1.1 About. Talentin LTD ("we", "us", or "our") operates the business known as Talentin, which provides services, defined below, including through the website talentin.com ("Site").
1.2 Acceptance. Your use of this Site constitutes your acceptance of this Policy. If you do not agree with this Policy, you may not use our Site. This Policy may change from time to time, and the date of last update is indicated at the top of this page.
1.3 Changes. We reserve the right to make changes to this Policy at any given time. If you want to make sure that you are up to date with the latest changes, please be sure to check back periodically. Your continued use of this Site after we revise this Policy is deemed to be acceptance of the revisions, so please check this page from time to time for updates.
2.1 Data Controller. The Data Controller, in accordance with the General Data Protection Regulation (EU) 2016/679 (known as GDPR), is us, Talentin LTD, company number 206665749, registered at Sofia, 1463, Triaditsa district, 66 Vitosha Blvd., floor 4, Bulgaria.
2.2 About our Services. Our Site is a job aggregator, that means that we index job vacancies published online and allow you to search all of these different job postings easily within one place, our Site. It’s effectively like a search engine, for job vacancies. We don’t input into the hiring or selection processes, and are not a recruitment firm, we simply index available vacancies published by others and when you choose to apply for a vacancy you will be redirected to the original job post on the third party site or service directly or using our easy apply service. We also offer lots of tips and hints to job seekers, and have newsletters and other informative content. Some features of the Site include the ability for job seekers to upload a CV, create a CV, or simply get alerts about new posts in careers that are of interest to you. We also offer recruiters opportunities to broadcast their vacancies with us through collaboration. Collectively our activities, products and features on the Site and the Site itself, are referenced in this Policy as the "Services".
2.3 Commitment to privacy. We take a serious approach to safeguarding privacy rights and respecting them, and in particular we comply as a baseline across our business with the General Data Protection Regulation ((EU) 2016/679, known as GDPR) in recognition of the high standards of rights. Note however that depending on where you live you may not be protected by data privacy laws, or you may have different protection under law. Where we comply with other specific laws, we will state this within this Privacy Policy.
2.4 Protection of minors. We do not solicit or target persons under 18 years of age. We do not knowingly collect any information relating to children under the age of 18. If we discover that a child under 18 has provided us with personal information, or we have otherwise came into possession of personal information of a child, we will promptly delete such personal information from our systems.
3.1 This Policy (a) applies to any visitor to our Site, any individual who access the features of our Site, and to any professional recruiter or hirer using our Site, and (b) outlines how we collect, store, process and use personal data of such Jobseekers, Recruiters and Site Visitors.
'Jobseekers' means you, if you are an individual who is searching our Site for job vacancies, or have created an account with us for the purposes of learning about career development and job opportunities/applying for positions.
'Recruiter' means you, if you are a person acting in a business capacity who is using our Site or Services for the purposes of establishing a business relationship with us, or Jobseekers, including recruitment of Jobseekers. Whilst you may have your own privacy rights as an individual person, as a Recruiter you must also adhere to our privacy compliance requirements when you correspond with Job Seekers though our Services, as fully detailed in our Terms of Use.
'Site Visitor' means you, if you are not considered a Jobseeker or Recruiter, but are any other person who is accessing or otherwise making use of our Services, including this Site.
4.1 Understanding what laws apply to us. Our Services are targeted at users resident in the UK, thus we comply fully with the UK’s Data Protection Act 2018 (known as the UK’s Retained GDPR). However, we do apply a baseline of GDPR to our privacy practices in general and if you are a resident of the EU who is using this Site to obtain a job within the UK, for example, GDPR would apply to you. We collectively refer to these applicable laws in this Privacy Policy as "Data Laws" and any reference to ‘personal data’ within this Policy, has the meaning ascribed to it by the Data Laws.
4.2 Lawful basis for processing personal data.Under certain Data Laws that may apply to our processing of personal data belonging to you we require a lawful basis for processing that personal data.
Contract. In some cases, our lawful basis for processing your Personal Data is 'contract', meaning for the purposes of performing a contract to provide the Services to you, or for taking steps prior to entering into a contract such as for Site Visitors considering using our Services, or for Recruiters seeking to collaborate in business with us, or for Jobseekers to receive our career products and features.
Consent. In some cases, where contract is not the appropriate lawful basis, for example for marketing to you by email, we obtain the relevant consents from you (which you can manage and opt out of through your account settings with ease).
Legitimate interest. Where neither contract nor consent is appropriate, legitimate interest is the lawful basis.
