Privacy Policy

This Policy regulates the Privacy Policy of the companies that form part of the Ackermann Group, which may act as independent controllers of the personal data of candidates and users of the platform. This policy contains the information relating to the processing of data carried out through the website platform https://www.ackermanninternational.com, hereinafter, the “Platform”. When this policy refers to “Ackermann”, it shall be understood as referring to each of the companies that make up the Ackermann Group, as applicable to each processing activity.

Ackermann Group entities

You can consult the list of entities that form part of the Ackermann Group through the following link: Ackermann Group entities. This list may be updated whenever corporate, organisational or identification changes occur in the group’s entities, without the need to fully amend this Privacy Policy. This policy complies with the provisions of current legislation and, specifically, Regulation (EU) 2016/679, General Data Protection Regulation, GDPR, and Spanish Organic Law 3/2018, of 5 December, on the Protection of Personal Data and the guarantee of digital rights, LOPDGDD. This policy constitutes the extended information, or second layer of information, on the processing of your personal data. The basic information, or first layer, will be provided to you at the time your data is collected, for example, during Ackermann’s first contact with you as a candidate or through the forms on the Platform.

1. Data protection officer

Ackermann has appointed a Data Protection Officer, DPO, whom users may contact in relation to any matter concerning the processing of their personal data.

Email address: datos@ackermanninternational.com
Postal address: C/ Hermosilla, no. 30, 3rd floor, left door, 28001 Madrid, Spain.

2. Who is this policy addressed to?

This policy applies to the processing of personal data of the following categories of data subjects:

Candidates: professionals identified, assessed and managed by Ackermann within the framework of recruitment, employment intermediation and headhunting services.
Website users: individuals whose data is collected through the Platform.

3. Data controller

For each processing activity, the controller shall be the Ackermann Group entity that carries out such processing. In the context of candidate recruitment services, the Group entities act as independent data controllers. The contact details of the main controller for Spain are:

Entity: Ackermann Middle Management, S.L.
Registered office: C/ Hermosilla, 30, 3rd floor left, 28001 Madrid, Spain.
Tax ID number: B85789139
Data Protection Officer: datos@ackermanninternational.com

4. Data processing carried out by Ackermann

The main personal data processing activities carried out by Ackermann are detailed below, indicating the purpose of the processing, the categories of data processed, the applicable legal basis and the corresponding retention period.

4.1. Platform users

Purposes of processing	Categories of data	Legal basis	Retention period
Browsing the website. To allow access to the information and content made available on the Platform. Furthermore, if you access our website, we will process your browsing data for analytical, advertising and statistical purposes, provided that you have accepted the corresponding cookies in accordance with the Cookie Policy, and you may configure your preferences at any time.	Website browsing data, including data derived from your browsing with the support of cookies, pages visited, connection time and other similar information.	User consent, particularly when the user accepts or authorises the use of cookies that require such consent. Depending on the case, the legitimate interest associated with the proper technical usability, management, maintenance, development and evolution of the website, tools, network and associated information systems may also apply.	The data will be retained for the time that is essential and necessary to enable proper browsing and use of the website. With regard to data associated with cookies, the periods indicated in the Cookie Policy will apply.
Responding to queries or requests. To respond to queries or requests submitted through the contact form available on the Platform, as well as to manage requests received by telephone calls or other enabled channels.	Identification data, such as name and surname. Personal contact data, such as telephone number and email address. Personal data processed as a result of the query or request made.	User consent.	The data will be retained for the time strictly necessary to resolve or respond to the query or request made.

