Version Update: 01/12/2023
Talent Alpha Sp. z o.o. created this policy in line with its commitment to your privacy as a website user of https://talent-alpha.com (and any related site or mobile device application designated by us), as may be updated by us from time to time (“Users”) and/or a person with whom we cooperate, including our clients, business partners, their representatives and Alpha Specialists (henceforth referred to as “You” and “Yours”). Unless specifically referred to a given category of data subjects, the below provisions apply to all of them. For the terms of this policy, Talent Alpha Sp. z o.o. with its registered office at Podole 76, 30-394 Kraków, Poland is a controller of data collected in connection with our website and our business. The terms “we”, “us”, “our” refer to Talent Alpha Sp. z o.o. (henceforth referred to as “Talent Alpha” or “TA”). If you have any questions regarding the processing of your personal data please contact us at: firstname.lastname@example.org.
Terms Used in the Policy
GDPR – Refers to the European Parliament and Council Regulation (EU) 2016/679 of 27 April 2016 on the protection of natural persons with regard to the processing of personal data and on the free movement of such data (a general data protection regulation).
Personal Data − Refers to any information relating to an identified or identifiable natural person. An identifiable natural person is one who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an email address or a telephone number of the person and other data when combined with the above.
Sensitive Personal Data – Special categories of Personal Data mentioned in Art. 9 of the GDPR and Personal Data mentioned in Art. 10 of the GDPR include: racial or ethnic origin, political opinions, religious or philosophical beliefs, trade union membership, criminal convictions and offences or related security measures, genetic data, biometric data for the purpose of uniquely identifying a person, health, sex life or sexual orientation.
Talent Alpha Human Cloud Platform – Talent Alpha database and application program interface used to store Human Cloud Specialists provided by Human Cloud Subscribers.
Human Cloud Subscriber– A business partner of TA that provides data of its Specialists in order that Talent Alpha can provide services to this business partner.
Human Cloud Specialist – Individuals including Human Cloud Subscriber’s employees, co-workers, contractors and sub-contractors who become members of the Talent Alpha Human Cloud Platform.
Alpha Specialist – is a sub-category of Human Cloud Specialist and includes individuals including Contractor’s employees, co-workers, contractors and sub-contractors who become members of the Talent Alpha talent pool database.
Processing – Refers to any operation or set of operations which is performed on Personal Data or on sets of Personal Data, by automated means or otherwise, such as: collection, recording, organization, structuring, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, alignment or combination, restriction, erasure or destruction.
Contractor – A business partner of TA that provides, via its Specialists, services to TA clients based on TA orders.
Purposes & Legal Basis of Processing
We process Personal Data in order to:
- Execute the agreement concluded by You as our business partner, Contractor, client or in order to undertake actions on your request before the conclusion of the agreement with regards to the processing of Your data as a sole entrepreneur or Your company’s representatives authorized to conclude the agreement with us (Art. 6.1.b of the GDPR) and to make cooperation/execution of the agreement easier with regards to the processing of your contact persons’/representatives’ personal data (Art. 6.1.f of the GDPR).
- Provide responses to your inquiries sent through the website contact form, e-mail or phone. In such a case the legal basis for the processing of your Personal Data is our legitimate interest in contacting You in reference to Your inquiry (Art. 6.1.f of the GDPR).
- Conduct marketing and advertising activities, especially via sponsored ads or other materials published in the Internet. This may also be connected with various remarketing activities and taking actions in order to encourage users to interact with us and our services. We process personal data in this regard, basing on our legitimate interest (Art. 6.1.f of the GDPR).
- Send direct marketing information (including the Talent Alpha newsletter) to users, clients and business partners (Contractors), via e-mail addresses they provide on the legal basis of their consent (Art. 6.1.a of the GDPR) and in case we have already a relevant relation with You, based on our legitimate interest (Art. 6.1.f of the GDPR). Nevertheless, various legal provisions may require us to obtain a separate consent for providing You with our marketing information. Consequently, we may ask you for a separate consent in this regard.