Legal obligation. We may require to process your Personal Data to comply with a legal obligation as permitted by Data Laws, including retaining your Personal Data for set time periods in order to act in compliance with international laws and regulations that we are bound by as a business.
5.1 Generally. We may collect information directly from you, automatically through your use of our Services, or from third parties (if applicable). We may combine information collected from or about you from these various sources. The data we collect depends on the context of your interactions with us and our Services, the choices you make, including your privacy choices, and the products and features of our Services that you use or access.
5.2 When you provide it to us or use our Services. We collect information about you directly from you as you input the information to our Site when you use our Services, for example when Recruiters complete contact forms, or when Jobseekers upload CVs and/or create accounts to receive job alerts, or when you sign up to any mailing list and provide personal data such as email.
5.3 When you communicate with us and provide your data. If you contact us in any manner we will keep any information you provide to us including records of correspondence, and you should be aware that we monitor and may record telephone calls and written correspondence for training and security purposes. If you provide feedback or testimonials to us, or take part in any user survey, or participate in events, promotions, product, feature or service launches, or competitions, we will collect any information you provide voluntarily when doing so.
5.4 When you upload content to our Site. If you are uploading or creating a CV, or otherwise uploading any form of content to the Site, or your account with us, we will process that information in accordance with this Policy, (we call that content User Content), as well as other information, such as your name, may be available to us and potentially Recruiters if you choose this.
5.5 Information we collect automatically. If you are using the Services or a Site Visitor browsing the Site, we may automatically collect information about you through your use of our Services, and we explain those types of data below. We may combine information we collect automatically with information we collect directly from you or from other sources. Please see our Cookies section below for more information.
Please keep in mind that any third-party social networking platform controls the information it collects from you, how it is shared, and what permissions we are able to request. For information about how they may use and disclose your information, including any information you make public, please consult their respective privacy policies.
6.1 For all Site Visitors, Jobseekers and Recruiter. If you sign up to our mailing lists, or otherwise request to receive news or updates from us, we will collect information such as your email address. We will also collect data (automatically) about your activity on the Site such as access logs and click logs meaning (a) log information including your Internet protocol (IP) address, the type of browser you are using, information about the device you are using, domain name, the website that led you to our Services, the website to which you go after leaving our Services, your location, and the dates and times you access our Services, and (b) your interaction with the Site such as pages visited, content viewed and searched for, vacancies clicked and viewed. Please also read our Cookie section below for more details about our use of cookies.
6.2 Jobseekers. We may collect and process your personal details including but not limited to your email, name, telephone, location, and any other information you submit when you create an account or otherwise access our Services and opt to input data including data related to your CV such as education, work experience, skills, certifications, publications and similar information you choose to share with us. We may also collect information about your search history in terms of jobs you have searched for, vacancies you have clicked on, locations searched, and types of roles searched, in order to improve the jobs that are displayed. See section 7.7 Profiling for more information.
6.3 Recruiters. If you contact us to discuss commercial relationships with us, we may collect your name, email address, telephone number and company name, together with any other information you freely provide to us when corresponding.
We use the information we collect about you:
We use the information we collect about you:
We use the information we collect about you:
We use the information we collect about you:
We use the information we collect about you to comply with applicable legal or regulatory obligations, including as part of a judicial proceeding; to respond to a subpoena, warrant, court order, or other legal process; or as part of an investigation or request, whether formal or informal, from law enforcement or a governmental authority.
We use aggregate information about you, and non-personal information that we collect, to:
Profiling means that we may analyse your information and User Content in order to tailor the content that is displayed or broadcast to you whether on the Site or through our communications with you, for example, for Jobseekers this means that you will be shown vacancies that we believe may be most relevant to you after analysis of your CV, and Site activity such as past searches. Consent to profiling is given by you when accepting this Privacy Policy, although you may opt out at any time and revoke that consent by contacting us.
8.1 Disclosing Jobseekers’ information to Recruiters or third-party hirers. If any of our Services include features that allow you to share User Content with us, such as your CV or basic contact information, or other such personal data, we may share your User Content and information about you to that Recruiter, or advertiser of the job post to which you have applied.
8.2 Sharing with our affiliates. We may disclose your information to current or future affiliates or subsidiaries for research, marketing, and other purposes consistent with this Privacy Policy. Within our corporate group business, we may require to share your information to allow us to provide the Services to you, if our companies support us in the context of being service providers, which may include, data hosting, server maintenance, customer support, data analytics, marketing, legal and financial services, and safety and security services.
