Data Controller and Owner, Types of Data collected

The owner does not provide a list of Personal Data types collected.Other Personal Data collected may be described in other sections of this privacy policy or by dedicated explanation text contextually with the Data collection.The Personal Data may be freely provided by the User, or collected automatically when using this Application. Any use of Cookies - or of other tracking tools - by this Application or by the owners of third party services used by this Application, unless stated otherwise, serves to identify Users and remember their preferences, for the sole purpose of providing the service required by the User. Failure to provide certain Personal Data may make it impossible for this Application to provide its services.Users are responsible for any Personal Data of third parties obtained, published or shared through this Application and confirm that they have the third party's consent to provide the Data to the Owner.

How We Collect Personal Data

What personal data we collect depends largely on the interaction that takes place between you and Talenthon, most of which can be categorized under the following:

  • When you use Talenthon Service. When you use Talenthon Service, we store all the content you provide, including information related to you as a customer or an end user of the Service. We gather this information from you directly when you enter it, or from integrations that you linked to the Service (Facebook, Instagram, Whatsapp, Telegram, Stripe etc.). When you ask us to sign DPA or other documents, we also receive data about you and your representatives.

In some cases, we can receive information from third parties, e.g. from a payment serviceprovider on whether yourpayment was successful.

  • When you send us emails or message us. When we receive emails or messages from you in the chat, we can store the content of such emails, attachments as well as your contact details.
  • When you submit forms on the Site or participate in our events. When you complete forms on the Site (contact us, subscription, demo request, event registration, etc.) we collect your contact details and information you complete in the form. If we arrange joint events together with our partners, we can receive information from our partners.
  • When you use the Site. When you use the Site, we collect certain information, as described in more detail below that may, alone or in combination with other information, constitute personal data (e.g. cookie files).
  • When you join our communities. When you join our Facebook and other groups, we can see data in your profile and process comments you posted in our groups. However, we don’t gather that information or copy it into our systems, but rather just have access to it.

What Types of Personal Data We Process

We collect and process the following personal data:

  • Customer account details. To create or update your account and provide the Service we collect from you and third-party integrations (e.g. Facebook, Instagram, WhatsApp, Telegram) information about you, as a customer or end-user of the Service. This includes id, name, email, status, linked pages and accounts, products in use, location, etc.
  • Financial information. To process your payments for the Service subscription, we need your credit card details (last four digits of the card number), account details and payment information.
  • Contact details and business data. We receive information about our customers and potential customers for cooperation and communication purposes. This includes full name, title, company, email or other contact details as may be necessary.
  • Requests, messages and submitted forms details. We receive and process your messages, support requests, emails and information you share with us via online forms or social media accounts. This includes the content of such communications as well as your contact details if any.
  • Usage data, logs and other technical data. When you interact with the Service, metadata and log files are collected automatically. Log data may include the Internet Protocol (IP) address, your browser type and settings, the date and time you used the Service, information about browser configuration plugins, language preferences, the pages or features which you browsed, time spent on those pages or features, the frequency of pages and functions use, the links clicked on or used. If you use the Service from your phone, this may also include the type of device, operating system, device settings and device identifiers.
  • Email performance data. To track engagement and performance metrics of our newsletters, we can use a ‘clear image’ (gif) in email communications. Much of this data is aggregated. If you wish to turn off this tracking, you can do so by turning off images in the email itself.
  • Website cookies and similar technologies. We use cookie technology on the Site.
  • Customer Content. As you use our Service, you may import into our system personal data you have collected from your users, customers, prospective customers, social media and messaging platform contacts (collectively “Subscribers”) or other individuals. We process this data only on your behalf as our customer. We have no direct relationship with your Subscribers or any person other than you, and for that reason, you are responsible for making sure you have the appropriate permission and legal basis for us to collect and process information about those individuals. For information relating to how we process personal data relating to Subscribers, please see our Data Processing Addendum.

