SEEN YA TALENT (PTY) LTD
Registration No: 2026/015462/07
PRIVACY NOTICE
Protection of Personal Information Act, 4 of 2013 (“POPIA”)
Version 1.0 — June 2026
1
Who We Are
SEEN YA TALENT (Pty) Ltd (Registration No: 2026/015462/07) is a specialist technology recruitment and professional placement business. We are currently active in South Africa and are conducting business development outreach into the United States and the United Kingdom. We are the Responsible Party for the purposes of POPIA in respect of the personal information we process.
Contact Detail Information
Company Name SEEN YA TALENT (Pty) Ltd
Registration Number 2026/015462/07
Physical Address 11 Driebergen Way, Pinehurst, Durbanville, 7550
Email Address tonia@seenyatalent.com
Website www.seenyatalent.com
Information Officer Tonia Collard
Our Information Officer is responsible for ensuring compliance with POPIA and can be contacted at the email address above for any privacy-related queries or requests.
2 Scope of This Privacy Notice
This Privacy Notice explains how SEEN YA TALENT (Pty) Ltd collects, uses, stores, shares, and protects personal information during our business activities.
It applies to:
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Prospective clients - organisations and their representatives whom we contact during business development
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Candidates - technology professionals who are registered with us or whom we approach regarding placement opportunities
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Placed professionals - candidates who have been placed with client organisations through our services
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Clients - organisations with whom we have an active or historical working relationship
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Website visitors - persons who visit our website or interact with us digitally
2.1 Cross-Border Transfers of Personal Information
We may transfer personal information to service providers, clients, or technology platforms located outside South Africa, including in the United States, United Kingdom, India and other jurisdictions where our service providers operate.
Where personal information is transferred outside South Africa, we take reasonable steps to ensure that:
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the recipient is subject to laws, binding corporate rules, contractual obligations or other safeguards that provide an adequate level of protection for the personal information;
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the transfer is necessary for the performance of a contract with the data subject;
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the transfer is made with the consent of the data subject; or
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another lawful basis under section 72 of POPIA applies.
3 Personal Information We Collect
3.1 Prospective Client Contact Information
For the purposes of business development and outreach, we may collect and process the following categories of personal information relating to representatives of prospective client organisations:
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Full name
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Job title and seniority
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Company name and industry
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Business email address
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Business telephone number
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LinkedIn profile URL
This information is sourced from professional business intelligence platforms - specifically Seamless.AI - which aggregate publicly available professional information. We do not collect personal residential addresses, identity numbers, or financial information in respect of prospective client contacts.
We do not intentionally request or process special personal information unless it is necessary for recruitment, employment, legal compliance, diversity reporting, right-to-work verification, or where otherwise permitted by law.
Where special personal information is processed, we do so in accordance with POPIA and only where an applicable lawful basis exists.
3.2 Candidate Information
For candidates registered with us or whom we approach regarding placement opportunities, we collect and process:
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Full name and contact details - email address, telephone number, and physical address
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Professional qualifications, certifications, and educational history
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Curriculum vitae and employment history
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Skills, technology experience, and areas of expertise
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Current and expected remuneration
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Availability and preferred engagement model - contract or permanent, remote or onsite
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Identity number - where required for placement verification or contractual purposes
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Banking details - only where a placement is confirmed and payment processing is required, and only with the candidate's explicit consent
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References and referee contact details - provided by the candidate. We retain CVs in their original submitted format as a record of the candidate's professional profile. We do not separately capture referee details into our systems. Where we contact a referee, we do so only with the candidate's prior explicit permission, solely for the purpose of candidate verification, and on the basis of legitimate interest. Referees are identified and informed of our purpose at the point of contact.
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Work permit or right to work documentation - where applicable
For clarification, we may verify information supplied by candidates including qualifications, employment history, professional certifications, references, identity documentation and right-to-work status. Such
verification will only be conducted where reasonably necessary and, where required by law, with the candidate's consent.
Candidate information may be obtained directly from the candidate, through referrals, from professional networking platforms such as LinkedIn, from publicly available professional sources, or from third-party recruitment databases where permitted by law.
Our services are intended for adults and professional organisations. We do not knowingly collect personal information from children under the age of 18 unless required by law or authorised by a ompetent person.
