Website Privacy Policy

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

In this regard, this document sets out the privacy policy of the website (hereinafter, the

"Website") owned by Circular Talent, S.L. (hereinafter, "Circular"). We are an entity dedicated mainly to connect candidates and companies to explore potential professional collaborations. Hereunder, we indicate our identifying data:

Corporate name: Circular Talent, S.L.
Tax number: B88203641
Address: C/ Alcalá 155, 3ºI 28009 - Madrid
E-mail: contact@trycircular.com

Applicability of this Privacy Policy

In this Privacy Policy, we explain how we process the personal data of users who contact Circular through the Web Site or who access it - https://trycircular.com/. This would include the processing of personal data of (i) employees of companies registered in the Circular platform(hereinafter "Recruiter" or "Recruiters"), (ii) employees of Circular service providers, (iii) candidates to form part -only- of the Circular template-, (iv) users and/or potential users of the Website and (v) any other user who accesses or transmits information through the Web Site.

If you are a candidate who uses the platform offered by Circular through the Website, we inform you that your personal data will be processed in accordance with the Candidate Privacy Policy present in the bottom of this page.

1. What personal data do we process, for what purpose and on what legitimate basis?

We inform you that all the data we request or may request from you are necessary for the purposes described in this privacy policy and if you do not provide them, we will not be able to contact you or offer a response to any request you make. For this reason, we reserve the right not to respond or process any kind of request if you do not provide the above data.

It is important that you guarantee the veracity of the personal data that you provide us, and

periodically we may ask you to review and update them, in order that such personal data are the most accurate and truthful, as far as possible.

If you are a Recruiter, you guarantee us that, both in the event that your company makes a

recommendation about a candidate, as well as when we can access your company's database of discarded candidates through the Applicant Tracking System ("ATS"), your company complies

with the obligations imposed by data protection regulations, when giving third parties access to these personal data.

In this Website, you can find additional information regarding the services that are offered by Circular, as well as how to make the most of the Platform. In this respect, Circular will only process the necessary data to process the consultation carried out, provide the contracted service or 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, that is, we explain why we will process your personal data. Also - by means of the following titles - we indicate you the legal basis through which we legitimize these processing:

1.1 Performance of a contract or, prior steps to enter into a contract:

a) If you are an employee/representative of an entity registered on the platform

  • Manage the existing contractual relationship (formalized through the acceptance of the T&C) between the company you represent and Circular, allowing said company to benefit from the advantages offered on the platform.
  • Attend to the requests and queries you may have.

b) In case you are an employee of a Circular service provider

  • Manage the existing contractual relationship between the company you belong to and Circular.
  • Attend to the requests and queries you may have.

c) If you are a candidate to be part of the Circular workforce only

  • Manage your possible participation in the selection processes that we carry out in Circular, as well as keep you informed of possible selection processes in which you could fit in the future and facilitate your participation in them.

d) If you are a user and/or potential user of the Website or any other user who accesses or transmits information through the Website

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

1.2 Legal obligation:

  • Communicate information to public authorities, regulators or government bodies when required to do so by law, local regulations or in compliance with regulatory obligations.

1.3 Legitimate interest of Circular:

  • Only if you are a Recruiter, we will process your personal data to keep you informed of the main news related to Circular, the Website or, the products and services we provide. In this case, our legitimate interest would be to carry out direct marketing activities, in accordance with Article 47 of the General Data Protection Regulation.
  • We will perform 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 the use of our services. Our legitimate interest in carrying out this processing lies in the improvement of our commercial offer, in the best knowledge and continuous improvement of our business.

Data processing related to the mere browsing of the Website

In order to improve our services, provide you more relevant content, and analyse how visitors use this Website, we may use technologies, such as cookies or tracking software. In most cases, we will not be able to identify you by the information we collect with such technologies.

