Privacy Policy & Candidate Agreement.

Privacy Notice for website visitors, hiring companies and referees

Version 1.0

This part is for visitors to our websites, for hiring companies and the people who work there, and for referees. If you are a candidate, the Candidate Privacy Notice in Part 2 of the Candidate Agreement below applies to you.

A1. Who we are

BE Consultancy Group BV, De Vrièrestraat 54/2, 2000 Antwerpen, Belgium, enterprise number BE 0811.467.950 (BE Consultancy Group), and All European Careers Spain SL, C. de Manuel Galiana i Uriarte, 5, bajo C, 03100 Alicante, Spain, NIF B02930345 (All European Careers) ("we", "us") are joint controllers of your personal data (Art. 26 GDPR): we share one candidate database and decide together how it is used. BE Consultancy Group BV operates the database and is your single point of contact, whichever company you deal with. You can also exercise your rights with All European Careers Spain SL, and we coordinate the answer. On request, we send you the essence of our arrangement. The GDPR, the Belgian Data Protection Act of 30 July 2018 and the Spanish Organic Law 3/2018 govern how we handle your data.

Privacy contact: gdpr@be-consultancy-group.com.

A2. Website visitors

Visiting our sites. Our hosting provider Cloudflare records technical data in server logs when you visit: IP address, browser type, pages requested, date and time. We use it only to keep the sites secure and running (legitimate interest, Art. 6(1)(f)). Logs are kept for 30 days. We set no tracking cookies and do not use Google Analytics. The vacancies shown on our jobs page come from our recruitment system and contain no personal data.

Contact form. The form opens an email in your own mail application. We receive what you send: your name, company, email address and message. We use it to answer you (steps at your request, Art. 6(1)(b)) and keep the exchange for 12 months after our last message, unless it leads to an agreement (section A3) or to a candidate record (Part 2).

Profile pages. If you open a link to an anonymised candidate profile that we sent you, we record that the link was opened, so that links can expire and we know an introduction reached you (legitimate interest).

A3. Hiring companies and their contacts

This section is for people who work at companies with open vacancies (hiring managers, talent teams, recruiters, founders) and for our client contacts.

What we collect: your name, job title, company, work email address, work phone number, LinkedIn profile address, the vacancy your company published, our correspondence with you, whether our emails were opened and our links visited, meeting notes, signed terms, and for clients the details needed for contracts and invoicing.

Where it comes from: you; your company's website and published vacancies; the job board or platform where the vacancy was posted; business-contact data providers like Apollo; and our own records under either brand.

Why, and on what legal basis:

What we do	Why (legal basis)
Contact you about a candidate who fits a vacancy your company has published	Our legitimate interest in offering our service, and yours in filling a live role (Art. 6(1)(f)). We contact you only about roles your company has published, only at work contact details, and we stop the moment you ask. Where the law of your country requires your prior agreement, we ask for it first.
Manage introductions, agreements, interviews and offers once you engage with us	Our agreement with your company (Art. 6(1)(b))
Invoicing, accounting and tax	Legal obligation (Art. 6(1)(c))
Keep a suppression list when you opt out, so we do not contact you again	Legitimate interest and legal obligation

Opting out. Every message from us has a simple way to stop further contact: reply "no thanks" or use the link. We then add your address, and your company's domain if you ask, to a suppression list that is checked before every send, across email, LinkedIn and phone.

Anonymised profiles you receive are confidential and subject to our terms. You must not attempt to identify the candidate before the full profile is released. Once you hold a candidate's identified profile, your company is a data controller of that data in its own right.

Who receives your data: the service providers listed in Part 2, section 7 (our CRM, email, e-signature and file-storage tools), our lawyers, accountants, auditors and insurers, and public authorities where the law requires it. Candidates are told your company's name and the role, never your personal details.

How long we keep it: contacts we approached who did not engage, 12 months after our last message, then deleted, with a minimal suppression record kept if you opted out; client contacts, for the length of the relationship and 7 years after the last contract or invoice, as Belgian accounting and tax law requires; signed terms, 7 years after they end.