We ask that you not send or disclose to us any sensitive personal data (e.g., social security numbers, information related to racial or ethnic origin, political opinions, religion or other beliefs, health, biometrics or genetic characteristics, criminal background or union membership) on or through the Service or otherwise.

For Which Purposes We Use Personal Data

We collect and process your personal data for the following purposes:

  • To operate the Service: We use data to enter into the agreement with you as a customer and operate, maintain and administer your account in the Service, as well as to communicate with you regarding the account (sending announcements, technical notices, updates, security alerts, and support and administrative messages) and to respond to Service-related requests, questions and feedback. We also use your data to perform our billing obligations.

To provide the Service we process Customer Content information on your behalf as a customer (see details in Data Processing Addendum).

  • To communicate with you and inform you about the Service. If you request information from us, register for the Service, complete a form or feedback on a Site, or participate in our surveys, promotions or events, we may send you Talenthon-related marketing communications if permitted by law. In all such communications, we will provide you with the possibility to opt-out.
  • To conduct events and communicate with you. We use your personal data, which you provided while registering for the event, to send you reminders about the event, communications related to the event and Talenthon-related services. As well, we may ask for your feedback. In communications, we always provide the possibility to opt-out from communications.
  • To comply with law. We use your personal data as necessary to comply with applicable laws, including sanction requirements, accounting and tax obligations, legal processes or audits, to respond to subpoenas or legally binding requests from government authorities. Before disclosing any information to an authority upon its request, we check the validity of such request carefully.
  • To negotiate, enter and perform agreements. We have to collect and process information about our counterparties and their representatives to negotiate and enter into legally valid agreements and cooperate with them.
  • For compliance and safety. We use your personal data as we believe necessary or appropriate to (a) enforce the terms and conditions that govern the Service; (b) protect our rights, privacy, safety or property, and/or that of you or others; and (c) protect, investigate and deter against fraudulent, harmful, unauthorized, unethical or illegal activity.

How We Share Personal Data

We do not sell your data to third parties for commercial or advertising purposes. We share your data as described in this Privacy Policy or upon obtaining your consent for such data sharing.

We disclose personal data to third parties under the following circumstances:

  • Service Providers. We employ third-party companies and individuals to help us with performance of certain activities, e.g. payment service providers. We also use third-party software to process data (e.g. CRM, email agent, cloud storage solutions, etc.).

We also use third-party cookies on the Site.

  • Professional Advisors. We may disclose your personal data to professional advisors, such as lawyers, bankers, auditors and insurers, where necessary in the course of the professional services that they render to us.
  • Third-party Applications and Integrations. For the provision of the Service we receive and share data with integrations and apps linked by customers (Facebook, Instagram, WhatsApp, Telegram, Stripe, etc.)
  • Business Transfers. As we develop our business, we might sell or buy businesses or assets. In the event of a corporate sale, merger, reorganization, dissolution or similar event, personal data may be part of the transferred assets. You acknowledge and agree that any successor to or acquirer of Talenthon (or its assets) will continue to have the right to use your personal data and other information in accordance with the terms of this Privacy Policy. Further, Talenthon may also disclose aggregated personal data in order to describe our Service to prospective acquirers or business partners.
  • Compliance with Laws and Law Enforcement. Talenthon may disclose information about you to government or law enforcement officials or private parties as required by law, and disclose and use such information as we believe necessary or appropriate to (a) comply with applicable laws and lawful requests and legal processes, such as to respond to subpoenas or requests from government authorities; (b) enforce the terms and conditions that govern the Service; (d) protect our rights, privacy, safety or property, and/or that of you or others; and (e) protect, investigate and deter against fraudulent, harmful, unauthorized, unethical or illegal activity.