3.3 Client Information
For client organisations and their authorised representatives, we collect and process:
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Company name, registration number, and physical address
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Contact person name, job title, email address, and telephone number
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Contractual and invoicing information
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Payment and banking details - for invoicing and payment processing purposes
4 Why We Process Your Information — Purpose and Legal Basis Purpose Category of Data Subject Legal Basis Under POPIA Business development outreach - contacting representatives of organisations that may benefit from our services Prospective client contacts Legitimate interest (Section 11(1)(f)) - we have a legitimate interest in contacting professionals in relevant roles about services that may be of professional relevance to them. This processing is conducted in a B2B context using professional contact information sourced from a professional business intelligence platform. Candidate registration and management Candidates Consent (Section 11(1)(a)) - candidates provide information voluntarily for the purpose of seeking placement opportunities, and/or contractual necessity (Section 11(1)(b)) where a placement is being progressed. Presenting candidate profiles to prospective clients Candidates Consent - we obtain explicit candidate consent before sharing any personal information including CVs with prospective client organisations. Processing placements - sharing contact and banking details with clients upon confirmed placement Placed candidates Consent - explicit written consent is obtained from the candidate before their contact and banking details are shared with the client organisation. Client relationship management and invoicing Clients Contractual necessity (Section 11(1)(b)) - processing is necessary for the performance of a contract to which the data subject is party. Accounting and financial record keeping Clients and candidates Legal obligation (Section 11(1)(c)) - retention of financial records as required by South African tax and company law.
5 Legitimate Interest Assessment - Business Development Outreach
Where we rely on legitimate interest as the legal basis for processing prospective client contact information, we have conducted the following assessment:
5.1 The Legitimate Interest
SEEN YA TALENT has a legitimate commercial interest in identifying and contacting organisations and their representatives who may benefit from our specialist technology recruitment and professional placement services. This is a standard and widely recognised B2B commercial activity.
5.2 Necessity
The processing of professional contact information - name, job title, business email address, and business telephone number - is necessary to conduct this outreach. We limit the information processed to what is strictly necessary for the purpose of initial business contact.
5.3 B2B Context
Our outreach is conducted exclusively in a business-to-business context. We contact individuals solely in their professional capacity, using professional contact information obtained from a professional business intelligence platform. We do not contact individuals in a personal capacity or at personal contact details. The information processed relates to their professional role, not their personal life. This B2B context is a material factor in the balancing of our legitimate interest against the privacy rights of the individuals concerned.
5.4 Balancing Test
We have considered whether our legitimate interest is outweighed by the rights and interests of the individuals whose information we process. In conducting this assessment, we note:
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We process professional contact information only - not personal residential or sensitive information
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All information is processed in the context of the individual's professional role and capacity - not their personal life
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The information is sourced from a legitimate professional business intelligence platform (Seamless.AI) which aggregates publicly available professional data
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Our outreach relates directly to services that are professionally relevant to the individual's role
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Every electronic communication includes a clearly visible unsubscribe mechanism allowing individuals to opt out immediately and at no cost
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We honour all opt-out requests immediately and maintain a suppression list to prevent future contact
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We maintain a manual Do Not Contact list for individuals who request removal through any channel
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We do not process sensitive personal information for this purpose
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The volume and frequency of outreach is managed to avoid unreasonable intrusion
On the basis of this assessment, we have determined that our legitimate interest in conducting B2B professional outreach is not outweighed by the privacy interests of the individuals concerned, given the professional context, the nature of the information processed, and the safeguards in place.
6 Retention of Personal Information Category Retention Period Basis Prospective client contacts - no response received 12 months from last contact attempt, then deletion or suppression No longer necessary for the original purpose Prospective client contacts - responded but no engagement 24 months from last interaction, then deletion or suppression Reasonable period for business relationship to develop Active candidates Duration of active relationship plus 3 years Ongoing legitimate interest and potential future placements Placed candidates 5 years from date of last placement Contractual and potential dispute resolution purposes Client records Duration of relationship plus 5 years Legal and contractual obligations Financial and accounting records (Zoho) 5 years minimum from date of transaction South African tax law - Income Tax Act and Companies Act Unsuccessful candidate applications 12 months from application, unless candidate consents to longer retention POPIA minimum necessary principle Do Not Contact and Unsubscribed records Retained indefinitely on a suppression list Retention of suppressed records is in the data subject's own interest - it prevents accidental re-contact and ensures opt-out requests are permanently honoured
7 Who We Share Your Information With
7.1 Client Organisations
We share candidate personal information - including CVs, professional profiles, and upon confirmed placement contact and banking details - with client organisations. This is done exclusively with the candidate's prior explicit consent. We do not share candidate information with any client without that consent.