- Organize competitions by Talent Alpha, conferences or events. Your Personal Data will be processed only if You have registered as a participant. The legal basis for the organization of competitions is consent (Art. 6.1.a of the GDPR).
- Organize and conduct open and dedicated training sessions. In the case of training sessions, the legal basis for the processing of Personal Data is an agreement for the provision of training services conducted with Talent Alpha by sending electronically the respective order form (Art. 6.1.b of the GDPR).
- Process a contact persons’ data in order to execute the agreement with our client, business partner (Contractor) is regarded as facilitation of the execution of the agreement. The legal basis of the processing is our legitimate interest in connection with an execution of the agreement concluded between us and our client or business partner (Art. 6.1.f of the GDPR).
- connect You, a Human Cloud Specialist, with enterprise clients by matching projects suitable to Your level of professional experience and sending Your Personal Data to clients on this basis; by managing the relationship with You to enable You, as an Human Cloud Specialist, to participate in Talent Alpha clients’ projects. In such a case the legal basis for the processing of Your Personal Data is a necessity for the performance of a contract concluded between us and You (Art. 6.1.b of the GDPR).
- If You are a Human Cloud Specialist whose services may be needed by our clients, we may also process Your Personal Data for the purposes of testing Your skills, performance, evaluating potential matching roles in the interest of placing You in a project. The processing of Your Personal Data will take place mostly as a result of cooperation with our business partner (Contractor) who hired You and shared Your Personal Data with us. The Personal Data we receive includes Your professional skills, experience, education and Your contact details. If this is the case, You will find more information on processing Your Personal Data in section 4 below. The legal basis of the processing will be a necessity for the performance of a contract concluded between You and us (Art. 6.1.b of the GDPR). Within various measurement tools such as tests and games You take part in, we may process multiple personal characteristics for the purposes of measuring, testing Your skills and performance, evaluating potential matching roles in order to match You to project opportunities on the Talent Alpha Platform and Your eventual placement in a project.
- Enable You to use our websites, such as talent-alpha.com (and any other website controlled by us). Processing Your Personal Data in this regard is connected with our use of cookie files or other, similar technologies, storing data about visits on our website (logs) such as IP address and data concerning the device you are using, analyzing the way you use our websites. The legal basis for processing this data is the provision of Art. 6.1.f) of the GDPR, stating that we may process Personal Data if it is necessary for the purposes of the legitimate interests pursued by the data controller.
Our legitimate interest is related to the:
- necessity of controlling a traffic within our websites,
- preventing errors and technical defects,
- safety of websites, as well as the necessity to prevent abuse and violations of the law,
- analyzing users’ activities within our websites,
- performing marketing activities.
- Please note that we may keep certain information within our measurement tools such as tests, games You take part in, that does not constitute Your Personal Data and that is gathered, stored and processed according to scientific research standards and can be used in scientific publications and conference presentations. Note that this information does not constitute Your Personal Data and if You withdraw your consent to participate in such skills testing it will be impossible to remove Your anonymized data from the aggregate, anonymized pool.
The Provision of Your Data
professional skills, experience and education we may get such information from You directly or from our business partner (Contractor) who hired You. We may also get such information from other person/entity who recommended You as an Alpha Specialist and Your LinkedIn profile or information about your teamwork as an Alpha Specialist i.e., Your performance within a team You work on or a project that might be obtained from Your team members working with You on the same team, based on the questions to be answered by you in the tests, questionnaires relating to your teamwork experience. In specific situations we may also process other data, like data relating to Your work status (e.g. residence and work permit if needed).
Sensitive Personal Data
Talent Alpha does not process Sensitive Personal Data unless:
- The processing is required or permitted by law or;
- Talent Alpha has obtained Your explicit consent, such as for the measurement of Your personal
characteristics, where relying on consent is permitted or appropriate under applicable law.