8.3 Sharing to third party service providers. We may disclose your information to our vendors, service providers, agents, or others who perform functions on our behalf and we take all steps to ensure that such providers are under contract to comply with applicable Data Laws.
We may disclose your information to another party in connection with, including during negotiations of, an acquisition or merger, sale or transfer of a business unit or assets, bankruptcy proceeding, or as part of any other similar business transfer to a buyer or prospective buyer of our business, our professional advisers, such as our lawyers or compliance advisors, or accountants, where it is necessary for them to advise and to any other persons if we are under a duty to disclose or share your information in order to comply with any legal obligation. In the event of our business being sold or otherwise acquired by another party your data may form part of the transferred business or assets and you understand that this may be the case, and further (in respect of UK and EU residents only) you understand and consent to the physical transfer of your data outside of the UK or EU if applicable, if that party is located outside of the UK or EU.
We may be required by law, through potential or actual litigation, court order, public or governmental authorities, or rules and regulations within or out with your country of residence to disclose all or part of your information to third parties. We may also deem it necessary to make such a disclosure in the event of an issue of national security, law enforcement or other such similar situations as we deem necessary including, for example, allegations of alleged infringement of copyright, trademarks or other third parties’ rights by users or any criminal activity, whether formal or informal, from law enforcement or a government official or regulatory body.
We may be required by law, through potential or actual litigation, court order, public or governmental authorities, or rules and regulations within or out with your country of residence to disclose all or part of your information to third parties. We may also deem it necessary to make such a disclosure in the event of an issue of national security, law enforcement or other such similar situations as we deem necessary including, for example, allegations of alleged infringement of copyright, trademarks or other third parties' rights by users or any criminal activity, whether formal or informal, from law enforcement or a government official or regulatory body.
We may disclose aggregate, anonymous, or de-identified information about you for marketing, advertising, research, compliance, or other purposes.
9.1 Marketing by us, to you. We may share your information with our affiliates or third parties to develop and deliver targeted advertising to you of our or third-party products and services, or to help us to prepare marketing reports. We may send you information about our or our affiliates’ products and services, news and offers, and selected third party products and services that we think may be of interest to you. We may do this by contacting you through your email address or mobile phone number that you have provided. Any communication received from us, as consented to by you, will clearly state that it is being sent by us. You have the option to opt-out of our marketing communications at any time (see below).
9.2 Third party marketing. If you have consented to receive marketing communications from third parties your data may be passed on to such third parties as we enter into data sharing agreements with, from time to time, for marketing and analytical reporting purposes. We cannot be held liable for the content of the third party’s communications or products/services they are promoting. If you have provided this consent, but change your mind, you can opt-out at any time (see below). Please be advised that you will also require to contact the individual third parties who have been marketing to you if you wish to stop receiving their communications directly. Such parties can include other career specialist services, what we call our Partners, who offer similar services to ourselves. Currently, our Partners and their associated privacy policies are:
9.3 Opting Opt from marketing and communications. If you are, a Jobseeker, or a person who has previously consented to receive marketing communications, and have changed your mind about the marketing consent you have granted to us, or you wish to update your choices about receiving tips and advice or such other communications (or the frequency of these), you can follow the opt out procedures contained in any marketing email, or you can adjust your communications preferences easily within your account to tailor the messages you’d like to keep receiving. Please be aware that it may take up to ten (10) business days for us to process opt-out requests.
9.4 Opt-out exceptions. If you are a Jobseeker and request to opt out of our marketing or communication emails, please be aware that opting out of marketing emails will not impact upon email communications you may continue to receive which are relevant to the administration of your account, or relative to any other Services you have requested to receive from us (unless those have been opted out of also or adjusted in your account settings), or which are required in order to communicate with you regarding any support, response, regulatory, legal or other permitted use as described in this Policy.
10.1 Storage locations and international transfers. If we are processing and storing your personal data as a Site Visitor, Jobseeker or Recruiter, then that data is stored on our servers in the Netherlands. If you are a resident of the European Economic Area ('EEA') please be informed that we may transfer your data outside of the EEA to other countries. By submitting your personal data to us as a resident of EEA, you agree to any such transfer, storing or processing. We will take all steps reasonably necessary to ensure that your data is treated securely and in accordance with this Privacy Policy and we enter into appropriate agreements with any third parties in compliance with Data Laws for such transfer purposes.
