Privacy Policy — Emerald Talent Solutions

This Privacy Policy explains how Emerald Talent Solutions SAS collects, uses, stores, and protects your personal data. We are committed to handling your data responsibly and in accordance with applicable data protection law, including the UK General Data Protection Regulation (UK GDPR), the EU General Data Protection Regulation (EU GDPR), and Colombian data protection law (Ley 1581 de 2012 — Habeas Data).

1. Who We Are

Emerald Talent Solutions SAS is a technology talent placement company registered in Colombia (NIT 901843923), operating at emeraldtalentsolutions.net. The data controller is Emerald Talent Solutions SAS, based in Medellín, Colombia.

For data protection enquiries, contact us at: info@emeraldtalentsolutions.net

2. What Data We Collect

Client enquiries

When you submit a client enquiry via our website, we collect: first name, last name, job title, company name, email address, telephone number (optional), and the content of your message.

Candidate registration

When you register as a candidate, we collect: first name, last name, email address, LinkedIn profile URL, primary technology specialism, years of experience, and current location.

Website usage data

We collect anonymised data about how visitors use our website through Google Analytics 4 and Microsoft Clarity. This includes pages visited, time on site, device type, and approximate location. This data does not identify you personally.

Cookies

We use cookies to operate our website and analytics tools. See our Cookie Policy for full details.

3. How We Use Your Data

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

To respond to client enquiries and progress placement conversations
To assess candidate profiles and match candidates to relevant technology roles
To manage the Emerald Assure evaluation process and produce Candidate Assessment Profiles
To deliver the Emerald Sky post-placement programme to placed consultants
To manage our client and candidate relationships through HubSpot CRM
To comply with our legal and contractual obligations
To improve our website and services through anonymised analytics

4. Legal Basis for Processing

We process your personal data on the following legal bases:

Consent: where you have provided explicit consent via our website forms, including GDPR consent checkboxes
Legitimate interests: where processing is necessary for our legitimate business interests in providing technology talent placement services, provided those interests are not overridden by your rights
Contract: where processing is necessary to perform a contract with you or to take steps at your request before entering into a contract
Legal obligation: where processing is necessary to comply with a legal obligation

5. How We Store and Protect Your Data

Your personal data is stored in the following systems, all of which operate appropriate technical and organisational security measures:

HubSpot CRM: client enquiry and candidate registration data. HubSpot is GDPR-compliant and a Data Processing Agreement is in place.
Microsoft SharePoint: operational candidate and placement records, held within Emerald's Microsoft 365 tenancy, protected by Microsoft's enterprise security controls.
Microsoft 365: email communications and document storage, protected by two-factor authentication and Microsoft's security infrastructure.

Emerald operates in alignment with ISO 27001 information security principles. Access to personal data is restricted to authorised personnel involved in the placement process.

6. How Long We Keep Your Data

Client enquiry data: retained for 24 months from the date of last contact, or for the duration of an active client relationship
Candidate data: retained for 24 months from the date of registration or last contact, unless you request earlier deletion
Placed consultant data: retained for the duration of the Emerald Sky programme and for 24 months thereafter
Website analytics data: retained in accordance with Google Analytics and Microsoft Clarity data retention settings (maximum 26 months)

You may request deletion of your data at any time by contacting us at info@emeraldtalentsolutions.net.

7. Sharing Your Data

We do not sell your personal data. We share your data only in the following circumstances:

With prospective employers / clients: candidate data is shared with client organisations in the form of Candidate Assessment Profiles, only with the candidate's knowledge and as part of the placement process
With technology service providers: HubSpot (CRM), Microsoft (365 and SharePoint), Google (Analytics), and Microsoft (Clarity) — all subject to appropriate data processing agreements
Where legally required: in response to lawful requests from public authorities or to comply with applicable law

8. International Data Transfers

Emerald Talent Solutions is based in Colombia and processes data on behalf of clients and candidates in the UK and US. Data transfers between Colombia, the UK, the EU, and the US are conducted in compliance with applicable transfer mechanisms, including Standard Contractual Clauses where required under UK GDPR and EU GDPR.

HubSpot and Microsoft operate data centres in multiple jurisdictions. Their data transfer mechanisms are documented in their respective Data Processing Agreements, available on their websites.

9. Your Rights

Depending on your location, you have the following rights regarding your personal data:

Right of access: to request a copy of the personal data we hold about you
Right to rectification: to request correction of inaccurate or incomplete data
Right to erasure: to request deletion of your personal data, subject to our legal obligations
Right to restrict processing: to request that we limit how we use your data
Right to data portability: to receive your data in a structured, commonly used format
Right to object: to object to processing based on legitimate interests
Right to withdraw consent: where processing is based on consent, to withdraw that consent at any time
Habeas Data (Colombia): the right to know, update, rectify, and delete personal data held about you under Colombian law

To exercise any of these rights, contact us at info@emeraldtalentsolutions.net. We will respond within 30 days.

10. Complaints

If you are based in the UK and believe we have not handled your data appropriately, you have the right to lodge a complaint with the Information Commissioner's Office (ICO) at ico.org.uk.

If you are based in the EU, you may contact your local supervisory authority.

If you are based in Colombia, you may contact the Superintendencia de Industria y Comercio (SIC) at sic.gov.co.

We would always appreciate the opportunity to address your concern directly before you escalate to a regulatory body.

11. Changes to This Policy

We may update this Privacy Policy from time to time to reflect changes in our practices or applicable law. The date of the most recent update is shown at the top of this page. We encourage you to review this policy periodically.

12. Contact Us

For any questions about this Privacy Policy or how we handle your personal data:

Emerald Talent Solutions SAS
Medellín, Colombia · NIT 901843923
info@emeraldtalentsolutions.net
emeraldtalentsolutions.net