Privacy Policy

Last Date of Revision : March 2026

1. Introduction

Phoenix Executive (“we”, “us”, “our”) is committed to protecting your personal data and handling it responsibly, transparently, and in accordance with applicable data protection laws, including the General Data Protection Regulation (GDPR).

This Privacy Policy explains how we collect, use, process, and protect personal data when you:

  • Visit our website
  • Contact us
  • Interact with us in a professional context
  • Register as a candidate

 

2. Data Controller

Phoenix Executive is the data controller responsible for the processing of personal data described in this Privacy Policy.

Controller details:
[Full Legal Name]
[Registered Address]
info@phoenixexecutive.com

 

3. Categories of Personal Data

We may process the following categories of personal data:

a) Website Visitors

  • Name and contact details provided via contact forms
  • Information voluntarily submitted in communications

b) Clients and Business Contacts

  • Name, role, organisation
  • Professional contact details
  • Correspondence and meeting information

c) Candidates

  • Name and contact details
  • Curriculum vitae and professional background
  • Career history and qualifications
  • Interview notes and assessment information
  • Other information voluntarily provided during the recruitment process

We collect personal data directly from you, through professional interactions, or from publicly available professional sources.

 

4. Purposes of Processing

We process personal data for the following purposes:

  • Responding to inquiries and maintaining communication
  • Managing client and business relationships
  • Conducting executive search and recruitment assignments
  • Assessing candidate suitability for roles
  • Complying with legal and regulatory obligations

We do not use personal data for unrelated purposes.

 

5. Legal Basis for Processing

Processing may be based on one or more of the following legal grounds:

  • Performance of a contract or pre-contractual measures
  • Compliance with legal obligations
  • Legitimate interests in conducting and developing our executive search activities
  • Consent, where required

Where processing is based on legitimate interests, we ensure that our interests are balanced against your rights and freedoms.

 

6. Use of External Candidate Portal (Cluen / Encore)

For the management of candidate data, Phoenix Executive uses a specialised executive search platform provided by Cluen Corporation (Encore Search / SearchBriefing Portal).

Through this platform, candidates may register and submit personal data, including:

  • Contact details
  • CV and professional history
  • Qualifications and career-related information
  • Additional application-related data

Purpose

The platform is used to:

  • Manage and maintain candidate profiles
  • Assess suitability for executive search assignments
  • Conduct recruitment and pre-contractual activities

Role of Cluen

Cluen acts as a data processor within the meaning of Article 28 GDPR and processes personal data on behalf of Phoenix Executive.

Phoenix Executive remains responsible for ensuring lawful processing. Appropriate contractual agreements are in place to ensure that personal data is processed only in accordance with our instructions and subject to appropriate technical and organisational safeguards.

International Processing

Where personal data is processed outside the European Economic Area (EEA), appropriate safeguards are implemented in accordance with applicable data protection laws.

All data subject rights described in this Privacy Policy apply equally to data processed through the Cluen / Encore system.

 

7. Data Sharing

Personal data may be shared with:

  • IT and hosting providers
  • The Cluen / Encore candidate management platform
  • Professional advisers where necessary
  • Service providers supporting our business operations

All such providers are contractually bound to protect personal data and may process it only in accordance with our instructions.

We do not sell personal data.

 

8. Cookies and Tracking

This website does not use cookies for tracking, analytics, marketing, or profiling purposes.
We do not deploy analytics tools, advertising technologies, or tracking scripts.
If this changes in the future, this Privacy Policy will be updated accordingly and, where required, appropriate consent mechanisms will be implemented.

 

9. International Transfers

If personal data is transferred outside the EEA, appropriate legal safeguards are applied to ensure an adequate level of protection.

 

10. Data Retention

We retain personal data only for as long as necessary to fulfil the purposes described in this Privacy Policy or to comply with legal obligations.
Candidate data may be retained for future executive search opportunities unless deletion is requested or retention is no longer justified.

 

11. Your Rights

Under applicable data protection law, you have the right to:

  • Access your personal data
  • Request correction of inaccurate data
  • Request deletion of your data
  • Restrict or object to processing
  • Request data portability
  • Withdraw consent at any time where processing is based on consent

Requests can be directed to the contact details provided above.

 

12. Updates to this Policy

We may update this Privacy Policy from time to time. The current version will always be available on our website.