Privacy Policy

1. General provisions

Talentgram App. care not only about the convenience of our Clients and opportunities provided by our services, but also about protecting the Privacy of the Clients. We invest resources so that our Clients would feel safe and take care of protecting Clients’ data in our daily operations.

The purpose of this Privacy Policy is to explain how we protect Clients’ privacy and to help Clients understand how their personal data are processed and what are our and Clients’ rights and responsibility in the course of processing their data.

In processing personal data, we observe the General Data Protection Regulation, as well as other laws and regulations and binding instructions applicable in the European Union.

This Privacy Policy applies to our relations with Clients, including any existing Client, buyer, applicant or any other person using or wishing to use any of our services, or addressing us with any request or claim, submitting any kind of document, visiting our home page or contacting us through remote means of communications, including post, e-mail or phone.

Key Terms:

  • Personal data: Any information related to an identified or identifiable natural person, for example, given name, surname, contact details, etc.
  • Anonymized data: Information that is not personal data and cannot identify a natural person.
  • Processing: Any operation performed on personal data, such as collection, organisation, storage, etc.

2. How do we obtain personal data and what is the basis for data processing?

  • The Client has provided us with personal data when they use our services, submit applications, or request information.
  • Personal data created using our service, e.g., by visiting or using our website.
  • Personal data received from legal entities that submit data of employees and beneficiaries.
  • Personal data collected from public databases and registers in the course of implementing legal requirements such as anti-money laundering checks.

Data is collected from the following sources:

  • United Nations Security Council sanctions lists
  • European Union financial sanctions lists
  • Office of Foreign Assets Control (U.S. Treasury Department)
  • IDenfy.com for politically exposed person screening
  • Public sources such as company registers and sanctions databases

Data subjects have the right to refuse to provide their personal data. However, without the requested data, we may not be able to provide our services.


3. What personal data do we collect?

Types of personal data include:

  • Clients (natural persons): First name, last name, contact details, citizenship, address, employment status, signature, bank statement, and tax identification numbers.
  • Directors and Owners of legal persons: Full name, email, date of birth, tax residency, identification numbers, and politically exposed person status.
  • Ultimate Benef, address, politically exposed person status, ownership and control structure.
  • Employees of a legal person: Name, surname, contact details, position, signature, content of communication.
  • Personal data related to services: Payment and transaction data, contact details, information collected through forms, and submitted data from clients or legal entities.
  • Data from public databases and registers: Sanctions applicability, political exposure, validity of identity documents, and business ownership structure.

We do not deliberately collect or process identifiable information from persons younger than the age limit set by regulatory laws.

4. How do we use personal data?

We process personal data for the following purposes:

  • Conclusion and execution of contracts: Offering services, ensuring transactions, and performance of related services.
  • Resolution of submitted questions: Examining and resolving submitted questions or complaints.
  • Fulfillment of regulatory obligations: Compliance with anti-money laundering, terrorist financing prevention, and legal duties.
  • Provision of offers: Providing information or opinions on services based on Client consent or legitimate interests.
  • Accounting and tax management: Managing accounting records, taxes, and settlements.
  • Administration of settlements: Managing financial activities and settlements.
  • Statistics and analysis: Evaluating and improving services, systems, and operations.
  • Organizational management: Ensuring traceability, control, and improvement of internal processes.

We only process personal data to the extent necessary for the intended purpose while respecting privacy.


5. How we protect personal data

We ensure the confidentiality of personal data by taking appropriate security measures. These measures include protecting personnel, IT infrastructure, and information resources to prevent unauthorized access.

6. To whom we can provide personal data

Personal data may be shared with:

  • Cooperation partners: Partners providing delivery, security, accounting, or IT services.
  • Supervisory and governmental authorities: Authorities requiring data to comply with legal obligations.
  • Databases and registers: Providing verification data such as name, surname, date of birth, and identification number.
  • Other service providers: Attorneys, lawyers, and consultants assisting in our operations.
  • Business transfers: In cases of mergers, acquisitions, or sales of company assets.

Anonymized data may also be processed and transferred to other parties for lawful purposes.


7. How long do we store data

We retain personal data only as long as necessary to achieve the purposes outlined in this Privacy Policy, unless otherwise required by law. For example:

  • Data related to purchases of services is retained for 8 years.
  • Anonymized data has no specific retention limit.
  • Data necessary for legal obligations or dispute resolution may be stored longer (e.g., 10 years for invoices).

Clients are encouraged to provide updated and accurate information to ensure compliance.


8. What are Client’s rights and responsibilities?

Clients have the right to:

  • Access their data, request corrections, deletions, or restrictions of processing.
  • Object to data processing, including data used for legitimate interests.
  • Request data portability.
  • Revoke consent at any time, though previous processing remains unaffected.
  • Lodge complaints with the data protection supervisory authority in Lithuania: State Data Protection Inspectorate, L. Sapiegos street 17, Vilnius, LT-10312.

Clients are responsible for:

  • Informing us about changes to their personal data.
  • Providing identification when requesting access or modifications to their data.
  • Becoming familiar with this Privacy Policy and informing related parties.

9. How can you find out about changes in this Privacy Policy?

We may update this Privacy Policy periodically. Clients are encouraged to review the latest version on our website. Changes will also be communicated via notices on our website.


10. How to contact us

If you have questions regarding this Privacy Policy or personal data processing, please contact us using the details provided at the beginning of this document.