Your rights. You can access, correct, erase, restrict, object to and port your data, and complain to the Belgian Data Protection Authority (www.dataprotectionauthority.be) or the authority of the country where you live, in the same way as described in Part 2, section 10. International transfers, security and changes to this notice are covered in Part 2, sections 8, 11 and 12, and apply to you in the same way.

A4. Referees and people who refer a candidate

If a candidate names you as a referee, we contact you only when that candidate reaches a shortlist, use what you tell us only to assess that candidate, and keep it as part of the candidate's record (Part 2, section 9). If you refer someone to us, we keep your name as the source of that referral. You have the rights described in Part 2, section 10.

Candidate Agreement and Privacy Notice

BE Consultancy Group BV — Version 1.1

Applies to candidates of BE Consultancy Group (BE Consultancy Group BV) and All European Careers (All European Careers Spain SL).

Part 1: Candidate Terms

Clause 1. Who we are and what this covers

BE Consultancy Group BV, De Vrièrestraat 54/2, 2000 Antwerpen, Belgium, enterprise number BE 0811.467.950 (BE Consultancy Group), and its sister company All European Careers Spain SL, C. de Manuel Galiana i Uriarte, 5, bajo C, 03100 Alicante, Spain, NIF B02930345 (All European Careers) ("we", "us"), represent you, the candidate, for permanent and contract roles with hiring companies. Either company may sign the contract for a placement; the contract says which. Representation is non-exclusive and free for you: hiring companies pay our fee, you never pay anything.

These terms apply whether you applied to a specific vacancy or asked us to represent you. In both cases we present you to the company concerned and may match you to other roles that fit, as set out below.

Clause 2. What we do

• Assess your experience through your CV, a call or an intake interview, and where relevant a technical screen. References are taken only at shortlist stage and only after telling you.
• Build your profile, including an anonymised version that does not identify you.
• Match your profile continuously against live vacancies. Matching is AI-assisted; a recruiter reviews every match and decides. No introduction, rejection or other significant decision is made by a machine alone.
• Present your anonymised profile to companies with a fitting vacancy, release your full profile once a company signs our terms, coordinate interviews and support you through to offer.

Clause 3. How your identity is protected

• Until a company has signed our terms for you, it sees only your anonymised profile: no name, no contact details, no employer names and no details that would identify you.
• We never approach your current or past employers, nor any company on your block-list. You can add companies to your block-list at any time by a simple message.
• By accepting these terms you authorise us, once and for all, to release your full profile to any company that has signed our terms for a role that fits you, within the limits above. We do not ask you again for each company.
• Each time we are about to release your full profile, we send you the company name and the role, and release it before the end of the next business day. Reply STOP and we do not send it, or we withdraw you if it has already gone. You never need to reply for an introduction to go ahead.
• Tell us at the start, and whenever it changes, which companies you are already talking to, directly or through another agency. We do not introduce you to those companies.

Clause 4. Representation per introduction

• For each company we introduce you to, we are your representative for that company and role for six months from the date of the introduction message.
• If that company offers you a role or approaches you within those six months, including for a different role, you tell us within five business days.
• If you are already in a process with a company named in an introduction message, reply STOP: that introduction does not count.

Clause 5. Your freedom

You remain free to apply anywhere, work with other agencies and run your own search.

You can pause or end our representation at any time by a simple message. Introductions already made are closed gracefully: we tell the company and stop. Clause 4 continues to apply to those introductions.

Clause 6. What we ask of you

• Give us accurate and current information about your experience, availability, expectations and work authorisation, and tell us when any of it changes or when you accept a role elsewhere.
• Keep your block-list and your list of ongoing processes up to date; we can only exclude what we know about.
• Respond to our messages about interviews within two business days where you can.
• Treat information about companies and roles that you receive through us as confidential.

Clause 7. Your data

How we handle your personal data is set out in Part 2, the Candidate Privacy Notice, which you accept together with these terms.

