We ask that you read this privacy notice carefully as it contains important information on who we are, how and why we collect, store, use and share personal information, your rights in relation to your personal information and on how to contact us and supervisory authorities in the event you have a complaint.
Who we are
Talking Talent Limited is a company incorporated in England and Wales with company number 05617899, whose registered office is at Milton Gate, 60 Chiswell Street, London, United Kingdom, EC1Y 4AG (referred to as “Talking Talent”, “we”, “us” and “our” in this notice).
Talking Talent is a provider of coaching programmes and consultancy services (coaching programmes) including providing coachees with access to digital coaching platform (TT Online).
Scope of this notice
This notice describes our processing of personal data we obtain about:
- visitors to our website at talking-talent.com;
- staff and representatives of our business customers and potential business customers; and
- staff and representatives of our business suppliers and potential business suppliers.
For the purposes of UK and EU data protection law, we are the ‘controller’ of this personal data (meaning that we determine why and how it is processed).
This notice does not describe our processing of personal data relating to our coachees in the course of delivering coaching programmes and providing TT Online. This processing is instead described in and governed by contracts between us and our business customers and where we process any personal data of coachees as a controller, the details of such processing is set out in our Coachee Privacy.
This notice does not describe our processing of personal data relating to people who apply for jobs with us. Neither does this notice describe our processing of personal data relating to our employees. Our processing for employment-related purposes is set out in a separate notice that we make available to our employees and job applicants.
The personal data that we collect and use
In this section we have set out the general categories of personal data that we process and, in the case of personal data that we did not obtain directly from you, information about the source and specific categories of that data.
Business contact data: data relating to our business customers’ and potential customers’ staff and representatives collected in connection with providing services to our customers and potential customers. The business contact data may include your name, business email address, telephone number, postal address, job title, your classification / categorisation within our customer relationship management system and information contained in or relating to communications between us and you, or between us and your employer. The source of the business contact data is you, your colleagues, your employer, public sources (such as LinkedIn or corporate websites) or reputable lead generation list providers.
Account data: data collected for the purpose of setting up customer accounts and to enable our customers to access our services. The account data may include your name, username, email address, account creation and modification dates and access permissions. The primary source of the account data is you and/or your employer, although some elements of the account data may be generated by our platform.
Communication data: information contained in or relating to any communication that you send to us or that we send to you. The communication data may include any personal data contained in the content, name, address, company name, contact details and any metadata associated with the communication such as the date and time of sending. We obtain this data when you contact us by email, phone, post, social media, website contact forms or live chat web service. The source of the communication data is you and/or your employer, and our website will generate the metadata associated with communications made using the website contact forms.
Usage data: data about your use of our website. The usage data may include your IP address, geographical location, browser type and version, operating system, referral source, length of visit, page views and website navigation paths, as well as information about the timing, frequency and pattern of your service use. The source of the usage data is our analytics tracking system.
Marketing data: data collected in connection with any marketing subscription (including data collected via lead generation applications or webinars we run) or opt-out request. The marketing data may include your name, email address and marketing preferences. The source of this data is you and/or your employer.
Please do not supply any other person’s personal data to us, unless we prompt you to do so.
Information collected from other sources
- From cookies on our website for more information on our cookies please see our cookies policy
- Our IT systems for automated monitoring of our websites and other technical systems such as computer networks and connections, communications systems, and access control systems, email and other instant messaging systems
- From a third party with your consent, for example Zoom or Webex
What does Talking Talent use your personal information for
Below we describe the purposes we use the personal information for, the types of personal information we use for those purposes and our legal bases for doing so.
