Privacy Policy

 

Effective date: March 26, 2026

Createria (“Createria,” “we,” “us,” or “our”) respects your privacy and is committed to protecting personal data in accordance with the General Data Protection Regulation (GDPR), the UK GDPR, and other applicable data protection laws.

This Privacy Policy explains how we collect, use, disclose, and otherwise process personal data when you use our website, interact with us, engage our services, or otherwise communicate with us.

1. Who we are

Createria is the controller of your personal data for the purposes described in this Privacy Policy.

Controller: Createria
Email: info@createria.agency
Phone: +351 914 343 267
Website: https://www.2pwc.com

For privacy-related questions or to exercise your rights, you may contact us at: info@createria.agency

2. Whose data we process

We may process personal data relating to:

• candidates and prospective candidates

• clients and prospective clients

• business partners and their representatives

• website visitors

• individuals who contact us directly

Our services are intended for business and professional audiences. They are not directed to children, and we do not knowingly collect personal data from children.

3. What personal data we collect

Candidate data

We may collect:

• name

• contact details, such as email address, phone number, and location

• CV, resume, employment history, education, qualifications, and skills

• professional interests and preferences

• compensation expectations and availability, where relevant

• interview notes, assessments, and feedback

• links to professional profiles, such as LinkedIn

• references and referral information, where relevant

• correspondence and communications with us

Client and partner data

We may collect:

• name

• business contact details

• company name

• job title or role

• information relating to hiring mandates, organisational needs, and project requirements

• correspondence and communications with us

Website usage data

When you use our website, we may collect:

• IP address

• browser type and version

• device information

• operating system

• pages viewed and navigation data

• date, time, and duration of visits

• form submissions and website interactions

Marketing and communication data

We may collect:

• your communication preferences

• records of marketing interactions

• information you provide when subscribing to updates or contacting us

4. How we collect personal data

We collect personal data:

• directly from you

• from our clients, where relevant to a hiring mandate

• from publicly available professional sources, such as LinkedIn or company websites

• from referrals and recommendations

• automatically through cookies and similar technologies on our website

Where we receive personal data from third parties, we process it in accordance with applicable law and this Privacy Policy.

5. Why we process personal data and our legal bases

Under GDPR and UK GDPR, we must have a lawful basis for processing personal data.

To provide executive search, recruitment, and advisory services

We process personal data to:

• assess suitability for roles or mandates

• identify, contact, and evaluate candidates

• support hiring decisions

• manage client engagements

• provide strategic HR and advisory services

Legal basis: legitimate interests, performance of a contract, and steps taken at your request before entering into a contract, where applicable.

To manage communications and business relationships

We process personal data to:

• respond to enquiries

• schedule meetings

• manage ongoing client, candidate, and partner communications

Legal basis: legitimate interests and performance of a contract.

To operate, secure, and improve our website and services

We process personal data to:

• administer our website

• analyse usage

• improve performance and user experience

• maintain security and prevent misuse

Legal basis: legitimate interests and, where required, consent for non-essential cookies or similar technologies.

To send marketing or business communications

Where permitted, we may send updates about our services, insights, or relevant business communications.

Legal basis: legitimate interests, where permitted by law, or consent where required.

You may opt out of marketing communications at any time.

To comply with legal and regulatory obligations

We may process personal data where necessary to:

• comply with legal obligations

• respond to lawful requests from authorities

• establish, exercise, or defend legal claims

Legal basis: compliance with a legal obligation and legitimate interests.

6. Our legitimate interests

Where we rely on legitimate interests, these may include:

• delivering and developing our executive search and advisory services

• managing professional relationships

• identifying suitable candidates for business-critical mandates

• maintaining records of business interactions

• improving our website and services

• ensuring information security

• protecting our business against fraud, misuse, or legal risk

Where required, we balance these interests against your rights and freedoms.

