Winning Hire Find your A-Player

Legal

Privacy Policy

Effective 4 November 2026. Last revised 4 November 2026.

1. Introduction and scope

This Privacy Policy explains how Winning Hire LLC collects, uses, discloses and retains personal data in connection with the website at winning-hire.com (the "Site") and the talent platform services provided through it (the "Services"). Winning Hire LLC is a limited liability company organized under the laws of the State of Wyoming, United States ("Winning Hire", "we", "us" or "our").

Winning Hire is the controller of the personal data described in this Policy, except where this Policy states that we act as a processor on behalf of a client.

This Policy applies to: (a) specialists who apply for a seat, are assessed, or are placed through the platform; (b) representatives and personnel of client businesses; (c) persons who contact us or schedule a call with us; and (d) visitors to the Site.

2. Categories of personal data we process

We process the following categories of personal data, in each case limited to what the relevant purpose requires:

  • Identity and contact data. Name, email address, telephone number where provided, country of residence, time zone and preferred language.
  • Professional and application data. Role applied for, current and requested rate, availability and notice period, working hours, portfolio, work samples, case studies, employment and engagement history, references where provided, and the content of any application form.
  • Assessment data. Work test submissions, scorecard results, structured interview scores, written assessor notes, and interview recordings and transcripts where an interview was recorded with prior notice and consent.
  • Verification data. Information required to verify identity and business standing before a first payout or a first invoice, which may include government-issued identification, company registration details and tax identifiers, processed only as necessary and retained in accordance with Section 8.
  • Commercial and billing data. Company details, billing contacts, invoices, payment references, payout records and correspondence relating to them. Card details are entered directly with our payment provider and we do not store complete payment card numbers.
  • Engagement communications. Messages, briefs, candidate cards, check-in notes and other records created in the course of a placement.
  • Technical and usage data. Aggregate page views and referrer information collected through privacy-preserving analytics that set no cookies and do not fingerprint visitors, together with server logs retained for security purposes.

We do not request, and we ask you not to provide, special categories of personal data within the meaning of Article 9 of the General Data Protection Regulation, including data concerning health, racial or ethnic origin, political opinions, religious beliefs, trade union membership, genetic data, biometric data, sex life or sexual orientation. We do not knowingly process the personal data of any person under the age of eighteen (18).

3. Sources of personal data

We obtain personal data: (a) directly from you, when you apply, complete an assessment, correspond with us, schedule a call or enter into an agreement; (b) from a client or a specialist in the course of a placement; (c) from publicly available professional sources and professional networking platforms, where we source candidates in accordance with the terms of those platforms and applicable law; and (d) from our service providers, in each case as described in Section 6.

4. Purposes of processing

We process personal data for the following purposes:

  • To assess, test and score candidates, and to present qualified candidates to a client.
  • To administer placements, including contracting, onboarding, scheduled check-ins and any replacement.
  • To invoice clients, to remunerate specialists, and to maintain the associated financial records.
  • To verify identity and business standing, to prevent and detect fraud and misuse, and to protect the security and integrity of the Site and the Services.
  • To comply with legal, regulatory, accounting and tax obligations, and to establish, exercise or defend legal claims.
  • To communicate with you about an application, an engagement or an enquiry.
  • To understand, in aggregate and without identifying individuals, how the Site is used, in order to improve it.

We do not sell personal data. We do not share personal data with any third party for that party's own marketing purposes. We do not make personal data available to any third party for the training of that party's models. We do not make decisions producing legal or similarly significant effects on the basis of automated processing alone: every assessment outcome is reviewed by a person before a candidate is advanced or declined.

5. Legal bases for processing

Where the General Data Protection Regulation or the United Kingdom GDPR applies, we rely on the following legal bases:

  • Performance of a contract, or steps taken at your request prior to entering into one (Article 6(1)(b)): to assess an application, administer a placement, invoice and pay.
  • Legitimate interests (Article 6(1)(f)): to source and vet candidates, to operate and secure the platform, to maintain business records, to prevent fraud and to defend legal claims. Where we rely on this basis we have assessed that our interests are not overridden by your interests or fundamental rights, and you may object as described in Section 10.
  • Consent (Article 6(1)(a)): to disclose a candidate profile to a client, and to record an interview. Consent may be withdrawn at any time without affecting the lawfulness of processing carried out before withdrawal.
  • Compliance with a legal obligation (Article 6(1)(c)): where accounting, tax, anti-money-laundering or other law requires us to collect or retain data.

