1. WHO WE ARE

1.1 Talent 2U Direct Ltd (“we”, “us”, or “our”) operates recruitment services and technology platforms designed to connect employers with professional candidates. We are registered in England and Wales under company number 17256191.

1.2 Our services include:

• Jobs 2U Direct – a candidate registration platform
• Talent 2U Direct – a confidential talent marketplace accessed by employers
• Integrations with partner recruitment agencies and recruitment technology systems

1.3 Talent 2U Direct Ltd is the data controller responsible for personal data collected through the Jobs 2U Direct platform.

1.4 This Privacy Policy explains how we collect, use, process, and protect your personal data when you register with Jobs 2U Direct.

2. PLATFORM OVERVIEW

2.1 Jobs 2U Direct allows candidates to create a professional profile and register their interest in career opportunities.

2.2 As part of our recruitment ecosystem, candidate profiles may be promoted to employers through the Talent 2U Direct platform.

2.3 Profiles displayed to employers are initially presented in anonymised format, meaning identifying information such as name, contact details, and current employer are not visible to employers at that stage.

2.4 If an employer wishes to engage with a candidate profile, they may send a job invitation through the platform. The candidate may accept or decline the invitation. If accepted, identifying details may be shared with the employer to enable further communication. If declined, the candidate’s identity will not be revealed.

3. DATA ROLES

3.1 Talent 2U Direct Ltd acts as data controller for all personal data collected and processed through the Jobs 2U Direct platform.

3.2 Where candidate profiles are shared with employers following acceptance of an invitation, the employer becomes an independent data controller in respect of any further processing of that candidate’s personal data.

3.3 Where we work with partner recruitment agencies, each agency acts as an independent data controller for their own candidate relationships.

4. PERSONAL DATA WE COLLECT

4.1 Identity and Contact Data: name, email address, telephone number, and location.

4.2 Professional Profile Data: CV or employment history, qualifications, professional skills, salary expectations, and career preferences.

4.3 Account Data: login credentials and account preferences.

4.4 Technical Data: IP address, device and browser information, and activity logs.

4.5 Communication Data: correspondence with our support team and recruitment communications.

5. HOW WE USE YOUR PERSONAL DATA

5.1 To provide recruitment services, including creating and maintaining candidate profiles, matching candidates with employment opportunities, and sending and managing job invitations.

5.2 To promote candidate profiles in anonymised format on the Talent 2U Direct platform, enabling employers to send job invitations which candidates may accept or decline.

5.3 For platform administration, including system security, analytics, and service improvement.

5.4 For legal and regulatory compliance, including fraud prevention and responding to lawful requests.

5.5 To share relevant platform and candidate data with Talent 2U Direct LLC, our affiliated company registered in Florida, USA, to support the delivery and operation of our recruitment services and technology platforms. Any such transfer is subject to appropriate safeguards as described in clause 9.

6. AUTOMATED PROCESSING AND PROFILING

6.1 We may use automated processing to match candidate profiles with relevant employer searches and to rank or suggest profiles based on employer criteria. This processing does not produce legal or similarly significant effects for candidates.

6.2 Candidates have the right to request human review of any automated decision that significantly affects them. Please contact us using the details in clause 13 to exercise this right.

7. LAWFUL BASIS FOR PROCESSING

7.1 Contractual necessity – processing required to deliver the recruitment service you have registered for.

7.2 Legitimate interests – operating and improving our platform, fraud prevention, and promoting profiles to relevant employers.

7.3 Consent – where you have provided explicit consent, for example to receive marketing communications.

7.4 Legal obligations – where processing is required to comply with applicable law.

8. SHARING PERSONAL DATA

8.1 We may share personal data with:

• Employers, following a candidate’s acceptance of a job invitation
• Partner recruitment agencies, where relevant to a candidate’s profile and career preferences
• Technology and service providers who support platform operations, acting as data processors under our instruction
• Professional advisers, regulators, and law enforcement where required by law
• Talent 2U Direct LLC, our affiliated company registered in Florida, USA, for the purpose of supporting and delivering our recruitment services and platform operations

8.2 We do not sell personal data to third parties.

9. INTERNATIONAL TRANSFERS

9.1 Personal data may be transferred outside the UK in the following circumstances: (a) to Talent 2U Direct LLC, our affiliated company in the United States, for the purposes described in clause 5.5, under a UK International Data Transfer Agreement (IDTA) executed between the two entities; and (b) to technology providers or partners who operate internationally, under standard contractual clauses or other UK GDPR-compliant mechanisms. A copy of the applicable safeguards is available on request by contacting us using the details in clause 14.

9.2 The United States does not benefit from a UK adequacy decision covering all commercial data transfers. Transfers to Talent 2U Direct LLC are therefore made under an IDTA, which requires the recipient to provide equivalent protections to those required under UK GDPR.

10. DATA RETENTION

10.1 Active candidate profiles: retained while the account remains active.

10.2 Inactive profiles: up to 24 months following last activity.

10.3 Technical logs: up to 12 months.

10.4 Legal and compliance records: up to 6 years.

10.5 We will delete or anonymise personal data once it is no longer needed for the purpose for which it was collected.

11. DATA SECURITY

11.1 We maintain appropriate technical and organisational security measures to protect personal data against unauthorised access, loss, or disclosure. These include secure infrastructure, encryption, and access controls.

11.2 In the event of a personal data breach that is likely to result in a risk to your rights and freedoms, we will notify the ICO and affected individuals in accordance with our legal obligations.

12. YOUR RIGHTS

12.1 Under UK GDPR, individuals have the following rights in respect of their personal data:

• Right of access – to obtain a copy of your personal data
• Right to rectification – to correct inaccurate or incomplete data
• Right to erasure – to request deletion in certain circumstances
• Right to restriction of processing – to limit how your data is used
• Right to object – to processing based on legitimate interests
• Right to data portability – to receive your data in a structured, machine-readable format
• Right to withdraw consent – at any time where processing is based on consent

12.2 To exercise any of these rights, please contact us using the details in clause 13.

12.3 You also have the right to lodge a complaint with the Information Commissioner’s Office (ICO) at www.ico.org.uk.

13. CHANGES TO THIS POLICY

13.1 We may update this Privacy Policy from time to time. Where changes are material, we will notify you by email or by a prominent notice on the platform. Continued use of the platform following notification constitutes acceptance of the revised policy.

14. CONTACT

14.1 Talent 2U Direct Ltd – support@jobs2udirect.com