7. How we share personal data

We may share personal data with:

Clients

Where relevant to a search or advisory engagement, we may share candidate information with clients or prospective employers.

We do not share candidate profiles indiscriminately. Sharing is limited to what is relevant and appropriate in the context of a mandate.

Service providers and processors

We may share personal data with trusted third-party service providers, such as:

• cloud hosting providers

• email and communication platforms

• applicant tracking or CRM systems

• scheduling tools

• analytics providers

• legal, compliance, or IT support providers

These providers process personal data on our behalf under appropriate contractual protections.

Professional advisers and authorities

We may disclose personal data to:

• legal advisers

• auditors

• insurers

• regulators

• courts or public authorities

where required by law or where necessary to protect our rights or comply with legal obligations.

We do not sell personal data.

8. International data transfers

Because we work across jurisdictions and may use international service providers, personal data may be transferred outside the European Economic Area or the United Kingdom.

Where we transfer personal data internationally, we take appropriate safeguards, which may include:

• adequacy regulations or adequacy decisions

• Standard Contractual Clauses

• the UK International Data Transfer Agreement or UK Addendum, where applicable

• other lawful transfer mechanisms recognised under applicable law

You may contact us for further information about the safeguards we use for international transfers.

9. How long we keep personal data

We retain personal data only for as long as necessary for the purposes for which it was collected, including to satisfy legal, regulatory, contractual, and business requirements.

Typical retention periods include:

• candidate data: up to 24 months after last meaningful contact

• client and business contact data: for the duration of the business relationship and for a reasonable period afterwards

• website analytics data: up to 12 months

• marketing suppression records: as long as necessary to respect your opt-out preferences

• legal or compliance-related records: as required by applicable law or as necessary to establish, exercise, or defend legal claims

We may retain data for longer where necessary to comply with legal obligations or resolve disputes.

At the end of the relevant retention period, we delete or anonymise personal data where feasible.

10. Your rights

If GDPR or UK GDPR applies to you, you may have the following rights, subject to applicable limitations:

• the right to access your personal data

• the right to correct inaccurate or incomplete data

• the right to request erasure

• the right to restrict processing

• the right to object to processing

• the right to data portability

• the right to withdraw consent, where processing is based on consent

To exercise your rights, contact us at: info@createria.agency

You also have the right to lodge a complaint with the data protection authority in the country where you live, work, or where you believe an infringement has occurred.

11. Cookies and similar technologies

We use cookies and similar technologies to operate, secure, and improve our website, and to understand how visitors use it.

These technologies may include:

• essential cookies

• analytics cookies

• performance cookies

• functionality cookies

Where required by law, we will ask for your consent before placing non-essential cookies on your device.

You can manage cookies through your browser settings and, where available, through our cookie banner or preference centre.

12. Automated decision-making

We do not make decisions based solely on automated processing, including profiling, that produce legal effects or similarly significant effects on individuals.

13. Data security

We implement appropriate technical and organisational measures designed to protect personal data against unauthorised access, loss, misuse, alteration, or disclosure.

These measures may include:

• access controls

• secure systems and infrastructure

• role-based permissions

• contractual controls with service providers

• internal procedures for handling personal data

No method of transmission or storage is completely secure, but we take reasonable steps to protect the data we process.

14. If you do not provide personal data

Where personal data is necessary for us to consider you for a role, manage an engagement, or respond to a request, failure to provide that data may limit our ability to do so.

15. Third-party websites

Our website may contain links to third-party websites or services. We are not responsible for the privacy practices of those third parties. We encourage you to review their privacy notices.

16. Changes to this Privacy Policy

We may update this Privacy Policy from time to time to reflect changes in law, regulation, or our business practices.

The latest version will always be published on our website, together with its effective date.

17. Contact us

If you have questions about this Privacy Policy or about how we process personal data, please contact us:

Createria
Email: info@createria.agency
Phone: +351 914 343 267
Website: https://www.2pwc.com