PRIVACY NOTICE

This Privacy Notice applies between you, the User of this Website, and Scorpius Talent Acquisition Ltd, the owner and provider of this Website.

Scorpius Talent Acquisition Ltd takes the privacy of your information very seriously. This Privacy Notice applies to our use of any and all Data collected by us or provided by you in relation to your use of the Website and the services of Scorpius Talent Acquisition Ltd.

This Privacy Notice was created on 1 November 2023 and last updated on 22 June 2026.

PLEASE READ THIS PRIVACY NOTICE CAREFULLY

1. In this Privacy Notice, the following definitions are used:

AI Tools - any artificial intelligence, machine learning or other automated software tools and systems that we use to assist with the provision of our recruitment and work-finding services, as further described in the section headed “Use of Artificial Intelligence (AI) Tools” below;

Data - collectively all information that you submit to Scorpius Talent Acquisition Ltd. This definition incorporates, where applicable, the definitions provided in the Data Protection Laws;

Data Protection Laws - any applicable law relating to the processing of personal Data, including but not limited to the GDPR, and any national implementing and supplementary laws, regulations, and secondary legislation;

GDPR - the UK General Data Protection Regulation;

Scorpius Talent Acquisition Ltd, we or us - Scorpius Talent Acquisition Ltd, a company incorporated in England and Wales with registered number 15222963 whose registered office is at 124 City Road, London, EC1V 2NX;

User or you - any third party that accesses the Website and is not either (i) employed by Scorpius Talent Acquisition Ltd and acting in the course of their employment or (ii) engaged as a consultant or otherwise providing services to Scorpius Talent Acquisition Ltd and accessing the Website in connection with the provision of such services; and

Website - the website that you are currently using, www.ScorpiusTA.co.uk, and any sub-domains of this site unless expressly excluded by their own terms and conditions.

2. In this Privacy Notice, unless the context requires a different interpretation:

a. the singular includes the plural and vice versa;

b. references to sub-clauses, clauses, schedules or appendices are to sub-clauses, clauses, schedules or appendices of this Privacy Notice;

c. a reference to a person includes firms, companies, government entities, trusts and partnerships;

d. “including” is understood to mean “including without limitation”;

e. reference to any statutory provision includes any modification or amendment of it;

f. the headings and sub-headings do not form part of this Privacy Notice.

3. This Privacy Notice applies only to the actions of Scorpius Talent Acquisition Ltd and Users with respect to this Website and our services. It does not extend to any websites that can be accessed from this Website including, but not limited to, any links we may provide to social media websites.

4. For purposes of the applicable Data Protection Laws, Scorpius Talent Acquisition Ltd is the “data controller”. This means that Scorpius Talent Acquisition Ltd determines the purposes for which, and the manner in which, your Data is processed. Where we use third-party AI Tools to process your Data on our behalf (see the section headed “Use of Artificial Intelligence (AI) Tools” below), those providers act as our “data processors” and only process your Data in accordance with our instructions.

5. We may collect the following Data, which includes personal Data, from you:

a. name;

b. date of birth;

c. gender;

d. job title and profession;

e. work history;

f. contact information such as email addresses, addresses, and telephone numbers;

g. certificates and supporting employment documentation;

h. photograph or video for submission to hiring clients;

i. employment references;

j. recordings and transcripts of meetings and telephone calls.

in each case, in accordance with this Privacy Notice.

6. We collect Data in the following ways:

a. data is given to us by you;

b. data is received from other sources, and

c. data is collected automatically.

7. Scorpius Talent Acquisition Ltd will collect your Data in a number of ways, for example:

a. when you contact us through the Website, by telephone, post, e-mail, job advert or through any other means;

b. when you use our services;

in each case, in accordance with this Privacy Notice.

8. We will receive Data about you from the following publicly available third-party sources:

a. internet job sites;

b. LinkedIn;

c. conferences and networking events; and

d. recommendations and referrals.

9. To the extent that you access the Website, we will collect your Data automatically, for example:

a. we automatically collect some information about your visit to the Website. This information helps us to make improvements to Website content and navigation and includes your IP address, the date, times, and frequency with which you access the Website, and the way you use and interact with its content.