Clause 8. Confidentiality

We keep your job search confidential, including from your current employer. You keep confidential what you learn through us about companies and their vacancies.

Clause 9. No guarantee, liability

We work on a best-efforts basis and do not guarantee introductions, interviews or a placement. We are liable only for direct damage caused by our fault, to the extent the law allows.

Clause 10. Duration, changes, law

These terms apply from your acceptance until you or we end the representation. Clauses 4 and 8 survive for introductions already made.

If we change these terms or the privacy notice in a way that matters to you, we tell you before the change takes effect and ask for your renewed acceptance where needed.

Belgian law applies to these terms. Disputes go to the courts of Antwerp, without prejudice to any mandatory rules of the country where you live. A placement contract signed with All European Careers Spain SL follows the law and courts stated in that contract.

Part 2: Candidate Privacy Notice

1. Who we are

BE Consultancy Group BV, De Vrièrestraat 54/2, 2000 Antwerpen, Belgium, enterprise number BE 0811.467.950 (BE Consultancy Group), and All European Careers Spain SL, C. de Manuel Galiana i Uriarte, 5, bajo C, 03100 Alicante, Spain, NIF B02930345 (All European Careers) ("we", "us") are joint controllers of your personal data (Art. 26 GDPR): we share one candidate database and decide together how it is used. BE Consultancy Group BV operates the database and is your single point of contact, whichever company you deal with. You can also exercise your rights with All European Careers Spain SL, and we coordinate the answer. On request, we send you the essence of our arrangement. The GDPR, the Belgian Data Protection Act of 30 July 2018 and the Spanish Organic Law 3/2018 govern how we handle your data.

Privacy contact:gdpr@be-consultancy-group.com. Use it for any question, request or complaint about your data.

Privacy lead: Pablo de Prado Lopez.

2. Two ways to work with us, one agreement

Whichever way you came to us, you accept one document, the Candidate Agreement, of which this notice is Part 2, and both paths are open to you from then on. Everything here applies equally whether you came to us through our website, a LinkedIn advert, a job board, a referral, a recruiter approaching you, or either of our brands.

3. What data we collect and where it comes from

• From you: name, contact details, location and work authorisation, your CV and everything in it (career history, education, skills, languages, certifications, links to professional profiles), your target roles, salary or day-rate expectations, availability and notice period, remote or on-site preferences, companies you are already in process with, companies you would like to work for, your block-list, and anything you tell us in messages or calls.
• Created by us while working with you: interview and screening notes, a written assessment of your fit for the roles we handle, the anonymised version of your profile, match proposals and the reasons for them, which companies you were introduced to and when we told you, any introduction you stopped, submission and interview history, feedback from companies, and offer details.
• From other people, with your knowledge: references (only at shortlist stage, and we tell you first), interview feedback from hiring companies, and, where you were referred, the name of the person who referred you.
• From public professional sources: if a recruiter approaches you rather than the other way round, we will have found you on LinkedIn, GitHub, a job board where you posted your CV, a similar public professional source, or in our own database from an earlier contact under either brand. We tell you this at first contact and point you to this notice. If you do not respond within 12 months, we delete what we collected.
• Records we keep about the process: the date, time and version of your acceptance of the Candidate Agreement, of which this notice is part, the introduction messages we sent you and any stop request, your objections, delivery and open data for emails we send you, and the source you came from (which advert or page).

What we do not want: please do not send us data about your health, religion, ethnicity, sexuality, political opinions, union membership or criminal record. We do not ask for it and it plays no role in our assessment. If you need an adjustment during the process, for example for an interview, tell us and we record only what is needed to arrange it, with your explicit consent. Where a company legally requires a background or criminal-record check for a specific role, we tell you before anything happens and the company runs it under its own responsibility. We do not knowingly process data of anyone under 18.

4. What we do with your data and on what legal basis

Providing your data is voluntary, but without it we cannot consider you for a role or represent you.

What we never do: sell your data, contact your current employer, use your data for advertising, or make a decision about you by machine alone (section 5). Our websites set no tracking cookies.

