Privacy Policy

Last updated: 1 October 2026

1. Who is responsible for your personal data?

The data controller is Victoria Eugenia Aragón Espinosa, a self-employed professional established in Spain and operating commercially under the name Growing People Co. Contact: victoria@growingpeopleco.com. Business address: C/ Poeta Garcilaso 2, Bajo Izquierda, 03005 Alicante, Spain.

2. What data do we process and why?

Business enquiries: identification and contact details, company information and the content of your enquiry are processed to respond to requests, discuss recruitment or assessment services and manage the pre-contractual or contractual relationship where applicable.

Candidates and talent network: identification and contact details, CV, education, professional experience, skills, location, availability, right-to-work information and other information voluntarily supplied for recruitment purposes may be processed to assess suitability for relevant opportunities and manage recruitment processes.

We ask candidates not to include unnecessary special-category information in a CV or application. Where a recruitment process involves psychometric or psychological assessment that produces special-category data, separate information and an appropriate legal basis will be provided before that assessment.

3. Legal bases

We process business enquiries and recruitment applications where necessary to take steps at the request of the individual before entering into a contract, to manage contractual relationships, to comply with legal obligations, or on the basis of legitimate interests where applicable. Where consent is legally required — including certain future talent-pool uses after a recruitment process or specific assessment activities — it will be requested separately and may be withdrawn.

4. Who may receive the data?

Candidate data may be shared with a prospective employer only where this is relevant to a recruitment process and the candidate has been appropriately informed. Service providers supporting hosting, website forms, email, recruitment administration or professional assessment may process data on our behalf under applicable data-protection safeguards. Data will not be sold.

5. International processing

Growing People Co. operates from Spain and may support employers and candidates across Malta, Spain and other markets. Where personal data is transferred outside the European Economic Area, an appropriate transfer mechanism and safeguards required by the GDPR will be used where applicable.

6. How long do we keep data?

Data is retained only for as long as necessary for the purpose for which it was collected and for any period required to establish or defend legal claims or comply with legal obligations. Candidate data relating to a specific recruitment process will not automatically be retained for unrelated future opportunities once that process ends. Where we invite a candidate to remain in the Growing People Co. talent network, the relevant retention basis and period will be communicated and managed separately.

7. Your rights

You may request access, rectification, erasure, restriction, portability where applicable, or object to processing where the GDPR provides that right. You may also withdraw consent at any time where processing is based on consent. Requests can be sent to victoria@growingpeopleco.com. You also have the right to lodge a complaint with the Spanish Data Protection Agency (AEPD).

8. Data security

Appropriate technical and organisational measures are applied to protect personal data against unauthorised access, loss, alteration or disclosure. Access to candidate information is limited according to the recruitment purpose and operational need.

9. Data obtained from other sources

Where we identify a potential candidate through professional platforms, referrals or other lawful sources rather than directly from the individual, we will provide the information required by Article 14 GDPR, including the source and purpose of the processing, within the applicable period.

10. Updates

This policy may be updated when our services, recruitment processes, technology or legal obligations change. The current version and its update date will be published on this page.