Welcome to Countertalk. We value the trust you place in us and we do not take it for granted.

Countertalk Ltd. ("we", "us", "our") is committed to protecting and respecting your privacy. This policy explains how we collect, use, and store your personal data when you use our website, apply for jobs, or engage with our community.

For the purpose of the UK General Data Protection Regulation (UK GDPR), Countertalk Ltd. is the Data Controller.

• Registered office: 505 Pinner Road, Harrow, Middlesex, England, HA2 6EH
• Company number: 12085098
• Contact: service@countertalk.co.uk

1. Information We Collect

We collect different types of data depending on how you interact with us.

1.1 Information You Give Us

• Job Seekers: When you create a profile or apply for a job, we collect your Name (mandatory), Email Address (mandatory), and Telephone Number (optional). We also process your CV/Resume, work history, and any other information you choose to include in your profile or application.
• Employers: We collect your name, business email, company details, and billing address.
• Event Attendees: If you book tickets for a Countertalk event, we may collect dietary requirements or access needs. (This is classified as Special Category Data, which we treat with extra care).
• Communications: When you contact us (e.g., to report a poor working environment), we collect the details of your correspondence.

1.2 Information We Collect Automatically

• Technical Data: Internet Protocol (IP) address, browser type and version, time zone setting, and operating system.
• Usage Data: How you use our website, which pages you visit, and how you interact with job posts (via Cookies).

1.3 Payment Information

All financial transactions are processed securely via Stripe. We do not store or have access to your full debit/credit card details. We only retain limited information (such as the last 4 digits of a card) to verify payments and handle refunds if necessary.

2. How and Why We Use Your Data

Under UK GDPR, we must have a "lawful basis" for using your data. We rely on the following:

Purpose

Lawful Basis

To provide our services: Creating your account, posting jobs, and processing applications.

Contract: We need this data to fulfil our agreement with you.

To vet Employers: Reviewing job posts and company culture to ensure they meet Countertalk standards.

Legitimate Interest: It is vital for our community's safety and our brand ethos to vet employers.

To send service updates: notifying you of application status or changes to terms.

Contract / Legal Obligation

To send marketing: Newsletters, event invites, or promotional offers.

Consent: You must actively opt-in to receive these. You can unsubscribe at any time.

To improve our website: Using analytics to understand user behaviour.

Legitimate Interest: Helping us improve the platform experience.

To process payments: Handling billing for job packages.

Contract

To comply with the law: Keeping financial records for HMRC.

Legal Obligation

3. Sharing Your Data

We do not sell your personal data. We only share it in the following specific circumstances:

• Employers: If you are a Job Seeker, your profile and application data will be available to the Employer you are applying to.
• Service Providers: We use trusted third parties to help run our business. They act as "Data Processors" and only use your data under our instructions:
  • Stripe: Payment processing.
  • Mailchimp: Email marketing and newsletters.
  • Google Analytics: Website performance tracking.
• Legal Requirements: We may disclose your data if required by law, or to protect the rights, property, or safety of Countertalk, our users, or others (e.g., investigating reports of abuse or fraud).

4. International Data Transfers

Some of our service providers (like Mailchimp or Google) are based outside the UK. Whenever we transfer your personal data out of the UK, we ensure a similar degree of protection is afforded to it by ensuring at least one of the following safeguards is implemented:

• We will only transfer your personal data to countries that have been deemed to provide an adequate level of protection for personal data by the UK Government (the "Data Bridge").
• Where we use providers based in the US or other countries, we may use specific contracts approved for use in the UK which give personal data the same protection it has in the UK (Standard Contractual Clauses / IDTA).

5. Data Retention

We will only retain your personal data for as long as strictly necessary to fulfil the purposes we collected it for.

• Job Seeker Profiles: Retained while your account is active. You may delete your account at any time.
• Application Data: Kept for a reasonable period to allow employers to manage the hiring process, after which it is anonymised or deleted.
• Financial Data: We are legally required to keep basic information about our customers (including Contact, Identity, Financial and Transaction Data) for 6 years after they cease being customers for tax purposes.
• Marketing Data: If you unsubscribe, we will stop sending emails immediately, but we may keep your email on a "suppression list" to ensure we don't accidentally contact you again.

6. Security

We use best-in-class security systems to protect your information.

• Encryption: Communications are sent over SSL/TLS connections.
• Access Control: User data is logically segregated, and sensitive data (like passwords) is stored in encrypted formats.

However, no internet transmission is 100% secure. You are responsible for keeping your login details confidential.

7. Your Legal Rights

Under the UK GDPR, you have specific rights regarding your personal data:

1. The Right to Access: You can request a copy of the personal data we hold about you.
2. The Right to Rectification: You can ask us to correct any data that is inaccurate or incomplete.
3. The Right to Erasure ("Right to be Forgotten"): You can ask us to delete your data where there is no good reason for us continuing to process it.
4. The Right to Restrict Processing: You can ask us to suspend processing your data in certain scenarios.
5. The Right to Data Portability: You can ask for your data to be transferred to you or a third party.
6. The Right to Object: You can object to us processing your data where we rely on "Legitimate Interest" (e.g., direct marketing).
7. Rights regarding Automated Decision Making: We do not currently use automated decision-making or profiling that has legal effects on you.

To exercise any of these rights, please contact us at service@countertalk.co.uk. We aim to respond to all legitimate requests within one month.

8. Cookies Policy

We use cookies to help our site run smoothly and to understand how it’s being used.

• Essential Cookies: These are necessary for the website to function. We use them to keep you logged in and to process secure payments via Stripe.
• Analytics Cookies: We use tools like Google Analytics to see how many people visit our site and which pages are most popular. This helps us improve the user experience.

You can choose to block cookies through your browser settings at any time. However, please note that blocking "Essential Cookies" may stop parts of our site (like job applications or payments) from working correctly.

9. Changes to This Policy

We may update this privacy policy from time to time. Any material changes will be notified to you by email or a notice on our website.

10. Contact Us

If you have any questions about this privacy policy or our privacy practices, please contact us:

• Email: service@countertalk.co.uk
• Address: Countertalk Ltd, 505 Pinner Road, Harrow, Middlesex, England, HA2 6EH.

You also have the right to make a complaint at any time to the Information Commissioner's Office (ICO), the UK supervisory authority for data protection issues (www.ico.org.uk). We would, however, appreciate the chance to deal with your concerns before you approach the ICO, so please contact us in the first instance.