4.2. Candidates

Purposes of processing	Categories of data	Legal basis	Retention period
Managing registration and access to the candidate area. To manage your registration and access to the candidate area, connect with Ackermann and become part of the Global Alliance network. Your application for any process will be treated with the utmost confidentiality, and Ackermann will contact you only if your profile matches the requirements of a specific position or fits the needs of a client.	Personal identification and contact data, such as name and surname, national ID number, email address, telephone number and, where applicable, photograph. Academic and professional data, such as academic background, professional experience, professional and language skills, and salary expectations. In certain cases, special category data may be processed, such as data relating to disability.	If you apply for a specific vacancy, the processing will be necessary in order to take pre-contractual measures at the request of the data subject to assess your application and manage the process. If the vacancy is managed by a client company, that company will be the data controller and Ackermann will act as processor, processing the data in accordance with its instructions. If you register without being linked to a specific job offer, the applicable legal bases may include consent to include you in the talent database and inform you of future opportunities, as well as legitimate interest in maintaining a candidate pool and contacting you about similar positions, with the corresponding safeguards.	As a general rule, the data will be retained for as long as the information remains adequate, relevant and up to date for the stated purposes and there is a legal basis to continue considering the candidate’s professional profile for future employment opportunities in line with their experience and professional background. Ackermann will take into account, among other factors, the nature of the relationship maintained with the candidate, the existence of subsequent interactions or contacts, the validity and updating of the professional profile, the operational needs of the business, the criteria of the competent supervisory authorities, compliance with legal obligations and the handling of potential liabilities or claims. In any case, the candidate may request the deletion of their data or the restriction of its processing at any time.
Providing employment intermediation, recruitment and headhunting services. To manage the candidate’s participation in recruitment processes aimed at the possible formalisation of an employment relationship. Within this framework, Ackermann may maintain communications with the candidate, respond to queries, assess applications, identify professional opportunities aligned with their profile, create and manage their candidate profile, provide guidance on remuneration matters, coordinate interviews, carry out suitability assessments and, where applicable, submit their application to potential employers.	Personal identification and contact data, such as name and surname, national ID number, email address, telephone number and, where applicable, photograph. Academic and professional data, such as academic background, professional experience, professional and language skills, and salary expectations.	When the candidate applies for a specific recruitment process, responds to a published job offer or spontaneously sends their CV, the legal basis for the processing is the performance of pre-contractual measures taken at the request of the data subject. In direct talent search or headhunting activities, Ackermann may identify professional profiles through publicly accessible sources, such as LinkedIn, sector-specific job portals or professional directories, and contact the candidate to present a professional opportunity. In these cases, the legal basis will be legitimate interest. Once initial contact has been established, if the candidate expresses interest in participating in the process, the legal basis will become the performance of pre-contractual measures.	Candidates’ personal data will be retained for the time necessary to manage their participation in recruitment processes and to provide the employment intermediation and talent search services offered by Ackermann. As a general rule, the data will be retained for as long as the information remains adequate, relevant and up to date for the stated purposes and there is a legal basis to continue considering the candidate’s professional profile for future employment opportunities in line with their experience and professional background. Ackermann will take into account, among other factors, the nature of the relationship maintained with the candidate, the existence of subsequent interactions or contacts, the validity and updating of the professional profile, the operational needs of the business, the criteria of the competent supervisory authorities, compliance with legal obligations and the handling of potential liabilities or claims.
Creating and maintaining an internal candidate database. To create and maintain an internal database with candidate profiles collected in different recruitment processes, in order to offer future professional opportunities and provide clients with services for identifying or facilitating professional profiles.	Personal identification and contact data, such as name and surname, national ID number, email address, telephone number and, where applicable, photograph. Academic and professional data, such as academic background, professional experience, professional and language skills, and salary expectations.	The inclusion of the candidate’s profile in the database for future processes requires the data subject’s consent.	As a general rule, the data will be retained for as long as the information remains adequate, relevant and up to date for the stated purposes and there is a legal basis to continue considering the candidate’s professional profile for future employment opportunities in line with their experience and professional background. Ackermann will take into account, among other factors, the nature of the relationship maintained with the candidate, the existence of subsequent interactions or contacts, the validity and updating of the professional profile, the operational needs of the business, the criteria of the competent supervisory authorities, compliance with legal obligations and the handling of potential liabilities or claims. In any case, the candidate may request the deletion of their data or the restriction of its processing at any time.

When the legal basis for processing is consent, the candidate may withdraw it at any time, easily and free of charge, by writing to (mailto:datos@ackermanninternational.com). When personal data is no longer necessary for the processing purposes for which it was collected, it will be blocked, where applicable, and made available only to the competent authorities for the possible determination of legal liabilities, in accordance with the applicable regulations. Once the relevant legal periods have elapsed, the data will be deleted or, where appropriate, securely anonymised.

5. Source of the data

The personal data processed by Ackermann may come from the following sources:

Directly from the candidate: when they register in the candidate area, send their CV, respond to a job offer or contact Ackermann.
Publicly accessible and professional sources: such as LinkedIn, professional networks, Google, search engines, job portals, professional directories, references provided by third parties or sector-specific databases.
Platform users: through contact forms, cookies or similar technologies whose use has been authorised.

