Privacy Policy

This Privacy Policy explains how Talentro ("Talentro," "we," "us," or "our") collects, uses, discloses, and retains personal information.

It applies to:

• Visitors to our website (the "Site");
• Representatives of accounting firms and other organisations that engage or consider engaging our recruitment services ("Clients");
• Individuals we consider, contact, or represent for employment opportunities ("Candidates"), including individuals whose information we obtain from sources other than the individual themselves.

If you are a Candidate and you are reading this because we contacted you, Section 3 explains where we obtained your information and Section 8 explains how to have it corrected or deleted.

1. Information we collect

1.1 Information you give us directly

1.2 Information collected automatically

When you visit the Site, our hosting provider and embedded third-party services may automatically receive limited technical information, including IP address, browser type, device type, referring page, and pages viewed. Our scheduling tool (Cal.com) is embedded on the Site and sets its own cookies when you interact with it; its use of that information is governed by Cal.com's own privacy policy.

We do not operate advertising trackers on the Site and we do not use the Site to build advertising profiles.

1.3 Information we obtain from other sources

This section is most relevant to Candidates. In the ordinary course of recruitment we obtain professional information about individuals from sources including:

• Publicly available professional networking platforms and public profiles;
• Publicly available professional directories, firm websites, licensing registries, and industry publications;
• Business contact data and data enrichment providers;
• Referrals from mutual professional contacts;
• Clients, in relation to roles they ask us to fill.

The information we obtain in this way is limited to professional information — name, employer, job title, professional history, professional qualifications, and business contact details. We do not seek out or knowingly collect information about your private life from these sources.

1.4 Information we do not collect

We do not request or knowingly collect Social Security numbers, government identification numbers, financial account details, precise geolocation, biometric data, health information, or information about race, ethnicity, religion, sexual orientation, or political affiliation. Please do not send us this information. If you send it to us unsolicited, we will delete it.

2. How we use personal information

We use personal information to:

• Identify and evaluate individuals who may be suitable for roles we are engaged to fill;
• Contact Candidates about potential opportunities and discuss their career objectives;
• Present Candidates to Clients, with the Candidate's knowledge;
• Provide recruitment services to Clients, including intake, search, shortlisting, and offer support;
• Schedule, hold, and follow up on calls and meetings;
• Maintain our records of Client and Candidate relationships;
• Respond to enquiries received through the Site;
• Operate, secure, and improve the Site;
• Comply with legal obligations and enforce our agreements.

We do not use personal information for automated decision-making that produces legal or similarly significant effects without human involvement. A person reviews every Candidate we put forward.

3. How we disclose personal information

We disclose personal information only as follows:

To Clients

We share Candidate information with the Client for a specific role. We seek the Candidate's agreement before submitting their details for a specific opportunity. We do not circulate Candidate profiles speculatively to firms that have not asked for them.

To service providers

We use vendors who process personal information on our behalf and under contract, in the following categories: data enrichment and sourcing platforms, email and messaging platforms, customer and applicant tracking systems, calendar and scheduling tools, cloud storage and document tools, workflow automation tools, and website hosting. These providers are permitted to use personal information only to provide services to us.

For legal reasons

We may disclose personal information where required by law, subpoena, or other legal process, or where we believe disclosure is necessary to protect our rights, your safety, or the safety of others, or to investigate fraud.

In a business transaction

If we are involved in a merger, acquisition, financing, or sale of assets, personal information may be transferred as part of that transaction, subject to this Policy.

We do not sell personal information, and we do not share personal information for cross-context behavioural advertising, as those terms are defined under the California Consumer Privacy Act as amended by the California Privacy Rights Act. We have not done so in the preceding twelve months.

4. Retention

We retain Candidate information for as long as it remains professionally relevant, and in any event for no longer than 36 months following our last substantive contact with the Candidate, unless a longer period is required by law or the Candidate asks us to keep their details on file.

We retain Client information for the duration of the engagement and for 7 years thereafter for tax, accounting, and contractual limitation purposes.

We delete or de-identify information that is no longer needed for these purposes.

5. Security

We maintain administrative and technical safeguards designed to protect personal information, including access controls, encrypted transmission, and vendor due diligence. No method of transmission or storage is completely secure, and we cannot guarantee absolute security.

6. Children

The Site and our services are directed to working professionals. We do not knowingly collect personal information from anyone under 18. If you believe a minor has provided us with personal information, contact us and we will delete it.

7. Your California privacy rights

If you are a California resident, the California Consumer Privacy Act, as amended, gives you the following rights.

• Right to know. You may request the categories and specific pieces of personal information we have collected about you, the categories of sources, our purposes for collecting it, and the categories of third parties to whom we disclose it.
• Right to delete. You may request that we delete personal information we collected from you, subject to statutory exceptions.
• Right to correct. You may request that we correct inaccurate personal information about you.
• Right to opt out of sale or sharing. We do not sell or share personal information as those terms are defined by the CCPA, so there is nothing to opt out of. If this changes, we will update this Policy and provide the required mechanism.
• Right to limit use of sensitive personal information. We do not collect sensitive personal information as defined by the CCPA.
• Right to non-discrimination. We will not deny you services, charge you a different price, or provide a different level of service because you exercised any of these rights.

Notice at collection. The categories of personal information we collect, the purposes for which we use them, and our retention periods are described in Sections 1, 2, and 4 above. We collect this information for the recruitment purposes described in Section 2 and for no other purpose.

Global Privacy Control. Where your browser transmits a Global Privacy Control signal, we treat it as a valid request to opt out of sale and sharing for that browser.

8. Rights of residents of other US states

If you are a resident of a state with a comprehensive consumer privacy law — including Virginia, Colorado, Connecticut, Utah, Texas, Oregon, Montana, Delaware, Iowa, Nebraska, New Hampshire, New Jersey, Minnesota, Maryland, Tennessee, Indiana, Kentucky, or Rhode Island — you may have rights to access, correct, delete, and obtain a portable copy of your personal information, and to opt out of targeted advertising, sale, and certain profiling.

Right to appeal. If we decline your request, you may appeal that decision by replying to our response or contacting us at the address in Section 10. We will respond to your appeal within the period required by your state's law, and if we deny the appeal we will provide a mechanism for contacting your state Attorney General.

9. How to exercise your rights

Send your request to info@talentro.co with the subject line "Privacy Request."

Tell us what you would like us to do and include enough information for us to locate your records — typically the name and email address or LinkedIn profile we contacted you on. We will verify your identity by confirming the information you provide against our records; we may ask for additional information if we cannot reasonably verify you, and we will not use that information for any other purpose.

We will respond within 45 days, and may extend once by a further 45 days where reasonably necessary, in which case we will tell you before the first period expires.

Authorised agents. An authorised agent may submit a request on your behalf with written proof of authorisation. We may contact you directly to confirm.

If you ask us to delete your information, we will remove it from our records and instruct our service providers to do the same. Note that we cannot delete information held by third-party platforms we do not control, such as your own public LinkedIn profile.

10. Contact

Talentro info@talentro.co

11. Changes to this Policy

We may update this Policy from time to time. When we do, we will revise the "Last updated" date above. Material changes will be brought to the attention of Clients and active Candidates by email.