5. AI-assisted tools, and the decisions people make

We use AI tools in three places: to read your CV into structured fields, to propose matches between your profile and published vacancies (with a short written reason for each proposal), and to draft documents: your anonymised profile, the recruiter's interview notes from the transcript, and the messages we send to companies.

Every draft is a draft. A recruiter reads it, corrects it and decides. No introduction, submission, rejection or other decision with a significant effect on you is ever made solely by automated means (GDPR Art. 22). In practice:

• a recruiter decides whether we represent you, after interviewing you;
• a recruiter decides which proposed matches are real before anything is sent;
• a recruiter reviews every anonymised profile before it leaves us;
• you set the limits: your block-list, the companies you are already talking to, and the right to stop any introduction.

Under the EU AI Act, AI used in recruitment is classed as high-risk. We are a deployer of such tools and inform you accordingly: people oversee every output, we keep logs of what the AI proposed and what the recruiter decided, and you can ask us at any time what role an AI tool played in a decision about you, ask a person to review that decision, and give your point of view.

Our AI providers process your data only on our instructions under a data processing agreement and may or may not use it to train their models.

6. The representation safeguards (candidate-first)

• Anonymised first: Until a company has signed our terms for you, it only ever sees an anonymised profile: no name, no contact details, no employer names, and no dates or details that would let someone identify you. A recruiter checks every profile against a deliberate reverse-search and generalises it until the answer is no. We call the profile anonymised because a company cannot identify you from it. In our own hands it remains your personal data and stays protected under this notice.
• Never your employers, never your block-list: Your current and past employers are excluded automatically. Any other company you name, at signup or later by a simple message, goes on your block-list and is never approached about you. The block-list is checked before any profile is sent, and our system blocks the send if that check has not been recorded.
• Your mandate, given once: By accepting the Candidate Agreement, you authorise us to release your full profile to any company that has signed our terms for a role that fits you, within the limits above, without asking you again for each company. This is what lets us move within hours of a company signing.
• We tell you every time: Each time your profile is about to go to a company, we send you the company name and the role, and release your profile before the end of the next business day. Reply STOP and we do not send it, or we withdraw you if it has already gone. You never need to reply to let an introduction go ahead.
• Already in process elsewhere: Tell us at intake which companies you are already talking to, directly or through another agency, and keep that list current. It is the only way we can avoid introducing you twice.
• Only after terms: Your full profile is released only to a company that has signed our terms. Every release is logged with the date, time, company, role and the message we sent you.
• Profile links expire: Anonymised profiles travel through non-guessable, non-indexed links that expire, never as attachments.
• You can pause or leave at any time (section 10).

For direct applications to a vacancy the same principle applies in a simpler form: if the vacancy was published without the company's name, we tell you the company before your details go to them, and you can withdraw.

7. Who receives your data

Hiring companies: For a vacancy you applied to: that company, by name, after confirmation with you. For representation: matching companies receive the anonymised profile; your identified profile only after they have signed our terms, with a message to you each time (section 6). Once a company holds your identified profile it becomes a controller of that data in its own right, and its own privacy notice applies to its selection process.

Service providers (processors) who act only on our instructions, under data processing agreements:

Vacancy data reaches us from job boards and vacancy-data providers. No candidate data goes to those providers, nor to the tools we use to find hiring contacts at companies.

Others, when relevant: your referees (at shortlist, announced to you); payroll, employer-of-record or umbrella partners for contract placements; our lawyers, accountants, auditors and insurers; public authorities where the law requires it.

LinkedIn and job boards where you applied are independent controllers for what you did on their platform. Their notices apply there.

Our team: members of our team in Spain and Sri Lanka may access your data to support the process; for Sri Lanka, under the safeguards in section 8.

8. Where your data goes (international transfers)

We are based in Belgium and store your data in the EEA. Some providers, or members of our team, are outside the EEA; currently the USA for AI processing, website hosting and dictation, the United Kingdom for telephony, and Sri Lanka, where team members may access records. For every such transfer we rely on a lawful mechanism: an EU adequacy decision (including the EU-US Data Privacy Framework for certified providers), or the European Commission's Standard Contractual Clauses together with a transfer risk assessment. You can ask us for a copy of the safeguards in place.

