Talentlush Information Technology Services, using the Talentlush® brand (“Talentlush,” “we,” “us,” or “our”), acts as the personal information controller for the personal data covered by this policy.

We respect your privacy and are committed to processing personal data responsibly and in accordance with Republic Act No. 10173, or the Philippine Data Privacy Act of 2012, its Implementing Rules and Regulations, and applicable issuances of the National Privacy Commission.

This policy explains how we collect, use, store, disclose, retain, and protect personal data obtained through our website, forms, tools, reports, programmes, communications, and other digital services.

1. SCOPE OF THIS POLICY

This policy applies to personal data processed through Talentlush’s current digital services, which may include:

• career decision-support tools, reports, and intake forms;
• talent and workforce intelligence resources;
• process, cost, organisational-effectiveness, and workplace-support services;
• learning, capability-development, and digital training content;
• free tools, downloadable resources, newsletters, and website interactions;
• service enquiries, partnerships, customer support, and business communications;
• analytics, security, and technical functions necessary to operate the website.

Talentlush provides structured information, decision support, practical frameworks, and digital services. It does not provide clinical diagnosis, psychotherapy, legal representation, or other regulated professional services unless expressly stated and delivered by a properly qualified professional under separate terms.

2. PERSONAL DATA WE COLLECT

The information collected depends on the service, form, tool, or communication you use.

2.1 Identity and contact information

• name;
• email address;
• telephone or mobile number;
• country, city, or general location;
• organisation, role, or professional affiliation, where relevant.

2.2 Career, work, and organisational information

• employment status, role, industry, and career stage;
• career concerns, preferences, goals, and decision factors;
• workplace, role-fit, workforce, process, capability, or organisational context;
• answers submitted through assessments, intake forms, and decision-support tools;
• documents or information you voluntarily provide for a requested service.

2.3 Information requested by selected tools or reports

Certain specialised tools or reports may request additional information, such as date and/or place of birth. When this occurs, the relevant form will explain why the information is requested, whether it is required or optional, how it will be used, and the lawful basis for processing. Where consent is required, we will request it separately before collection.

These details are not required for general website use and are not used to make decisions that produce legal or similarly significant effects.

2.4 Transaction and service information

• service selected, request history, and communications;
• payment status and transaction references, where applicable;
• records needed to provide, document, or support a requested service.

Payment-card information may be processed directly by an authorised payment provider and may not be stored by Talentlush.

2.5 Technical and usage information

• IP address;
• browser, device, operating system, and approximate location information;
• access dates and times;
• pages viewed, referral sources, clicks, and interaction data;
• cookie identifiers, security logs, and diagnostic information.

3. HOW WE COLLECT PERSONAL DATA

We may collect personal data:

• directly from you when you complete a form, use a tool, purchase or request a service, contact us, or subscribe;
• automatically through cookies, analytics, server logs, and similar technologies;
• from an organisation or authorised representative engaging Talentlush on your behalf;
• from publicly available or lawfully accessible sources when relevant to a requested service and permitted by law.

4. PURPOSES AND LAWFUL BASES FOR PROCESSING

We process personal data only for specified and legitimate purposes, including:

• providing requested tools, reports, programmes, resources, and services;
• responding to enquiries and providing customer support;
• personalising a requested output or decision-support process;
• administering payments, records, and service communications;
• maintaining website security, reliability, functionality, and fraud prevention;
• measuring and improving service quality, content, and user experience;
• sending updates or marketing communications where permitted and subject to opt-out rights;
• establishing, exercising, or defending legal claims;
• complying with legal, regulatory, accounting, and contractual obligations.

Depending on the circumstances, processing may be based on:

• Consent — where you have freely, specifically, and knowingly agreed to the processing;
• Contractual necessity — where processing is needed to provide a service you requested or to take steps before entering into an agreement;
• Legal obligation — where processing is required by applicable law;
• Legitimate interests — where processing is necessary for reasonable business, security, service-improvement, or administrative purposes and is not overridden by your rights;
• another lawful basis recognised under applicable Philippine data-protection law.

5. AUTOMATED PROCESSING AND DECISION SUPPORT

Talentlush does not use personal data to make solely automated decisions that produce legal or similarly significant effects. Digital tools may organise information, calculate user-provided inputs, or generate structured outputs, but these are intended to support reflection and human judgement rather than replace them.

6. DATA SHARING AND DISCLOSURE

We may disclose personal data only when necessary and subject to appropriate safeguards, including to:

• website-hosting, cloud-storage, form, email, analytics, security, payment, and technical-service providers;
• professional advisers, auditors, or contractors who require access for a legitimate service purpose and are bound by confidentiality or data-protection obligations;
• an organisation or authorised representative connected with a service requested by or for you;
• government authorities, regulators, courts, or law-enforcement agencies when disclosure is required or permitted by law;
• a successor or authorised party in connection with a lawful restructuring, transfer, or protection of business assets, subject to applicable safeguards.

