Privacy Policy Effective Date: May 25, 2026
This Privacy Policy explains how VANTAEL collects, uses, stores, and protects your personal data when you visit this website or engage with our advisory services. It is written to be read — not buried.
WHO WE ARE
VANTAEL is a Talent Sourcing Advisory firm registered in Quezon City, Metro Manila, Republic of the Philippines. We provide talent market intelligence, candidate pipeline research, and sourcing strategy advisory to client organizations. We are not a licensed Private Employment Agency (PEA) as defined under DOLE regulations and we do not place, recruit, refer, or deploy labor.
In processing personal data through this website and our advisory operations, VANTAEL acts as a Personal Information Controller (PIC) as defined under Republic Act No. 10173 (Data Privacy Act of 2012) and is registered with the National Privacy Commission (NPC).
Data Privacy Contact:
| Data Protection Officer | Ed Angelo Bulatao |
| data-privacy@vantaelsearch.com | |
| Mailing Address | 66 Anakbayan, Paltok, Quezon City, Metro Manila 1105, Philippines |
| Response Time | Within 15 business days of receipt of a complete and valid data subject request |
SCOPE OF THIS POLICY
This Privacy Policy governs all personal data collected by VANTAEL through:
- This website (vantaelsearch.com) and all sub-pages, including /candidates, /candidates/mandates, /clients, and /clients/start
- Candidate intake forms and mandate registration forms embedded on this website
- Client inquiry forms submitted through this website
- Email correspondence and career consultation calls initiated through or facilitated by this website
This Policy does not govern personal data collected under separate Talent Sourcing Advisory Agreements (TSAAs) or Candidate Profile Consent Forms, which are governed by those specific documents in conjunction with VANTAEL’s Data Retention Policy.
WHAT PERSONAL DATA WE COLLECT AND WHY
VANTAEL collects personal data from two categories of website visitors: Candidates and Client Representatives.
Candidate Data
When you register your interest via the Active Advisory Mandates page or the Candidate Profile Form, we collect:
| Data Element | Purpose | Legal Basis (RA 10173) |
|---|---|---|
| Full name | Identification and profile creation | Consent — Sec. 12(a) |
| Email address | Communication and consent delivery | Consent — Sec. 12(a) |
| Phone number (optional) | Career consultation scheduling | Consent — Sec. 12(a) |
| Current job title | Mandate relevance assessment | Consent — Sec. 12(a) |
| Current employer | Market mapping and org research context | Consent — Sec. 12(a) |
| LinkedIn profile URL | Profile verification and research | Consent — Sec. 12(a) |
| Skills and years of experience | Mandate fit assessment | Consent — Sec. 12(a) |
| Compensation expectations | Benchmark compilation (anonymized in reports) | Consent — Sec. 12(a) |
| Availability status | Outreach prioritization | Consent — Sec. 12(a) |
| Career consultation call notes | Advisory assessment | Consent — Sec. 12(a) |
| Data retention preference | RA 10173 compliance — Talent Database opt-in | Consent — Sec. 12(a) |
We do not collect sensitive personal information as defined under RA 10173 Section 3(l) — including race, ethnicity, health data, sexual orientation, government-issued identification numbers, or financial account numbers — at any stage of the candidate intake process.
Client Representative Data
When a client representative submits an inquiry or books a discovery call, we collect:
| Data Element | Purpose | Legal Basis (RA 10173) |
|---|---|---|
| Full name | CRM record and communication | Contractual necessity — Sec. 12(b) |
| Business email address | Mandate correspondence | Contractual necessity — Sec. 12(b) |
| Company name and HQ country | Client CRM and market segmentation | Contractual necessity — Sec. 12(b) |
| Industry and role type | Mandate scoping | Contractual necessity — Sec. 12(b) |
| Compensation budget range | Internal pricing and mandate feasibility | Contractual necessity — Sec. 12(b) |
| Discovery call notes | Mandate qualification and TSAA preparation | Contractual necessity — Sec. 12(b) |
Automatically Collected Technical Data
When you visit the VANTAEL website, the following technical data is collected automatically by Google Analytics 4 (GA4) and our hosting platform (Hostinger):
- IP address (anonymized in GA4)
- Browser type and version
- Operating system
- Pages visited and time spent on page
- Referring and exit URLs
- Device type (desktop, mobile, tablet)
This data is used solely for website performance analysis and does not identify individual visitors. Cookie consent is obtained via the Complianz cookie banner before any tracking is activated.
