Privacy Policy Employer Branding and Recruitment Leadtech Innovation S.L.
Published date: 07-09-2026
Leadtech Innovation S.L., a company incorporated under Spanish law, with Tax Identification Number B65053589 and registered address at Av. del Litoral 12-14, 5th floor, 08005 Barcelona, Spain, manages its employer branding and recruitment processes through our Employment Portal (the "Employment Portal") and by means of an applicant tracking system (ATS).
This Privacy Policy describes how we process your personal data if you fall into any of the following categories of data subjects:
You may visit our Employment Portal, (being considered a 'Visitor')
You may connect with us through our Employment Portal to create a profile and receive information about our current or future vacancies, (being considered a 'Connected Candidate')
You may apply for a position with us through our Employment Portal or a third-party service, (being considered an ' Applicant Candidate')In certain cases, we may obtain information about you from publicly available sources or third parties, such as professional networking platforms (for example, LinkedIn), employment databases or similar services, if we consider that your professional profile may be of interest for a current or future vacancy within our organisation, (being considered a “Prospected Candidate”):
We may receive information about you from our employees or partners who consider your profile of interest for our current or future vacancies, (being considered a “Referred Candidate”).
We may receive information about you from a Candidate who has named you as their reference, (being considered a “Reference”)
This Privacy Policy also describes the data subject rights you are entitled to exercise in relation to the processing of your personal data, and the means by which those rights may be exercised.
Throughout this Privacy Policy, the term "Candidate" refers collectively to “Connected Candidates”, “Applicant Candidates”, Prospected Candidates” and “Referred Candidates”, unless otherwise specified.
1. Processing of Personal Data
Personal data means any information relating to an identified or identifiable natural person (data subject). Examples include name, email address, telephone number and IP address. Processing means any operation performed on personal data, whether or not by automated means, including collection, recording, organisation, structuring, storage, adaptation, retrieval, consultation, use, disclosure, erasure or destruction.
Personal data processing is governed by data protection laws and regulations applicable to the nature of the processing and the jurisdiction in which it takes place. The primary data protection framework applicable to the processing described in this Privacy Policy is Regulation (EU) 2016/679 of the European Parliament and of the Council (General Data Protection Regulation, "GDPR").
Under the GDPR, the entity that determines the purposes and means of processing personal data is the controller. The controller may engage a processor, which is an entity authorised to process personal data solely on the instructions of the controller and for no purpose of its own.
Leadtech Innovation S.L. acts as controller in respect of all processing of personal data described in this Privacy Policy.
2. Categories of Personal Data Processed
All Data Subjects
Device information: if you visit our Employment Portal, we may collect information about your device, including IP address, browser type and version, session behaviour, traffic source, screen resolution, preferred language, geographic location, operating system, and device settings and usage.
Technical and statistical data: if you visit our Employment Portal, we may collect technical and statistical data about your use of the site, including URLs visited and on-site activity.
Communications data: we may collect and store your communications with us, including the content of emails, video recordings, social media messages, information added to your account, and survey responses.
Contact data: including your name, email address, telephone number and postal address.
Candidates
Interview, assessment, and recruitment process data: including interview notes, assessments and tests completed, and salary expectations.
Application data: including your CV, cover letter, work samples, references, letters of recommendation, and educational background.
Public profile information: information collected from publicly available sources relating to your professional experience, such as LinkedIn or your current employer's website.
Information provided by references: information received from our employees or partners who refer you, or from persons you have named as your references.
3. Sources of Personal Data
All Data Subjects
From the Employment Portal: we may collect technical and statistical data about how you use the Employment Portal, as well as device information.
Directly from you: the majority of personal data we process is received directly from you, for example when you apply for a position or connect with us. You may choose not to provide certain information; however, some personal data is necessary for us to process your application or respond to your enquiry.
References
Candidates
From publicly available sources: we may collect personal data from public sources such as LinkedIn or your current employer's website.
From our referrers: we may receive information about you from our employees or partners (such as recruitment service providers) if they consider your profile of interest.
From your references: if you provide references, we may collect information about you from them.
Data created by us or in cooperation with you: information about your application and profile is generally created by us, or jointly with you, during the recruitment process. This may include interview notes, assessments and tests.
4. Purposes of Processing
Protecting and enforcing our rights and interests, and those of third parties, including in connection with legal claims.
Data Subjects Affected: Data subjects affected by the relevant legal matter — which may include individuals from all categories listed above.
Categories of Personal Data: All categories of personal data listed above may be used for this purpose.
Sharing your personal data with other recipients, for the purposes described in Section 5 below.
Data Subjects Affected: Varies depending on the purpose of the sharing — see Section 5 below.
Categories of Personal Data: All categories of personal data listed above may be used for this purpose.
Collecting information about your use of the Employment Portal using cookies and other tracking technologies, as described in our Cookie Policy.
Data Subjects Affected: Visitors.
Categories of Personal Data: Device information.
Maintaining, developing, testing, and ensuring the security of the Employment Portal.
Data Subjects Affected: Visitors.
Categories of Personal Data: Device information; Technical and statistical data.
