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SmileTech s.r.o. · Talentgrator

PRIVACY POLICY

Effective Date: 21 October 2026

1. INTRODUCTION

This Privacy Policy explains how Limited Liability Company "SmileTech s.r.o." ("we", "us", "our", "Talentgrator") collects, uses, discloses, stores, and otherwise processes personal data when you interact with or access our recruitment, professional training and educational services, or our website and related online platforms, in accordance with the EU General Data Protection Regulation ("GDPR") and other applicable data protection laws.

SmileTech s.r.o. is the controller of personal data processed for the purposes described in this Privacy Policy. Our contact details are set out in Section 14.

For the purposes of this Privacy Policy, the term "Services" refers to Talentgrator's activities in connection with:

Our Services are designed to connect job seekers and independent contractors with employers and business clients seeking talent, primarily within the technology and related sectors.

By interacting with our Services, including by visiting our website, submitting a CV or application, completing a questionnaire provided by us (whether through our website or by email), responding to job postings, or otherwise communicating with us, you acknowledge that Talentgrator will process your personal data for the purposes described in this Privacy Policy, depending on the Services you use in accordance with this Privacy Policy and applicable data protection laws.

We will not use or share your information except as described in this Privacy Policy. We are committed to protecting the privacy and security of all personal data processed as part of our business activities.

Depending on your interaction with us and the nature of processing, we rely on one or more lawful bases under GDPR, including performance of pre-contractual steps at your request, compliance with legal obligations, legitimate interests, or your consent where required.

2. HOW WE COLLECT YOUR PERSONAL DATA

We may collect and process your personal data in the course of providing our recruitment,talent acquisition, professional training and educational services. We collect personal data from the following sources:

(1) Directly from you

Including when you:

(2) Automatically, when you use our Site or digital services

Including through:

(For more information, please see our Cookies Policy.)

(3) From third-party sources

Including:

(4) From our clients or business partners

Where:

We will process personal data obtained from third-party or public sources only in accordance with this Privacy Policy and applicable data protection laws. Where required by law, we will inform you within the statutory time frame after receiving your data.

3. PERSONAL DATA WE COLLECT AND PROCESS

We collect and process personal data only to the extent necessary for the performance of our recruitment,talent acquisition, professional training and educational services, compliance with legal obligations, and the legitimate interests pursued by Talentgrator or our clients, as described in this Privacy Policy.

We may collect the following categories of personal data, depending on your interaction with us:

(1) Identification and Contact Details

Information that allows us to identify and contact you, such as:

(2) Professional and Career Information

Information contained in your CV, résumé, or professional profile, including:

(3) Education and Training

(4) Recruitment and Assessment Data

(5) Financial and Contractual Information

(6) Online and Technical Information

(7) Visual and Communication Data

(8) Data Obtained from Third Parties or Public Sources

We may also receive personal data about you from:

(9) Professional Training and Educational Services Data

Where you apply for, purchase or participate in a course, we process the following data, as applicable:

Special Categories of Personal Data

Talentgrator does not intentionally collect or process sensitive or special categories of personal data such as:

Voluntary disclosure alone does not authorise processing. We process special categories of personal data only where both a lawful basis under Article 6 GDPR and an applicable condition under Article 9(2) GDPR are satisfied. Unnecessary special-category data is deleted or redacted. Data relating to criminal convictions and offences is processed only where authorised under Article 10 GDPR and applicable law.

We rely on the accuracy of the information you provide to us. You are encouraged to update your personal data if it changes or becomes outdated, particularly regarding your contact details, employment history, or professional qualifications.

4. PURPOSES OF PROCESSING PERSONAL DATA

We process personal data solely for specified, explicit and legitimate purposes related to the provision of our recruitment, talent acquisition, placement, professional training and educational services, and the operation of our Site and related platforms. We will not use your personal data for any purpose that is incompatible with those described in this Privacy Policy.

(1) Recruitment and Placement Activities

We process your personal data in order to:

(2) Service Management and Operations

We use personal data to:

(3) Legal and Regulatory Compliance

We may process your personal data to:

(4) Marketing and Business Development

We send electronic promotional communications with your prior consent, except where applicable law permits us to promote our own similar services to existing customers. In that case, we rely on our legitimate interest and provide a clear, free opt-out when collecting contact details and in every message. You may withdraw consent or object to direct marketing at any time, including by contacting GDPR@talentgrator.com. We then stop processing your data for that purpose. Recruitment contacts are not automatically subscribed to course promotions.