HOW WE USE YOUR PERSONAL DATA
VANTAEL uses collected personal data strictly for the following purposes. We do not use personal data for automated decision-making, profiling for non-advisory purposes, or any purpose not listed below.
For Candidates:
- Assessing your professional background for relevance to active advisory mandates
- Conducting career consultation calls to evaluate mandate fit
- Preparing your profile for inclusion in a Talent Intelligence Report, subject to your separate written consent via the Candidate Profile Consent Form
- Retaining your profile in the VANTAEL Talent Database for future advisory engagements, subject to your explicit opt-in and the two-year retention limit
- Communicating the outcome of your mandate assessment, including non-selection notifications
- Responding to RA 10173 data subject rights requests
For Client Representatives:
- Responding to mandate inquiries and conducting discovery calls
- Preparing and executing Talent Sourcing Advisory Agreements (TSAAs)
- Managing active advisory engagements and delivering Talent Intelligence Reports
- Issuing invoices and tracking payment status
- Post-engagement relationship management
LEGAL BASIS FOR PROCESSING
| Legal Basis | When Applied |
|---|---|
| Consent — Sec. 12(a) | All candidate data collected through website intake forms and the Candidate Profile Consent Form. Consent is freely given, specific, informed, and unambiguous. Withdrawal is possible at any time. |
| Contractual Necessity — Sec. 12(b) | Client representative data processed for the purpose of negotiating, executing, and delivering services under a TSAA. |
| Legal Obligation — Sec. 12(c) | Data retained or processed to meet NPC registration requirements, respond to regulatory inquiries, or comply with tax and business registration obligations. |
| Legitimate Interests — Sec. 12(f) | Technical analytics data processed to maintain website security and performance. These interests are proportionate and do not override data subject rights. |
WHO WE SHARE YOUR DATA WITH
VANTAEL does not sell, rent, or trade personal data.
Candidate data is shared only with the specific client for whose mandate you have provided explicit written consent — and only at the point of Talent Intelligence Report delivery. It is not circulated to other clients, posted on any platform, sold or transferred to any third party, or shared with your current or former employers.
Client representative data is not shared outside VANTAEL’s internal operations, except as required by law or to fulfill contractual obligations under a signed TSAA.
Sub-processors who handle personal data on VANTAEL’s behalf under data processing terms:
| Sub-Processor | Purpose | Data Handled |
|---|---|---|
| Google LLC (Workspace, Sheets, Drive) | Operations Hub, CRM, document storage | Candidate and client data |
| Tally.so | Intake form submission | Candidate and client intake data |
| Dropbox Sign | E-signature for TSAAs and consent forms | Name and email of signing parties |
| Wave Financial | Invoicing and accounting | Client billing contact and payment data |
| Complianz | Cookie consent management | Cookie preference records only |
| Google LLC (Analytics 4) | Website analytics | Anonymized technical data |
| Hostinger | Website hosting | Technical/server-level data |
VANTAEL will notify affected data subjects where disclosure of personal data is required by law or regulatory authority, where legally permitted to do so.
DATA RETENTION
Personal data is retained for the minimum period necessary for the stated purpose. Retention periods are as follows:
| Data Category | Retention Period | Basis for Deletion |
|---|---|---|
| Candidate profiles (Talent Database) | 2 years from date of consent or last engagement | RA 10173 proportionality; D-06 Data Retention Policy |
| Candidate Profile Consent Forms | 2-year retention period + 1 year for compliance record | NPC audit trail requirements |
| Client representative data (CRM) | Duration of engagement + 3 years | TSAA Clause 7 confidentiality period |
| TSAA and legal documents | 7 years from engagement close date | Philippine Civil Code prescription periods |
| Invoice and financial records | 10 years | BIR record-keeping requirement |
| Website analytics data (GA4) | 14 months (anonymized) | Legitimate interest proportionality |
| Discovery call inquiry forms | 90 days if no TSAA executed; ongoing if TSAA executed | Operational necessity |
Upon expiry of the applicable retention period, personal data is permanently deleted from the VANTAEL Operations Hub, Google Drive, and all third-party sub-processors where it was stored. Deletion is logged.
