Privacy Policy

Data controller: Element 10 Ltd, trading as Talent First. Company number 04950164. Registered in England. Email: hello@talent-first.ai.

We are the data controller for personal data we process about our customers and for personal data we source independently to deliver lead intelligence (see Section 3). Where we process personal data on behalf of a customer (for example, contact data uploaded into their account), we act as a data processor and the customer is the controller.

We process two broad categories of personal data:

• Customer account data. Information you provide when creating and using an account: name, work email, work phone, company, billing details, ICP configuration, search parameters, and account preferences. We also collect technical data such as IP address, browser type, and basic usage logs to operate the Service securely.
• Lead data. Information about hiring decision makers and the companies they work for, sourced from publicly available job postings and publicly visible professional profiles. This typically includes name, job title, employer, location, work email address, and work phone number where publicly listed. We do not knowingly collect special category data.

Lead data is built from publicly accessible sources, processed through our own classification and scoring pipeline. Sources include:

• Public job postings published by employers on company career pages, public job boards, LinkedIn Jobs, Reed, Indeed, and equivalent third-party aggregators.
• Publicly visible professional profile data, used to identify the relevant decision maker associated with a public job posting.
• Specialist B2B contact-enrichment providers (for example providers of work email addresses and direct dials commonly published in business directories or otherwise lawfully available). We require any third-party data provider we use to warrant compliance with applicable data protection law.

We do not scrape behind logins, bypass technical controls, or collect personal data from sources where the data subject has indicated it should not be processed for marketing or business development purposes.

Customer account data. We rely on contract (UK GDPR Article 6(1)(b)) where processing is necessary to provide the Service you have requested, and on legitimate interests (Article 6(1)(f)) for internal operations, security, and product improvement. Where we send you marketing communications, we rely on the soft opt-in for existing customers under PECR or your explicit consent.

Lead data. We rely on legitimate interests (UK GDPR Article 6(1)(f)) to process publicly available business contact data for the purpose of B2B business development on behalf of recruitment agencies. Our legitimate interest is the commercial viability of providing the Service. We have completed a Legitimate Interest Assessment (LIA) which balances this interest against the rights and freedoms of data subjects, having regard to the public nature of the source material, the limited scope of fields we process, the business-context-only use, and the availability of an objection mechanism (see Section 8).

We use personal data to:

• Provide, operate, and maintain the Talent First service, including delivering daily lead reports and configuring your ICP.
• Match public job postings to relevant decision makers, score them for hiring intent, and surface the resulting leads in customer reports.
• Communicate with you about your account, billing, support, and material service updates.
• Improve the accuracy and quality of the Service, including measuring lead relevance and refining scoring models. We do not use customer data to train models that benefit other customers.
• Detect, prevent, and respond to fraud, abuse, and security incidents.
• Comply with legal obligations.

We do not sell personal data. We do not share your account data with other customers. We engage a small number of trusted sub-processors to operate the Service, including cloud hosting, email delivery, payment processing, customer support, and the specialist B2B data providers described in Section 3. We require all sub-processors to provide appropriate safeguards and to process personal data only on our documented instructions.

We may disclose personal data where required by law, in response to a valid legal request, or where necessary to protect our rights, the rights of others, or the security of the Service.

We are based in the United Kingdom and process personal data primarily within the UK and European Economic Area. Where a sub-processor is located outside the UK or EEA (for example, a US-based hosting or analytics provider), we put in place appropriate safeguards such as the UK International Data Transfer Agreement, the UK Addendum to the EU Standard Contractual Clauses, or reliance on a valid adequacy decision.

Subject to UK GDPR conditions and exceptions, you have the right to:

• access the personal data we hold about you;
• request correction of inaccurate or incomplete data;
• request erasure of your data ("right to be forgotten");
• object to our processing where we rely on legitimate interests, including objection to direct marketing at any time;
• request restriction of processing;
• request portability of data you provided to us;
• withdraw consent at any time where processing is based on consent (without affecting prior lawful processing).

To exercise any of these rights, including if you appear in a lead surfaced through Talent First and would like your details removed from our systems, please email hello@talent-first.ai. We will respond within one calendar month.

You also have the right to complain to the UK Information Commissioner's Office (ICO) at ico.org.uk if you believe we have not handled your personal data in accordance with the law.

Customer account data is retained for the duration of your relationship with us and for a reasonable period afterwards to comply with legal, accounting, and regulatory obligations (typically up to seven years for financial records).

Lead data is refreshed continuously from public sources. We hold lead records for as long as the underlying signal (such as the originating job posting) is current and commercially relevant, plus a limited period afterwards for audit and quality purposes. Data subjects who object to processing under Section 8 are added to a suppression list to prevent re-processing.

We use appropriate technical and organisational measures to protect personal data, including encryption in transit, access controls, secrets management, environment isolation between customers, and routine review of our security posture. No system is perfectly secure; if we become aware of a personal data breach that meets the UK GDPR notification threshold, we will notify the ICO within 72 hours and affected individuals where required.

The Talent First marketing website uses a minimal set of cookies and equivalent technologies necessary to operate the site and to measure aggregate usage. We do not use third-party advertising cookies. Where we deploy any non-essential cookie or analytics tag, we do so on the basis of your consent, which you can withdraw at any time via your browser settings.

We may update this Privacy Policy from time to time. The "Last updated" date at the top of the page reflects the most recent version. Material changes will be communicated to active customers by email.

Element 10 Ltd, trading as Talent First.
Company number 04950164, registered in England.
Email: hello@talent-first.ai