Privacy Policy

1. Who We Are

Colibrí Talent Solutions Ltd, registered in the United Kingdom (Company No. 17391952), operates this website and is the contracting party for our technology talent placement services. Colibrí is the data controller for personal data collected through this website and our placement activities.

Sourcing, assessment, and delivery work in Latin America is carried out on our behalf by Emerald Talent Solutions SAS, our Colombia-registered delivery partner (NIT 901843923), acting under our instructions and a data processing agreement.

For data protection enquiries, contact us at: info@colibritalentsolutions.com

2. What Data We Collect

Client enquiries

When you submit a client enquiry via our website, we collect: first name, last name, job title, company name, email address, telephone number (optional), and the content of your message.

Candidate registration

When you register as a candidate, we collect: first name, last name, email address, LinkedIn profile URL, primary technology specialism, years of experience, and current location.

Website usage data

We collect anonymised data about how visitors use our website through Google Analytics 4 and Microsoft Clarity. This includes pages visited, time on site, device type, and approximate location. This data does not identify you personally.

Cookies

We use cookies to operate our website and analytics tools. See our Cookie Policy for full details.

3. How We Use Your Data

We use the personal data we collect for the following purposes:

• To respond to client enquiries and progress placement conversations
• To assess candidate profiles and match candidates to relevant technology roles
• To manage the Colibrí Assure evaluation process and produce Candidate Assessment Profiles
• To deliver Colibrí Sky, our post-placement consultant engagement initiative, to placed consultants
• To manage our client and candidate relationships through HubSpot CRM
• To comply with our legal and contractual obligations
• To improve our website and services through anonymised analytics

4. Legal Basis for Processing

We process your personal data on the following legal bases:

• Consent: where you have provided explicit consent via our website forms, including GDPR consent checkboxes
• Legitimate interests: where processing is necessary for our legitimate business interests in providing technology talent placement services, provided those interests are not overridden by your rights
• Contract: where processing is necessary to perform a contract with you or to take steps at your request before entering into a contract
• Legal obligation: where processing is necessary to comply with a legal obligation

5. How We Store and Protect Your Data

Your personal data is stored in the following systems, all of which operate appropriate technical and organisational security measures:

• HubSpot CRM: client enquiry and candidate registration data. HubSpot is GDPR-compliant and a Data Processing Agreement is in place.
• Microsoft SharePoint: operational candidate and placement records, held within Colibrí's Microsoft 365 tenancy, protected by Microsoft's enterprise security controls.
• Microsoft 365: email communications and document storage, protected by two-factor authentication and Microsoft's security infrastructure.

Colibrí operates in alignment with ISO 27001 information security principles. Access to personal data is restricted to authorised personnel involved in the placement process.

6. How Long We Keep Your Data

• Client enquiry data: retained for 24 months from the date of last contact, or for the duration of an active client relationship
• Candidate data: retained for 24 months from the date of registration or last contact, unless you request earlier deletion
• Placed consultant data: retained for the duration of the Colibrí Sky initiative and for 24 months thereafter
• Website analytics data: retained in accordance with Google Analytics and Microsoft Clarity data retention settings (maximum 26 months)

You may request deletion of your data at any time by contacting us at info@colibritalentsolutions.com.

7. Sharing Your Data

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

• With our delivery partner: Emerald Talent Solutions SAS (Colombia), which carries out candidate sourcing, assessment, and placement delivery on our behalf, under a data processing agreement
• With prospective employers / clients: candidate data is shared with client organisations in the form of Candidate Assessment Profiles, only with the candidate's knowledge and as part of the placement process
• With technology service providers: HubSpot (CRM), Microsoft (365 and SharePoint), Google (Analytics), and Microsoft (Clarity) — all subject to appropriate data processing agreements
• Where legally required: in response to lawful requests from public authorities or to comply with applicable law

8. International Data Transfers

Colibrí Talent Solutions Ltd is based in the United Kingdom and works with Emerald Talent Solutions SAS, our Colombia-based delivery partner, to source and assess candidates in Latin America on our behalf. We also process data for clients and candidates in the US. Data transfers between the UK, Colombia, the EU, and the US are conducted in compliance with applicable transfer mechanisms, including Standard Contractual Clauses and the UK's International Data Transfer Agreement, where required under UK GDPR and EU GDPR.

HubSpot and Microsoft operate data centres in multiple jurisdictions. Their data transfer mechanisms are documented in their respective Data Processing Agreements, available on their websites.

9. Your Rights

Depending on your location, you have the following rights regarding your personal data:

• Right of access: to request a copy of the personal data we hold about you
• Right to rectification: to request correction of inaccurate or incomplete data
• Right to erasure: to request deletion of your personal data, subject to our legal obligations
• Right to restrict processing: to request that we limit how we use your data
• Right to data portability: to receive your data in a structured, commonly used format
• Right to object: to object to processing based on legitimate interests
• Right to withdraw consent: where processing is based on consent, to withdraw that consent at any time
• Habeas Data (Colombia): the right to know, update, rectify, and delete personal data held about you under Colombian law

To exercise any of these rights, contact us at info@colibritalentsolutions.com. We will respond within 30 days.

10. Complaints

If you are based in the UK and believe we have not handled your data appropriately, you have the right to lodge a complaint with the Information Commissioner's Office (ICO) at ico.org.uk.

If you are based in the EU, you may contact your local supervisory authority.

If you are based in Colombia, you may contact the Superintendencia de Industria y Comercio (SIC) at sic.gov.co.

We would always appreciate the opportunity to address your concern directly before you escalate to a regulatory body.

11. Changes to This Policy

We may update this Privacy Policy from time to time to reflect changes in our practices or applicable law. The date of the most recent update is shown at the top of this page. We encourage you to review this policy periodically.

12. Contact Us

For any questions about this Privacy Policy or how we handle your personal data:

Colibrí Talent Solutions Ltd
United Kingdom  ·  Company No. 17391952
Delivered in partnership with Emerald Talent Solutions SAS  ·  Medellín, Colombia  ·  NIT 901843923
info@colibritalentsolutions.com
emeraldtalentsolutions.net