Privacy Policy

Version Update: 2205/062/2020

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: personaldata@talent-alpha.com.

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.

Online Services – Refers to all of the services made available to You by us or our affiliates via our Website or the Talent Lab mobile device application, including in particular the application program interface, Talent Alpha’s content, our talent pool database, your Account and any other service provided by us under our separate Terms of Use.

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).
  • 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). In cases where we will do marketing profiling, we shall process Your Personal Data based on Your consent, if required. (Art. 6.1.a of the GDPR). Consent/s for sending marketing information in accordance with Art. 10 of the act on rendering services by electronic means and / or Art. 172 of Polish Telecommunications Act, is expressed by You independently and separately.
  • 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).
  • If You are a Human Cloudn Alpha Specialist whose services may be needed by our clients, the processing of Your Personal Data will take place mostly as a result of TA’s cooperation with our business partner (Human Cloud Subscriber or Contractor) who hired You and shared Your Personal Data with us with the intent to pursue TA business opportunitiesuse the Talent Alpha Human Cloud Platform. In such a case we will process Your Personal Data in order to:
    • Pursue our business, i.e. connect You, an Alpha 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 Alpha Specialist, to participate in Talent Alpha clients’ projects. In such a case the legal basis for the processing of Your Personal Data is our legitimate interest in (Art. 6.1.f of the GDPR).
    • If You are a Human Cloudn Alpha Specialist whose services may be needed by our clients, we will process Your Personal Data for the purposes of evaluatingtesting Your skills, and 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 (Human Cloud Subscriber or 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 our legitimate interest in assigning You to a project (Art. 6.1.f of the GDPR) or the legal basis established with the Human Cloud Subscriber who hired You. 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 projectroles of your Human Cloud Subscriber. The legal basis of the processing will be Your consent under Art. 6.1.a of the GDPR and Art. 9.2.a of the GDPR.
    • We may, in random cases process Your Personal Data as an Alpha Human Cloud Specialist within the assessment of the effectiveness of the measurement tools we use such as tests, games and, questionnaires for the purpose of verifying their effectiveness. The legal basis of the processing will be our legitimate interest (Art. 6.1.f of the GDPR).
    • If you decide to use Talent Alpha Online Services, we will process Your Personal Data for the purpose of entering into an agreement concerning the provision of our Online Services, including the registration as defined in the Terms of Use for those Online Services. In such cases the legal basis for the processing of Your Personal Data is entering into a contract with You concerning the provision of Online Services (Art. 6.1.b of the GDPR).
    • If You decide to settle an Account with Talent Alpha Online Services, we may process Your Personal Data in order to manage Your Account and to manage any contacts with You in this scope. The legal basis of the processing will be our legitimate interest in assigning You to a project (Art. 6.1.f of the GDPR).
    • The legitimate interest of Talent Alpha is to:
      • Contact You to answer Your queries;
      • 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;
      • Send direct marketing communications to disseminate information about Talent Alpha’s services;
      • Manage Your Account on Talent Alpha’s Online Services – to facilitate Your use of these services and to answer Your queries;
      • To measure the effectiveness of the measurement tools we use – to verify the adequacy and usefulness of the measurement tools we use within our business model for matching teams of Alpha Specialists to a given project;
      • To simplify the process of evaluating, matching roles and making placements as well as facilitating the internal management of our relationship with Alpha Specialists – in order to more effectively manage the assignment of Alpha Specialists to TA client projects.
  • If consent is required for the processing in question, it will be sought from You separately to ensure that it is freely given and informed. To the extent that Talent Alpha relies on Your consent to process Your Personal Data, You have the right to withdraw Your consent to such processing at any time. You can do this by contacting our data protection team at: personaldata@talent-alpha.com. The withdrawal of Your consent does not affect the lawfulness of its processing based on consent before its withdrawal.
  • 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.
  • If You are an Alpha Specialist whose services may be needed by our clients, the processing of Your Personal Data will take place mostly as a result of TA’s cooperation with our business partner (Contractor) who hired You and shared Your Personal Data with us with the intent to pursue TA business opportunities. In such a case we will process Your Personal Data in order to:
    • Pursue our business, i.e. connect You, an Alpha 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 Alpha Specialist, to participate in Talent Alpha clients’ projects. In such a case the legal basis for the processing of Your Personal Data is our legitimate interest in (Art. 6.1.f of the GDPR).
    • If You are an Alpha Specialist whose services may be needed by our clients, we will 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 our legitimate interest in assigning You to a project (Art. 6.1.f 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. The legal basis of the processing will be Your consent under Art. 6.1.a of the GDPR and Art. 9.2.a of the GDPR.

The Provision of Your Data

Whenever you provide us directly with Your Personal Data, the provision of Your Personal Data, in each case is voluntary, however without its provision, You won’t be able to receive certain information (e.g. marketing newsletters) or take part in training, conferences, competitions, events or You won’t be able to settle an Account with Talent Alpha Online Services as stated in our Terms of Use or we won’t be able to address your enquiry or, in the case of Alpha Specialists, to match a client’s project that is suitable for You and as a consequence to be able to recommend Your services to our clients. We may not always receive Your Personal Data directly from You in the case when You are a representative/ contact person of our business partner (Contractor) or client, and your contact details such as name, surname, business title, business email, business phone number are obtained via our client, business partner (Contractor) and when You are an Alpha Specialist, with respect to Your contact details, 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.

Your Rights

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: personaldata@talent-alpha.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 Data Protection Authority. In Poland You can make a complaint to Prezes Urzędu Ochrony Danych Osobowych, ul. Stawki 2, 00-193, Warsaw, Poland.

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.
  • Maintaining Your Account within Talent Alpha Online Services, as stated in our Terms of Use for the period You use our Online Services and longer, only if and when we are required to do so by law.
  • 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:

  • Our Subcontractors where relevant including IT Platform providers;
  • Our Business Partners;
  • Entities cooperating with us in the assessment of Human Cloud Specialists and selection process of Alpha Specialists;
  • If you are an Alpha Specialist, we advise that Your Personal Data will be shared and processed by clients of Talent Alpha. You will receive information about clients in the project descriptions;
  • Entities authorized by law to obtain Your Personal Data.

The Transfer of Personal Data to Third Countries

Talent Alpha does not transfer Your Personal Data to third countries. In case of data transfers to third parties established outside the EEA or Switzerland; 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 (1.) the EU “Standard Contractual Clauses”, (2.) and the Privacy Shield Certification of the third party (if established in the U.S.). 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 personaldata@talent-alpha.com.

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.

Changes to This Privacy Policy

We reserve the right to change this Privacy Policy at any time. When we make material changes to this Privacy Policy, we will post the changes on our website and update the revision date at the top of the Privacy