Privacy Policy

Last Updated: February 2026

1. Introduction

CLM Consulting (Entreprise Individuelle – Camila Lanzillo Moreira), registered in Luxembourg with RCS A46703, is committed to protecting the privacy of our candidates, clients, and website users. This policy outlines how we collect, use, and safeguard your personal data in accordance with the General Data Protection Regulation (GDPR) and the Luxembourgish Law of 14 August 2000 on electronic commerce.

2. Information We Collect

To provide specialized recruitment services in STEM and FinTech, we collect the following categories of data:

  • Candidates: Name, contact details, CVs, employment history, educational qualifications (e.g., BSc, Certifications), salary expectations, and right-to-work status.
  • Clients: Business contact information, job specifications, and organizational structure data for workforce planning.
  • Website Users: IP addresses, browser types, and interaction data via cookies to improve our platform's performance.

3. How We Collect Data

We collect data directly from you when you:

  • Submit your CV through our website or portal.
  • Register for a consultation via our booking system.
  • Engage with us via LinkedIn or other professional networks.
  • Apply for a specific role.

4. Purpose of Processing

We process your data for the following "human-first" recruitment purposes:

  • Assessing your suitability for permanent, contract, or executive roles.
  • Providing Market Intelligence and Talent Mapping to help businesses scale.
  • Expert-Led Technical Vetting: Validating technical skills against real-world market demands using our industry-leading advisory network.
  • Fulfilling our legal obligations as a registered Luxembourgish entity.

5. Legal Basis for Processing

We rely on the following legal grounds:

  • Consent: When you explicitly submit your profile for a specific opportunity.
  • Contractual Necessity: To take steps to enter into an employment or service contract.
  • Legitimate Interest: To connect top-tier talent with high-growth companies in high-demand technical markets.
  • Legal Obligation: To comply with regulatory requirements, such as AML (Anti-Money Laundering) checks in FinTech.

6. Data Sharing and Transfers

In line with our "No CV Spamming" policy, your data is shared only with your explicit consent.

  • Tailored Searches: We only present your profile to clients after a dedicated match is identified.
  • Technical Partners: We may use specialized third-party tools (e.g., Manatal ATS) to store and process data securely.
  • International Transfers: If we share data with clients in Ireland or other non-Luxembourgish jurisdictions, we ensure appropriate safeguards (such as Standard Contractual Clauses) are in place.

7. Data Security and Retention

We implement industry-standard security measures to protect your information.

  • 48-Hour Ownership Verification: We verify candidate ownership of profiles to ensure data accuracy.
  • Retention: We only keep your data as long as necessary for the recruitment process or as required by Luxembourgish law.

8. Your Rights

Under the GDPR, you have the right to:

  • Access and receive a copy of your data.
  • Rectify any inaccurate or incomplete information.
  • Erase your data ("Right to be Forgotten").
  • Withdraw Consent at any time.

9. Contact Information

To exercise your rights or for any privacy-related inquiries, please contact:

Camila Lanzillo Moreira
CLM Consulting
Contern, Luxembourg

Email: camila@clm-hrconsulting.com

Phone: +352 691 227-994