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Talent2

Version 1.1

Personal Data Processing Policy (Privacy Policy)

Version 1.1 — Effective from October 19, 2026

This Policy is issued in compliance with Colombian Statutory Law 1581 of 2012, Decree 1377 of 2013 (compiled in Decree 1074 of 2015) and related regulations. For data subjects located outside Colombia, Regulation (EU) 2016/679 (GDPR) and other applicable local data protection laws also apply where relevant.

1. Data controller

  • Legal name: Talent2.AI Inc, a corporation organized in the State of Delaware (USA)
  • Tax ID: FEIN 41-2637060 (U.S. federal employer identification number)
  • Registered address: 16192 Coastal Highway, Lewes, Delaware 19958, United States
  • Privacy contact e-mail: info@online-sat.com
  • Phone: +1 954 305 5497
  • Platform: Talent2 (the "Platform")

2. Definitions

  • Data subject: the individual whose personal data is processed (consultants, company representatives and users, business contacts and visitors).
  • Personal data: any information linked or reasonably linkable to an identified or identifiable individual.
  • Sensitive data: data affecting a person's privacy or whose misuse may lead to discrimination (e.g. biometric or health data).
  • Processing: any operation on personal data, such as collection, storage, use, disclosure, transfer or deletion.
  • Authorization / consent: the data subject's prior, express and informed consent.
  • Processor: a party that processes data on the controller's behalf.

3. Data we process

| Data subject | Data | |---|---| | Consultants | Name, ID document, date of birth, nationality, contact details (e-mail, phone, address, professional networks), profile photo, CV, work experience, education, certifications, languages, skills, expected rate, references, availability, performance evaluations, time records, billing and payment information. | | Client companies (representatives and users) | Name, position, e-mail, phone, company name, tax ID, address, signed agreements and billing data. | | Business contacts | Name, e-mail, phone, company and the message sent through the contact form. | | Visitors and users | IP address, device and browser identifiers, access logs and cookie preferences (see the Cookie Policy). | | All | Consent records: date and time, accepted document version, IP address and user agent. |

Sensitive data: the Platform does not require sensitive data. If you voluntarily provide it (for example, in your CV or photo), doing so is optional, and it will only be processed for the purposes described here.

Minors: the Platform is intended only for people aged 18 or over.

4. Purposes

  1. Create, manage and authenticate user accounts.
  2. Provide the Platform's services: job requests, search and matching of consultants with companies, interviews, offers, hiring, project management, time tracking, invoicing and payments (hire-to-pay).
  3. Assess consultants' fit for requests, including through automated and artificial-intelligence tools (see section 5).
  4. Share consultant profiles with client companies interested in their services.
  5. Generate master agreements, order forms, invoices and other contractual documents.
  6. Handle requests and complaints, and provide support.
  7. Send service-related operational and transactional communications.
  8. Only with separate, additional consent: send marketing communications and newsletters. Refusing does not affect use of the Platform, and you can withdraw this consent at any time.
  9. Produce statistics, aggregated reports and market analysis (e.g. salary benchmarks), preferably with anonymized data.
  10. Keep the Platform secure, prevent fraud and keep evidence of the consents given.
  11. Comply with legal, accounting and tax obligations and with requests from competent authorities.

Legal bases (GDPR): performance of a contract (purposes 1–7), consent (8 and non-essential cookies), legitimate interest (9–10) and legal obligation (11).

5. Automated decision-making and AI

The Platform uses machine-learning models to score the fit between consultant profiles and requests, and AI assistants to answer questions and generate reports. These outputs are supporting recommendations: hiring decisions are made by people at the client company. You may request information about the logic involved, ask for human review and object to this processing through the channels in section 9 (GDPR art. 22; SIC External Circular 002 of 2024).

6. Disclosures and international transfers

  • Processors: providers of cloud infrastructure (Google Cloud Platform), e-mail, storage and AI services, which may be located outside Colombia (including the United States), bound by data processing agreements.
  • Client companies: consultant profiles are shared with companies looking for talent.
  • International transfers: made to countries with an adequate level of protection, or under article 26 of Law 1581 of 2012 and, for EEA data subjects, under Standard Contractual Clauses or other valid mechanisms. By accepting this Policy, you expressly authorize such transfers for the stated purposes.
  • Authorities: when legally required.

We do not sell personal data.

7. Your rights

You have the right to access, update and correct your data; to request proof of your consent; to be informed of how your data is used; to withdraw consent and/or request deletion when no legal or contractual duty requires us to keep it; to access your data free of charge; and to lodge a complaint with the Colombian Superintendence of Industry and Commerce (SIC) or your local supervisory authority. Where the GDPR or equivalent laws apply, you also have the rights to data portability, restriction of processing and objection.

8. How requests are handled

  • Inquiries are answered within 10 business days (extendable by 5 business days, with notice).
  • Claims (correction, update, deletion or withdrawal of consent) are answered within 15 business days (extendable by 8 business days, with notice). Where the GDPR applies, requests are answered within one month.

9. Contact channel

  • Responsible area: Personal Data Protection Area, Talent2.AI Inc
  • E-mail: info@online-sat.com
  • Phone: +1 954 305 5497
  • Postal address: 16192 Coastal Highway, Lewes, Delaware 19958, United States
  • In the Platform: the account settings let you review your consents and change your marketing and cookie preferences.

10. Security

We apply reasonable technical and organizational measures, including encryption in transit, role-based access control, secret management, audit logs and backups.

11. Retention

Data is kept for as long as the relationship lasts and as needed to fulfil the stated purposes and legal obligations. Consent records are kept for as long as the processing lasts and, after that, for the applicable statute-of-limitations period, as evidence.

12. Changes

We will notify material changes before they take effect. Where a change affects the purposes of processing, we will ask for your consent again. Every version is recorded with its date and fingerprint (hash).