7.2 Technology Platforms and Service Providers
In the course of our operations we use the following third party platforms which may process personal information on our behalf:
Platform Purpose Location Seamless.AI Sourcing professional contact information for business development, and automated email sequence delivery. Seamless.AI maintains a global suppression list. When a recipient clicks the unsubscribe link, they are permanently removed from all future outbound campaigns and sequences - not just the active one. The unsubscribe status is reflected on the contact record and the contact is automatically excluded from all future sends across all campaigns. We also maintain a manual Do Not Contact list within Seamless.AI for contacts who request removal through any channel. United States Manatel Candidate and client relationship management - CRM and ATS function South Africa Zoho Accounting, invoicing, and financial record keeping. May contain client and placed candidate financial details necessary for invoicing and payment processing. India / Global LinkedIn Professional networking and outreach United States Claude AI (Anthropic) Assistive processing of candidate CVs - including skills matching against role requirements, gap analysis, error checking, and CV optimisation and formatting. Claude AI is used as a processing aid only and does not make decisions about candidates. All AI-assisted outputs are reviewed and verified by a human before any action is taken. No candidate profile is presented to a client without final human review and approval. United States
We take reasonable steps to ensure that third party platforms we use to process personal information provide adequate levels of protection. We select reputable platforms with established privacy and security frameworks, and we only share personal information with them to the extent necessary for the purposes described in this notice.
We do not solely use artificial intelligence systems to make automated decisions that produce legal effects or similarly significant consequences for candidates. All recruitment, screening, shortlisting and placement decisions are made by appropriately trained human personnel.
7.3 Legal and Regulatory Obligations
We may disclose personal information where required to do so by law, by court order, or by a regulatory authority including the Information Regulator of South Africa.
7.4 No Sale of Personal Information
We do not sell, rent, or trade personal information to any third party for their own marketing purposes under any circumstances.
8 Your Rights Under POPIA
As a data subject under POPIA you have the following rights in respect of your personal information: Right What It Means How to Exercise It Right of access You may request confirmation of whether we hold your personal information and a copy of that information Contact our Information Officer by email. For security purposes, we may require reasonable proof of identity before processing a data subject rights request. Right to correction You may request that we correct inaccurate or incomplete personal information we hold about you Contact our Information Officer by email Right to deletion You may request that we delete your personal information where it is no longer necessary for the purpose for which it was collected Contact our Information Officer by email Right to object You may object to the processing of your personal information, including for direct marketing purposes Contact our Information Officer by email or click the unsubscribe link in any email communication Right to opt out of direct marketing You may opt out of receiving marketing communications from us at any time Click the unsubscribe link in any email, or reply with 'Unsubscribe' in the subject line, or contact our Information Officer. (Where required by applicable law, we will obtain consent before sending direct electronic marketing communications. Where we rely on legitimate interests for B2B business development activities, we ensure that recipients can opt out at any time and that all objections are promptly honoured). Right to lodge a complaint You may lodge a complaint with the Information Regulator of South Africa if you believe your rights under POPIA have been infringed Contact the Information Regulator at:
Information Regulator (South Africa) JD House, 27 Stiemens Street, Braamfontein, Johannesburg, 2001
Website: www.inforegulator.org.za
Email: POPIAComplaints@inforegulator.org.za
We will respond to all data subject rights requests within 30 days of receipt.
9 Security of Your Personal Information
We implement appropriate technical and organisational measures to protect personal information against unauthorised access, loss, destruction, or alteration.
These security measures may include:
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Password protection and access controls on all systems containing personal information
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Use of reputable third-party platforms with their own security certifications and standards
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Limiting access to personal information to those who need it for the purposes described in this notice
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Deletion of personal information from our systems when it is no longer required for the purposes described in this notice, subject to any legal retention obligations. Where personal information has been sourced from third party platforms, deletion is applied within our own processing environment. We are not able to delete personal information held by third party source platforms in their own systems, but we suppress or remove such information from our own active use.
In the event of a personal information breach that poses a risk to data subjects, we will notify the Information Regulator and affected data subjects as required by POPIA.
10 Website and Cookies
Our website may use cookies and similar technologies to improve user experience and analyse site traffic. Where we use non-essential cookies, we will request your consent. Further detail on our cookie usage is available in our Cookie Policy on our website.
11 Changes to This Privacy Notice
We may update this Privacy Notice from time to time to reflect changes in our business, legal obligations, or the way we process personal information. The current version of this Privacy Notice will always be available on our website. We recommend checking periodically for updates.
12 How to Contact Us
For any queries, requests, or complaints relating to the processing of your personal information, please contact our
Information Officer:
SEEN YA TALENT (Pty) Ltd Registration No: 2026/015462/07
Information Officer: Tonia Collard
Email: tonia@seenyatalent.com
Website: www.seenyatalent.com
For complaints to the Information Regulator of South Africa:
Website: www.inforeg.org.za Email: inforeg@justice.gov.za
This Privacy Notice was adopted by SEEN YA TALENT (Pty) Ltd in June 2026.
It will be reviewed annually or whenever there is a material change in how personal information is processed.