Analysing the performance and usage of the Employment Portal and its content, in order to obtain statistics and improve operational performance.
Data Subjects Affected: Visitors.
Categories of Personal Data: Device information; Technical and statistical data.
Providing you with updates about our current vacancies.
Data Subjects Affected: Connected Candidates.
Categories of Personal Data: Contact data; Communications data.
Reviewing profiles and applications submitted to us, including communicating with you about your application and profile.
Data Subjects Affected: Connected Candidates; Applicant Candidates.
Categories of Personal Data: All categories of personal data listed above may be used for this purpose.
Independently collecting and evaluating your professional profile, including communicating with you in that regard.
Data Subjects Affected: Prospected Candidates; Referred Candidates.
Categories of Personal Data: All categories of personal data listed above may be used for this purpose.
Contacting you directly about specific current and future vacancies.
Data Subjects Affected: Candidates.
Categories of Personal Data: All categories of personal data listed above may be used for this purpose.
Recording the interview(s) conducted with you.
Data Subjects Affected: Candidates.
Categories of Personal Data: Communications data.
Contacting you to request your participation in surveys.
Data Subjects Affected: Candidates.
Categories of Personal Data: All categories of personal data listed above may be used for this purpose.
Contacting you to request information about a Candidate and evaluating the information you provide.
Data Subjects Affected: References.
Categories of Personal Data: Contact data; Communications data.
5. Recipients of Personal Data
Service providers (processors): we may share your personal data with providers that supply services and functionalities for our employer branding and recruitment processes. This includes our recruitment service provider and the provider of our Employment Portal and associated applicant tracking system, Teamtailor AB, acting as processor pursuant to Article 28 GDPR.
Group companies: we may share your personal data with entities within our corporate group if they provide services or functionalities for our employer branding and recruitment processes, such as access to specific systems and software.
Cookie providers: subject to your consent, third-party companies may place cookies on the Employment Portal and will process the data collected by those cookies in accordance with their own privacy policies. Details of the cookies applied are set out in our Cookie Policy.
Competent authorities and public bodies: we will disclose your personal data to authorities and other public bodies if we are subject to a legal obligation to do so.
Parties to legal proceedings: if necessary to protect or enforce our rights, we may share your personal data with public authorities or other parties involved in actual or potential legal proceedings, including, for example, in connection with discrimination claims.
Mergers, acquisitions, and corporate restructuring: in connection with a potential merger, sale of company assets, financing, or acquisition of all or part of our business by another entity, we may share your personal data with the other parties involved in the process.
6. Legal Bases for Processing
We only process your personal data if a lawful basis under Article 6 GDPR exists. The applicable legal basis depends on the purpose for which the personal data is collected and processed. In the majority of cases, the legal basis will be one of the following:
Performance of pre-contractual measures: for the purpose of managing and processing your application for a published vacancy, including reviewing your profile, contacting you to arrange an interview, and assessing your suitability for the relevant position. If the management of recruitment processes involves the use of third-party tools, your personal data may be processed through those tools strictly for these purposes.
Performance of a contract and/or pre-contractual measures: for managing communications with third parties in connection with attending to and providing the information you have requested, and/or responding to your enquiries.
Compliance with a legal obligation: for complying with our legal and regulatory obligations and requirements, including responding to judicial, law enforcement, or competent authority requests.
Consent: exclusively for optional activities that are not necessary for processing your application, such as recording an interview, conducting a voluntary assessment, or retaining your application for future employment opportunities. You may withdraw your consent at any time without affecting the lawfulness of processing carried out prior to withdrawal or the continuation of the remainder of the selection process. Applicable retention periods for each of these processing activities are set out in Section 8 of this Privacy
Policy.
7. International Transfers of Personal Data
We endeavour at all times to process your personal data within the European Economic Area (EEA). However, some of our service providers process personal data outside the EEA. We also engage providers whose parent company, or whose sub-processor's parent company, is established outside the EEA. In such cases, we have taken into account the risk that personal data may be disclosed to recipients in third countries, including as a result of a governmental authority request.
If a recipient of your personal data (as described in Section 5) is established outside the EEA, this will also result in a transfer of your personal data to a third country.
For all international transfers of personal data carried out by us or by our processors, we ensure that an appropriate safeguard recognised under GDPR is in place. The safeguards we rely upon include:
Adequacy decisions (Article 45 GDPR): a decision by the European Commission that the third country to which personal data is transferred ensures an adequate level of protection equivalent to that afforded by the GDPR. In particular, we rely on the EU-US Data Privacy Framework adequacy decision and the adequacy decision for the United Kingdom.
Standard Contractual Clauses (Article 46(2)(c) GDPR): the execution of the European Commission's Standard Contractual Clauses with the recipient of the personal data outside the EEA, requiring the recipient to guarantee that the level of protection afforded by the GDPR continues to apply and that your rights remain protected.
In addition to the above contractual safeguards, we implement appropriate technical and organisational measures to protect personal data transferred to third countries against unauthorised disclosure. The specific measures implemented depend on what is technically feasible and sufficiently effective for the particular transfer.
For further information about the circumstances in which your personal data is transferred outside the EEA, please contact us using the details provided in Sections 9 and 10 below.