Wherever you live, this notice and the GDPR apply to you, because we are established in Belgium. If the law of your own country gives you additional rights, you keep them: tell us and we will honour them.

9. How long we keep your data

Where a legal claim or investigation is under way, we may keep the relevant data until it is closed.

10. Your rights, and how to use them

You can, at any time and free of charge:

• Access your data and get a copy of it, including our notes about you.
• Correct anything inaccurate or incomplete. Your recruiter can do this on the spot.
• Erase your data, subject to the rows in section 9 that the law requires us to keep.
• Restrict processing while a question about it is being resolved.
• Object to processing based on legitimate interest, including being kept in the talent pool. We then stop unless we can show a compelling reason, which for recruitment we normally cannot, so in practice we stop.
• Take your data with you (portability) in a machine-readable format, for the data you gave us.
• Withdraw consent where consent is the basis (interview recording, insights emails), with no effect on what was done before.
• Ask about AI: what role automated tools played in a decision about you, and have a person review it (section 5).
• Stop a specific introduction by replying STOP to the message we send you, or by telling your recruiter. This has no consequence for anything else.
• Pause or withdraw from representation with a simple message. Introductions already made and in process are closed gracefully: we tell the company you have withdrawn and stop. The per-introduction commitments in Part 1 continue to apply to those introductions.
• Complain to a supervisory authority. Our lead authority is the Belgian Data Protection Authority (Gegevensbeschermingsautoritéit / Autorité de protection des données, www.dataprotectionauthority.be), or the Spanish Data Protection Agency (Agencia Española de Protección de Datos, www.aepd.es). You can also complain to the data protection authority of the country where you live. We would appreciate the chance to resolve any concern first.

Write to gdpr@be-consultancy-group.com or tell your recruiter. We may need to confirm your identity. We respond within one month; if a request is complex we may take up to two more months and will tell you why.

11. How we keep your data safe

Access to candidate data is limited to the recruiters who work with you and the founder. Roles in our system prevent recruiters from deleting or exporting the database, and compliance fields (your acceptance date, the introduction messages sent to you) are read-only for staff. Anonymised profiles travel through expiring, non-guessable links, never as attachments. Our providers encrypt data in transit and at rest. Interview recordings are deleted automatically. We keep no candidate data in shared spreadsheets or personal drives.

Keep your side safe too: tell us when your contact details change, and treat what we share with you about companies as confidential.

12. Changes to this notice

We may update this notice as our services or the law change. Each version carries a number and a date. If a change affects how we use your data in a material way, we tell you before it takes effect. Where a new purpose would need your agreement, we ask for it; we do not assume it.

13. Contact

BE Consultancy Group BV, De Vrièrestraat 54/2, 2000 Antwerpen, Belgium, enterprise number BE 0811.467.950 — gdpr@be-consultancy-group.com

All European Careers Spain SL, C. de Manuel Galiana i Uriarte, 5, bajo C, 03100 Alicante, Spain, NIF B02930345 — gdpr@all-european-careers.com

Your acceptance

In our online forms (one tick on every form, under both brands):

(required) I accept the Candidate Agreement of BE Consultancy Group BV and All European Careers Spain SL (BE Consultancy Group / All European Careers): the Candidate Terms, under which they represent me for this and other roles that fit, market my anonymised profile and release my full profile to companies that sign their terms, never to my current or past employers or a company I block, with a message to me each time that I can stop; and the Privacy Notice, which describes how my personal data is processed, including AI-assisted matching with human review.(optional) Send me relevant market and salary insights for my profile. Unsubscribe any time.

How your acceptance is recorded: We store the date, time, source and version of your acceptance and email you a copy of this document. If you prefer a signed copy, ask your recruiter and we send it through Zoho Sign: I accept the Candidate Agreement, version 1.1, Parts 1 and 2.