Privacy Policy, Talented LLC

0. Key Points

• Talented LLC recruits, vets, and places overseas talent (primarily based in the Philippines) with US, EU, and UK businesses.
• We collect contact details, applicant information (including résumés and interview recordings), client requirements, payment information, and standard website analytics.
• We do not sell personal information for money. We do use advertising and analytics cookies (Meta and LinkedIn) that some US state privacy laws classify as “sharing” for cross-context behavioral advertising. You can opt out (Section 14).
• You can access, correct, delete, or download your data by emailing privacy@scout-talented.com.
• Interview recordings are made with applicant consent and reviewed only by Talented staff and the specific client considering the applicant.

1. Who We Are and Scope

Controller: Talented LLC, 6262 Fairbourne Ct, Hanover, MD 21076, USA. For EU/UK data subjects, Talented LLC is the data controller for personal data processed in connection with our recruiting services.

This Policy applies to visitors of scouttalented.com and our subdomains (including apply.scouttalented.com and hire.scouttalented.com), prospective and current clients, and talent applicants who interact with our recruiting platform, forms, calls, and communications.

2. Information We Collect

2.1 Information You Provide

• Contact Details: name, email, phone, company, location.
• Applicant Information: résumé/CV, work history, skills, assessment responses, salary expectations, interview recordings and transcripts, references, and any other materials you submit through our application process.
• Client Requirements: role descriptions, team structure, KPIs, hiring preferences, feedback on shortlisted candidates.
• Payment Information: billing address and limited card data. Card numbers are processed and stored by Stripe; we do not store full card numbers on our systems.
• Communications: emails, SMS messages, support tickets, and recorded sales or onboarding calls (where lawful and disclosed).

2.2 Information Collected Automatically

When you browse our site we log IP address, device and browser type, referrer URL, pages viewed, time on page, and approximate location derived from IP. Our first-party analytics endpoint records session events (page views, clicks, form interactions) tied to a session identifier, along with marketing attribution parameters (UTM tags, Meta click ID, LinkedIn click ID) where present. This helps secure the site, debug issues, and understand performance trends.

2.3 Sensitive Information

We do not intentionally collect sensitive categories of personal data (race or ethnicity, health, religion, sexual orientation, biometric identifiers, government ID numbers, or precise geolocation in the sense of GPS-level coordinates) and ask that you do not include them in applications or correspondence unless required by law or specifically requested. The approximate, IP-derived location described in Section 2.2 is not precise geolocation.

3. CCPA/CPRA Categories of Personal Information

For California residents, in the past 12 months we have collected the following categories of personal information as defined by the California Consumer Privacy Act:

We do not sell personal information for monetary consideration. We do share identifiers and internet activity with advertising partners (Meta, LinkedIn) for cross-context behavioral advertising. This qualifies as “sharing” under the CPRA. See Section 14 to opt out.

4. Cookies, Pixels, and Similar Technologies

We use:

• Essential cookies: site security, load balancing, session and variant detection.
• Analytics: aggregate traffic and performance measurement.
• Advertising pixels: the Meta Pixel (facebook.com/tr) and the LinkedIn Insight Tag (snap.licdn.com/li.lms-analytics/insight.min.js). These help us measure ad performance and reach similar audiences. Under CPRA and similar laws this is treated as “sharing” for cross-context behavioral advertising. We also send corresponding server-side events to Meta and LinkedIn, described in Section 4A.

You can block cookies and pixels through your browser settings, an ad blocker, or by using the opt-out mechanisms in Section 14. We honor Global Privacy Control (GPC) signals as a valid opt-out where the law requires. Blocking browser cookies does not by itself stop server-side conversion events; to opt out of server-side sharing, use the mechanisms in Section 14.

4A. Server-Side Conversion Events (Meta CAPI and LinkedIn CAPI)

In addition to the browser-side pixels described in Section 4, we send conversion events to Meta and LinkedIn server-to-server using the Meta Conversions API and the LinkedIn Conversions API. These server-side events run independently of browser cookies and ad blockers and are used to measure the performance of our advertising campaigns.

When we send a server-side event, we may include:

• Hashed identifiers: email address and phone number, hashed with SHA-256 before transmission so that the underlying values are not readable by Meta or LinkedIn.
• Online identifiers: IP address, user-agent string, page URL, the Meta browser ID (_fbp), the Meta click ID (_fbc), and the LinkedIn click ID where available.
• Event metadata: event name (for example, “Lead” or “Schedule”), event time, and a deduplication ID that prevents the same conversion from being counted twice across the browser pixel and the server event.

Meta and LinkedIn process this data on our behalf to attribute conversions, optimize ad delivery, and build similar audiences. Under several US state privacy laws (including the CPRA), this transfer is treated as “sharing” for cross-context behavioral advertising rather than a sale for monetary consideration. See Section 14 for opt-out options.

5. How We Use Data

• Operate, secure, and improve our recruiting services.
• Match applicants with suitable roles and present shortlists to clients.
• Communicate with you: confirmations, scheduling, service updates, and marketing. You can opt out of marketing at any time.
• Process payments, issue invoices, and maintain financial records.
• Measure and optimize our marketing campaigns and website performance.
• Comply with legal obligations and respond to rights requests.

6. Interview Recordings and Call Recordings

We record interviews and certain sales or onboarding calls to evaluate applicants, train our team, and improve our service. Recording occurs only after we provide notice and obtain consent.

