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Privacy Policy

Talent Unlocked Ltd. Last updated: 7 July 2026.

Who we are

Talent Unlocked Ltd (“we”, “us”, “our”) operates TalentUnlocked, a recruitment marketplace that connects employers posting job vacancies with recruitment agencies bidding to fill them.

Our registered address is:

Talent Unlocked Ltd
The Beacon, Pilgrims Lane
Caterham, CR3 5BH

For all privacy-related queries, you can contact us at: simon.smith@talentunlocked.ai

What information we collect

When you register or enquire via our landing page, we collect the following personal data:

  • Full name
  • Email address
  • Company name and job title
  • Any other details you choose to provide in our form

We also collect usage data automatically (such as IP address, browser type, and pages visited) via cookies, subject to your consent.

Why we collect it (lawful basis)

We process your personal data on one or more of the following lawful bases under Article 6 UK GDPR:

  • Performance of a contract (Article 6(1)(b)): where processing is necessary to create and manage your account and to provide you with access to and use of the TalentUnlocked marketplace. This is our primary basis for processing the data you provide on registration and in connection with your use of the platform.
  • Legal obligation (Article 6(1)(c)): where processing is necessary for compliance with a legal obligation to which we are subject — for example, under tax, company law, anti-money laundering, or other applicable legislation.
  • Consent (Article 6(1)(a)): where you have freely given your clear and unambiguous agreement to us processing your personal data for a specific purpose, such as the sending of marketing or promotional communications or the use of non-essential analytics cookies. You may withdraw your consent at any time without affecting the lawfulness of processing carried out before withdrawal by contacting us at simon.smith@talentunlocked.ai or, in the case of cookies, by adjusting your cookie preferences via our website.
  • Legitimate interests (Article 6(1)(f)): where processing is necessary for our legitimate interests, or those of a third party, provided those interests are not overridden by your rights and freedoms. We rely on this basis for purposes including platform security, fraud detection and prevention, and improving the quality and functionality of TalentUnlocked.

How we use your data

We use the personal data we collect to:

  • Create and manage your account on TalentUnlocked
  • Communicate with you about your account, the platform, and relevant updates
  • Facilitate matches between employers and recruitment agencies on the marketplace
  • Analyse and improve our service (analytics cookies, with your consent only)
  • Comply with legal and regulatory obligations

Who we share your data with

We do not sell your personal data to third parties. We may share it with:

  • Vercel Inc. — application hosting and Vercel AI Gateway, which routes certain automated processing requests to upstream AI providers. Vercel is based in the United States; transfers are made under Vercel’s data processing agreement and appropriate UK GDPR transfer safeguards.
  • OpenAI — language-model inference used to extract structured fields from uploaded CV and job-specification text, reached via Vercel AI Gateway. OpenAI is based in the United States; we configure routing so prompts are not used to train models. Transfers are made under appropriate UK GDPR safeguards via our processor arrangements with Vercel.
  • HubSpot, Inc. — our CRM and marketing platform, used to manage contact records and communications. HubSpot is based in the United States; transfers of your personal data to HubSpot are made in reliance on the UK Extension to the EU-US Data Privacy Framework (also known as the UK-US Data Bridge), which has been recognised as providing an adequate level of protection under UK data protection law. HubSpot processes data on our behalf under a Data Processing Agreement that incorporates appropriate UK GDPR safeguards.
  • Hosting and infrastructure providers who support the operation of TalentUnlocked, all bound by data processing agreements.
  • Law enforcement, regulators, or courts where we are legally required to do so.

All third-party processors are contractually required to handle your data in accordance with UK GDPR.

Security of your data

We take appropriate technical and organisational measures to protect your personal data against accidental loss, destruction, alteration, unauthorised access, or disclosure, in accordance with our obligations under Article 32 UK GDPR. Such measures may include encryption of data in transit and at rest, access controls limiting who within our organisation can access your data, and periodic security reviews. Whilst we take the protection of your personal data seriously, please note that no transmission of data over the internet and no method of electronic storage is entirely secure, and we cannot guarantee absolute security.