| Purpose | Type of personal data used | Legal basis |
| Providing our services to our customers and communicating with customers in connection with providing those services. | Business contact data | Our legitimate interests in providing our services to customers. |
| Communicating with people for example in response to an enquiry or complaint. | Business contact data Account data
Communication data |
Our legitimate interests, namely communications with our website visitors, service users, potential customers, customers and customer personnel, and the proper administration of our website, services and business. |
| Providing support to our customers. | Business contact data Account data
Communication data |
Our legitimate interests in providing our services to customers. |
| Billing customers | Business contact data | Our legitimate interests in charging customers for using our services. |
| Customer relationship management, including dealing with complaints, keeping records of our interactions with customers and keeping in contact with customers. | Business contact data
Communication data |
Our legitimate interests in providing good quality service to our customers, dealing effectively with complaints and maintaining relationships with our customers. |
| Sending marketing communications (see more on this in the “Using personal data for marketing purposes” section below) | Marketing data
Business contact data |
Our legitimate interests in promoting our business and services to drive sales and sustain and grow our business. |
| Analysing use of our website, e.g. finding out how many people visit various parts of the site, so that we can assess how successful our website is and how it could be improved and developed. | Usage data | Consent of our website visitors
|
| Keeping our website secure and functional | Usage data | Our legitimate interests in protecting our website and ensuring it works effectively.
|
Other processing purposes
In addition to our core processing purposes set out above, we may also process personal data if and to the extent necessary for the following purposes:
Record keeping – We may process your personal data for the purposes of creating and maintaining our databases, back-up copies of our databases and our business records generally. The legal basis for this processing is our legitimate interests, namely ensuring that we have access to all the information we need to properly and efficiently run our business in accordance with this policy.
Security – We may process your personal data for the purposes of security and the prevention of fraud and other criminal activity. The legal basis of this processing is our legitimate interests, namely the protection of our website, services and business, and the protection of others.
Insurance and risk management – We may process your personal data where necessary for the purposes of obtaining or maintaining insurance coverage, managing risks and/or obtaining professional advice. The legal basis for this processing is our legitimate interests, namely the proper protection of our business against risks.
Legal claims – We may process your personal data where necessary for the establishment, exercise or defence of legal claims, whether in court proceedings or in an administrative or out-of-court procedure. The legal basis for this processing is our legitimate interests, namely the protection and assertion of our legal rights, your legal rights and the legal rights of others.
Legal compliance and vital interests – We may also process your personal data where such processing is necessary for compliance with a legal obligation to which we are subject or in order to protect your vital interests or the vital interests of another natural person.
Using personal data for marketing purposes
We send occasional emails containing information about our business and services to the following categories of people:
- staff and representatives of our business customers or target business customers; and
- people who have subscribed to receive our newsletter or other marketing communications
If you receive such communications from us and do not wish to, you can tell us by using the unsubscribe link in any email we send to you or emailing Info@talking-talent.com].
Who we share your personal information with
Service providers
We use a number of service providers in connection with our website, services, communications and IT infrastructure, which involves those service providers processing some of the personal data described in this notice to the extent necessary to provide the relevant services. We currently use the following providers:
| Provider | Service provided | Type of personal data used |
| Microsoft 365 | Office Suite of Tools including Microsoft Teams (used for Vid Conferencing)
|
Business contact data
Communication data |
| Salesforce | Customer Relationship Management system
|
Business contact data
Contract data Account data Communication data |
| Certinia | Project and Finance Systems
|
Business contact data for invoicing |
| Hubspot | Outreach and marketing tool – funnels info into Salesforce | Business contact data
|
| (Location data, IP address, device information, browser information) | Usage data | |
| SalesIntel | Platform to enhance prospects contact information for Sales leads | Business contact data
|
| Zoom* | Video conferencing tool | |
| Webex* | Video conferencing tool | |
| Qualtrics* | Survey/feedback Tool |
The service providers which are not marked with an asterisk are sub-processors of the personal data which means they will only process any such personal data on our behalf and therefore in accordance with our strict instructions.
The service providers marked with an asterisk (*) are data controllers. Controllers are the main decision-makers – they exercise overall control over the purposes and means of the processing of personal data. Therefore, such service providers will provide you with their own privacy policies explaining why and how personal data is collected and processed by those service providers.
Other parties we may share your personal information with:
- Other third parties who help us to run a business, such as marketing agencies, insurers, lawyers, accountants and business consultants, but only if and to the extent necessary for them to carry out the work we engage them to assist us with, for example in relation to a legal claim made against us or obtaining insurance cover.