10. Any or all of the above Data may be required by us from time to time in order to provide you with the best possible service and experience when using our Website and our recruitment services. Specifically, Data may be used by us for the following reasons:

a. internal record keeping;

b. improvement of our products/services;

c. using AI Tools to assist our consultants with screening and ranking candidates, sourcing candidates and researching market intelligence, and drafting communications and reports, as further described in the section headed “Use of Artificial Intelligence (AI) Tools” below;

d. transmission by email of marketing materials that may be of interest to you;

in each case, in accordance with this Privacy Notice.

11. We may use your Data for the above purposes if we deem it necessary to do so for our legitimate interests. If you are not satisfied with this, you have the right to object in certain circumstances (see the section headed “Your Rights” below).

12. For the delivery of direct marketing to you via e-mail, our basis for processing will be legitimate interest or via an opt-in or soft-opt-in. If you are not satisfied with our approach to marketing, you have the right to withdraw consent at any time. To find out how to withdraw your consent, see the section headed “Your Rights” below.

13. We use AI Tools to support our consultants in providing our recruitment and work-finding services. We currently use AI Tools to:

a. screen, assess and rank CVs and other candidate Data against the requirements of a specific job specification;

b. source and identify potential candidates, and research hiring signals and market intelligence relevant to a role, sector or client; and

c. assist our consultants in drafting candidate-facing and client-facing communications, reports and other documents;

in each case, in accordance with this Privacy Notice.

14. AI Tools assist our consultants - they do not replace them. A member of our team reviews the output of our AI Tools before any decision affecting you is made. We do not make any decision about you based solely on automated processing (including profiling) that produces legal effects concerning you or otherwise significantly affects you, such as a decision to reject your application or remove you from consideration for a role.

15. The AI Tools we currently use process Data on servers located in the UK and/or the European Economic Area (EEA). If we change our AI Tools in a way that means your Data will be transferred outside the UK or EEA, we will update this Privacy Notice and put in place appropriate safeguards before doing so.

16. We do not permit providers of the AI Tools we use to use your Data to train their general-purpose or publicly available AI models. Data processed using AI Tools is retained in accordance with the section headed “Data Retention” below.

17. As with the other uses of your Data described in this Privacy Notice, we rely on our legitimate interests as the legal basis for using AI Tools (see clause 11 above). You have the right to object to this processing - see the section headed “Your Rights” below.

18. We record and transcribe certain meetings and phone calls with candidates and clients, for example:

a. Teams meetings, using a third-party AI notetaker;

b. phone calls, using a dedicated call recording and transcription system; and

c. face-to-face meetings, using a mobile AI notetaker app;

in each case, in accordance with this Privacy Notice.

19. We will always tell you before a meeting or call is recorded - for example, by giving verbal notice at the start of the call or meeting, including notice in the calendar invite, or making clear that a notetaker has joined or is present. If you do not want to be recorded, please let us know and we will turn off the recording for that conversation.

20. We record and transcribe meetings and calls to keep an accurate record of our discussions with you, prepare notes and summaries, and help us provide and improve our recruitment and work-finding services. Recordings and transcripts are added to our customer relationship management (CRM) system as part of your candidate or client record, and may also be reviewed using the AI Tools described in the section headed “Use of Artificial Intelligence (AI) Tools” above.

21. We rely on our legitimate interests as the legal basis for recording and transcribing meetings and calls (see clause 11 above). We retain recordings and transcripts for 24 months, in line with the section headed “Data Retention” below, unless you ask us to delete them earlier.

22. We may share your Data with the following groups of people for the following reasons:

a. any of our group companies or affiliates - to ensure the proper administration of our website and business operation;

b. our employees, agents, and/or professional advisors - to provide work-finding services;

c. providers of the AI Tools described above - to enable those tools to assist us in providing our recruitment and work-finding services, under contracts that restrict their use of your Data;

d. providers of the meeting and call recording/transcription tools described above - to enable those tools to record and transcribe your conversations with us, under contracts that restrict their use of your Data;

e. clients - to introduce you to potential hiring clients.

in each case, in accordance with this Privacy Notice.

23. We will use technical and organisational measures to safeguard your Data, for example:

a. access to your account is controlled by a password and a user name that is unique to you.

b. we store your Data on secure servers.

c. we only engage providers of AI Tools who can demonstrate appropriate technical and organisational security measures, and we have contracts in place with them governing their use of your Data.

d. we only engage providers of meeting and call recording/transcription tools who can demonstrate appropriate technical and organisational security measures, and we have contracts in place with them governing their use of your Data.

