, we have made the appropriate balancing judgments in order to verify that your interests, rights and fundamental freedoms do not prevail over ours before applying the legitimate interest as a basis of lawfulness for the purposes mentioned in this section. You can request a summarized version of the same at the following e-mail address: dpo@circular.io

2. Who are the third parties with whom we share your data?

Your personal data may be communicated to other users of the Website for the sole purpose of providing you with the requested service, in accordance with the provisions of section "1. For what purpose and on what legitimate basis do we process your personal data" above.

Likewise, in certain cases, the personal data you have provided to Circular may be communicated to public authorities, in order to comply with the requirements of such authorities and the applicable regulations, if any.

In addition to the aforementioned communications, we have the collaboration of some third party service providers who have access to your personal data and who process the aforementioned data in our name and on our behalf, only during the provision of the service we have contracted.

In this sense and with the aim of protecting your privacy, Circular follows strict criteria for the selection of suppliers in order to comply with its obligations regarding data protection and undertakes to sign with them the corresponding data processing contract - in compliance with one of the requirements established by the regulations -, by means of which it will impose on them, among others, the following obligations: to apply appropriate technical and organizational measures; to process personal data for the agreed purposes and only in accordance with Circular's documented instructions; and to delete or return the data once the provision of the services has been completed. All these obligations we impose on our suppliers who access your personal data are aimed at guaranteeing your privacy to the maximum extent possible.

International transfers

Circular may transfer your personal data to recipients located in countries outside the European Economic Area that have data protection regulations different from the European one. This includes those countries that, according to the European Commission, do not have a level of personal data protection equivalent to the European level. In these cases, Circular will ensure that there is a legal basis for the transfer in accordance with the applicable data protection legislation, applying the appropriate safeguards in each case. You can obtain more information about international transfers of your data carried out by Circular at the following e-mail address: dpo@circular.io .

3. How do we protect your personal data?

Circular has appropriate policies and technical and organizational measures in place to safeguard and protect your personal data against unlawful or unauthorized access, accidental loss or destruction, damage, unlawful or unauthorized use and disclosure.

We will also take all reasonable precautions to ensure that our staff and employees who have access to your personal data have received appropriate training.

4. How long do we keep your data?

We will retain your personal data according to the duration of your commercial, pre-contractual or contractual relationship with Circular and the periods established by law. In this sense, the criteria we will use to set the retention periods of your data have been determined in accordance with the requirements established in the applicable legislation, regulations and normative guidelines, as well as Circular's operational requirements related to the correct management of the existing relationship with the different categories of interested parties.

At the end of the relationship, we will delete your personal data as soon as all the necessary actions have been carried out to manage and terminate any remaining obligations between the parties, carrying out all the necessary administrative steps during this period.

5. What rights do you have and how can you exercise them?

We inform you that you can contact Circular whenever you consider it necessary, being able to exercise your rights of access, rectification, suppression, limitation, opposition, as well as the right to the portability of your data and not to be subject to automated decisions, by means of a request addressed to Circular Talent, S.L. with address at C/ Alcalá 155, 3ºI 28009 - Madrid, or to the following e-mail address: dpo@circular.io attaching a copy of your ID card or documentation proving your identity.

Also, at any time you will have the possibility to withdraw the consents that, if any, you have given us, by contacting Circular Talent, S.L. at the address or email indicated above.

Finally, in case you want to access more information about your rights regarding data protection or if you need to file a complaint, you can contact the Spanish Data Protection Agency (www.aepd.es ), located at Calle Jorge Juan, 6, 28001, Madrid, in order to safeguard your rights.

© 2022 CIRCULAR TALENT, S.L. All rights reserved.

Last update: May, 4th, 2022