10.2 Retaining your personal data. We retain the data collected pursuant to this Privacy Policy for the period necessary to fulfil the purposes outlined in this Privacy Policy unless a longer retention period is required or permitted by law, including Data Laws. Thereafter if the collected data is no longer needed for purposes specified in this Privacy Policy, we delete all aforementioned data in our possession within a reasonable timeframe, ensuring we only retain the data we need (or parts of it, for example for legal purposes). Typically this may see us retain some elements of data for up to 3 years. Irrespective of the above, we may still retain some of the data to the extent such retention is necessary to enforce our terms or policies, and comply with technical and legal requirements and constraints related to the security, integrity and operation of Services and international law enforcement, regulatory requests, or matters of dispute. If your account is ever terminated by us, or you have been identified by us as a potential or otherwise threat to our business, our Services, our Site or our users, your email address will be retained on our internal blacklist for as long as we deem necessary to protect the business and its users.
11.1 Introduction. Data Laws give users a number of rights which you are free to exercise at any time regarding any personal data that you have provided to us and we generally apply the rights afforded by the GDPR to all users, even if they are not resident in Europe. We will respond to requests to access or delete your personal data promptly and in any case within any time limits set by applicable Data Laws (if applicable to us in your case). We have summarised the rights here and how you can exercise them to ensure that we are reasonably and fairly processing your personal information in line with your rights, however you should obtain your own legal advice if you wish to rely on any legislative rights not covered here which you believe in good faith we have a duty to respond to. Subject to our own legitimate interests and any regulatory requirements placed upon us we will endeavour to meet requests made in exercising your rights.
11.2 Verifying you when you make a request. We may require you to provide identification if you are exercising some of these rights, for cases where it is not immediately obvious that you are truly the person to whom the personal information relates, as we need to be certain before making any changes to someone’s personal information that it is your information (or you have that person’s authority to act for them). If identification documents are requested as part of the process; that document will only be collected, stored and processed by us for the sole purpose of confirming your identity in response to your request, and upon completing your request we will delete it.
11.3 Use of your email address. We may need to communicate with you in response to your request, and we may require to update you on progress/confirm outcomes. We do this by email. If you contact us by email, we have the fair expectation of a legitimate interest to provide a response to you following your instigating of the communication. Where any rights exercised by you result in you seeking to object to us processing your personal information or otherwise deleting your personal information, then in order to ensure we do not process any personal information of yours in future, we will retain your email address for the purpose of our opt out list only, and we will delete or anonymise all other information held.
11.4 Retaining other information. Sometimes we need to keep a record of some data for security purposes (for example to assist law enforcement agencies with any criminal investigations or other regulatory authorities or dispute matters) or for payment processing (to prove to banks that we were authorised to take payments from you if you pay to use the Services), even if you have requested removal of your data. Any such data retained will only be used for these limited purposes.
11.5 Important information about removal. We can only be responsible for removing any personal data or User Content that we hold on our servers, or hold otherwise within our control or possession.
13.1 About cookies. Cookies are small text files which a website may put on your computer or mobile device when you first visit a site or page. The cookie will help our Site, or another website, to recognize your device the next time you visit. For example, cookies can help us to remember your username and preferences, analyze how well our Site is performing, or even allow us to recommend content we believe will be most relevant to you. We don't store any personally identifiable information about you on any of our cookies.
13.3 What we use cookies for, specifically. We use cookies for: (i) identification of the logged in user, (ii) unique user IDs creation (to distinguish one non-logged in user from another), (iii) compiling a list of viewed search results (for statistics about what queries are viewed by users who came to a particular area of our Site), and (iv) csrf token, to prevent forgery attacks on our Site and Services.
13.5 Cookies on third party sites. If, as a Job Seeker, you apply for a job on our Site, sometimes you'll be redirected to an external site to complete your application. These external sites may use cookies, which will not be included in the lists above and you should familiarise yourself with that website’s privacy and cookie policies.
13.6 Managing your cookie choices. Most browsers allow you to turn off cookies. To do this, look at the "help" menu on your browser. Switching off cookies may restrict your use of the Site and/or delay or affect the way in which it operates including being unable to register for an account, sign in to an account, or apply for jobs (as a Jobseeker).
14.1 What we are doing. Although we will do our best to protect your personal data, we cannot guarantee the security of your data transmitted to the Site/Services and any transmission is at your own risk. We take reasonable administrative, physical, and electronic measures designed to safeguard and protect your information from unauthorized access or disclosure. This includes using secure software and storing your information in encrypted form behind a firewall designed to block access from outside our network. Although we use commercially reasonable efforts to safeguard the privacy of your information, transmissions on the Internet cannot be made absolutely secure. Where any information is required to be disclosed to third party service providers to ensure the provision of Services to you, all such third parties are subject to strict agreements to ensure the continued safeguarding of your data as much as possible. We assume no responsibility or liability for disclosure of any of your information due to errors in transmission, unauthorized third-party access, or other causes beyond our reasonable control.