24. Technical and organisational measures include measures to deal with any suspected data breach. If you suspect any misuse or loss or unauthorised access to your Data, please let us know immediately by contacting us via this e-mail address: Insights@ScorpiusTA.co.uk

25. If you want detailed information from Get Safe Online on how to protect your information and your computers and devices against fraud, identity theft, viruses and many other online problems, please visit www.getsafeonline.org. Get Safe Online is supported by HM Government and leading businesses.

26. Unless a longer retention period is required or permitted by law, we will hold your Data on our systems for 24 months on the legal basis of legitimate interest to facilitate the provision of work-finding services to you, unless you request that the Data be deleted earlier.

27. Even if we delete your Data, it may persist on backup or archival media for contractual, legal, tax, or regulatory purposes.

28. You have the following rights in relation to your Data:

a. Right to access - the right to request (i) copies of the information we hold about you at any time, or (ii) that we modify, update or delete such information. If we provide you with access to the information we hold about you, we will not charge you for this, unless your request is “manifestly unfounded or excessive.” Where we are legally permitted to do so, we may refuse your request. If we refuse your request, we will tell you the reasons why.

b. Right to correct - the right to have your Data rectified if it is inaccurate or incomplete.

c. Right to erase - the right to request that we delete or remove your Data from our systems.

d. Right to restrict our use of your Data - the right to “block” us from using your Data or limit the way in which we can use it.

e. Right to data portability - the right to request that we move, copy or transfer your Data.

f. Right to object - the right to object to our use of your Data including where we use it for our legitimate interests.

g. Right related to automated decision-making - the right not to be subject to a decision based solely on automated processing, including profiling, which produces legal effects concerning you or otherwise significantly affects you. As explained in the section headed “Use of Artificial Intelligence (AI) Tools” above, we do not make such decisions about you without human review.

29. To make enquiries, exercise any of your rights set out above, or withdraw your consent to the processing of your Data (where consent is our legal basis for processing your Data), please contact us via this e-mail address: Insights@ScorpiusTA.co.uk

30. If you are not satisfied with the way a complaint you make in relation to your Data is handled by us, you may be able to refer your complaint to the relevant data protection authority. For the UK, this is the Information Commissioner’s Office (ICO). The ICO’s contact details can be found on their website at https://ico.org.uk/.

31. It is important that the Data we hold about you is accurate and current. Please keep us informed if your Data changes during the period for which we hold it.

32. This Website may, from time to time, provide links to other websites. We have no control over such websites and are not responsible for the content of these websites. This Privacy Notice does not extend to your use of such websites. You are advised to read the privacy notice or policy of other websites prior to using them.

33. Scorpius Talent Acquisition Ltd may, from time to time, expand or reduce our business and this may involve the sale and/or the transfer of control of all or part of Scorpius Talent Acquisition Ltd. Data provided by Users will, where it is relevant to any part of our business so transferred, be transferred along with that part and the new owner or newly controlling party will, under the terms of this Privacy Notice, be permitted to use the Data for the purposes for which it was originally supplied to us.

34. We may also disclose Data to a prospective purchaser of our business or any part of it.

35. In the above instances, we will take steps with the aim of ensuring your privacy is protected.

36. You may not transfer any of your rights under this Privacy Notice to any other person. We may transfer our rights under this Privacy Notice where we reasonably believe your rights will not be affected.

37. If any court or competent authority finds that any provision of this Privacy Notice (or part of any provision) is invalid, illegal or unenforceable, that provision or part-provision will, to the extent required, be deemed to be deleted, and the validity and enforceability of the other provisions of this Privacy Notice will not be affected.

38. Unless otherwise agreed, no delay, act or omission by a party in exercising any right or remedy will be deemed a waiver of that, or any other, right or remedy.

39. This Privacy Notice will be governed by and interpreted according to the law of England and Wales. All disputes arising under this Privacy Notice will be subject to the exclusive jurisdiction of the English and Welsh courts.

Scorpius Talent Acquisition Ltd reserves the right to change this Privacy Notice as we may deem necessary from time to time or as may be required by law. Any changes will be immediately posted on the Website and you are deemed to have accepted the terms of the Privacy Notice on your first use of the Website following the alterations.

You may contact Scorpius Talent Acquisition Ltd by email at Insights@ScorpiusTA.co.uk