Privacy Policy

Eastern Consultancy Spain Company Limited ("we", "us", "our") is committed to protecting and respecting your privacy. This Privacy Policy explains how we collect, use, disclose, and safeguard your personal data when you visit our website or utilise our diverse specialised services, in compliance with the General Data Protection Regulation (GDPR) (EU) 2016/679 and the Spanish Organic Law on Data Protection and Guarantee of Digital Rights (LOPDGDD 3/2018).

Please read this policy carefully to understand our views and practices regarding your personal data and how we will treat it.

1. Important Information and Who We Are

1.1 Data Controller

Eastern Consultancy Spain Company Limited is the data controller responsible for your personal data.

• Registered Office Address: C. Ángel del Alcázar, 5, 3H. 45600 Talavera de la Reina, Toledo, España.
• Company Status: Registered private exempt limited liability company.
• Contact Email: espana@easternconsultancy.org

1.2 Scope of This Policy

Given our diverse business sectors, this policy applies to website visitors, job candidates, corporate clients, partners, suppliers, individuals receiving private caregiving services, and workers participating in our relocation programs.

2. The Data We Collect About You

Personal data, or personal information, means any information about an individual from which that person can be identified. We may collect, use, store, and transfer different kinds of personal data about you, which we have grouped as follows depending on your relationship with us:

2.1 For Website Visitors

• Technical Data: Internet protocol (IP) address, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform, and other technology on the devices you use to access this website.
• Usage Data: Information about how you use our website, products, and services.

2.2 For Recruitment Candidates and Provided Staff

• Identity Data: First name, last name, username or similar identifier, marital status, title, date of birth, gender, passport/ID number, and nationality.
• Contact Data: Billing address, delivery address, email address, and telephone numbers.
• Professional & Employment Data: Your curriculum vitae (CV), employment history, academic qualifications, professional certifications, language skills, and references.
• Relocation & Travel Data: Visa status, work permits, travel itineraries, and accommodation arrangements.

2.3 For Private Caregiving and Monitoring Clients

• Client Identity & Contact Data: Identity and contact details of the care recipient and their designated family sponsors or legal guardians.
• Special Category Data (Health Data): To provide safe and adequate private caregiving and monitoring to elderly individuals, we process sensitive health details, including medical conditions, care requirements, physical mobility limitations, dietary needs, and emergency medical contacts. Note: We only process this data with explicit, written consent or where necessary for vital interests.

2.4 For Corporate Clients, Suppliers, and Medical Organisations

• Business Contact Data: Name, job title, corporate email, phone number, and physical office address of company representatives, clinics, hospitals, or international trading partners.
• Financial & Transaction Data: Bank account details, payment card details, and details of payments to and from you, alongside invoices and order history for medical supplies, personnel services, or import/export commodities.

3. How Your Personal Data Is Collected

We use different methods to collect data from and about you, including through:

• Direct Interactions: You may give us your Identity, Contact, Professional, or Health Data by filling in forms on our website, uploading a CV, requesting medical supplies, booking caregiving services, or corresponding with us by post, phone, or email.
• Third Parties or Publicly Available Sources: We may receive personal data about you from various third parties, such as recruitment platforms, professional networking sites, background check agencies, or public corporate registries.
• Automated Technologies or Interactions: As you interact with our website, we may automatically collect Technical Data about your equipment, browsing actions, and patterns via cookies and server logs.

4. How We Use Your Personal Data

We will only use your personal data when the law allows us to. Most commonly, we will use your personal data in the following circumstances:

5. Data Sharing and International Transfers

5.1 Sharing with Third Parties

We may share your personal data with internal and external third parties, including:

• Corporate Clients: Third-party companies requiring contracted staff or specialised personnel services.
• Service Providers: IT, hosting, cloud storage, and administrative tool providers.
• Logistics & Relocation Partners: Airlines, travel agencies, visa processing entities, and housing coordinators to facilitate worker settlement.
• Healthcare Professionals & Authorities: Clinics, hospitals, or emergency services in connection with our medical supply distribution or elderly care services.
• Professional Advisers: Lawyers, bankers, auditors, and insurers providing consultancy, banking, legal, insurance, and accounting services.
• Regulators and Authorities: Tax authorities, customs offices, and law enforcement agencies regulating employment or import/export compliance in Spain, Africa, and other relevant markets.

5.2 International Data Transfers

Because our operations involve exporting Spanish products to Africa and other global markets, importing international products to Spain, and managing cross-border personnel placement, your personal data may be transferred outside the European Economic Area (EEA).

Whenever we transfer your personal data out of the EEA, we ensure a similar degree of protection is afforded to it by ensuring at least one of the following safeguards is implemented:

• We will transfer your personal data to countries that have been deemed to provide an adequate level of protection for personal data by the European Commission.
• Where we use certain service providers or international trade partners, we may use specific Standard Contractual Clauses (SCCs) approved by the European Commission which give personal data the same protection it has in Europe.

6. Data Security

We have put in place appropriate technical and organisational security measures to prevent your personal data from being accidentally lost, used, or accessed in an unauthorised way, altered, or disclosed. In addition, we limit access to your personal data to those employees, agents, contractors, and other third parties who have a business need to know. They will only process your personal data on our instructions and they are subject to a duty of confidentiality.

We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.

7. Data Retention

We will only retain your personal data for as long as necessary to fulfill the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements.

• Job Applications & CVs: Retained for a maximum of 2 years from submission or last contact, unless explicit consent is renewed, or the candidate is hired.
• Caregiving Records: Retained in accordance with Spanish health data retention laws and clinical observation protocols following the termination of the service agreement.
• Commercial, Tax, & Contractual Records: Retained for up to 5 to 10 years following contract termination to comply with Spanish corporate and fiscal statute of limitations laws.

8. Your Legal Rights

Under European and Spanish data protection laws, you have specific rights regarding your personal data:

• Request access to your personal data (commonly known as a "data subject access request").
• Request correction of the personal data that we hold about you.
• Request erasure of your personal data (the "right to be forgotten").
• Object to processing of your personal data where we are relying on a legitimate interest.
• Request restriction of processing of your personal data.
• Request the transfer of your personal data to you or to a third party (right to data portability).
• Withdraw consent at any time where we are relying on consent to process your personal data (such as processing special category health data for caregiving).

If you wish to exercise any of these rights, please contact us at our designated privacy email address. You also have the right to make a complaint at any time to the Spanish Data Protection Agency (Agencia Española de Protección de Datos - AEPD), the Spanish supervisory authority for data protection issues (www.aepd.es).

9. Cookies

You can set your browser to refuse all or some browser cookies, or to alert you when websites set or access cookies. If you disable or refuse cookies, please note that some parts of this website may become inaccessible or not function properly. For more details, please see our Cookies Policy.

10. Changes to This Privacy Policy

We keep our Privacy Policy under regular review. Any updates we make will be posted on this page. Your continued interaction with our platform and services constitutes acceptance of the updated terms.

11. Contact Details

If you have any questions about this Privacy Policy or our privacy practices, please contact us at:

Eastern Consultancy Spain Company Limited C. Ángel del Alcázar, 5, 3H.
45600 Talavera de la Reina, Toledo. España
Email: espana@easternconsultancy.org