Privacy Policy

This Privacy Policy sets out how Talentyana collects and handles personal data through Talentyana itself, its subsidiaries, affiliates, and the associated offices listed here (each acting as "Data Controller," as applicable). Any personal information gathered by the Data Controller is managed and processed in line with the terms of this Privacy Notice.

This Privacy Notice applies to: visitors to our websites and applications listed here; representatives of our business partners, clients, and vendors; job candidates; recipients of our career services; and associates — individuals to whom we provide placement or career transition services, including those on assignment with one of our clients. It does not apply to our directly employed, country-based staff who work for Talentyana rather than for our clients.

This policy sets out the types of personal data we collect, how we use, process, and safeguard it, how long we retain it, who it is shared with, how it is transferred internationally, and the rights individuals hold over our use of their personal data.

We also explain how to reach us to discuss our privacy practices or exercise your rights. Our policies are designed to meet applicable local laws and regulations, including, where relevant, the EU's General Data Protection Regulation (GDPR), and may therefore vary by country depending on local legal requirements and practice. Specific local terms applicable to you are available on our website.

Information We Collect

We collect personal information through a range of channels — our websites and social media accounts, events, phone, fax, job applications, in-person recruitment, and our dealings with clients and vendors. Where permitted under local law, this may include:

• Contact details (name, postal address, email address, telephone number);
• Username and password when you register on our Sites;
• Details of friends or other individuals you'd like us to contact (the Data Controller assumes the other person has already given authorization for such contact); and

• Any other information you choose to provide, such as through surveys or our "Contact Us" feature.

If you are an associate or job candidate applying for a role or creating an account to apply, we may also collect, as permitted under local law:

• Employment and education history;
• Language proficiencies and other work-related skills;
• Social Security number, national identifier, or other government-issued ID number;
• Date of birth;
• Gender;
• Bank account details;
• Citizenship and work authorization status;
• Benefits information;
• Tax-related information;
• Reference-provided information; and
• Details in your resume/CV, your career interests, and other employment qualifications.

With your explicit consent, where required by law, we may also collect:

• Disability and health-related information; and
• Results of drug tests, criminal background checks, and similar screenings.

We may also collect information you provide about other individuals, such as emergency contact details.

How We Use the Information We Collect

Where permitted under local law, the Data Controller collects and uses this data to:

1. Provide workforce solutions and connect people with work;
2. Create and manage online accounts;
3. Process payments;
4. Manage relationships with business partners, clients, and vendors;
5. Send promotional materials, job notifications, and other permitted communications in line with this Notice;
6. Where permitted, administer participation in events, promotions, programs, offers, surveys, contests, and market research;
7. Respond to inquiries and claims;
8. Manage communications, conduct data analytics, and operate, assess, and improve our business — including service enhancement, accounting, auditing, and other internal functions;
9. Detect, prevent, and protect against fraud and other unlawful activity, claims, or liabilities; and
10. Comply with and enforce applicable laws, industry standards, contractual obligations, and internal policy.

All processing relies on a valid legal basis, which may include:

• Consent or explicit consent from the data subject, where legally required;
• Compliance with a statutory or contractual obligation, or a step necessary to enter into a contract (e.g., processing data to ensure correct payment of wages and taxes); or
• The Data Controller's legitimate interests, as detailed further below (e.g., enabling website access to deliver the services offered).

If you are an associate or job candidate applying for, or creating an account to apply for, a position, we also use your information, as permitted under local law, to:

• Offer job opportunities and work assignments;
• Provide HR services, including benefits administration, payroll, performance management, and disciplinary matters;
• Provide additional services such as training, career counseling, and career transition support;
• Assess your suitability and qualifications for roles; and
• Carry out data analytics — including (i) analyzing our candidate and associate base, (ii) assessing performance and work-related skills, (iii) identifying skill shortages, (iv) matching individuals to opportunities, and (v) analyzing hiring trends across our pipeline.

We may use information in other ways for which specific notice is given at or before collection.

Use of Automated Data Collection Methods

When you visit our Sites, we may automatically collect data using tools such as cookies, web beacons, and server logs — including IP address, device identifiers, browser and device attributes, operating system, preferred language, referring URLs, on-site actions, visit times, and other usage statistics.

A "cookie" is a file a website sends to your device to identify your browser or store information and preferences.

A "web beacon" — also called an internet tag, pixel tag, or clear GIF — links web pages to servers and relays cookie-derived information back to the server. These methods may generate "clickstream data," a record of the links and content a visitor clicks while browsing.

Our Sites use the following cookie types:

a) Technical Cookies
Used solely to enable communication over electronic networks, or to deliver an information-society service specifically requested by the user.

b) Profiling Cookies
Used to build user profiles and serve advertising aligned with browsing preferences. Given their more intrusive nature, both local and EU law require clear user notice and informed consent before use.