Candidates who have opted into the Talent Database will receive a re-consent request before the two-year retention period expires. VANTAEL conducts a database review every six months.
YOUR RIGHTS AS A DATA SUBJECT
Under Chapter III of RA 10173, all data subjects — candidates and client representatives — have the following rights. VANTAEL will respond to all valid requests within 15 business days.
| Right | What It Means | How to Exercise It |
|---|---|---|
| Right to Be Informed — Sec. 16(a) | Know what personal data VANTAEL holds about you, how it is used, and how long it is retained | Review this Privacy Policy or email data-privacy@vantaelsearch.com |
| Right to Access — Sec. 16(b) | Request a copy of the personal data VANTAEL holds about you, including its source, purpose, and recipients | Email data-privacy@vantaelsearch.com with proof of identity |
| Right to Correction — Sec. 16(c) | Request correction of inaccurate, incomplete, or outdated personal data | Email data-privacy@vantaelsearch.com |
| Right to Erasure or Blocking — Sec. 16(d) | Request deletion of your personal data where it is no longer necessary, or where consent is withdrawn. Note: deletion of candidate data removes your profile from all active and future mandates | Email data-privacy@vantaelsearch.com |
| Right to Data Portability — Sec. 18 | Request your personal data in a structured, commonly used, machine-readable format (e.g. CSV or PDF) | Email data-privacy@vantaelsearch.com |
| Right to Object — Sec. 17 | Object to processing of your personal data for purposes other than those you originally consented to | Email data-privacy@vantaelsearch.com in writing |
| Right to Withdraw Consent — Sec. 16 | Withdraw consent to data processing at any time. Withdrawal does not affect the lawfulness of prior processing. Takes effect within 5 business days. | Email data-privacy@vantaelsearch.com |
| Right to Lodge a Complaint | If you believe your data privacy rights have been violated, file a complaint with the NPC | File via privacy.gov.ph or by written complaint to: NPC, 3/F Core G, GSIS Building, Financial Center, Pasay City 1308, Philippines |
Note: withdrawing consent after a Talent Intelligence Report has been delivered to a client does not retroactively remove your profile from that specific report. However, VANTAEL will remove your data from its Talent Database immediately upon receipt of a valid deletion request.
DATA SECURITY
VANTAEL implements the following technical and organizational measures to protect personal data against unauthorized access, loss, or disclosure.
Technical Measures:
- All candidate and client data is stored in a Google Sheets Operations Hub protected by two-factor authentication (2FA) on the VANTAEL Google Workspace account
- Google Drive document access is set to Restricted — no link-sharing; access limited to authorized personnel only
- This website uses HTTPS/SSL encryption for all data in transit
- Website security is maintained via Wordfence firewall and malware scanning
- E-signatures for TSAAs and consent forms are processed via Dropbox Sign, which uses encryption-at-rest
- Financial data is stored in Wave’s SOC 2-compliant cloud infrastructure
Organizational Measures:
- Personal data access is restricted to the Data Protection Officer and authorized personnel only
- No candidate profile is shared in any form without a signed Candidate Profile Consent Form on file
- All personnel with access to personal data are required to sign confidentiality agreements
- A Data Breach Incident Response Plan (D-07) is maintained and will be activated within 2 hours of a confirmed breach. NPC notification will follow within 72 hours as required under RA 10173 Section 20(f) and NPC Circular 16-03
VANTAEL is not liable for unauthorized access resulting from the data subject’s own actions, including sharing login credentials or using unsecured networks. If you suspect unauthorized access to your data, contact data-privacy@vantaelsearch.com immediately.
