Thrive Partners – Privacy Policy
At Thrive Partners, we are committed to protecting your personal data and ensuring full transparency regarding how we handle it. This Privacy Policy explains what personal data we collect, how we use it, with whom we share it, and the rights you have as a data subject.
This Policy addresses the following key questions:
- Which personal data does Thrive Partners process, to whom does it relate and how is it collected?
- For what purposes and on what legal grounds does Thrive Partners process personal data?
- How long do we keep personal data?
- With whom does Thrive Partners share personal data?
- What rights do you have as a data subject?
- How can you exercise your rights?
- How can you contact us?
- How can you stay informed about updates to this Policy?
The personal data we process may relate to various categories of data subjects, including candidates, clients, client representatives, business partners and suppliers.
Data may be collected directly from you—for example, when you apply for a role, send us an email, fill out a form on our website, or when a client engages us to provide Executive Search or related services.
In some cases, Thrive Partners may collect personal data indirectly, through public sources such as LinkedIn. When this occurs, we will inform the respective data subjects at the earliest opportunity.
1. What data does Thrive Partners process, to whom does it relate, and how is it collected?
Personal data means any information relating to an identified or identifiable natural person. Thrive Partners may process the following categories of personal data: identification data; education and professional experience data; professional data; professional activity data; billing and expense-related data; and image/audio recordings.
Personal data means any information relating to an identified or identifiable natural person. A person is considered identifiable if they can be identified, directly or indirectly, for example by name, identification number, location data, online identifiers or factors specific to their physical, physiological, genetic, mental, economic, cultural or social identity. Thrive Partners may process the following categories of personal data:
- Identification data (e.g., name, date of birth, gender, address, contact details, ID card/passport details, taxpayer number, nationality);
- Education and professional experience data (e.g., education history, qualifications, certifications, language skills, CV, references);
- Professional data (e.g., job title, position, role description, employer, office address);
- Professional activity data (e.g., information related to business activities, projects or assignments);
- Billing and expense-related data (e.g., fees, travel expenses or other expenses incurred on behalf of the client);
- Image and audio recordings (e.g., photographs, video or audio recordings).
2. For what purposes and on what legal grounds does Thrive Partners process personal data?
Thrive Partners processes personal data for Executive Search services, recruitment of candidates, communications, event management, billing and accounting, debt recovery, and recruitment for internal roles. Legal grounds include performance of a contract, legitimate interest, consent, and legal obligations.
Thrive Partners may process personal data for the following purposes:
a) Executive Search and Talent Advisory Services
This may include:
- Creation of client records and project files;
- Registration of proposals;
- Communications with clients, candidates, public entities or relevant stakeholders;
- Digital and physical archiving of documentation.
Legal basis:
- Performance of a contract;
- Legitimate interest, namely:
- Thrive Partners’ interest in managing client information efficiently and securely;
- Clients’ interest in receiving high-quality Executive Search and Talent Advisory services.
b) Recruitment and selection of candidates
This includes collecting and assessing applications and CVs, as well as conducting assessments and interviews.
Legal basis:
- Consent of the data subject.
c) Communications and information sharing
This includes newsletters, updates on Executive Search processes, insights and similar communications.
Legal basis:
- Legitimate interest in responding to requests from website subscribers and ensuring appropriate communication.
d) Event management
This includes:
- Sending invitations and managing participant registrations;
- Internal and external promotion of events.
Legal basis:
- Legitimate interest;
- Consent (when required).
(Consent will be requested when events are recorded in audio or video, or when photographs are taken.)
e) Billing and accounting management
This includes:
- Expense, cost and reimbursement control;
- Billing and account management;
- Keeping accounting records.
Legal basis:
- Performance of a contract;
- Legitimate interest;
- Compliance with legal obligations.
f) Debt recovery and legal claims
This includes pursuing outstanding payments or defending Thrive Partners’ rights.
Legal basis:
- Legitimate interest.
g) Recruitment for internal positions at Thrive Partners
This includes collecting and analysing applications, conducting interviews and assessments.