(5) Website Operation and Analytics

When you visit our Site, we may process certain technical and usage data (such as IP address, browser type, device identifiers, date and time of access, and cookies) for the purposes of:

(For more information, please refer to our Cookies Policy.)

(6) Professional Training and Educational Services

We process course-related personal data to:

Application information, including job-search status, is used to assess course suitability and learning needs. Course participation does not automatically result in inclusion in our recruitment database or disclosure to potential employers.

With your separate consent, we may use your name, contact details, professional information provided in your course application and course results, including your final project, to recommend you to partner companies seeking candidates and contact you about relevant job opportunities. Consent is optional and does not affect admission, course participation or access. You may withdraw it at any time by contacting GDPR@talentgrator.com, without affecting the lawfulness of processing before withdrawal. Course marketing is governed separately by Section 4(4).

(7) Lecture Recordings

Only the instructor’s lecture and presentation are recorded. Participants’ images, voices, displayed names, chat messages and contributions are excluded from recordings. Pair work, discussions, project review sessions and final project defences are not recorded. Feedback on participants’ projects is documented in writing and provided to the participants concerned.

Lecture recordings are available through the LMS to enrolled participants of the relevant course during the course and for one month after the final project defence. Authorised personnel and service providers may access recordings where necessary to administer and deliver the course. Recordings are not sold separately.

5. LAWFUL BASES FOR PROCESSING

Talentgrator will process personal data only where there is a valid legal basis under applicable data protection laws.

Depending on the circumstances, we rely on one or more of the following legal bases:

For course applications, we rely on Article 6(1)(b) GDPR to take steps at your request before entering into a course contract, including reviewing your application and communicating an admission decision. The same basis applies to processing necessary for enrolment, payment administration, LMS access, teaching, assessments, support and issuing the promised completion certificate.

Article 6(1)(c) GDPR applies to statutory accounting, tax and consumer protection obligations. Article 6(1)(f) GDPR applies to necessary and proportionate processing for platform security, fraud prevention and the establishment, exercise or defence of legal claims.

Fields required to review an application or provide the purchased course are identified in the relevant form. If necessary information is not provided, we may be unable to assess the application or deliver the course. Optional information is identified separately.

Submitting an application, accepting the course terms or acknowledging this Privacy Policy does not constitute consent to optional marketing.

6. PERSONAL DATA SHARING

We do not sell your personal data. However, in the course of providing our Services, we may share your personal data with certain third parties, always in accordance with applicable data protection laws and subject to appropriate safeguards. We ensure that any disclosure of personal data is limited to what is necessary for the relevant purpose and that recipients are bound by confidentiality and data protection obligations.

(1) Clients and Potential Employers

We share candidates' personal data with our clients (potential employers, contracting partners, or business customers) for recruitment and placement purposes, including to:

Such sharing occurs only where you have expressed interest in or applied for a particular position, or where the data transfer is necessary to provide our recruitment services to you, or where you have separately consented to graduate recommendations under Section 4(6). We require all our clients to process your personal data strictly for recruitment-related purposes and to ensure an equivalent level of data protection.

For graduate recommendations, we share only the course application profile and course results, including the final project, covered by your consent. Recipients are partner companies seeking candidates for employment or contracting opportunities. We identify the intended recipient companies before obtaining your consent to disclosure to them. These companies act as independent controllers for their recruitment processing.

(2) Service Providers and Business Partners

We may engage trusted third-party service providers that support our business operations, such as:

Service providers acting as data processors process personal data on our behalf under agreements meeting Article 28 GDPR. Where a third party acts as an independent controller, including certain payment service providers, it processes personal data under its own responsibility and applicable privacy notice.

(3) Affiliates

We may share personal data with affiliated entities where necessary to provide, manage, or improve recruitment services, including administrative and operational purposes. All such data transfers are conducted in accordance with GDPR and other applicable data protection laws, with appropriate safeguards to ensure the security and confidentiality of personal data.