How We Collect Information by Automated Means
We may log your clicks as you navigate our Sites. To assess, for example, whether you opened an email from us, we may combine automatically collected data — such as browser information — with other data we hold about you. Your browser lets you disable, restrict, or receive alerts for certain cookies; note that disabling cookies may affect some site functionality.

Third-party providers of tools, widgets, and plug-ins on our site — such as social sharing features — may use their own automated methods to collect usage data. These providers are directly responsible for their data practices, and their own privacy terms apply. To the extent permitted by law, Talentyana disclaims liability for these third parties' information practices.

We will obtain your consent before collecting information via cookies or other automated methods, as required by applicable law.

How We Use Information Collected through Automated Means

We use data collected via cookies, web beacons, pixels, server logs, and similar tools to:

1. Customize the user experience on our Sites;
2. Deliver content aligned with user interests and browsing patterns; and
3. Manage our Sites and other business operations.

Third-Party Cookies

We use third-party analytics platforms, such as Adobe Omniture and Google Analytics, which apply cookies, server logs, and web beacons to help us understand site usage. Data collected this way — including IP addresses — may be accessible to these providers and other relevant third parties for evaluating user activity.

Profiling and Interest-Based Advertising

We may collect data on your online activity to serve advertising tailored to your interests, including data obtained from third-party sites where our ads appear.

Through partnerships with third-party ad networks, you may see Talentyana ads on other sites. These networks let us target audiences using demographic, interest-based, behavioral, and contextual signals, gathered over time via web beacons, pixels, third-party cookies, and server logs, in order to serve ads customized to your preferences and past activity.

Our ad networks may track your visits to sites showing Talentyana ads, including pages viewed and actions taken, whether on our own or partner sites, helping us measure marketing effectiveness.

Legitimate Interest

The Data Controller may process personal data for legitimate business purposes, including:

• Improving and personalizing our services and communications for clients, candidates, and associates;
• Detecting and preventing fraud;
• Strengthening network and information security;
• Understanding how visitors interact with our websites;
• Direct marketing; and
• Measuring the effectiveness of promotions and advertising.

We carefully weigh your rights whenever data is processed for these purposes. You may object by contacting us using the details below, though this may limit our ability to provide services that serve your interests.

How We Process and Protect Personal Information

To avoid retaining data longer than necessary, we process what we collect — including via automated means — only for the purposes above, for periods set by our internal retention policy.

We maintain administrative, technical, and physical safeguards against accidental, unlawful, or unauthorized loss, alteration, access, disclosure, or misuse of your data, which may include:

• Encryption of data in transit;
• Strong authentication controls;
• Hardened network infrastructure; and
• Network monitoring.

Information We Share

We do not share your personal data with outside parties except as set out in this Notice or in notices tied to specific activities. Vendors performing services on our behalf may be given access to personal data, but only to the extent needed to perform those services or meet legal obligations — they may not use or disclose it otherwise.

We may also share your data:

• With our subsidiaries and affiliates;
• If you are a job candidate, with clients who have relevant openings or interest in our candidates; and
• With partners such as job placement consultants and subcontractors who help find you work.

We may also disclose your data:

• Where required by law or legal process;
• To law enforcement or government authorities pursuant to a lawful request; and
• Where we believe disclosure is necessary to prevent physical harm or financial loss, or to investigate suspected or actual fraud or illegal activity.

We also reserve the right to transfer your data as part of a sale or transfer of all or part of our business or assets, including in a reorganization, dissolution, or liquidation.

Your Rights as a Data Subject

Where permitted by applicable law, you may exercise the following rights:

1. Right of access: to confirm your data is processed lawfully and to access it.
2. Right to rectification: to request correction of incomplete or inaccurate data.
3. Right to erasure: to request that we stop processing and delete your data.
4. Right to restriction of processing: to request that we limit how your data is processed.
5. Right to data portability: to receive your data in a structured, commonly used format, or have it transferred to another controller where feasible.
6. Right to object: to object at any time, on grounds relating to your situation, to processing of your data, without needing to give a reason.
7. Right not to be subject to automated decision-making: including profiling, where a decision produces legal or similarly significant effects on you.
8. Right to lodge a complaint: with a supervisory authority, if you believe processing of your data breaches the GDPR — ideally in the EU member state where you live, work, or where the alleged breach occurred.
9. Right to withdraw consent: at any time, where processing is based on consent under GDPR Article 7.

Updates to Our Privacy Notice

We may update this Privacy Notice periodically to reflect changes in our practices or legal requirements. Material changes will be flagged via a prominent notice on our Sites, with the latest update date shown at the top.

How to Contact Us

For questions or comments about this Privacy Notice, or to exercise your rights, please write to: info@talentyana.com