Candidate and third-party personal data

The TalentUnlocked platform enables recruitment agencies to respond to employer vacancies. In doing so, agencies may upload or transmit personal data relating to third-party candidate job seekers via the platform. Where this occurs:

  • The recruitment agency is the data controller in respect of that candidate personal data and bears responsibility for: (i) having a lawful basis under UK GDPR for sharing the candidate’s data via the platform; and (ii) having provided the candidate with appropriate privacy information, including informing them that their personal data may be shared through TalentUnlocked.
  • Talent Unlocked Ltd acts as a data processor in respect of candidate personal data shared through the platform, processing it solely on the instructions of the relevant recruitment agency and not for our own purposes beyond facilitating the marketplace service.

If you are a candidate whose personal data has been shared through TalentUnlocked and you wish to exercise your data protection rights under UK GDPR, you should contact the recruitment agency that submitted your data in the first instance. You may also contact us at simon.smith@talentunlocked.ai and we will endeavour to assist or redirect your request as appropriate.

How long we keep your data

We retain your personal data for as long as your account remains active. Following account closure or withdrawal of consent, we retain data for a period of 2 years to meet our legal and business obligations, after which it is securely deleted or anonymised.

Your rights

Under UK GDPR, you have the following rights:

  • Right of access — to request a copy of the personal data we hold about you
  • Right to rectification — to request correction of inaccurate or incomplete data
  • Right to erasure — to request deletion of your data (“right to be forgotten”)
  • Right to withdraw consent — at any time, without affecting the lawfulness of prior processing
  • Right to object — to processing of your personal data based on legitimate interests, and an absolute right to object at any time to processing for direct marketing purposes (no balancing of interests is required in respect of a marketing objection)
  • Right to restriction — to limit how we process your data in certain circumstances
  • Right to data portability — to receive your personal data in a structured, commonly used, and machine-readable format, where processing is based on consent or a contract and is carried out by automated means
  • Right to lodge a complaint — with the Information Commissioner’s Office (ICO)

To exercise any of these rights, please email us at simon.smith@talentunlocked.ai. We will respond within one calendar month of receiving your request. In complex or high-volume cases, we may extend this period by a further two months, but we will inform you of any such extension within one calendar month of your request.

Cookies

We use essential cookies that are necessary for the site to function. With your consent, we also use analytics cookies to understand how visitors use TalentUnlocked and improve our service.

You can accept or reject non-essential cookies via the consent banner displayed on our site. You may change your preference at any time.

International data transfers

We do not routinely transfer your personal data outside the United Kingdom. Where any transfer does occur (for example, through third-party service providers with servers located overseas), we ensure that appropriate safeguards are in place in accordance with UK GDPR. Lawful transfer mechanisms we may rely on include: (i) an adequacy decision made by the UK Secretary of State under Article 45 UK GDPR, recognising that the destination country provides an adequate level of data protection; (ii) an International Data Transfer Agreement (IDTA) approved by the Information Commissioner, or an International Data Transfer Addendum to the EU Standard Contractual Clauses (UK Addendum); or (iii) another transfer mechanism permitted under Chapter V UK GDPR. Specific information about the transfer mechanism used in respect of any particular third-party processor is available on request.

Automated decision-making and profiling

We do not make decisions about you that produce legal or similarly significant effects based solely on automated processing (including profiling) within the meaning of Article 22 UK GDPR. While TalentUnlocked may use algorithms to suggest potential matches between employers and recruitment agencies on the platform, any such suggestions are intended to assist human decision-making and not to replace it. Final decisions regarding matches and engagements are made by the users of the platform themselves.

Changes to this policy

We may update this Privacy Policy from time to time to reflect changes in our practices or legal obligations. We will notify you of any material changes by email or via a prominent notice on our website. The date at the top of this document indicates when it was last revised.

Contact us

For any privacy queries, to exercise your rights, or to raise a concern, please contact:

Data Controller: Talent Unlocked Ltd
Email: simon.smith@talentunlocked.ai
Address: The Beacon, Pilgrims Lane, Caterham, CR3 5BH

You also have the right to lodge a complaint with the Information Commissioner’s Office (ICO):

Website: ico.org.uk
Telephone: 0303 123 1113