Please note that cookies are small pieces of information stored by your browser on your computer's hard drive. They allow you to navigate this Website and allow us to provide features such as remembering aspects of your last search in order to perform subsequent searches more quickly. If you wish, you can delete cookies. Although most features will still be accessible without cookies, we inform you that certain cookies are necessary for viewing and browsing this Website. For more information on how to use cookies and how to delete them, we make our Cookies Policy available to you if requested to contact@trycircular.com

2. With whom do we share your data?

The personal data you have provided to Circular may only be communicated to third parties to whom Circular is obliged to transmit information, such as public authorities, in order to comply with the requirements of those authorities and the applicable regulations, where applicable.

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

In this regard and with the aim of protecting your privacy, we follow strict criteria for the selection of our service providers in order to comply with our data protection obligations. In this regard, we undertake to sign with them the corresponding Data Processing Agreement- in compliance with the requirements established by GDPR. This agreement will impose, among others, the following obligations: to apply appropriate technical and organisational measures; to process personal data for the agreed purposes, attending only to Circular's instructions and to delete or return the data once the provision of services has ended. All obligations that we impose on our service providers who access your personal data are aimed at ensuring maximum privacy.

3. How do we protect your personal data?

We have appropriate policies and technical and organizational measures 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.

In any case, we inform you that any data transfer over the Internet is not completely secure and, as such, is at your own risk. Although we will do our best to protect your personal data, we cannot guarantee the security of personal data transmitted through our Website.

4. How long do we keep your data?

We will keep your personal data according to the duration of your relationship with Circular - that is, as long as you are registered on the Platform - and the legally established periods. In this sense, the criteria that we will use to fix 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 the operational requirements of the Circular related to the correct management of the existing relationship with the different categories of data subjects.

Your data will be kept as long as you have any pre-contractual or contractual relationship with Circular or, where appropriate; as long as they are necessary to correctly manage the request, you send us or the evaluation of your candidature.

Once this has been completed, we will delete your personal data as soon as all the necessary actions have been carried out to manage and conclude any obligation that may remain between the parties, carrying out all the necessary administrative formalities during this period.

In addition, your data will be kept properly blocked, as long as responsibilities may arise from the execution of our contractual or pre-contractual relationship, as well as for the fulfilment of other legal obligations in charge of Circular.

In this respect, Circular guarantees that these data will not be processed unless it is necessary for the formulation, exercise or defense of claims or when this is required to provide the same to the Public Administration, Judges and Courts during the period of limitation of their legal rights or obligations.

5. Which rights do you own as data subject? How can you exercise them?

We inform you that you will be able to 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 object of automated decisions, by means of request directed to CIRCULAR TALENT, S.L. with address in C/ Alcalá 155, 3ºI 28009 - Madrid, or to the following e-mail address contact@trycircular.com, attaching a copy of your DNI or documentation accrediting your identity.

Likewise, at any time you will have the possibility of withdrawing the consents you have given us, by contacting CIRCULAR TALENT, S.L. at the address or e-mail indicated above.

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


Candidate Privacy Policy

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

Through this privacy policy, we inform you that your personal data will be processed by Circular Talent S.L. (hereinafter, "Circular"), as the data controller. We are an entity dedicated mainly to [-]. Hereunder, we indicate our identifying data:

Corporate name: Circular Talent, S.L.
Tax number: B88203641
Address: C/ Alcalá 155, 3ºI 28009 - Madrid
E-mail: contact@trycircular.com

It is important for you to note that when we refer throughout this privacy policy to your personal data we are referring to the information you have provided to us during your registration on our platform (hereinafter the "Platform"). In this sense, you will not have to provide us with your Curriculum Vitae in the strict sense.

1. ¿What personal data do we process, for what purpose and on what legitimate basis?

We inform you that all the data that we request are necessary for the purposes described in this privacy policy and if you do not provide them, we will not be able to contact you or offer a response to any request you make. For this reason, we reserve the right not to allow your registration or process your request if you do not provide us with the above data.

It is important for you to guarantee the veracity of the personal data that you provide us with, and periodically we may ask you to review and update them, so that these personal data are as accurate and truthful as possible.

