Privacy Policy

At Cabo Norte, we take your privacy seriously. This Privacy Policy explains what personal data we collect, why we collect it, how we use it, and what rights you have. We aim to keep this information clear, transparent, and easy to understand.

1. Who We Are (Data Controller)

Navigant BV, operating under the commercial name Cabo Norte, is responsible for processing your personal data in accordance with the General Data Protection Regulation (GDPR) and acts as the Data Controller.

2. When and Why We Collect Your Personal Data

We may collect your personal data when:

• You apply for a role with us or through us
• You leave your details on our website, at an event, or via digital tools
• We obtain your details from publicly available sources (such as LinkedIn) and believe you may be interested in leadership or growth-related opportunities
• You work with us as a candidate, client, advisor, freelancer, or partner

We use your personal data for the following purposes:

• Executive search, leadership recruitment, and talent advisory services
• Matching your profile with current or future opportunities
• Communicating with you about roles, services, insights, or events
• Improving our services through quality control, coaching, and internal training
• Complying with legal and regulatory obligations (including tax, labor, and anti-fraud requirements)

3. Personal Data We Collect

Depending on your relationship with Cabo Norte, we may process the following categories of personal data:

• Contact details (name, address, phone number, email)
• Personal details (date of birth, nationality, gender, marital status)
• Professional information (CV, education, diplomas, work experience, references)
• Identification documents (passport, work permit, residence permit, where legally required)
• Assessment data (leadership assessments, personality or technical evaluations)
• Publicly available information (for example LinkedIn profiles)
• Availability, role preferences, and career interests
• Photos, video introductions, or other information you voluntarily provide

4. Special Categories of Personal Data

Cabo Norte does not actively collect sensitive personal data such as health data, political opinions, religious beliefs, trade union membership, or criminal records.

Where required for a specific role, we may request proof of legal compliance (such as a certificate of good conduct). Such documents are provided directly by you and are not further processed unless legally required.

Sensitive data is only processed with your explicit consent or where required by law.

5. Legal Grounds for Processing

We process your personal data based on the following legal grounds:

• Contractual necessity: To provide recruitment, search, or advisory services
• Consent: Given when you submit data voluntarily, agree to marketing communications, or allow reference checks. You may withdraw consent at any time
• Legitimate interest: To operate our business responsibly, prevent fraud, and ensure service continuity
• Legal obligation: To comply with applicable labor, tax, or social security laws

6. Data Retention

We do not retain data longer than necessary.

• Active candidate or contact files: Retained while we are in active contact
• Inactive files: After 12 months of no contact, we will ask if you wish to remain in our database
  • If you decline, your data will be retained passively for up to 4 years (statutory limitation period)
  • If no response is received, a reminder will be sent after another 12 months
  • Without confirmation, data will be archived for a further 3 years and then deleted
• Legal and administrative data: Retained as required by Belgian law (typically 7–10 years)
• Marketing data: Retained until you unsubscribe or withdraw consent

7. Data Sharing

We only share personal data when necessary and appropriate, including with:

• Clients – for evaluating profiles or engaging leadership talent
• Service providers – such as IT platforms, cloud services, assessment providers, or payroll partners, all bound by Data Processing Agreements (DPAs)
• Auditors or certification bodies – when required for compliance
• Public authorities – when legally required

8. International Data Transfers

Where personal data is transferred outside the European Union, Cabo Norte ensures appropriate safeguards, including:

• European Commission adequacy decisions
• Standard Contractual Clauses (SCCs)
• Additional security measures such as encryption and restricted access

9. Automated Processing and Profiling

We may use digital tools to support candidate-role matching and leadership profiling.

• These tools do not make final decisions
• All outcomes are reviewed by a human consultant
• You have the right to request information about profiling logic and to request human review

10. Cookies and Online Tracking

The Cabo Norte website uses cookies and similar technologies to support website functionality. Depending on the services enabled, preference, analytics and marketing cookies may also be used. Non-essential cookies require your consent before they are placed.

You can manage or withdraw consent through the website’s cookie settings. You can also manage or delete cookies through your browser settings. For more information about cookie categories, purposes and consent, see our Cookie Policy.

11. Data Security

We implement appropriate technical and organizational measures to protect personal data, including:

• Access control limited to authorized Cabo Norte personnel
• Secure authentication and encrypted systems where applicable
• GDPR-compliant contracts with service providers

12. Your Rights Under GDPR

You have the right to:

• Access and obtain a copy of your personal data
• Rectify inaccurate or incomplete data
• Request deletion of your data (“right to be forgotten”)
• Restrict processing in specific circumstances
• Object to processing based on legitimate interest or direct marketing
• Data portability
• Withdraw consent at any time

Requests can be sent to privacy@cabonorte.eu. Identity verification may be required.

13. Children’s Data

Cabo Norte does not knowingly process personal data of individuals under the age of 18. If such data is identified, it will be deleted immediately.

14. Questions or Complaints

For questions or concerns, contact:

You also have the right to lodge a complaint with the Belgian Data Protection Authority (Gegevensbeschermingsautoriteit – GBA):

If you suspect a data breach, please contact privacy@cabonorte.eu immediately.

15. Changes to This Privacy Policy

Cabo Norte may update this Privacy Policy from time to time. The most recent version will always be available on our website.