Welcome to G&M Fashion Career’s Privacy Policy!

This privacy policy sets out how G&M Fashion Career SL protects any information that you provide when using our websites www.gm-fashioncareer.com and any of our services.

1. Introduction

G&M Fashion Career (“we,” “us,” or “our”) is committed to protecting your personal data and respecting your privacy. This Privacy Policy explains how we collect, use, share, and protect your personal information when you interact with our recruitment services, whether as a candidate seeking employment opportunities or as a client organization.

We are a boutique executive recruitment consultancy specializing in luxury fashion, based in Barcelona, Spain. We operate in compliance with the EU General Data Protection Regulation (GDPR) and Spanish data protection legislation (Ley Orgánica 3/2018, de Protección de Datos Personales y garantía de los derechos digitales – LOPDGDD).

2. Data Controller

Identity: G&M Fashion Career Barcelona, Spain

Contact: for any questions about this Privacy Policy or to exercise your data protection rights, please contact us at: info@gm-fashioncareer.com

3. What Personal Data We Collect

3.1 Candidate Data

When you apply for positions or register with us as a candidate, we may collect:

  • Personal identification information: name, date of birth, nationality, contact details (email, phone, address).

  • Professional information: CV/resume, employment history, education, qualifications, skills, language proficiency.

  • References and recommendations from previous employers or professional contacts.

  • Salary expectations and compensation history.

  • Work authorization status and right-to-work documentation.

  • Professional social media profiles (LinkedIn, portfolio websites).

  • Interview notes and assessments.

  • Communication records (emails, messages, call notes).

3.2 Client Organization Data

When you engage us as a client organization, we may collect:

  • Company information and contact details.

  • Business contact information of relevant personnel.

  • Job descriptions and hiring requirements.

  • Feedback on candidate submissions.

  • Commercial and contractual information.

3.3 Website Visitors

We may collect technical information when you visit our website, including IP address, browser type, device information, and pages viewed. This data is collected through cookies and similar technologies (see Section 11).

4. Legal Basis for Processing

We process your personal data on the following legal grounds:

4.1 Legitimate Interests (Article 6(1)(f) GDPR)

For most recruitment activities, we rely on our legitimate interest in providing recruitment services to clients and matching suitable candidates with employment opportunities. This includes sourcing candidates, maintaining our talent database, and facilitating introductions between candidates and client organizations.

4.2 Consent (Article 6(1)(a) GDPR)

Where required by law or when we process special categories of data (see Section 5), we obtain your explicit consent. You may withdraw your consent at any time by contacting us.

4.3 Contract Performance (Article 6(1)(b) GDPR)

When we have a contractual relationship with you (as a client organization), we process data necessary to fulfill our contractual obligations.

4.4 Legal Obligation (Article 6(1)(c) GDPR)

We may process personal data to comply with legal obligations, such as tax, accounting, or employment law requirements.

5. Special Categories of Personal Data

We do not routinely collect special categories of personal data (such as data revealing racial or ethnic origin, political opinions, religious beliefs, health information, or data concerning sex life or sexual orientation) unless:

  • You have given explicit consent for specific purposes.

  • It is necessary for employment law compliance (e.g., disability accommodations).

  • The data has been manifestly made public by you. 

Where we do process special categories of data, we implement additional safeguards and only process such data where absolutely necessary.

6. How We Use Your Personal Data

We use your personal data for the following purposes:

For Candidates:

  • To match you with relevant job opportunities.

  • To present your profile to prospective employers (with your consent).

  • To maintain our candidate database and talent pool.

  • To communicate with you about opportunities and provide career guidance.

  • To verify your professional background and qualifications.

  • To facilitate interviews and negotiations.

  • To comply with legal obligations (e.g., right-to-work checks).

For Client Organizations:

  • To provide recruitment services as per our engagement terms.

  • To manage our business relationship.

  • To issue invoices and manage payments.

  • To improve our services and conduct business development activities.

7. Who We Share Your Personal Data With

We may share your personal data with the following categories of recipients:

7.1 Client Organizations

With your consent, we share candidate profiles with prospective employers to facilitate recruitment opportunities. We only share information relevant to the specific opportunity.

7.2 Data Processors

We use third-party service providers who process data on our behalf, including:  Recruitly (Recruit CRM): Our applicant tracking system (ATS) provider, which stores and manages candidate and client data. Recruitly is based in the United States and processes data in accordance with Standard Contractual Clauses (SCCs) approved by the European Commission. For more information about Recruitly’s data processing practices, please visit: https://recruitcrm.io/legal/data-processing-agreement/

7.3 Professional Advisors

We may share data with our legal advisors, accountants, auditors, and other professional advisors where necessary for business operations and legal compliance.

7.4 Legal and Regulatory Authorities

We may disclose personal data to comply with legal obligations, respond to lawful requests, protect our rights, or ensure safety and security.

8. International Data Transfers

As part of our recruitment services, we may transfer your personal data to countries outside the European Economic Area (EEA), including the United States, Asia, and the Middle East. These transfers occur when:

  • We present candidate profiles to client organizations located in these regions.