Talentlush does not sell personal data. We do not disclose personal information to third parties for unrelated commercial use.

7. CROSS-BORDER PROCESSING

Some technology and service providers may process or store data outside the Philippines. Where cross-border processing occurs, we take reasonable steps to use providers and arrangements that support appropriate confidentiality, security, and data-protection safeguards.

8. DISCONTINUED FEATURES AND LEGACY DATA

Talentlush no longer offers its former job-posting, résumé-upload, or related employment-platform features.

Personal data collected through those former features is not used for current recruitment, candidate matching, placement, or job-posting activities. Any remaining legacy records are retained only where reasonably necessary for legal compliance, recordkeeping, security, dispute resolution, or the completion of an outstanding user request. Records no longer required are securely deleted, anonymised, or otherwise disposed of in accordance with applicable requirements.

9. DATA RETENTION

Personal data is retained only for as long as reasonably necessary for the purpose for which it was collected, including service delivery, recordkeeping, security, dispute resolution, and compliance with legal or contractual obligations.

Retention periods may vary according to the type of data and service. When data is no longer required, it is securely deleted, anonymised, or otherwise disposed of in accordance with applicable requirements and reasonable business practices.

10. SECURITY MEASURES

We implement reasonable and appropriate organisational, physical, and technical safeguards designed to protect personal data against accidental or unlawful destruction, alteration, loss, unauthorised disclosure, misuse, or access. Measures may include:

• access controls and restricted permissions;
• secure hosting and transmission methods where applicable;
• authentication, password, and account-security controls;
• confidentiality obligations and internal handling procedures;
• data minimisation, backup, monitoring, and incident-response practices.

No website or electronic system can guarantee absolute security. Users should also take reasonable steps to protect their accounts, devices, and communications.

11. COOKIES AND ANALYTICS

Talentlush may use essential cookies and similar technologies to operate, secure, and improve the website. Optional analytics or marketing technologies will be handled in accordance with applicable consent and preference requirements.

Where available, you may manage non-essential cookie preferences through the website’s cookie controls or your browser settings. Disabling certain technologies may affect site functionality.

12. YOUR RIGHTS AS A DATA SUBJECT

Subject to the conditions and limitations provided by law, you may have the right to:

• be informed about the collection and processing of your personal data;
• object to certain processing activities;
• access personal data held about you;
• request correction of inaccurate or incomplete data;
• request erasure, blocking, or restriction of processing where legally available;
• withdraw consent where processing is based on consent;
• obtain data portability where applicable;
• claim compensation for damage caused by unlawful processing, where legally established;
• file a complaint with the National Privacy Commission.

We may request reasonable information to verify your identity and authority before acting on a request. Some requests may be limited where retention or processing is required by law, necessary for legal claims, or otherwise permitted under the Data Privacy Act.

13. CONSENT AND WITHDRAWAL

Where consent is the lawful basis for processing, you may withdraw it at any time by contacting us. Withdrawal does not affect the lawfulness of processing completed before withdrawal and may affect our ability to provide a service that depends on the relevant data.

Submitting a form does not constitute unlimited consent for unrelated uses. Form-specific privacy notices or consent statements may apply to particular services.

14. INFORMATION RELATING TO MINORS

Unless a service expressly states otherwise, Talentlush services are intended for adults. We do not knowingly collect personal data from a minor without an appropriate lawful basis and, where required, valid consent from a parent or legal guardian.

15. THIRD-PARTY SERVICES AND LINKS

The website may contain links to or integrations with third-party platforms. Their privacy practices are governed by their own policies. Talentlush is not responsible for the privacy practices of independent third parties, although we seek to use reputable service providers where practical.

16. PERSONAL DATA BREACHES

Talentlush maintains procedures for assessing and responding to suspected personal data breaches. Where notification is required by applicable law or National Privacy Commission rules, we will notify the appropriate authority and affected data subjects within the applicable period based on the circumstances and available information.

17. POLICY UPDATES

We may update this policy to reflect changes in our services, processing activities, technology, or legal obligations. The revised policy will be posted on this page with an updated effective date.

Where a change materially affects how personal data is processed, we will provide additional notice or seek consent when required.

18. CONTACT INFORMATION

For privacy questions, requests, objections, or complaints, contact:

Talentlush Information Technology Services
Using the Talentlush® brand

Privacy contact: services@talentlush.com
Telephone: +63 918 762 3335
Website: https://talentlush.com/
Privacy Policy: https://talentlush.com/data-privacy-policy/