Privacy Policy

Status: September 25, 2025

We are very pleased about your interest in Ayensa Investments Holding SL and our services. Protecting your privacy is of great importance to us. This Privacy Policy explains how we process your personal data when you use our website https://ayensagroup.com, when you contact us, and when you engage with our recruitment and coordination services.

1. Controller (Art. 4(7) GDPR)

Ayensa Investments Holding SL

Finca Ses Dornades, Poligono 8, Parcela 237

07669 Calonge, Illes Balears, Spain

E-mail: joel@ayensagroup.com

We are the controller within the meaning of the EU General Data Protection Regulation (GDPR).

2. Categories of Data and Purposes of Processing

(a) Website Visits

  • Data processed: IP address, date and time of access, pages viewed, browser type, operating system, referrer URL.

  • Purpose: Ensuring website functionality, IT security, statistical analysis.

  • Legal basis: Art. 6(1)(f) GDPR (legitimate interests).

(b) Contact via E-Mail or Form

  • Data processed: Name, e-mail address, content of inquiry, attachments.

  • Purpose: Responding to your inquiry.

  • Legal basis: Art. 6(1)(b) GDPR (contract/pre-contractual measures) or Art. 6(1)(f) GDPR (legitimate interests).

(c) Recruitment Services (Candidates)

  • Data processed: Contact details, CV/resumé, qualifications, references, work samples, salary expectations, availability, other data voluntarily provided.

  • Purpose: Assessing suitability, contacting you, forwarding data to clients for recruitment projects (with your consent).

  • Legal basis:

    • Art. 6(1)(b) GDPR (pre-contractual measures at your request),

    • Art. 6(1)(a) GDPR (consent for forwarding data to clients or inclusion in our talent pool),

    • Art. 6(1)(f) GDPR (legitimate interest in presenting suitable candidates).

(d) Recruitment Services (Clients)

  • Data processed: Company details, contact person details, communication content, billing data.

  • Purpose: Contract management, project coordination, invoicing.

  • Legal basis: Art. 6(1)(b) GDPR (contract performance).

(e) Marketing & Newsletter (if offered)

  • Data processed: E-mail address, name, marketing preferences.

  • Purpose: Sending newsletters and marketing content.

  • Legal basis: Art. 6(1)(a) GDPR (consent).

  • We use a double opt-in procedure. You may withdraw your consent at any time.

3. Cookies and Similar Technologies

We use cookies and similar technologies on our website:

  • Essential cookies: Necessary for site operation.

  • Analytics/marketing cookies: Only with your prior consent (Art. 6(1)(a) GDPR).

You can manage or withdraw your consent at any time via the cookie banner or your browser settings.

4. Data Recipients

  • Service providers (processors): IT hosting, CRM, communication, and analytics providers under Art. 28 GDPR.

  • Clients / potential employers: Candidate data is disclosed only with prior consent.

  • Legal obligations: Disclosure may occur if required by law (Art. 6(1)(c) GDPR).

5. International Data Transfers

Some of our clients and service providers are located outside the European Economic Area (EEA), including the United States.

  • Transfers are made only if adequate safeguards exist (Art. 44 ff. GDPR), e.g. EU Standard Contractual Clauses (SCCs).

  • A copy of these safeguards can be requested via joel@ayensagroup.com.

6. Storage Periods

  • Candidate data: Deleted 6 months after completion of the application process unless you consent to talent pool storage.

  • Talent pool data: Until you withdraw consent, max. 2 years.

  • Contract & billing data: Retained for up to 10 years (tax/commercial law).

  • General correspondence: Deleted after 3 years (standard limitation period).

7. Data Security

We use appropriate technical and organizational measures, including encryption (HTTPS), role-based access control, backups, and up-to-date firewall/antivirus systems.

8. Your Rights (Art. 15–22 GDPR)

  • Right of access

  • Right to rectification

  • Right to erasure (“right to be forgotten”)

  • Right to restriction of processing

  • Right to data portability

  • Right to object (including objection to processing based on legitimate interests or to marketing)

  • Right to withdraw consent (Art. 7(3) GDPR)

You also have the right to lodge a complaint with a supervisory authority (Art. 77 GDPR).

9. Additional Rights under Spanish Law (LSSI/CE)

In accordance with Ley 34/2002 (LSSI), commercial e-mails will only be sent with your prior consent, and always include an opt-out option.

10. California Residents (CCPA)

If you are a California resident, you have the right to:

  • Request disclosure of categories of personal data processed.

  • Request deletion of personal data.

  • Opt-out of the “sale” of personal data (note: we do not sell personal data).

Requests can be submitted to joel@ayensagroup.com.

11. Clarification of Role

Ayensa Investments Holding SL acts solely as a coordination and contracting partner between clients and independent professionals. We are not an official employment agency (“intermediación laboral”) under Spanish law.

12. Changes to this Privacy Policy

We may update this Privacy Policy from time to time to reflect changes in our services or legal requirements. The current version is always available on our website.