CROSS-BORDER DATA TRANSFERS
VANTAEL serves clients headquartered primarily in the United States, Australia, Singapore, and the United Kingdom. In delivering Talent Intelligence Reports, candidate profile data — with individual explicit consent — is disclosed to client organizations in these jurisdictions.
All cross-border transfers are governed by the following safeguards:
- Transfer occurs only upon delivery of a Talent Intelligence Report under a signed TSAA, which includes mandatory data confidentiality obligations on the client under TSAA Clause 7
- Each candidate has provided explicit, informed consent through the Candidate Profile Consent Form, which discloses that their profile may be shared with a specific international client
- Client organizations are contractually prohibited from sharing candidate profiles with third parties without VANTAEL’s written consent
For international website visitors, cookie consent is managed via Complianz to meet GDPR Article 6 requirements for EU and UK visitors. VANTAEL does not transfer technical analytics data across borders in personally identifiable form.
VANTAEL will apply GDPR-equivalent standards to the processing of data from EU and UK data subjects where those standards exceed the requirements of RA 10173.
COOKIES AND TRACKING TECHNOLOGIES
| Cookie Type | Purpose | Can Be Refused? |
|---|---|---|
| Strictly Necessary | Website security, session management, cookie consent record storage | No — required for basic website function |
| Analytics (Google Analytics 4) | Aggregate traffic analysis; anonymized IP; no personal identification | Yes — via cookie banner opt-out |
| Functionality | Remembering visitor preferences | Yes — via cookie banner |
| Marketing / Targeting | Not used by VANTAEL. No advertising cookies are deployed on this website. | N/A — not deployed |
You may withdraw cookie consent at any time by clearing your browser cookies and revisiting the site, or by using the Manage Cookies link in the website footer. Withdrawal does not affect data already collected with your prior consent.
CHILDREN’S DATA
This website and VANTAEL’s advisory services are directed exclusively at working professionals and business representatives. We do not knowingly collect personal data from individuals under the age of 18. If you believe a minor has submitted personal data through this website, contact data-privacy@vantaelsearch.com immediately. VANTAEL will delete the data within 5 business days of confirmed notification.
AUTOMATED DECISION-MAKING
VANTAEL does not make decisions about candidates or client representatives solely on the basis of automated processing — including profiling — that produces legal effects or similarly significant effects. All advisory assessments and mandate fit determinations involve human review.
CHANGES TO THIS POLICY
VANTAEL reserves the right to update this Privacy Policy at any time to reflect changes in data processing activities, applicable law, or regulatory guidance from the National Privacy Commission.
Material changes will be communicated via:
- A prominent notice on the VANTAEL website homepage for a minimum of 30 days before the updated Policy takes effect
- Direct email notification to candidates and client representatives whose data we hold, where the change materially affects their rights or our obligations
The Effective Date at the top of this page reflects the date of the most recent substantive revision. Continued use of the VANTAEL website after the effective date of a revised Policy constitutes acceptance of the revised terms, to the extent permitted by applicable law.
GOVERNING LAW AND JURISDICTION
This Privacy Policy is governed by the laws of the Republic of the Philippines, including Republic Act No. 10173 (Data Privacy Act of 2012) and its Implementing Rules and Regulations, as amended.
Any dispute arising from this Privacy Policy shall be subject to the jurisdiction of the appropriate courts of Quezon City, Metro Manila, Philippines, or resolved through mediation as provided under RA 9285 (Alternative Dispute Resolution Act of 2004).
Data Privacy Contact
| Data Protection Officer | data-privacy@vantaelsearch.com |
| NPC Complaint Portal | privacy.gov.ph |
| Mailing Address | 66 Anakbayan, Paltok, Quezon City, Metro Manila 1100, Philippines |
VANTAEL Search is a Talent Sourcing Advisory registered in Quezon City, Philippines. VANTAEL is not a licensed recruitment or placement agency.
© 2026 VANTAEL. All rights reserved.