Privacy Policy

Last updated: 23. 02. 2026

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This privacy policy contains information about how TalentHub OÜ (register code 14837747) collects, processes, and shares personal data. It is created based on the General Data Protection Regulation (GDPR).

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1. Roles and Responsibilities

TalentHub may act either as:

1. Data Processor

When we provide recruitment services on behalf of our clients.

In these cases:

• Our client (the hiring company) is the Data Controller
• TalentHub processes personal data strictly on the client’s documented instructions
• A Data Processing Agreement (DPA) governs the processing

Candidates should refer to the hiring company’s privacy notice for full controller-level information.

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2. Data Controller

TalentHub acts as Data Controller when:

• Recruiting employees for TalentHub OÜ
• Managing newsletter subscriptions
• Handling website inquiries
• Conducting marketing activities
• Managing business contacts

For these processing activities, this Privacy Policy applies directly.

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2. Personal Data We Process

2.1 When Acting as Data Processor (Client Recruitment Projects)

We may process:

• Candidate name and contact details
• CV and application materials
• Employment history and qualifications
• Interview notes
• Interview recordings (if used)
• AI-generated transcripts and summaries
• Assessment results
• Communication records

We process this data solely on behalf of and under the instructions of the client (Data Controller).

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2.2 When Acting as Data Controller

Website Visitors

• Email address and company name (newsletter/contact forms)
• IP address and technical data
• Cookie identifiers
• Website interaction data

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Recruitment for TalentHub OÜ

• Application documents
• Interview notes
• Interview recordings (if used)
• AI-generated transcripts and summaries
• Communication history

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3. Interview Recording & AI Processing

For certain recruitment processes, interviews may be recorded and transcribed using AI-based tools (e.g., Metaview AI).

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Purpose:

• Accurate documentation
• Improved objectivity
• Quality assurance
• Structured candidate evaluation

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Legal Basis (when TalentHub is Controller):

• Legitimate Interest (Art 6(1)(f))
  or
• Consent (Art 6(1)(a)), where applicable

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Candidates are informed in advance and may request that interviews be conducted without recording.

AI tools assist in transcription and summarization only. Final hiring decisions are always made by human decision-makers. We do not conduct fully automated decision-making under Article 22 GDPR.

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4. Legal Basis of Processing (When Controller)

• Recruitment (TalentHub internal hiring)
  
  • Legal basis: Legitimate interest
• Interview recording
  
  • Legal basis: Legitimate interest or consent
• Newsletter distribution
  
  • Legal basis: Consent
• Website analytics
  
  • Legal basis: Consent (cookie-based)
• Responding to inquiries
  
  • Legal basis: Legitimate interest
• Marketing activities
  
  • Legal basis: Consent

Where processing is based on consent, consent may be withdrawn at any time.

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5. Data Retention

When TalentHub is Controller:

• Unsuccessful recruitment candidates: retained up to 6–12 months unless consent for longer retention is obtained
• Hired candidates: retained in accordance with employment data retention requirements
• Newsletter subscribers: until unsubscribed
• Marketing data: until consent withdrawal
• Website analytics: according to third-party tool retention settings

When acting as Processor, retention periods are determined by the Data Controller (our client).

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6. Third-Party Processors

We use trusted service providers, including:

• Metaview AI – interview transcription and notes
• HubSpot – CRM and email management
• Webflow – website hosting
• Google Analytics – analytics
• Hotjar – behavioral insights
• Meta (Facebook Pixel) – advertising services

All processors are bound by Data Processing Agreements.

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7. International Data Transfers

Where personal data is transferred outside the EU/EEA, we ensure appropriate safeguards such as:

• Standard Contractual Clauses (SCCs)
• Additional technical and organizational measures

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8. Data Security

We implement appropriate safeguards including:

• Role-based access control
• Encryption in transit
• Confidentiality agreements
• Limited data access
• Vendor due diligence

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9. Data Subject Rights

When TalentHub acts as Controller, individuals have the right to:

• Access their data
• Rectify inaccurate data
• Request deletion
• Restrict processing
• Object to processing based on legitimate interest
• Withdraw consent
• Request data portability
• Lodge a complaint with the Estonian Data Protection Inspectorate

When TalentHub acts as Processor, requests will be forwarded to the relevant Data Controller.

Contact: info@talenthub.eu

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10. Cookies

TalentHub uses cookies for functionality, analytics, and advertising purposes.

Users may manage cookie preferences via browser settings or cookie consent tools.

More information: https://www.aki.ee/et/kupsised

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11. Changes to This Privacy Policy

We may update this Privacy Policy to reflect changes in law or business operations.
The latest version is always available on our website.

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12. Contact

TalentHub OÜ

info@talenthub.eu

Estonia