Privacy Policy

Last updated: 2025

1. Introduction

This Privacy Policy explains how New Horizon Recruitment Europe B.V. (“NHRE”, “we”, “our”, or “us”) collects, uses, stores, and protects personal data in connection with our recruitment, RPO, business development, and related services. We are committed to ensuring that your personal data is handled in accordance with the General Data Protection Regulation (GDPR) and applicable Dutch and EU data protection laws.

By using our website or submitting your personal data to us, you acknowledge that you have read and understood this Privacy Policy.

2. Data Controller

The data controller responsible for processing your personal data is:

New Horizon Recruitment Europe B.V.
Registered in the Netherlands with its official seat in Amsterdam.
KvK: 98324217
VAT: NL868446749B01
Email: contact@newhorizon-recruitment.eu

We do not appoint a Data Protection Officer (DPO), but privacy-related matters are handled internally.

3. What Personal Data We Collect

We may collect and process the following categories of personal data, depending on how you interact with us:

A. Candidate Data

Full name
Contact details (email, phone number, address)
CV/resume and employment history
Education and qualifications
Skills, language proficiency, certifications
LinkedIn or other professional profiles
Visa/work permit status
Interview notes and assessment results
Salary expectations, career preferences
Any additional information you choose to provide

B. Client / Corporate Contact Data

Name, job title, department
Business contact details
Communications and meeting records
Contract-related information

C. Website and Technical Data

IP address
Browser type and device information
Website usage data
Cookies and tracking technologies (see Cookie Policy)

D. Business Development / M&A-Related Data

Publicly available corporate profiles
Contact details of decision-makers
Information voluntarily provided during discussions

Sensitive Data

We do not intentionally collect special categories of personal data (e.g., health, religion, political views, criminal records). If such data is provided voluntarily, we will delete it unless processing is legally justified.

4. How We Collect Personal Data

We may collect personal data through:

Direct submission via email or contact forms
CVs and documents you send to us
Interviews and online meetings
Business cards and professional networking
Public platforms (e.g., LinkedIn, company websites)
Referrals
Analytics tools (e.g., GA4, LinkedIn Insight Tag)

We do not scrape personal data from third-party databases without a lawful basis.

5. Legal Basis for Processing

We process personal data on one or more of the following legal bases under GDPR:

(a) Performance of a Contract (Art. 6(1)(b))
For recruitment activities, candidate representation, and client contract execution.
(b) Legitimate Interests (Art. 6(1)(f))
To operate a recruitment business, perform RPO services, conduct business development, manage relationships, and provide service updates. Our legitimate interests never outweigh your fundamental rights.
(c) Consent (Art. 6(1)(a))
For candidate registration, marketing communications, and storing CVs beyond the retention period.
(d) Compliance with Legal Obligations (Art. 6(1)(c))
Such as tax, anti-fraud, or regulatory requirements.

6. How We Use Personal Data

For Candidates

Evaluating suitability for job opportunities
Presenting candidate profiles to clients
Contacting you regarding roles, interviews, or processes
Providing career-related information or advice
Maintaining ongoing relationships and future opportunities

For Clients / Business Contacts

Communicating about vacancies, candidates, and services
Contract management and service delivery
Business development and account management
Sending proposals or commercial information

For Website Users

Improving website usability
Security and fraud prevention
Analytics and performance monitoring

For Internal Operations

Compliance and audit
System security and maintenance
Service improvement

We do not sell personal data under any circumstances.

7. Sharing Personal Data

We may share personal data with:

A. Recruitment Clients

Only with candidate consent, and only the necessary information for assessing suitability.

B. Service Providers (Processors)

Such as:

Cloud hosting (EU servers)
Email platforms
Google Workspace
Analytics tools
ATS/CRM services (e.g., Notion, Make, Zapier)

All processors operate under GDPR-compliant agreements.

C. Legal and Regulatory Authorities

If required by law, regulation, or court order.

D. Business Partners

For collaboration on recruitment or business development projects (always with consent where required).

We do not transfer data outside the EEA unless adequate safeguards are in place (e.g., EU SCCs).

8. Data Retention

We retain personal data only as long as necessary for its purposes:

Candidates

We retain candidate data only for as long as necessary for recruitment-related purposes and ongoing relationship management.
We may retain data for longer if you provide consent or if required for legitimate business or legal purposes.
You may request deletion of your personal data at any time.

Clients / Business Contacts

We retain client and business contact data only for as long as necessary for relationship management, service delivery, and compliance with applicable legal obligations.

Website & Technical Data

As defined in our Cookie Policy (typically 12–26 months).

9. Your Rights Under GDPR

You have the following rights:

Access your personal data
Rectify inaccurate information
Erase data (“right to be forgotten”)
Restrict processing
Object to processing based on legitimate interests
Data portability
Withdraw consent at any time
Lodge a complaint with the Dutch Data Protection Authority (Autoriteit Persoonsgegevens)

Requests can be made by emailing:
contact@newhorizon-recruitment.eu

10. Data Security

We implement appropriate technical and organisational measures, including:

Secure cloud storage
Access controls and permissions
Encryption where appropriate
Regular system monitoring
Staff confidentiality obligations
Secure deletion protocols

However, no system can be guaranteed fully secure; you submit data at your own risk.

11. International Data Transfers

If we transfer personal data outside the EEA, we will ensure one of the following:

Adequacy decision by the European Commission
Standard Contractual Clauses (SCCs)
Appropriate safeguards or explicit consent

We do not knowingly transfer data to jurisdictions without adequate protection.

12. Automated Decision-Making

NHRE does not use automated decision-making or profiling that produces legal or significant effects on individuals.

13. Updates to This Policy

We may update this Privacy Policy from time to time without prior notice. The latest version will always be published on this website.

14. Contact Information

For privacy-related inquiries or requests under GDPR:

New Horizon Recruitment Europe B.V.
Email: contact@newhorizon-recruitment.eu
Amsterdam, the Netherlands