Legal

Privacy Policy, HoldTalent

Last updated: 10 September 2026

This Privacy Policy explains what personal data HoldTalent collects, how it is used, and the rights you have. It uses the terms HoldTalent, we, us and our for the service described below.

1. Who we are

Ani Barry operates HoldTalent, a job board for Cybersecurity, GRC and Privacy & AI Governance roles in the EU. For the personal data described in this policy, Ani Barry is the data controller.

HoldTalent is currently run by Ani Barry as an individual, in its build phase and free to use. It will be registered as a business in Ireland when paid listings launch, and this policy, including the controller details, will be updated then.

2. What data we collect

2.1. When you browse the site

Your IP address, basic device and browser details, the pages you view, timestamps, and the site you came from. This comes through our hosting provider and, only if you accept analytics cookies, an analytics tool.

2.2. When you use a contact form

Your name, email address, your message, and anything else you choose to include.

2.3. When you ask us to list a job

Your name and role, your work email, your company details, and the job details you provide, such as title, location, description and apply link.

2.4. When you subscribe to updates

Your email address, your name if you give it, and your topic preferences, for example "jobseeker updates".

2.5. What we do not collect

• candidate accounts or profiles
• a CV database
• video interviews
• employer applicant tracking or AI screening tools

3. How we use it, and our legal bases

• Running and securing the siteLegal basis: our legitimate interest in a working, secure website.
• Replying to your messages and handling your submissionsLegal basis: steps taken at your request before any agreement, and our legitimate interest in running the service.
• Reviewing and publishing job listings, including sharing them by email or on social channelsLegal basis: our legitimate interest in running and promoting the board, and, for a direct employer post, steps taken at the employer's request.
• Sending you email updatesLegal basis: your consent, which you can withdraw at any time.
• Analytics, if you accept analytics cookiesLegal basis: your consent.
• Meeting legal obligations and handling disputesLegal basis: compliance with law, and our legitimate interest in protecting our rights and our users.

4. Cookies

A cookie is a small file a website stores on your device. We use as few as possible, and we do not use any cookies for advertising or to build a profile of you.

4.1. Your choice

When you first visit, a banner asks whether you accept analytics cookies. Nothing non essential is stored until you accept. You can change or withdraw your choice at any time by clicking the Cookie settings button in the bottom left corner of any page.

We use Google Consent Mode: the Google Analytics tag is present on every page, but it is blocked from storing anything or sending data about you until you accept analytics cookies. If you decline, or ignore the banner, it stays blocked.

4.2. Cookies we use

• cookieyes-consentSet by our consent tool, CookieYes. Remembers your cookie choices so you are not asked again. Lasts 1 year. Strictly necessary.
• _cfuvidSet by Cloudflare, part of our hosting. Helps tell real visitors from automated traffic for security and rate limiting. It does not track you across sites. Expires at the end of your session. Strictly necessary.
• _gaSet by Google Analytics, only after you accept analytics cookies. Distinguishes one visitor from another so we can count visits. Lasts up to 2 years. Analytics.
• _ga_X2YBF5H08PSet by Google Analytics, only after you accept analytics cookies. Keeps track of your current visit. Lasts up to 2 years. Analytics.

Webflow, our website platform, may also set short lived cookies needed for core features such as forms and security. The live list below always reflects what is currently in use.

4.3. Full, current cookie list

4.4. Cookies we do not use

• advertising or retargeting cookies
• social media tracking pixels
• cookies that build a profile of you or follow you across other websites

4.5. Analytics provider

If you accept analytics cookies, we use Google Analytics 4 to understand how the site is used and to improve it. Google acts as our processor for this, and Google Analytics 4 does not log full IP addresses. See Google's Privacy Policy and how Google uses cookies.

5. Personal data in job listings

Some listings are provided by employers, and others are gathered from job listings that are already public elsewhere. A listing can contain a person's name or work contact details, for example a hiring contact. Where it does, that information is shown as part of the listing.

If a listing shows your details and you want them corrected or removed, email hello@holdtalent.com and we will act on it.

6. Who we share data with

6.1. Service providers

Our website host and other providers that process data on our instructions under a data processing agreement, for example hosting, email delivery and analytics.

6.2. Independent controllers

Some analytics or social tools act as their own controllers under their own privacy policies.

6.3. Legal requirements

We share data where the law requires it, such as a valid court order or a request from a regulator.

We do not sell your personal data.

7. International transfers

Some providers may process data outside the EU or EEA. Where that happens, we rely on the safeguards EU law requires, such as an adequacy decision or the European Commission's standard contractual clauses.

8. How long we keep data

We keep personal data only as long as we need it for the purposes in this policy, then delete or anonymise it. Server and security logs are normally kept for up to 12 months. Contact and job posting messages are kept while they are useful for the enquiry and for a reasonable period afterwards.

9. Your rights

Under the GDPR you can ask to:

• see the personal data we hold about you
• correct it if it is wrong
• delete it
• restrict or object to how we use it
• receive it in a portable format
• withdraw consent at any time, which does not affect anything we did before you withdrew

To use any of these, email hello@holdtalent.com. We may need to confirm your identity first, and we aim to respond within one month.

If you believe we have handled your data wrongly, you can complain to the Irish Data Protection Commission at dataprotection.ie.

10. Children

HoldTalent is not aimed at children. We do not knowingly collect personal data from anyone under 16. If you believe a child has given us personal data, email hello@holdtalent.com and we will delete it.

11. Automated decisions and profiling

• we do not use your personal data to make automated decisions that have a legal or similarly significant effect on you
• we do not run AI profiling or scoring of candidates or employers

12. Other websites

When you click an apply button or an external link, you leave HoldTalent. Those sites have their own privacy policies and cookies, and we are not responsible for how they collect or use your data. Please read their policies.

13. Changes to this policy

We may update this policy from time to time. If we make a significant change, we will update the date at the top and, where appropriate, show a notice on the site.

14. Contact and complaints

Questions about this policy or your data: email hello@holdtalent.com, or write to 77 Camden Street Lower, Dublin, D02 XE80, Ireland (correspondence only). You can also contact the Irish Data Protection Commission at dataprotection.ie.