(4) Public Sources and Candidate Referrals

In some cases, information about your professional background (e.g., on LinkedIn or public CV databases) may be visible to or accessed by our clients as part of the recruitment process. Additionally, when your profile is shared based on a referral (for example, by a colleague, acquaintance, or another candidate), we will notify you accordingly, as required by applicable law.

(5) Legal and Regulatory Disclosures

We may disclose personal data where required to do so by law, court order, or regulatory authority, or to establish, exercise, or defend our legal rights. We may also share data to prevent or investigate suspected fraud, security incidents, or other unlawful activity.

(6) Corporate Transactions

In the event of a merger, acquisition, reorganization, or sale of Talentgrator or its assets, personal data may be transferred to the acquiring or successor entity, subject to continued protection consistent with this Privacy Policy.

(7) Instructors, Course Methodologists and Other Participants

Instructors and course methodologists receive application information, assignments, projects and assessment records only where necessary for their course responsibilities. Other participants may see names, Telegram identifiers and information shared in course discussions and group activities. Billing details and private support correspondence are not disclosed to other participants. Projects and related feedback may be discussed during group course activities. Individual written feedback is provided to the participant concerned.

Telegram is used for course communications. Your profile information and messages may be visible to other members according to the communication format and your Telegram settings. Telegram also processes personal data under its own privacy policy. You should not post payment information or sensitive personal data in the course channel or group.

7. INTERNATIONAL TRANSFER

As Talentgrator operates globally, your personal data may be transferred to and processed in countries outside the European Economic Area ("EEA"). Some of these countries may not offer the same level of data protection as within the EEA.

Whenever such transfers occur, we ensure they are carried out in compliance with applicable data protection laws, including GDPR. Where required, we implement appropriate safeguards such as:

We take reasonable legal, technical, and organizational measures to ensure that your personal data remains protected and handled securely during and after any international transfer.

For further information about applicable safeguards, including how to obtain a copy of them, you may contact us at GDPR@talentgrator.com

8. SECURITY OF PERSONAL DATA

Talentgrator applies appropriate technical, organizational, and administrative measures to protect personal data against unauthorized access, disclosure, alteration, or destruction.

Access to personal data is restricted to authorized personnel, clients, and service providers who need such access for legitimate business purposes and are bound by confidentiality and data protection obligations.

While we take reasonable steps to ensure the ongoing security and integrity of personal data, no system or transmission over the internet can be guaranteed to be fully secure. We continuously review and enhance our security measures in line with applicable legal requirements and industry best practices.

9. RETENTION

Talentgrator retains personal data only for as long as necessary to fulfill the purposes for which it was collected, including providing recruitment, professional training and educational services, complying with legal obligations, resolving disputes, and enforcing agreements.

Where we process candidate data based on consent (for example, to include a candidate in our talent pool or consider them for future opportunities), we retain such data until the consent is withdrawn or it is no longer necessary for the stated purpose.

Where you consent to graduate recommendations under Section 4(6), we may retain the relevant course application profile, course results and final project beyond the course access period, only for as long as necessary for those recommendations and while your consent remains valid. If you withdraw consent, we stop the related use and further disclosures and delete data retained solely for that purpose, except where retention is necessary for a legal obligation or legal claim. Withdrawal does not affect the lawfulness of disclosures made before withdrawal.

Participants have access to their LMS accounts, assignments and feedback during the course and for one month after the final project defence. They may download their own assignments and feedback before access closes. Personal data associated with accounts and learning activities, including assessments, is retained only for as long as necessary to provide the purchased access, complete course administration and resolve related enquiries. Further retention is limited to applicable legal obligations or the establishment, exercise or defence of legal claims. An account used for another purchased course may remain active for that course’s access period.

Application data relating to individuals who do not enrol is retained until the relevant admission process closes and related enquiries are resolved, unless further retention is necessary for a specific legal claim or based on separate consent for a specified purpose.

Participants’ access to lecture recordings ends one month after the final project defence. Recordings containing instructors’ personal data are retained for as long as necessary to deliver the relevant courses and carry out the recording uses agreed with the instructor, subject to applicable data protection law. They are then deleted or irreversibly anonymised, unless continued retention is necessary for a legal obligation or legal claim.

