At Liberato Consulting Group ("Liberato", "we") privacy and confidentiality are non-negotiable principles. This Policy explains what personal data we process, for what purpose and on what legal basis, who we share it with, how long we keep it, and the rights you have — in line with the law applicable in the European Union, Spain, the United Kingdom, Mexico and the United States.
1. Data controller
The controller of your data is Liberato Consulting Group, with an office in Madrid (Spain) and an office in Glasgow (United Kingdom). Website: liberatoconsultinggroup.com.
For any data-protection matter, contact us at [email protected].
2. Scope
This Policy applies to: (i) candidates and professionals; (ii) clients and their representatives; (iii) commercial counterparties assessed under our commercial-intelligence services; and (iv) visitors to this website.
3. Data we process
Depending on your relationship with us, we may process:
- Identity and contact data (name, email, phone, company, role).
- Professional and career data (CV, experience, education, salary expectations, references, public professional presence such as LinkedIn).
- Client and contractual data (billing, communications).
- Commercial and financial data of counterparties under the SafeTrade service (credit and solvency information from lawful sources).
- Browsing and device data (see the Cookie Policy).
4. Special categories of data
We do not request special-category data (GDPR Art. 9: health, origin, affiliations, etc.). Where strictly necessary in a process, it will only be processed on a valid legal basis and, where applicable, with your explicit consent. Please do not include such information in your CV or messages unless expressly requested.
5. Source of the data
We obtain data: (i) directly from you; (ii) from our clients (when they engage us for a search); and (iii) from lawful public or professional sources (e.g. professional networks, registries and commercial-information providers).
6. Purposes and legal bases
We process your data for the following purposes, on the GDPR Art. 6 basis indicated:
- Providing our search, career-development, employer-branding and commercial-intelligence services — performance of a contract or pre-contractual steps.
- Managing applications and including you in our talent pool — legitimate interest in connecting talent and opportunity, and/or your consent.
- Responding to your enquiries via the form or email — your consent or pre-contractual steps.
- Meeting legal, accounting and tax obligations — legal obligation.
- Improving and securing the website — legitimate interest (security) and consent (non-essential cookies).
7. Retention
We keep data for as long as the relationship lasts and, thereafter, blocked for the applicable legal periods (commercial, tax, employment). Candidate data in our talent pool is kept while there is mutual interest or until you withdraw consent, subject to periodic review.
8. Recipients and processors
We do not sell your data. We may share it with: (i) our clients, within a search (with your knowledge); (ii) providers acting as processors under contract (web hosting — Cloudflare; email and productivity — Google Workspace; scheduling — Calendly); and (iii) authorities where legally required.
9. International transfers
Some providers may process data outside the EEA/UK (e.g. the USA). In such cases we apply appropriate safeguards: adequacy decisions, Standard Contractual Clauses (SCCs), the UK International Data Transfer Addendum (IDTA), and/or the EU-US Data Privacy Framework where applicable.
10. Your rights
You may exercise your rights of access, rectification, erasure, restriction, portability and objection, as well as not to be subject to automated decisions with significant effects, by writing to [email protected] (state the right you are exercising; we may request identity verification).
- EU/Spain: you may lodge a complaint with the Spanish Data Protection Agency (AEPD, www.aepd.es).
- United Kingdom: with the Information Commissioner’s Office (ICO, ico.org.uk).
- Mexico: ARCO rights (Access, Rectification, Cancellation and Objection) and withdrawal of consent; authority: Secretaría Anticorrupción y Buen Gobierno / "Transparencia para el Pueblo".
- California (USA): rights to know, delete, correct and opt out of sale/sharing; we do not sell personal data.
11. Security
We apply appropriate technical and organisational measures (encryption in transit, access control, minimisation) to protect your data. No system is infallible, but we work with the diligence the sensitive information we handle demands.
12. Minors
Our services and this site are aimed at professionals and businesses; they are not directed at minors and we do not knowingly collect their data.
13. Changes to this Policy
We may update this Policy to reflect legal or operational changes. The current version will be posted on this page with its update date.