14.2 What you should do to protect yourself. You should take steps to protect against unauthorized access to your device and your User account by, among other things, choosing a robust password that nobody else knows or can easily guess and keeping your log-in and password private. We are not responsible for any lost, stolen, or compromised passwords or for any activity on your account via unauthorized password activity.
14.3 Third party links. Our Services as an aggregator will contain links to third-party websites and applications. Any access to and use of such linked websites and applications is not governed by this Privacy Policy but instead is governed by the privacy policies of those third parties. We are not responsible for the information practices of such third-party websites or applications and you should use caution and closely review any privacy policies applicable to any third-party websites or applications that may be linked to through our Site or Services.
15.1 No targeting to minors. Our Site is not directed to children under the age of 18. We do not knowingly collect any personal information about children under the age of 18. If we obtain actual knowledge that we have collected personal information about a child under the age of 18, that information will be immediately deleted from our database.
15.2 Awareness of children’s data. If a parent/guardian believes that his or her child has submitted personal information to us, he or she can contact us via e-mail. We will promptly delete the information upon learning that it relates to a child under the age of 18. Please note that it is possible some of this information may remain archived in web logs and back-up archives after we delete the information from our active database.
16.1 Limitation of liability. SOME JURISDICTIONS DO NOT ALLOW THE EXCLUSION OR LIMITATION OF CERTAIN DAMAGES, SO THE FOLLOWING LIMITATION AND EXCLUSIONS MAY NOT APPLY TO YOU AS A PERSON, A SITE VISITOR, A JOBSEEKER, A RECRUITER OR ANY OTHER FORM OF USER OF OUR SERVICES WHICH INCLUDES THE SITE. TO THE FULLEST EXTENT ALLOWED BY APPLICABLE LAW, UNDER NO CIRCUMSTANCES AND UNDER NO LEGAL THEORY (INCLUDING, WITHOUT LIMITATION, TORT, CONTRACT, STRICT LIABILITY, OR OTHERWISE) SHALL WE (OR OUR LICENSOR(S) OR SUPPLIER(S)) BE LIABLE TO YOU OR TO ANY OTHER PERSON FOR (A) ANY INDIRECT, SPECIAL, INCIDENTAL, OR CONSEQUENTIAL DAMAGES OF ANY KIND, INCLUDING DAMAGES FOR LOST PROFITS, LOSS OF GOODWILL, WORK STOPPAGE, ACCURACY OF RESULTS, OR COMPUTER FAILURE OR MALFUNCTION, OR (B) ANY AMOUNT, IN THE AGGREGATE, IN EXCESS OF THE GREATER OF (I) £100 OR (II) THE AMOUNTS PAID BY YOU TO US IN CONNECTION WITH THE SERVICES IN THE THREE (3) MONTH PERIOD PRECEDING THIS APPLICABLE CLAIM, OR (C) ANY MATTER BEYOND OUR REASONABLE CONTROL.
16.2 Governing law and jurisdiction. This Privacy Policy will be governed by the laws of England and Wales (unless any Data Laws take precedence). Any disputes relating to this Privacy Policy, or the Services to which they relate, will be heard exclusively in the courts located in England, UK.
16.3 Language. This Privacy Policy is written in the English language and any proceedings relating to these documents and any related dispute shall be conducted in English. If we make these documents available in any other language, the Policy in the English language version shall prevail.
18.1 Should you have any reason to contact our Data Protection & Information Officer, they can be contacted by writing to the above address, marked for their attention, or by emailing [email protected]
18.2 Any communications to the DPIO which do not relate to data protection and privacy matters will not be responded to.
18.3 In accordance with GDPR, as we are established in Europe, we are not required to designate an EU Representative and all enquiries may be made to the Data Protection & Information Officer. However, in compliance with the UK Data Protection Act 2018, we are required to designate a UK Representative and we use a third party representative for this service which is Elpha Fox Privacy, 7 Bell Yard, London, WC2A 2JR
We hope that we will be able to directly resolve any complaint that you may have, however, if you are not happy with how we handle any complaint, depending on your place of residence, you may be able to raise a complaint at any time to your country’s national data protection authority in accordance with Data Laws applicable to your country of residence.