If you are in a jurisdiction that requires all-party consent to recording (including California, Florida, Illinois, Maryland, Massachusetts, Montana, Nevada, New Hampshire, Pennsylvania, and Washington), we will obtain that consent at or before the start of the call. You may decline. If you decline we will use an alternative evaluation method or end the call.

Recordings are stored on access-controlled systems. Access is limited to Talented staff and to the specific client considering the applicant. Recordings are retained in line with Section 9.

7. Automated Processing and AI Tools

We may use software, including AI-assisted tools, to organize applications, generate shortlists, transcribe interviews, and surface candidate-role matches. A human recruiter reviews every shortlist before it is sent to a client. We do not make solely automated employment decisions that produce legal or similarly significant effects.

New York City applicants: if and where an Automated Employment Decision Tool (AEDT) within the meaning of NYC Local Law 144 is used in your evaluation, we provide separate notice in line with that law and post applicable bias audit summaries. Applicants may request information about the categories of data used by such tools.

8. Sharing and Disclosure

• Clients: applicant data is shared only with the specific client considering the applicant and only after the applicant agrees.
• Service providers: see Section 10 for the current list. Each is bound by confidentiality and data protection terms.
• Advertising partners: Meta and LinkedIn receive limited online identifiers and event data via browser pixels and via server-side Conversions API events (see Section 4A) for measurement and audience-building.
• Regulators and law enforcement: where disclosure is legally required or necessary to protect rights and safety.
• Corporate events: in a merger, financing, or acquisition, subject to this Policy.

9. Retention

We keep data only as long as needed for the purposes in Section 5 and any legally mandated period.

• Applicant files: reviewed every 24 months and deleted or anonymized if no longer relevant.
• Interview and call recordings: retained up to 24 months from the date of the recording unless a legal hold or active hiring process requires longer.
• Client and billing records: retained for the duration of the relationship plus 7 years for tax and audit purposes.
• Website logs and analytics: typically 14 months.

10. Sub-processors and Service Providers

We use the following key sub-processors. The list is current as of the effective date and may change; we will update this section when we add new categories of processors.

11. International Transfers

Talented LLC is based in the United States. Our talent network is based primarily in the Philippines and in other countries where we recruit. Personal data may be processed and stored in the United States, the Philippines, and other locations where we or our service providers operate.

For transfers from the European Economic Area, the United Kingdom, or Switzerland to the United States or other countries without an adequacy decision, we rely on the European Commission's Standard Contractual Clauses (and the UK Addendum or Swiss equivalents where applicable) together with supplementary safeguards.

For data processed in the Philippines, processing is conducted in line with the Republic Act No. 10173 (Data Privacy Act of 2012) and its implementing rules.

12. Legal Bases (EEA/UK)

Our processing relies on:

• Contract performance: to deliver the recruiting service you or your employer requested.
• Legitimate interests: security, fraud prevention, direct marketing to existing clients, service improvement.
• Consent: interview recording, marketing to prospects where required, non-essential cookies.
• Legal obligation: tax, accounting, and responding to lawful requests.

13. Your Rights

Depending on where you live you may have the right to:

• Know what personal information we hold about you.
• Access a copy of your personal information.
• Correct inaccurate information.
• Delete your personal information.
• Opt out of marketing communications.
• Opt out of the sale or sharing of personal information and of targeted advertising.
• Object to or restrict certain processing (EEA, UK, and several US states).
• Request data portability.
• Appeal a denied rights request (Virginia, Colorado, Connecticut, Texas, Oregon, and others). If we decline a request, we will explain why and provide instructions for appeal.
• Lodge a complaint with a supervisory authority (EEA/UK residents) or your state attorney general.

To exercise a right, email privacy@scout-talented.com from the email address associated with your data, or contact us via the postal address in Section 17. We verify identity before acting on a request and will respond within 45 days (US state laws) or 30 days (GDPR/UK GDPR), with one permitted extension where the request is complex. There is no charge for a first request in a 12-month period.

You may designate an authorized agent to submit a request on your behalf. We will require written authorization and may verify directly with you.

14. Do Not Sell or Share, Opt-Out of Targeted Advertising

We do not sell personal information for money. We do use advertising cookies and pixels that several US state laws define as “sharing” or “targeted advertising.” To opt out:

• Email privacy@scout-talented.com with the subject line “Do Not Sell or Share.”
• Enable the Global Privacy Control (GPC) signal in your browser. We honor GPC as a valid opt-out for sale and sharing where required by law.
• Adjust your ad preferences directly with Meta and LinkedIn.

15. Marketing Communications and SMS

We send marketing emails only to people who request information about our services or who are existing clients. You can unsubscribe at any time via the link in any marketing email or by emailing us.

If you provide a phone number, we may send transactional SMS related to your application or booking (for example, interview confirmations). Standard message and data rates may apply. You can opt out of SMS at any time by replying STOP. We do not share phone numbers with third parties for their marketing.

16. Security and Children

We use encryption in transit, access controls, multi-factor authentication, and periodic security reviews. No online system is entirely fool-proof, but we act promptly on any identified risk and will notify affected individuals where required by law.

Our services are not directed to children. We do not knowingly collect personal data from anyone under 16. If we learn we have collected such data, we delete it promptly.

17. Changes and Contact

We update this Policy from time to time. Material changes are posted here with a new effective date. Continued use of our site or services indicates acceptance of the revised Policy.

Data Protection Officer, Talented LLC
6262 Fairbourne Ct, Hanover, MD 21076, USA
privacy@scout-talented.com