You may have certain rights in relation to Your Personal Data. Some of these rights only apply in certain circumstances. If You would like to exercise any of these rights, please contact us at: email@example.com.
- Access: You are entitled to request access to Your Personal Data that we process.
- Correction: You are entitled to ask that any incomplete or inaccurate Personal Data we hold about
You is corrected.
- Erasure: You are entitled to ask us to delete or remove Your Personal Data in certain circumstances. There are also certain exceptions where we may refuse a request for erasure, for example, where the Personal Data is still required in relation to the purposes for which it was collected.
- Restriction: In some circumstances, You are entitled to ask us to suspend the processing of some of Your Personal Data, for example, if You want us to establish its accuracy or the reason for processing it.
- Data Portability: In some circumstances, You may ask us to transfer Your Personal Data to another party.
- Objection: Where we are processing Your personal data based on our legitimate interests (or those of a third party), You may object to its processing. However, we may be entitled to continue processing Your Personal Data if we can demonstrate compelling legitimate grounds for its processing.
- Withdrawing Your Consent: Where Your Personal Data is processed with Your consent, You have the right to withdraw Your consent at any time. The withdrawal of consent will not affect the lawfulness of its processing based on consent before its withdrawal.
You also have the right to file a complaint to a relevant Data Protection Authority.
How Long We Keep Your Personal Data
Talent Alpha retains personal data to meet the purposes for which the data was collected or in order to ensure compliance with applicable laws or to protect legitimate company interests (e.g. statute of limitations periods). We will store Your personal data for the purposes of:
- The execution of the agreement throughout the period of our cooperation with You and the lapse of the statute of limitations period.
- Answering your enquiries – for the time period of our correspondence and longer if justified to ensure we have an adequate log of our correspondences.
- Sending marketing materials – for the period of sending You our materials up to the period you shall file your objection to such processing.
- Keeping the results of Your tests, games, questionnaires in which You participated within our measurement tools, for the period necessary to match You to project opportunities on the Talent Alpha Platform and Your eventual placement in a project, however no longer than the time required for this purpose.
- Measuring the effectiveness of the measurement tools we use for the period of time necessary to verify the adequacy and usefulness of these tools within our business model, however no longer than the time required for this purpose.
- Keeping Your Personal Data, as an Alpha Specialist, in our database in order to match projects suitable for Your professional experience with our clients. We will process Your data for as long as our cooperation with an entity who hired You is in place and in the case that we base our processing on a consent, as long as it is valid.
With Whom Do We Share Your Personal Data
Your data provided to us can be disclosed to:
- software houses and IT Platform providers that develop and host our platform;
- Our Business Partners – entities that provide IT services via our platform,;
- Microsoft Ireland Operations Limited and Microsoft Corp. Redmond, Washington State USA – a
cloud service provider, which provides us with various services including e-mail hosting, software
for a team management and office work, customer relationship management software,
- Google Ireland Ltd and Google LLC, California, USA – a cloud service provider that allows Talent Alpha platform and our website to operate.
- Entities authorized by law to obtain Your Personal Data. The Transfer of Personal Data to Third Countries
As, in connection with our services, we may transfer Your Personal Data to third parties, established outside the EEA or Switzerland, mentioned above .In countries which are not deemed by the European Commission to provide adequate data protection (non-adequate third countries), Talent Alpha shall rely on transfer mechanisms in accordance with applicable laws, which includes the EU “Data Privacy Framework”). When the third party is established in a country that is deemed by the EU Commission to provide adequate data protection, we rely on the protections available under local law.
For more information about, or to obtain a copy of specific transfer mechanisms, including information on any of the existing safeguards implemented by Talent Alpha in case such transfers occurs, please contact firstname.lastname@example.org.
How We Secure Your Personal Data
Talent Alpha maintains appropriate administrative, technical and physical safeguards designed to protect Your Personal Data against accidental or unlawful destruction, accidental loss, alteration, unauthorized disclosure or access, use, and all other unlawful forms of processing of personal data in our possession.