6. Disclosure of personal data

We disclose personal data only as follows:

  • Parties to a placement. The client, the specialist and Winning Hire. A candidate profile is disclosed to a client only with the candidate's prior consent, and is disclosed on a blind basis, without name or personal links, until the client commits to the placement.
  • Service providers acting on our documented instructions, comprising hosting and content delivery, payment and banking, electronic signature, email and document storage, scheduling, interview recording and transcription, and privacy-preserving analytics. Each is engaged under a written data processing agreement containing confidentiality and security obligations.
  • Professional advisers, including legal, accounting and insurance advisers, bound by professional duties of confidentiality.
  • Public authorities, where disclosure is required by law, by a binding order, or to establish, exercise or defend legal claims.
  • A successor entity, in connection with a merger, acquisition, reorganisation or sale of assets, subject to the recipient being bound by terms no less protective than this Policy.

7. International transfers

Our clients and specialists operate across borders, and personal data may accordingly be processed in countries other than the country in which you reside, including the United States. Where a transfer from the European Economic Area, the United Kingdom or Switzerland requires a safeguard under applicable law, we put an appropriate safeguard in place, which may include the European Commission's standard contractual clauses together with any supplementary measures the transfer requires. We limit transferred data to what the relevant purpose requires. You may request details of the safeguard applicable to a transfer that concerns you by writing to the address in Section 13.

8. Retention

We retain personal data only for as long as is necessary for the purpose for which it was collected, and thereafter for the period required by law or necessary for the establishment, exercise or defence of legal claims. Application and assessment data of candidates who are not placed is kept while it remains relevant to future seats and is then deleted or anonymised.

Records relating to a placement are retained for the duration of the engagement and thereafter for the statutory limitation period applicable to the agreement. Financial and tax records are retained for the period required by applicable accounting and tax law. Interview recordings are retained for the shorter of the retention period above and any shorter period requested by the candidate. You may ask us at any time to remove your profile from consideration, and we will do so.

9. Security

We maintain technical and organisational measures that we consider appropriate to the risk. No method of transmission or storage is completely secure, and we cannot and do not warrant the security of information you transmit to us. Where applicable law requires us to notify a personal data breach to a supervisory authority or to affected individuals, we will do so as that law requires.

10. Your rights

Subject to the conditions and exceptions in applicable law, you have the right to request access to the personal data we hold about you, rectification of inaccurate data, erasure, restriction of processing, and portability, and the right to object to processing carried out on the basis of our legitimate interests. Where processing is based on consent, you have the right to withdraw that consent at any time.

Requests should be sent to hi@winning-hire.com. We will respond within the period required by applicable law. We may require information reasonably necessary to verify your identity before acting on a request.

If you are located in the European Economic Area or the United Kingdom, you have the right to lodge a complaint with the supervisory authority in your country of residence, place of work or place of the alleged infringement. We would welcome the opportunity to address your concern directly before you do so.

11. Cookies and analytics

This Site sets no cookies. It runs no advertising technology, no behavioural tracking and no third-party social plug-ins. Our analytics are aggregate and cookie-free and do not identify individual visitors, which is why no consent banner is presented. Should we in future introduce any technology that requires consent under applicable law, we will obtain that consent before it is deployed and will update this Policy accordingly.

12. Changes to this Policy

We may amend this Policy from time to time. The revised version takes effect when published on this page and the effective date at the top of this page will be updated. We encourage you to review this page periodically.

13. Contact

Questions, requests and complaints relating to this Policy or to our processing of personal data should be addressed to:

Winning Hire LLC, a Wyoming limited liability company
hi@winning-hire.com

Winning Hire LLC · Wyoming, USA · hi@winning-hire.com