Once you register in the Platform - either personally or through any of the companies registered, on the Platform that have invited you to join - we will process, among other, the following personal data: Name and surname, email, your field of expertise, location where you would like to work and professional experience profile. From Circular, we will not ask you for your Curriculum Vitae, neither will we process any personal data related to it. We will only share the link to your LinkedIn profile or other platforms that you have provided us (such as GitHub or your own personal Blog) with the companies registered in the Platform. However, if you give us your consent, we will be able to use all the information generated during the selection processes that, where appropriate, you have done or will do in any of the companies registered on the Platform.

Keep in mind that, as part of the benefit that Circular offers through the Platform, registered companies may publish in the same recommendations or ratings on your profile. These recommendations or ratings will always be positive, and in addition, from Circular we give you the possibility of deleting the information included in your profile that you do not want to be shown by contacting us: contact@trycircular.com.

In this Web Site, you can find information that can be useful in order to inform you about the services offered by Circular, as well as how to get the most out of the Platform. In this sense, Circular will mainly process your personal data to manage your registration as Candidate of the Platform, as well as to keep and develop the services object of the agreement signed with Circular (through the acceptance of the T&C) as a consequence of your registration in it.

Next, we describe the different purposes for which your personal data will be processed. That is to say, we explain you why we will process your personal data. Also - by means of the following titles - we indicate you the legal basis through which we legitimize such processing:

1.1. Performance of a contract or, prior steps to enter into a contract:

  • Manage your registration in the Platform, in response both to the request you may have sent to Circular, as well as to your acceptance of the invitation to join the Platform made by any of the registered companies.
  • Communicate your personal data to the companies registered in the Platform, so that, a greater number of said companies know your profile and can present suitable job offers. In order to do so, we will provide a link to your profile in Circular, made up of LinkedIn and/or any other URL with additional information that you have provided us, recommendations or, additional information that the companies have made about you.
  • Enrich your profile information, including feedback and recommendations.
  • In the event that you provide us with your personal details through the "Register as a candidate" section, we may transfer your identification and contact details to the person you have designated to recommend you.
  • Communicate with you by any means, including email, Telegram, WhatsApp, SMS LinkedIn, etc. as long as you have proactively provided us with access to these forms of contact, in order to inform you about possible job offers or the possible interest that the different companies using the Platform may have in your profile.

1.2 Legal obligation:

  • Communicate information to public authorities, regulators or government bodies when required to do so by law, local regulations or in compliance with regulatory obligations.

1.3 Legitimate interest of Circular:

  • We will process your personal data to keep you informed of the main news related to Circular, the Web Site or the products and services we provide. In this case, our legitimate interest would be to carry out direct marketing activities, in accordance with Article 47 of the General Data Protection Regulation.
  • We will perform statistics, studies and analysis of website visitors, for which we will carry out a commercial profile based on your browsing habits, consumer and preferences shown during the use of our services. Our legitimate interest in carrying out this processing is based on the improvement of our commercial offer and a better knowledge and continuous improvement of our business. Circular will process the data for the purposes indicated while evaluating the results of statistics, studies and analysis.

1.4 Based on the consent, if any, you have given us:

  • If you have given us your consent, we will process your personal data derived from the tests that, if any, you have carried out or will carry out during the selection process of any of the companies registered in the Platform. All in order to complete your profile within the Platform and thus, be able to offer more information about you to potential employers.

Data processing related to the mere browsing of the Website

In order to improve our services, provide you more relevant content, and analyse how visitors use this Website, we may use technologies, such as cookies or tracking software. In most cases, we will not be able to identify you by the information we collect with such technologies.

Please note that cookies are small pieces of information stored by your browser on your computer's hard drive. They allow you to navigate this Website and allow us to provide features such as remembering aspects of your last search in order to perform subsequent searches more quickly. If you wish, you can delete cookies. Although most features will still be accessible without cookies, we inform you that certain cookies are necessary for viewing and browsing this Website.