Data necessary to issue completion certificates is retained until issuance. If certificate replacement or verification services are offered, only the minimum certificate records necessary for those services are retained for as long as the services remain available, as communicated to participants. A certificate’s indefinite validity does not require indefinite retention of assignments, assessments or recordings.

Payment and accounting records will be retained for the periods required by applicable Czech law.

Records required for legal claims are retained for the applicable limitation period and, where a dispute arises, until its final resolution. Evidence of consent and withdrawal is retained only for as long as necessary to demonstrate compliance and address related legal claims. Data retained solely for legal obligations or claims is subject to restricted access and is not used for other purposes.

After the applicable retention period expires, or once personal data is no longer required, it will be securely deleted or irreversibly anonymized.

Course-related correspondence is retained until the relevant course and related enquiries are completed. Technical and security logs are retained for the period necessary to administer access and investigate security incidents. Further retention is limited to applicable legal obligations or legal claims.

10. YOUR PRIVACY RIGHTS AND CHOICES

We respect the privacy rights of all individuals whose personal data we process. Where our processing is subject to GDPR, you have the following rights, subject to the conditions and exceptions set out in GDPR, irrespective of your nationality or place of residence:

We primarily adhere to the principles of the EU General Data Protection Regulation (GDPR). However, If you are located in jurisdictions with local data protection frameworks (such as the United Kingdom, Switzerland, certain U.S. states, or other regions), you may have additional or similar rights under those laws. We will respond to such requests in accordance with the applicable legal requirements and our obligations under GDPR.

To exercise any of your rights or to submit a privacy-related inquiry, please contact us at GDPR@talentgrator.com. We may need to verify your identity before processing your request and will respond within the timeframes required by applicable law.

For information regarding the use of cookies and similar technologies, please refer to our separate Cookies Policy available on our website.

11. PROCESSING OF PERSONAL DATA OF MINORS

Our Services, including professional training courses, are intended for individuals aged 18 or over. We do not knowingly collect or process personal data of individuals under the age of 18.

If we learn that an individual under 18 has registered for our Services, we close the registration and delete unnecessary personal data, subject to applicable legal retention obligations.

12. COOKIES AND SIMILAR TECHNOLOGIES

Our website uses cookies and similar technologies to improve its functionality, analyze traffic, and enhance your user experience.

For detailed information about the types of cookies we use, their purposes, storage periods, and how you can manage or disable them, please refer to our separate Cookies Policy available on our website.

Strictly necessary cookies may be used without consent where permitted by law. Non-essential cookies and similar technologies are used only after obtaining the user's prior consent, where required. Users may refuse or withdraw such consent at any time through the cookie preferences tool available on our Site.

13. LINKS TO OTHER WEBSITES

Our website may contain links to third-party websites or platforms that are not operated or controlled by us. Please note that this Privacy Policy applies only to our own website and services.

We are not responsible for the content, security, or privacy practices of such external websites. When you follow a link to another website, you should review the privacy policy of that website to understand how your personal data is collected and used.

14. CONTACT INFORMATION

For questions about this Privacy Policy or our processing of personal data, to exercise your data protection rights or to withdraw consent to personal data processing, please contact us at:

Email: GDPR@talentgrator.com

Mailing address: SmileTech s.r.o., Na Hřebenech II 1718/10, 140 00 Prague 4, Czech Republic

We will respond to data protection requests within the time limits required by applicable law.

For course administration, course-related complaints, withdrawal from a course contract or refund requests, please contact courses@talentgrator.com.

If you believe your data protection rights have been infringed, you also have the right to lodge a complaint with the Office for Personal Data Protection (www.uoou.cz) or with your local data protection authority.

15. CHANGES TO THIS PRIVACY POLICY

We may update this Privacy Policy from time to time to reflect changes in our business operations, legal requirements, or data protection practices.

The most current version of this Policy will always be available on our website, and the date of the latest revision will be indicated at the top of the document.

If we make any material changes, we will take appropriate steps to inform you, such as by posting a prominent notice on our website or by other means as required by applicable law.

Material changes affecting the processing of personal data will be communicated to affected individuals where required by applicable law. Where a new processing purpose requires consent, such consent will be obtained before the processing begins.