  • We use service providers (such as Recruitly) that process data outside the EEA.

Where data is transferred to countries without an adequacy decision from the European Commission, we implement appropriate safeguards, including:

  • Standard Contractual Clauses (SCCs): We use the European Commission’s approved Standard Contractual Clauses with our data processors, including Recruitly.

  • Your Explicit Consent: Before sharing your profile with client organizations outside the EEA, we obtain your explicit consent and inform you of the transfer and any risks.

You have the right to obtain information about these safeguards by contacting us.

9. How Long We Keep Your Data

We retain your personal data only for as long as necessary to fulfill the purposes for which it was collected:

Candidate Data:

We retain candidate data for two (2) years from the date of your last interaction with us (e.g., application, interview, or update to your profile). This period allows us to contact you about relevant opportunities and maintain an up-to-date talent pool.  After this period, we will securely delete or anonymize your data unless:

  • You have given consent for longer retention.

  • We are legally required to retain it (e.g., for tax or employment law purposes).

  • It is necessary to establish, exercise, or defend legal claims.

Client Data:

We retain client data for the duration of our business relationship and for up to seven (7) years thereafter to comply with legal and regulatory obligations (e.g., accounting, tax, and contract law requirements).

You may request deletion of your data at any time by contacting us (see Section 12).

10. Your Rights Under GDPR

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

1. Right of Access (Article 15) You have the right to obtain confirmation as to whether we are processing your personal data and, if so, to access that data and receive information about how it is being used.

2. Right to Rectification (Article 16) You have the right to have inaccurate personal data corrected and to have incomplete data completed.

3. Right to Erasure / ‘Right to be Forgotten’ (Article 17) You have the right to request deletion of your personal data where:

  • It is no longer necessary for the purposes for which it was collected.

  • You withdraw consent (where processing is based on consent).

  • You object to processing and there are no overriding legitimate grounds.

  • The data has been unlawfully processed.

  • Deletion is required to comply with a legal obligation.

4. Right to Restriction of Processing (Article 18) You have the right to restrict processing of your personal data in certain circumstances, such as when you contest the accuracy of the data or when you have objected to processing.

5. Right to Data Portability (Article 20) You have the right to receive your personal data in a structured, commonly used, and machine-readable format and to transmit it to another controller.

6. Right to Object (Article 21) You have the right to object to processing based on legitimate interests. Where we rely on legitimate interests, we will stop processing your data unless we can demonstrate compelling legitimate grounds that override your interests, rights, and freedoms.

7. Right to Withdraw Consent Where we process your data based on consent, you have the right to withdraw that consent at any time. Withdrawal of consent does not affect the lawfulness of processing before withdrawal.

8. Right to Lodge a Complaint You have the right to lodge a complaint with a supervisory authority, particularly in the EU Member State of your habitual residence, place of work, or place of alleged infringement.  In Spain, the supervisory authority is: Agencia Española de Protección de Datos (AEPD) Website: www.aepd.es Email: ciudadano@aepd.es

How to Exercise Your Rights: To exercise any of these rights, please contact us at info@gm-fashioncareer.com. We will respond to your request within one month, or within two months for complex requests.

11. Cookies and Similar Technologies

Our website uses cookies and similar tracking technologies to enhance your browsing experience and analyze site traffic. Cookies are small text files stored on your device when you visit our website. 

Types of Cookies We Use:

  • Essential Cookies: Necessary for the website to function properly (e.g., security, session management).

  • Analytical/Performance Cookies: Help us understand how visitors interact with our website by collecting anonymous information.

  • Functionality Cookies: Remember your preferences and choices (e.g., language settings).

You can control and/or delete cookies through your browser settings. Please note that disabling cookies may affect the functionality of our website.

12. Data Security

We implement appropriate technical and organizational measures to protect your personal data against unauthorized access, alteration, disclosure, or destruction. These measures include:

  • Encryption of data in transit and at rest.

  • Access controls and authentication protocols.

  • Regular security assessments and updates.

  • Staff training on data protection and confidentiality.

  • Secure data storage with our ATS provider (Recruitly), which maintains SOC 2 compliance and industry-standard security practices.

In the event of a personal data breach that poses a risk to your rights and freedoms, we will notify you and the relevant supervisory authority withouth undue delayand in any case within 72 hours of becoming aware of the breach.

13. Changes to This Privacy Policy

We may update this Privacy Policy from time to time to reflect changes in our practices, legal requirements, or for other operational reasons. The “Effective Date” at the top of this policy indicates when it was last revised.  We will notify you of any material changes by posting the updated policy on our website and, where appropriate, by email. We encourage you to review this Privacy Policy periodically.

14. Contact Information

If you have any questions, concerns, or requests regarding this Privacy Policy or our data processing practices, please contact us:  G&M Fashion Career Barcelona, Spain. Email: info@gm-fashioncareer.com. We are committed to resolving any complaints or concerns you may have about our handling of your personal data.

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