For more information on how to use cookies and how to delete them, we make our Cookies Policy available to you at contact@trycircular.com

2. Where do we collect your personal data?

In addition to those cases in which you have provided us your personal data through the Register as a candidate section, Circular may obtain your personal data from different sources, mainly, through the different companies registered in the Platform which you have established some kind of previous relationship with and which you will be able to find listed in your Platform profile.

In this regard, the personal data that we obtain through the aforementioned entities are the e-mail and the assessments or recommendations that the entity has made about you.

3. With whom do we share your data?

The personal data you have provided may be transferred to third parties registered on the Platform, in

order to provide you with the service we offer through the Platform and, consequently, that a greater number of companies know your profile and increase the chances of presenting you with a job proposal. Likewise, we will also transfer your personal data to third parties to whom Circular is obliged to transmit information, such as public authorities, with the aim of complying with the requirements of said authorities and the applicable regulations, as the case may be.

Also, if you have joined our Platform through an invitation from any of the companies registered in the Platform, we inform you that the company may know if you are currently in a selection process - without knowing which company you are conducting the process – or, if you have finally been hired - without knowing, in the same way, which company has hired you. This information is provided for the sole purpose of registered companies know the impact they generate through the invitation of candidates to join the platform.

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 data in our name and on our behalf, only during the provision of the service we have contracted.

In this regard and with the aim of protecting your privacy, we follow strict criteria for the selection of our service providers in order to comply with our data protection obligations. In this regard, we undertake to sign with them the corresponding Data Processing Agreement - in compliance with the requirements established by GDPR. This agreement will impose, among others, the following obligations: to apply appropriate technical and organisational measures; to process personal data for the agreed purposes, attending only to Circular's instructions and to delete or return the data once the provision of services has ended. All obligations that we impose on our service providers who access your personal data are aimed at ensuring maximum privacy.

We also inform you that some of the third party service providers mentioned may be located outside the European Union. More precisely, we have service providers located in the USA. In these cases, it is worth noting that these providers are adhered to the "Privacy Shield" between the European Union and the USA, thus providing an adequate level of protection for personal data.

You can obtain a detailed copy of the service providers indicated in the previous paragraph and of the measures that Circular requires by contacting us through the contact details indicated below.

4. How do we protect your personal data?

We have appropriate policies and technical and organizational measures 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. In any case, we inform you that any data transfer over the Internet is not completely secure and, as such, is at your own risk. Although we will do our best to protect your personal data, we cannot guarantee the security of personal data transmitted through our Website.

5. How long do we keep your data?

We will keep your personal data according to the duration of your relationship with Circular - that is, as long as you are registered on the Platform - and the legally established periods. In this sense, the criteria that we will use to fix 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 the operational requirements of the Circular related to the correct management of the existing relationship with the different categories of data subjects.

Your data will be kept as long as you have any pre-contractual or contractual relationship with Circular or, where appropriate; as long as they are necessary to correctly manage the request, you send us or the evaluation of your candidature.

Once this has been completed, we will delete your personal data as soon as all the necessary actions have been carried out to manage and conclude any obligation that may remain between the parties, carrying out all the necessary administrative formalities during this period.

In addition, your data will be kept properly blocked, as long as responsibilities may arise from the execution of our contractual or pre-contractual relationship, as well as for the fulfilment of other legal obligations in charge of Circular.

In this respect, Circular guarantees that these data will not be processed unless it is necessary for the formulation, exercise or defense of claims or when this is required to provide the same to the Public Administration, Judges and Courts during the period of limitation of their legal rights or obligations.

6. Which rights do you own as data subject? How can you exercise them?

We inform you that you will be able to 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 object of automated decisions, by means of request directed to CIRCULAR TALENT, S.L. with address in C/ Alcalá 155, 3ºI 28009 - Madrid, or to the following e-mail address contact@trycircular.com attaching a copy of your DNI or documentation accrediting your identity.

Likewise, at any time you will have the possibility of withdrawing the consents you have given us, by contacting CIRCULAR TALENT, S.L. at the address or e-mail indicated above.

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

© 2018 CIRCULAR TALENT, S.L. All right reserved.

Last update: January the 15th 2019