- Talking Talent group companies (TT US and/or TT Asia) for internal administration purposes.
Some of those third-party recipients may be based outside the UK— for further information including on how we safeguard your personal data when this occurs, see ‘Transfer of your information out of the UK’.
We will share personal information with law enforcement or other authorities if required by applicable law.
There may be also circumstances in which we need to share personal information with other organisations or individuals, such as in order to protect your vital interests or the vital interests of another natural person.
How long your personal information will be kept
This section sets out our data retention policies and procedures, which are designed to help ensure that we comply with our legal obligations in relation to the retention and deletion of personal data.
Personal data that we process for any purpose or purposes shall not be kept for longer than is necessary for that purpose or those purposes.
We will retain your personal data as follows:
- Business contact data: We keep this in our CRM databases for 6 years after the relevant customer contract has terminated
- Account data: We delete this 6 years after the relevant customer contract has terminated
- Communication data: We archive and store emails for 6 years after the date of the correspondence, but if the email relates to a customer contract, we store them for 6 years after termination of the customer contract to which the email relates. Submitted web contact forms are stored for one year.
- Usage data: The statistical reports provided to us by Google are retained by us for 90 days. However, these contain only aggregated data that do not enable us to identify individual users.
- Marketing data: We will continue to use this data until we receive an opt-out request, after which time we will retain the email address and marketing preference information to ensure that we do not send marketing to the unsubscribed email address.
We may retain your personal data where such retention is necessary for compliance with a legal obligation to which we are subject, or in order to protect your vital interests or the vital interests of another natural person.
Transfer of your information out of the UK
To service providers
Where we use the service providers identified in the section above “Who we share your personal information with”, this may also involve transfers of your personal data outside of the UK.
To group companies
We transfer some personal data to our group companies that are based in the USA and Hong Kong.
Transfers
Where such transfers are to countries within the EEA, these are permitted under UK data protection law as the UK government deems EEA countries to provide an adequate level of protection for personal data. Japan (private sector organisations) also has been deemed as adequate.
In relation to any transfers to third parties who are based in countries not deemed to provide an adequate level of protection for personal data, we will ensure that appropriate safeguards are in place to protect your personal data (namely the use of standard data protection clauses adopted or approved by the competent data protection authorities). Please contact us (Dataprotection@talking-talent.com) if you would like to see a copy of these standard clauses.
Your rights
You have a number of different rights you might be able exercise against us in relation to personal data about you that we process. These are rights to:
- access your personal data
- obtain rectification or erasure of your personal data
- restrict and/or object to processing of your personal data
- have your personal data ‘ported’ to you or another organisation
- complain to a supervisory authority about our processing of your personal data
- withdraw consent to our processing of your personal data (where you have given consent)
The availability of these rights varies depending on the legal basis that we rely on for processing the relevant personal data. Below we have summarised these rights and explained how you can request to exercise them.
Access: You have the right to confirmation as to whether or not we process your personal data and, where we do, access to the personal data, together with certain additional information. That additional information includes details of the purposes of the processing, the categories of personal data concerned and the recipients of the personal data. Providing that the rights and freedoms of others are not affected, we will supply to you a copy of your personal data. The first copy will be provided free of charge, but additional copies may be subject to a reasonable fee.
Rectification: You have the right to have any inaccurate personal data about you corrected and, taking into account the purposes of the processing, to have any incomplete personal data about you completed. We may need to verify the accuracy of the new data you provide to us.
Erasure: You have the right to the erasure of your personal data without undue delay where the personal data are no longer necessary in relation to the purposes for which we collected or otherwise processed them, you successfully object to our processing, you object to our use of your personal data for direct marketing purposes, we have processed your personal data unlawfully, or an applicable law requires the relevant personal data to be erased. However, there are exclusions to the right to erasure, including where we have overriding legitimate grounds to continue processing the relevant personal data or are required to do so by applicable law or where we need it to establish, exercise or defend a legal claim.