Your Data Protection Rights & Choices

You have the following rights:

  • If you wish to access your personal data that Talenthon collects, you can do so at any time by contacting us.
  • You can also contact us to update, correct or delete information in your account.
  • If you are in the UK, you can object to processing of your personal data, ask us to restrict processing of your personal data or request portability of your personal data where it is technically possible.
  • Similarly, if you are in the UK and provided we have collected and processed your personal data under your consent, then you can withdraw your consent at any time. Withdrawing your consent will not affect the lawfulness of any processing we conducted prior to your withdrawal, nor will it affect processing of your personal data conducted in reliance on other lawful processing grounds.
  • You have the right to complain to a data protection authority about our collection and use of your personal data. Contact details for data protection authorities are available here.

You may submit your request via by sending an email to info@talenthon.co.uk. We will respond to all requests in accordance with applicable data protection laws.

Access to Data Controlled by our Customers. We don’t have any direct relationships with customers’ Subscribers, i.e. the individuals whose personal data is stored by our customers the Service. An individual who seeks access, or who seeks to correct, amend, or delete personal data processed in the Service by our customers should direct their request to the customer directly.

Mode and place of processing the Data

1. Methods of processing

The Data Controller processes the Data of Users in a proper manner and shall take appropriate security measures to prevent unauthorized access, disclosure, modification, or unauthorized destruction of the Data. The Data processing is carried out using computers and/or IT enabled tools, following organizational procedures and modes strictly related to the purposes indicated. In addition to the Data Controller, in some cases, the Data may be accessible to certain types of persons in charge, involved with the operation of the site (administration, sales, marketing, legal, system administration) or external parties (such as third party technical service providers, mail carriers, hosting providers, IT companies, communications agencies) appointed, if necessary, as Data Processors by the Owner. The updated list of these parties may be requested from the Data Controller at any time.

2. Place

The Data is processed at the Data Controller's operating offices and in any other places where the parties involved with the processing are located. For further information, please contact the Data Controller.

3. Retention time

The Data is kept for the time necessary to provide the service requested by the User, or stated by the purposes outlined in this document, and the User can always request that the Data Controller suspend or remove the data.

Additional information about Data collection and processing

1. Legal action

The User's Personal Data may be used for legal purposes by the Data Controller, in Court or in the stages leading to possible legal action arising from improper use of this Application or the related services. The User declares to be aware that the Data Controller may be required to reveal personal data upon request of public authorities

2. Additional information about User's Personal Data

In addition to the information contained in this privacy policy, this Application may provide the User with additional and contextual information concerning particular services or the collection and processing of Personal Data upon request.

3. System Logs and Maintenance

For operation and maintenance purposes, this Application and any third party services may collect files that record interaction with this Application (System Logs) or use for this purpose other Personal Data (such as IP Address).

4. Information not contained in this policy

More details concerning the collection or processing of Personal Data may be requested from the Data Controller at any time. Please see the contact information at the beginning of this document.

5. The rights of Users

Users have the right, at any time, to know whether their Personal Data has been stored and can consult the Data Controller to learn about their contents and origin, to verify their accuracy or to ask for them to be supplemented, cancelled, updated or corrected, or for their transformation into anonymous format or to block any data held in violation of the law, as well as to oppose their treatment for any and all legitimate reasons. Requests should be sent to the Data Controller at the contact information set out above. This Application does not support “Do Not Track” requests. To determine whether any of the third party services it uses honor the “Do Not Track” requests, please read their privacy policies.

6. Changes to this privacy policy

The Data Controller reserves the right to make changes to this privacy policy at any time by giving notice to its Users on this page. It is strongly recommended to check this page often, referring to the date of the last modification listed at the bottom. If a User objects to any of the changes to the Policy, the User must cease using this Application and can request that the Data Controller removes the Personal Data. Unless stated otherwise, the then-current privacy policy applies to all Personal Data the Data Controller has about Users.

7. Information about this privacy policy

The Data Controller is responsible for this privacy policy, prepared starting from the modules provided by Iubenda and hosted on Iubenda's servers.