8. Retention Periods
Visitors
We may retain your personal data for a maximum period of one (1) year for security purposes and to ensure the proper functioning of the Employment Portal. Retention periods applicable to cookies are set out in our Cookie Policy.
Candidates
If you submit an application through the Employment Portal, we may retain your personal data for the duration of the relevant recruitment process, which will generally not exceed 24 months from the date of your application, unless justified circumstances relating to the nature or complexity of the process require a longer period.
Upon conclusion of the recruitment process, we retain your personal data for the applicable limitation period under Spanish law for legal claims that may arise from the process, as well as for the period necessary to comply with our legal documentation obligations in relation to selection processes. Upon expiry of these periods, your personal data will be permanently and securely deleted from our systems and databases.
Upon conclusion of the recruitment process, we will retain your personal data in a blocked state — inaccessible for operational or commercial purposes — for the period necessary to comply with our legal documentation obligations and to address any legal claims that may arise from the process. In accordance with applicable Spanish law, this period will not exceed four (4) years from the conclusion of the process. Upon expiry of this period, your personal data will be permanently and securely erased from our systems and records. Additionally, you may have the option to provide your consent for us to retain your personal data for future employment opportunities. Should you choose to do so, we will retain your personal data in our candidate database for a period of up to twenty four (24) months from the date of your application or your last contact with us, in order to contact you regarding other positions that may be suitable for your profile. Upon expiry of that period, or in the event that you withdraw your consent, your personal data will be permanently deleted.
You may withdraw your consent at any time without affecting the lawfulness of processing carried out on the basis of that consent prior to its withdrawal.
References
We retain your personal data for the same period as the personal data of the Candidate in respect of whom you acted as a reference.
9. Data Subject Rights
This section sets out the rights you are entitled to exercise in relation to the processing of your personal data under the GDPR. As described below, certain rights are available only in connection with specific legal bases for processing.
To exercise any of the rights listed below, we recommend that you:
Visit the Data and Privacy page on our Careers Portal to facilitate the exercise of your rights;
Log in to your account with us, if account settings allow you to exercise certain rights directly; or
Contact us directly at privacy@leadtech.com.
Right to be informed
You have the right to be informed about how we process your personal data, as well as to be informed if we intend to process your personal data for a purpose other than that for which it was originally collected. We fulfil this obligation through this Privacy Policy, through updates published on our Employment Portal (see also Section 11 below), and by responding to any questions you may have.
Right of access
You have the right to obtain confirmation as to whether we process personal data concerning you and, if so, to receive a copy of that personal data together with information about how it is being processed.
Right to data portability
You may request a copy of the personal data relating to you that we process on the basis of the performance of a contract or your consent, in a structured, commonly used, and machine-readable format. This enables you to use that data elsewhere, including transferring it to another controller. When it is technically feasible, you also have the right to request that we transfer your personal data directly to another controller.
Right to erasure — 'right to be forgotten'
In certain circumstances, you have the right to request the erasure of personal data concerning you. This right applies, for example, if the personal data is no longer necessary for the purposes for which it was collected; if you withdraw your consent; or if you have objected to the processing and there are no overriding legitimate grounds for continuing it (see right to object below).
Right to object
You have the right to object to processing of your personal data that is based on our legitimate interests, on grounds relating to your particular situation.
Right to restriction of processing
If you consider that the personal data we process about you is inaccurate, that our processing is unlawful, or that we no longer require the data for a specific purpose, you have the right to request restriction of processing of that personal data. If you exercise the right to object, you may also request that processing be restricted while we assess your request. If processing is restricted, we will, subject to storage, only process the data with your consent or for the establishment, exercise, or defence of legal claims, to protect the rights of another natural or legal person, or for reasons of important public interest.
Right to rectification
You have the right to request that inaccurate personal data concerning you be corrected, and that incomplete personal data be completed.
Right to withdraw consent
If we process your personal data on the basis of your consent, you have the right to withdraw that consent at any time. Withdrawal of consent does not affect the lawfulness of processing carried out on the basis of consent prior to its withdrawal.
Right to lodge a complaint
If you have concerns about our processing of your personal data, you have the right to lodge a complaint with the competent supervisory authority. In Spain, the supervisory authority is the Agencia Española de Protección de Datos (AEPD). If you are located in another EU Member State, you may also lodge a complaint with your national supervisory authority, details of which are available at https://edpb.europa.eu/about-edpb/about-edpb/members_en. If you are located in the United Kingdom, you may lodge a complaint with the Information Commissioner's Office (ICO) at https://ico.org.uk/make-a-complaint/.
10. Contact Details
If you wish to exercise your data subject rights, or if you have any questions, comments, or concerns about how we manage your personal data, please contact us at privacy@leadtech.com.
11. Updates to this Privacy Policy
We update this Privacy Policy when necessary for example, if we commence processing your personal data in a new way, if we wish to provide clearer information, or if an update is required to ensure compliance with applicable data protection laws and regulations.
We encourage you to check this page regularly for updates. The date on which this Privacy Policy was last updated is always displayed at the top of the page.
