PRIVACY POLICY

WHO WE ARE

TalentSmiths is a trading name of TwoSmiths Limited, a company registered in England and Wales. We are an executive search firm specialising in the placement of Executive Assistants and Chiefs of Staff.

Registered address: TwoSmiths Limited, England and Wales.

Data controller contact: hello@talentsmiths.co.uk

WHAT DATA WE COLLECT

We collect personal data in the following circumstances:

- When you submit a search brief via our Start a Search form: name, company, email address, role requirements, and any information you provide in the message field. - When you apply to join The Circle: name, email address, current role title, years of experience, current principal type, and LinkedIn URL. - When you subscribe to The Edition: email address only. - When you use the Salary Calculator: email address and the profile information you enter (location, experience, principal type, scope). - When you contact us directly by email: any information you choose to share.

We do not collect sensitive personal data (as defined under GDPR Article 9) unless you voluntarily provide it.

HOW WE USE YOUR DATA

We use the personal data we collect for the following purposes:

- To respond to search briefs and conduct executive search assignments on behalf of principals. - To assess EA applications for inclusion in The Circle. - To send The Edition newsletter to subscribers who have opted in. - To deliver personalised salary benchmark results via the Salary Calculator. - To communicate with you about your enquiry or application.

We do not sell, rent, or share your personal data with third parties for marketing purposes. We do not use your data for automated decision-making or profiling in a way that produces legal or similarly significant effects.

LEGAL BASIS FOR PROCESSING

We process your personal data on the following legal bases under GDPR:

- Legitimate interests: where processing is necessary for our legitimate business interests in conducting executive search and talent network operations, and those interests are not overridden by your rights. - Consent: where you have actively opted in to receive communications such as The Edition. - Contract: where processing is necessary to fulfil a service you have requested, such as a search brief or salary calculation. - Legal obligation: where we are required to process data to comply with applicable law.

DATA RETENTION

We retain personal data only for as long as necessary for the purposes for which it was collected:

- Search brief submissions: retained for the duration of the search assignment and up to 12 months thereafter. - Circle applications: retained for up to 3 years from the date of application, or until you request deletion. - Edition subscriptions: retained until you unsubscribe. - General correspondence: retained for up to 2 years.

After the applicable retention period, data is securely deleted or anonymised.

THIRD-PARTY SERVICES

We use the following third-party services which may process your data on our behalf:

- Supabase: database and backend infrastructure, used to store form submissions and subscriptions. Data is stored on servers within the European Economic Area. - Anthropic: AI processing for the Salary Calculator feature. Only the profile information you enter (not your email) is sent to Anthropic's API to generate your salary benchmark. - Vercel: website hosting and deployment infrastructure.

All third-party processors are subject to data processing agreements and are required to process data only on our instructions and in accordance with applicable data protection law.

YOUR RIGHTS UNDER GDPR

If you are located in the UK or European Economic Area, you have the following rights regarding your personal data:

- Right of access: you may request a copy of the personal data we hold about you. - Right to rectification: you may request correction of inaccurate or incomplete data. - Right to erasure: you may request deletion of your personal data in certain circumstances. - Right to restriction: you may request that we restrict processing of your data in certain circumstances. - Right to data portability: you may request your data in a structured, machine-readable format. - Right to object: you may object to processing based on legitimate interests. - Right to withdraw consent: where processing is based on consent, you may withdraw it at any time.

To exercise any of these rights, contact us at hello@talentsmiths.co.uk. We will respond within 30 days. You also have the right to lodge a complaint with the Information Commissioner's Office (ICO) at ico.org.uk.

COOKIES

Our website uses minimal cookies necessary for the site to function correctly. We do not use advertising or tracking cookies. The theme preference you set (light or dark mode) is stored in your browser's localStorage, not as a cookie, and is not transmitted to our servers.

CHANGES TO THIS POLICY

We may update this privacy policy from time to time. The current version will always be available at talentsmiths.co.uk/privacy. Material changes will be communicated to active subscribers via The Edition.

CONTACT

For any questions about this privacy policy or how we handle your personal data, contact:

James Smith TwoSmiths Limited hello@talentsmiths.co.uk