1. Introduction

JM Data Talent ('we', 'us', 'our') is committed to protecting and respecting your privacy. This Privacy Policy explains how we collect, use, store, and protect personal data in accordance with the General Data Protection Regulation (GDPR) (EU) 2016/679 and any applicable Irish data protection legislation.

The data controller responsible for your personal data is:

JM Data Talent

51 Bracken Road, Dublin 18, D18 CV48, Ireland

Email: info@jmdatatalent.com | Phone: +353 89 975 4617

By using our website or engaging with our services, you acknowledge that you have read and understood this Privacy Policy.

The data controller responsible for your personal data is:

JM Data Talent

51 Bracken Road, Dublin 18, D18 CV48, Ireland

Email: info@jmdatatalent.com | Phone: +353 89 975 4617

By using our website or engaging with our services, you acknowledge that you have read and understood this Privacy Policy.

2. What Personal Data We Collect

Depending on how you interact with us, we may collect and process the following categories of personal data:

2.1 Candidates and Job Seekers

• Identity data: name, date of birth, nationality

• Contact data: email address, phone number, postal address

• CV and employment data: work history, qualifications, certifications, skills

• Recruitment data: interview notes, assessment results, feedback from clients

• Financial data: current and expected day rate or salary expectations

• Technical data: browser type, IP address, pages visited on our website

• Special categories of data: only where strictly necessary (e.g. right to work documentation, disability adjustments) and only with your explicit consent

2.2 Clients and Hiring Organisations

• Contact data: name, job title, business email address, phone number

• Company data: company name, address, billing details

• Recruitment requirements: job briefs, hiring criteria, interview feedback

Depending on how you interact with us, we may collect and process the following categories of personal data:

2.1 Candidates and Job Seekers

• Identity data: name, date of birth, nationality

• Contact data: email address, phone number, postal address

• CV and employment data: work history, qualifications, certifications, skills

• Recruitment data: interview notes, assessment results, feedback from clients

• Financial data: current and expected day rate or salary expectations

• Technical data: browser type, IP address, pages visited on our website

• Special categories of data: only where strictly necessary (e.g. right to work documentation, disability adjustments) and only with your explicit consent

2.2 Clients and Hiring Organisations

• Contact data: name, job title, business email address, phone number

• Company data: company name, address, billing details

• Recruitment requirements: job briefs, hiring criteria, interview feedback

3. How We Collect Your Data

We collect personal data in the following ways:

• Directly from you: when you submit your CV, contact us by email or phone, fill in a form on our website, or engage with us on LinkedIn

• From third-party sources: LinkedIn, job boards, referrals from existing candidates or clients

• Automatically: through cookies and similar technologies when you visit our website (see Section 8 — Cookies)

We collect personal data in the following ways:

• Directly from you: when you submit your CV, contact us by email or phone, fill in a form on our website, or engage with us on LinkedIn

• From third-party sources: LinkedIn, job boards, referrals from existing candidates or clients

• Automatically: through cookies and similar technologies when you visit our website (see Section 8 — Cookies)

4. How We Use Your Data and Our Lawful Basis

We process your personal data only where we have a lawful basis to do so under Article 6 of the GDPR. The table below sets out our main processing activities:

Purpose

Data Used

Lawful Basis

Lawful Basis

Lawful Basis

Matching candidates to contract roles

Identity, Contact, CV, Recruitment

Legitimate Interest / Consent

Maintaining a candidate database for future roles

Identity, Contact, CV

Consent

Processing client hiring requirements

Contact, Company, Recruitment

Contract / Legitimate Interest

Communicating about relevant opportunities

Contact, Profile

Consent / Legitimate Interest

Legal and compliance obligations

As required by law

Legal Obligation

Website analytics and improvement

Technical, Usage

Legitimate Interest / Consent

Where we rely on legitimate interests, we have assessed that our interests do not override your fundamental rights and freedoms. You may object to processing based on legitimate interests at any time (see Section 7 — Your Rights).

5. How We Share Your Data

We do not sell your personal data. We will never share your CV or profile with a client without your explicit consent. We may share your data with:

• Clients and hiring organisations: only after your explicit consent has been obtained for each specific introduction

• IT and platform providers: recruitment software, email systems, and website hosting providers who act as data processors under our instruction

• Professional advisers: lawyers, accountants, and insurers where necessary

• Regulatory and government bodies: where required by law or regulation

We do not sell your personal data. We will never share your CV or profile with a client without your explicit consent. We may share your data with:

• Clients and hiring organisations: only after your explicit consent has been obtained for each specific introduction

• IT and platform providers: recruitment software, email systems, and website hosting providers who act as data processors under our instruction

• Professional advisers: lawyers, accountants, and insurers where necessary

• Regulatory and government bodies: where required by law or regulation

6. International Data Transfers

We primarily process and store your data within the European Economic Area (EEA). In the event that any data is transferred outside the EEA, we will ensure that appropriate safeguards are in place in accordance with GDPR requirements, such as Standard Contractual Clauses approved by the European Commission.

7. Data Retention

We retain personal data only for as long as is necessary for the purposes for which it was collected, or as required by applicable law. Our general retention periods are:

• Active candidates: data retained for up to 2 years from the date of last contact, or until you request removal

• Placed candidates: data retained for up to 6 years following the end of the placement

• Client contact data: retained for up to 6 years from the end of the client relationship

• Website usage data (cookies and analytics): typically 13 months

You may request deletion of your data at any time (subject to any legal obligations we may have to retain it). Please contact info@jmdatatalent.com.

We retain personal data only for as long as is necessary for the purposes for which it was collected, or as required by applicable law. Our general retention periods are:

• Active candidates: data retained for up to 2 years from the date of last contact, or until you request removal

• Placed candidates: data retained for up to 6 years following the end of the placement

• Client contact data: retained for up to 6 years from the end of the client relationship

• Website usage data (cookies and analytics): typically 13 months

You may request deletion of your data at any time (subject to any legal obligations we may have to retain it). Please contact info@jmdatatalent.com.

8. Your Rights Under GDPR

You have the following rights in relation to 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 any inaccurate or incomplete data

• Right to erasure: to request deletion of your data, subject to any legal retention obligations

• Right to object: to object to processing based on legitimate interests

• 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, machine-readable format

• Right to withdraw consent: where processing is based on consent, you may withdraw it at any time without affecting the lawfulness of prior processing

To exercise any of these rights, please contact us at: info@jmdatatalent.com

You also have the right to lodge a complaint with the Data Protection Commission (DPC) of Ireland at www.dataprotection.ie.