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We take your privacy seriously and will only use your personal information to administer your account and to provide the service you have requested from us. However from time to time we would like to contact you by email, post and phone. We’ll always treat your details with the utmost care and will never sell them to other companies.

Privacy Policy

Client Privacy Policy

The Aspekt32 Ltd is committed to protecting and respecting your privacy. We have created this policy to inform you and make sure we are transparent about our processes. This policy might be subject to changes and updates. This version was last updated on 22 May 2018.


This Data Processing Notice applies to you if you (1) are a representative of any of our (prospective) clients or suppliers (e.g. umbrella companies), (2) you reside within the European Union and (3) if your personal data is processed on Aspekt32 Ltd’s CRM database and other internal systems.

When you use our services, you trust us with your personal data. This Data Processing Notice is meant to help you understand what personal data we collect, why we collect it, and what we do with it. Furthermore, it will briefly outline your rights as a data subject. This is important, and we hope you will take time to read it carefully. Your new rights under GDPR will only apply once the GDPR comes into effect on 25 May 2018.


General Data Protection Regulation

In accordance with the General Data Protection Regulation (EU) 2016/679 (‘GDPR’) that comes into effect on 25 May 2018, Aspekt32 Ltd is obliged to issue a Data Processing Notice if we store your personal data in our database.

The GDPR is a new regulation which replaces the Data Protection Directive 95/46. The GDPR aims to harmonise data protection legislation across EU member states, enhancing privacy rights for individuals and providing a strict framework within which commercial organisations can legally operate.


This Data Processing Notice will outline:

1. Aspekt32 Ltd as a data controller

2. Which personal data Aspekt32 Ltd collect and how we collect it

3. Why we hold your data and legal basis

4. Optional Marketing communication

5. How long will we store your data

6. What are your rights under GDPR

7. Automated decision making

8. Lodging a complaint

9. Changes to this Data Processing Notice

10. Contact details for GDPR and data queries


1. Identity and contact details of the Data Controller

All our entities act as Data Controllers as they jointly determine the purposes and means of the processing of your personal data.

Your personal data will be stored in our CRM system, Invenias. Your personal data can, therefore, be accessed and used by our employees. All the Aspekt32 Ltd offices, are thus obliged to comply with GDPR when processing your personal data, provided you reside inside the European Union. Your personal data will also be shared with our candidates if we introduce you to them for the purposes of a smooth recruitment process.


We may moreover be under a duty to disclose or share your personal data in order to comply with any legal obligation, to defend our business against a legal claim or in order to enforce or apply our standard terms of business or other agreements, or to protect the rights, property or safety of Aspekt32 Ltd, our customers, or other parties.


2. Which personal data Aspekt32 Ltd collects and how we collect it

Aspekt32 Ltd will collect the following personal data:

⦁ Your full name

⦁ Job title

⦁ Job function

⦁ LinkedIn profile

⦁ Your email addresses

⦁ Your (mobile) telephone number

⦁ Your company details (location, department)


This information may be received from you individually, but Aspekt32 Ltd is a recruitment company who acquires details from various sources e.g. through job boards, your company website, candidate referrals etc. When we process your data, our Recruitment Consultants will inform you as soon as possible of collecting the data of the source your personal data originates from. If this information is not provided, please let us know straight away and we will confirm how we located your data.


3. Why we hold your data and legal basis

Aspekt32 Ltd will collect your information to carry out our core business and ancillary activities; in particular, Aspekt32 Ltd will collect your personal data for the following purposes:

⦁ Providing you with information about current or prospective candidates;

⦁ Communicating with you to identify opportunities for your business;

⦁ Contacting you in relation to the performance of a contract with your organisation;

⦁ Evaluating your experience with Aspekt32 Ltd and our recruitment process;

⦁ Keeping your business updated by means of regular newsletters and how we can better support you to find the right candidate for the job


The legal basis under the current laws for collecting and processing your personal data is legitimate interests pursued by Aspekt32 Ltd. We have carried out a three-part test (a so-called legitimate interest’s assessment).


Aspekt32 Ltd will need to process this data to build and maintain relationships with its clients and suppliers. We also need your details to provide the best possible services to our clients, candidates, suppliers, and other business partners.


Furthermore, to support our candidate’s career aspirations and our client’s resourcing needs, we require a database of client and supplier representative data containing historical information as well as current points of contact. We will only collect information that is necessary to satisfy our legitimate business interests. Furthermore, if Aspekt32 Ltd has entered into a contract with your organisation or is in the process of entering into a contract, it moreover may need your personal data for the performance of a contract as you may be signing some of the contracts on behalf of your organisation.

4. Optional Marketing communication

Aspekt32 Ltd will hold your personal data for marketing purposes which are optional.

The legal basis for collecting and processing this personal data for marketing purposes is ‘consent,’ which means Aspekt32 Ltd will only send you marketing communication if you have opted into receiving this.


