Privacy Policy

Last Updated: December 28, 2025

This Privacy Policy describes how Mateusz Paszkowski, operating under the commercial name P&D Talent ("we", "us", or "our"), collects, uses, and discloses your information when you use our website (https://www.pndtalent.com) or engage with our recruitment and headhunting services.

We are committed to protecting your personal data in strict accordance with the General Data Protection Regulation (GDPR) (EU) 2016/679 and the Spanish Organic Law 3/2018 (LOPDGDD) on Personal Data Protection.

1. Information We Collect

We collect different types of data depending on whether you are a Candidate seeking a job, a Client seeking services, or a website visitor.

A. For Candidates (Job Seekers)

When you apply for a job or send us your CV via email/LinkedIn:

• Identity Data: Name, surname.
• Contact Data: Email address, phone number, LinkedIn profile URL.
• Professional Data: Curriculum Vitae (CV/Resume), employment history, education, portfolio, languages, and salary expectations.

B. For Clients (Companies)

When you contact us to hire talent:

• Business Contact Data: Name of representative, professional email, phone number, job title.
• Billing Data: Company tax ID (NIF/CIF), invoicing address.

C. Technical Data (Website Users)

• Usage Data: IP address, browser type, and interaction data via cookies (see our Cookie Policy).
• B2B Identification Data: We may collect data related to your business identity (Company Name, Industry) based on your IP address via Apollo.io.

2. Purpose and Legal Basis for Processing

We process your data for the following specific purposes:

For Candidates

• Purpose: To assess your profile against job openings, conduct interviews, and present your candidature to potential employers.
• Legal Basis: Explicit Consent (when you send us your CV) and Legitimate Interest (to maintain a database of talent for future opportunities).

For Clients

• Purpose: To manage the commercial relationship, provide headhunting services, and process billing.
• Legal Basis: Contractual Necessity (execution of a service agreement) and Legal Obligation (tax/accounting laws).

3. Data Enrichment and Lead Identification (Apollo.io)

We use third-party lead identification services, specifically Apollo.io, to identify business visitors to our website. This service tracks IP addresses and matches them against a business database to provide us with information such as company name, industry, and professional contact details.

This processing is based on our Legitimate Interest (GDPR Art. 6.1.f) to identify potential B2B clients and improve our marketing relevance. We do not use this technology to identify individual consumers, only business entities. You can opt-out of this tracking via our Cookie Manager or by contacting us directly.

4. Data Sharing and Disclosure

We treat your data with strict confidentiality. We do not sell your personal data. We share it only in the following necessary circumstances:

• With Hiring Companies (Clients): If you are a candidate, we share your CV and professional notes with potential employers only after discussing the specific role with you.
• Service Providers: We use trusted third-party tools (processors) to manage our operations (e.g., Email hosting, Cloud storage, Accounting software). These providers adhere to GDPR standards.
• Legal Authorities: If required by law enforcement or public administration (e.g., Spanish Tax Agency).

5. International Transfers

We primarily process data within the European Economic Area (EEA). If a recruitment process involves a client located outside the EEA (e.g., UK, USA), we will only transfer your data with your explicit consent or where Standard Contractual Clauses (SCCs) are in place to ensure data protection.

6. Data Retention

• Candidates: We retain your CV and professional data for a period of 2 years from our last meaningful contact. After this period, we will either delete your data or ask for your consent to keep it longer.
• Clients: We retain contractual and billing data for 5 years (or as required by Spanish Tax Law) after the business relationship ends.

7. Your Rights

Under GDPR and LOPDGDD, you have the following rights regarding your data:

• Access: Ask if we hold your data and request a copy.
• Rectification: Ask us to correct inaccurate data (e.g., update your CV).
• Erasure ("Right to be Forgotten"): Ask us to delete your data from our systems completely.
• Restriction: Pause the processing of your data while keeping it stored.
• Portability: Request your data in a structured, common format.
• Withdraw Consent: You can withdraw your consent for us to hold your CV at any time.

To exercise any of these rights, please email Mateusz Paszkowski at international@pndtalent.com. We will respond within 1 month.

8. Security

We implement appropriate technical and organizational measures to protect your data against unauthorized access, loss, or alteration. We restrict access to personal data to only what is necessary for the recruitment process.

9. Contact

If you have any questions about this policy or our data practices, please contact:

P&D Talent (Mateusz Paszkowski)
Passeig del Roser 19, Sant Cugat del Vallès 08197, Spain.
Email: international@pndtalent.com