Legal basis:
- Pre-contractual steps at the request of the data subject;
- Legitimate interest.
3. How long do we keep personal data?
Personal data is retained only for the period necessary for each purpose or as required by law. Retention periods vary between 2 and 20 years depending on purpose.
Thrive Partners retains personal data only for the period necessary for the purposes described in this Policy or for the period required by applicable law.
Purpose of processing | Retention period |
Executive Search and client services | Duration of the contractual relationship + 20 years |
Recruitment of external candidates | 3 years from receipt of the application/CV if the candidate is not selected |
Communications and information sharing | Until the data subject objects |
Event management | 2 years from last contact or participation |
Billing and accounting | 10 years |
Debt recovery and legal claims | Until the debt is settled or the dispute is resolved |
Recruitment for Thrive Partners roles | 3 years if the candidate is not selected, or as long as the contractual relationship lasts |
4. With whom does Thrive Partners share personal data?
We share data only when necessary, including with clients, service providers, regulatory authorities, and group companies. International transfers comply with EU adequacy decisions or appropriate safeguards.
Thrive Partners does not share personal data with third parties except when necessary to provide contracted services or to comply with legal obligations.
Personal data may be shared with:
- Clients using our Executive Search or Talent Advisory services;
- Entities relevant to the services provided (e.g., regulatory authorities, government bodies, legal advisors);
- Companies within the Thrive Partners alliance – Kestria;
- Service providers such as IT suppliers, communication providers, translation services and digital or physical archiving providers.
If data is transferred outside the European Economic Area, Thrive Partners will:
- Ensure that the country benefits from an EU adequacy decision; or
- Where no adequacy decision exists, implement appropriate safeguards as required by law.
5. What rights do you have as a data subject?
You have the following rights under applicable data protection law:
- 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
- Right not to be subject to automated decision-making
- (Thrive Partners does not use automated decision-making or profiling.)
- Right to withdraw consent
- If processing is based on consent, you may withdraw it at any time.
- Right to lodge a complaint
- You may file a complaint with the Portuguese Data Protection Authority (CNPD): www.cnpd.pt
Please note that some rights may be limited by legal obligations or the rights and freedoms of third parties.
6. How can you exercise your rights?
You may exercise your rights via email at info@thrivpartners.com or by postal mail to the company’s registered address.
7. How can you contact us?
For questions regarding your personal data or this Policy, contact p info@thrivpartners.com.
8. How can you stay informed about updates?
This Policy may be updated periodically. Please consult it regularly.
This policy also applies to candidates, clients, sources and referees involved in Executive Search processes or any other kind of Talent Advisory services.
We may collect information indirectly through research systems, online databases and public sources to identify suitable candidates.
Our website may use cookies, analytics tools and tracking pixels to understand usage patterns and improve services.
Thrive Partners – Cookies Policy
This Cookie Policy explains how Thrive Partners uses cookies and similar technologies on our website.
What Are Cookies?
Cookies are small text files stored on your device when you visit a website. They help the website recognise your device and improve your browsing experience.
Types of Cookies We Use:
- Essential cookies: Required for website functionality.
- Analytical cookies: Used to understand website performance and user behaviour, including third‑party tools such as Google Analytics and Hotjar.
- Preference cookies: Store user preferences such as language settings.
- Marketing cookies: Track user interactions to provide relevant content and communications.
Why We Use Cookies:
We use cookies to enhance website performance, personalise content, perform analytics, and ensure the website functions correctly.
Managing Cookies:
You may disable cookies via your browser settings. Please note that blocking some types of cookies may impact your experience on the website.
Third‑Party Tools:
Our website may use third‑party services that collect data through cookies or tracking pixels. These providers may include Google Analytics, Hotjar, and others. Their use of data is governed by their own privacy policies.
Updates to This Policy:
We may update this Cookie Policy from time to time. We recommend reviewing it regularly.
Contact Us:
If you have questions about our use of cookies, please contact us at info@thrivpartners.com.