If you opted into receiving updates from Aspekt32 Ltd, we will use your data, preferences, user behavior, and information you have provided to personalize your experience, provide you with relevant service announcements and updates, and to better understand your needs and interests in relation to your job search.


Aspekt32 Ltd uses the personal data and information you have provided with your CV or portfolio to match your profile with relevant job opportunities. Our marketing team analyses your profile to provide you with additional information that helps you to better position yourself in the job market, i.e. with invitations to networking events in your city, news and updates relevant for your area of expertise, or job alerts tailored to your preferences, if you have opted in to receiving marketing communication.


You are entitled to withdraw consent or restrict the use of your personal information for whatever purpose at any time, without affecting the lawfulness of processing based on consent before its withdrawal. To opt out of any data processing and/ or marketing communications from Aspekt32 Ltd, please click the ‘unsubscribe’ link in the footer of the respective email or use the Preference Centre to update your settings.


5. How long will we store your data?

Your personal data will be stored in our systems as long as Aspekt32 Ltd is in touch with your organisation. If Aspekt32 Ltd enters into an agreement with your organisation it shall keep your data on file for the duration of the client relationship, and six years thereafter unless there is a direct statutory requirement (that comes into force) under which Aspekt32 Ltd is obliged to keep your data stored in our internal databases for a longer period of time, or Aspekt32 Ltd needs to hold your data on file for a longer period of time for the purposes of executing an agreement to which your organisation is a party, to comply with a legal obligation or to defend itself against a legal claim. If, however, we never signed a contract with your organisation we will remove your details from our database if we have not been in touch with you for a period of 6 years, or if it appears that you do not work for your organisation anymore.


6. What are your rights under GDPR

Under GDPR you are entitled to various rights:

• You can request correction of the personal information that we hold about you. This enables you to have any incomplete or inaccurate information we hold about you corrected. This means when working with our Recruitment consultants, make sure you notify us of any changes or update your information like email, phone number etc. when they change.

• You can request erasure of your personal information. This enables you to ask us to delete or remove personal information where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal information where you have exercised your right to object to processing (see below). This means should you wish to be removed from Aspekt32 Ltd’s database, please email info@aspekt32.com. We will review and process your request within 30 days.

• You can object to the processing of your personal information where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground. You also have the right to object where we are processing your personal information for direct marketing purposes. This means we will only send you marketing communication if you have opted in. You can opt out at any time by clicking the ‘unsubscribe’ link in the footer of the email in question and will be removed from the Aspekt32 Ltd marketing mailing list. You can also use the Aspekt32 Ltd Preference Centre to opt in and out of other communication from Aspekt32 Ltd.

• You can request the restriction of processing of your personal information. This enables you to ask us to suspend the processing of personal information about you, for example, if you want us to establish its accuracy or the reason for processing it.

• You can request the transfer of your personal information to another party in certain formats, if practicable.

All such requests need to be addressed to info@aspekt32.com.

The fact that you can lodge a request does not necessarily mean we will grant your request at all times, especially if Aspekt32 Ltd has legitimate interest that outweighs your interests as an individual.

Aspekt32 Ltd will, however, provide information without undue delay and in any event within one month (this can be extended to 2 months in exceptional circumstances) of the receipt of the request, however where requests are manifestly unfounded or excessive, in particular, because of its repetitive character, Aspekt32 Ltd may refuse to act upon your request. In that case, we will inform you within one month of the request of the possibility of lodging a complaint with a supervisory authority (ICO) or seeking a judicial remedy.


7. Automated decision-making, including profiling

Aspekt32 Ltd will not conduct any forms of automated processing of your personal data consisting of the use of personal data to evaluate certain personal aspects relating to you; in particular to analyse or predict aspects concerning your performance at work, economic situation, health, personal preferences, interests, reliability, behaviour, location or movements. We will not make decisions that are based solely on automated processing which produces legal effects or similarly significantly affects you as a data subject.

8. Lodging a complaint

If you feel that your rights as a data subject have been breached, you are entitled to lodge a complaint with the supervisory authority (in the UK this will be the Information Commissioner’s Office via https://ico.org.uk/concerns/) or seek a legal remedy. However, we strongly encourage you to contact us via info@aspekt32.com. We will then review your complaint at our earliest convenience.


9. Changes to this Data Processing Notice

Any changes we make to our Data Processing Notice in the future will be posted on this website and where appropriate, notified to you by email. Please check back frequently to see any updates or changes to this Data Processing Notice.


10. Contact details for GDPR and data queries

Questions, comments, and requests regarding this Data Processing Notice are welcome and should be addressed to:

Oliver Seidel

Data Protection Officer

16 Warner Street



Phone +49 (0) 69 348 770 940


Last updated on 22 May 2018