Restriction: You have the right to restrict our processing of your personal data where you contest the accuracy of the personal data, our processing is unlawful, we no longer need the personal data for our purposes but you require it to establish, exercise or defend a legal claim, or you have objected to processing, pending the verification of that objection. Where processing has been restricted on this basis, we may continue to store your personal data. However, we will only otherwise process it to establish, exercise or defend a legal claim, to protect the rights of another natural or legal person or for reasons of important public interest or with your consent.
Object: You have the right to object to our processing of your personal data where we rely on legitimate interests as the legal basis for the processing. If you make such an objection, we will cease to process the personal information unless we can demonstrate compelling legitimate grounds for the processing that override your interests, rights and freedoms, or the processing is for the establishment, exercise or defence of legal claims.
Object to processing for direct marketing purposes: You have the right to object to our processing of your personal data for direct marketing purposes (including profiling for direct marketing purposes).
Data portability: where our processing of your personal data is based on performance of a contract or consent and is carried out by automated means, you have the right to receive your personal data from us in a structured, commonly used and machine-readable format. However, this right does not apply where it would adversely affect the rights and freedoms of others.
Complain to a supervisory authority: If you consider that our processing of your personal data infringes data protection laws, you have a legal right to lodge a complaint with a supervisory authority responsible for data protection.
Withdraw consent: where any of our processing is based on your consent, you have the right to withdraw that consent at any time. Withdrawal will not affect the lawfulness of processing before the withdrawal.
How to exercise these rights against us
If you would like to exercise any of those rights, please:
- Email, call or write to us
- Let us have enough information to identify you, including your username and password where appropriate
- Let us have proof of your identity and address (a copy of your driving licence or passport and a recent utility or credit card bill), and
- Let us know the information to which your request relates
Keeping your personal information secure
We have appropriate security measures in place to prevent personal information from being accidentally lost, or used or accessed in an unauthorised way. We limit access to your personal information to those who have a genuine business need to know it. Those processing your information will do so only in an authorised manner and are subject to a duty of confidentiality.
We also have procedures in place to deal with any suspected data security breach. We will notify you and any applicable regulator of a suspected data security breach where we are legally required to do so.
How to complain
We hope that we can resolve any query or concern you raise about our use of your personal information.
The data protection laws in the UK also give you right to lodge a complaint with a supervisory authority. To make a complaint to a supervisory authority, you may contact the supervisory authority of your choice using contact details made available by that supervisory authority. Relevant contact details for the UK supervisory authority, the ICO, can be found here: https://ico.org.uk/concerns/
Personal data of children
Our website and services are targeted at persons over the age of 18.
If we have reason to believe that we hold personal data of a person under that age in our databases, we will delete that personal data.
Updating information
Please let us know if the personal information that we hold about you needs to be corrected or updated.
Third parties
We may from time to time provide you with hyperlinks to, and details of, third party websites. In general, we have no control over and are not responsible for, the privacy policies and practices of third parties.
Some third party service providers mentioned in this notice may handle your personal data as a controller in their own right (for example, Zoom, Webex and others mentioned above in the section “Who we share your personal information with”). This will tend to be the case where you are asked to register directly with the service provider in order to receive our services. Any information you provide to these service providers will be subject to their own privacy policy so please review them to see how they will handle your personal data.
Changes to this privacy notice
This privacy notice was last updated on 24th May 2024. Any changes we make to this privacy notice in the future will be posted on our website and, where appropriate, notified to you by e-mail or other suitable method.
How to contact us
This website is owned and operated by Talking Talent Limited.
Please contact us if you have any questions about this privacy notice or the information we hold about you.
If you wish to contact us please send an email to Dataprotection@talking-talent.com or write to the Chief Financial Officer, Talking Talent Limited, Milton Gate, 60 Chiswell Street, London, United Kingdom, EC1Y 4AG or call 01491 821850.
Data protection registration
We are registered as a data controller with the UK Information Commissioner’s Office.
Our data protection registration number is ZA017840.