6. Consequences of not providing the data

Ackermann requests only the minimum and essential data for the stated purposes. Failure to provide certain data may prevent proper browsing of the website, the handling of a query or the candidate’s participation in recruitment processes. In the case of candidates, if the necessary data is not provided, Ackermann will not be able to include the profile in recruitment processes or offer professional opportunities aligned with their profile. The data provided must be sufficient, accurate, up to date and truthful. The user or candidate will be responsible for the personal information they provide to Ackermann.

7. Disclosure of data to third parties

Once registered in the candidate database, the information may be available to Ackermann’s global team of consultants. Likewise, in order to provide recruitment services and facilitate professional opportunities, Ackermann may disclose personal data to potential employers in relation to those offers in which the candidate has expressed interest. The following may also access the data, where necessary:

Ackermann Group companies and authorised internal staff.
Technology and IT service providers.
Providers that collaborate in recruitment processes, such as job platforms, employment boards, professional networks or assessment tools.
Third parties involved in the verification of applications, such as previous employers, educational institutions or entities related to professional references.
Professional advisers and corporate service providers.
Public authorities and competent bodies where there is a legal obligation or where necessary for the establishment, exercise or defence of claims.

Providers acting as data processors will operate under contracts compliant with Article 28 of the GDPR and will only access the data to the extent necessary to provide the contracted services.

8. International data transfers

As an international recruitment and headhunting services company, Ackermann operates through entities located in different countries. Therefore, in certain circumstances, personal data may be transferred outside the European Economic Area, EEA. Within the framework of candidate data processing activities, international transfers may take place to the following locations:

United Kingdom: the candidate management platform, Ezekia, managed by Executives Place Ltd., is located in the United Kingdom. The United Kingdom has an adequacy decision from the European Commission.
Americas: Chile, Brazil, Colombia, Ecuador, Mexico, Peru, the United States and Panama. The Ackermann Group entities in these countries act as independent controllers and may access candidate data in the context of the activities described.

International transfers are carried out with the appropriate safeguards required by the GDPR, including, where applicable, standard contractual clauses approved by the European Commission, intragroup agreements, adequacy decisions and transfer impact assessments where necessary. The data subject may request additional information on the applicable safeguards by contacting (mailto:datos@ackermanninternational.com). In relation to Platform user data, as a general rule, no international transfers are planned, without prejudice to those that may arise from the use of third-party cookies. You can find further information in the Cookie Policy.

9. Rights of data subjects

Current regulations recognise the following data protection rights for data subjects:

Access: to know whether Ackermann processes their personal data and to obtain information about such processing.
Rectification: to request the correction of inaccurate or incomplete data.
Erasure: to request the deletion of data when it is no longer necessary or where another legal ground applies.
Restriction of processing: to request the restriction of processing in certain circumstances.
Portability: to receive the data provided in a structured, commonly used and machine-readable format, where applicable.
Objection: to object to the processing of their data when it is based on legitimate interest.
Not to be subject to automated decision-making: not to be subject to decisions based solely on automated processing that produce legal effects or significantly affect them.
Withdrawal of consent: to withdraw consent at any time, without affecting the lawfulness of processing carried out prior to its withdrawal.

You may exercise your rights by sending a letter to the registered office indicated above or by sending an email to (mailto:datos@ackermanninternational.com). Where it is necessary to verify your identity, a copy of your national identity document or equivalent identification document may be requested. Ackermann will respond to your request within a maximum period of one month from its receipt. If you consider that your rights have not been duly addressed, you may lodge a complaint with the competent supervisory authority. In Spain, the supervisory authority is the Spanish Data Protection Agency, AEPD: (http://www.aepd.es).

10. Security measures

Ackermann applies technical and organisational measures appropriate to the level of risk of each processing activity, in accordance with Article 32 of the GDPR. Among other measures, Ackermann may apply access controls, data encryption, strong authentication, backups, intrusion protection tools, access logs, internal security policies, confidentiality obligations, data protection training and incident management procedures. Providers that access personal data as data processors are assessed beforehand and operate under contracts compliant with Article 28 of the GDPR.

11. Validity and amendment of the policy

This policy has been in force since 4 June 2026. Ackermann reserves the right to amend this policy in order to adapt it to future legislative, doctrinal or case-law developments, or for technical, operational, commercial, corporate and business reasons. The date of the last update will always be indicated at the beginning of this document. We recommend reviewing this policy periodically, as any amendment will be published through the Platform.