Privacy Policy

THCO (Talentco Holding Company) is committed to protecting the privacy and personal data of every individual who interacts with our organisation. We recognise that the responsible handling of personal information is fundamental to the trust our clients, candidates, employees, partners, and website visitors place in us.

This Privacy Policy explains how we collect, use, store, share, and protect your personal information when you engage with THCO through our website, services, platforms, communications, and business operations. It also describes your rights regarding your personal data and how you can exercise those rights.

We have designed this policy to comply with the Nigeria Data Protection Act, 2023 (NDPA), the General Data Protection Regulation (GDPR) where applicable to individuals in the European Economic Area and United Kingdom, and other data protection laws in jurisdictions where we operate, including but not limited to Canada, the Caribbean, and the Asia-Pacific region.

By engaging with THCO’s services, visiting our website, subscribing to our newsletters, submitting your information through our platforms, or otherwise providing your personal data to us, you acknowledge that you have read and understood this Privacy Policy.

1. Information we collect

We collect and process various categories of personal data depending on how you interact with us. The following sections describe the types of information we may collect.

1.1 Information You Provide Directly

• Identity Information: full name, title, job title, employer name, professional

  qualifications, and biographical details

• Contact Information: email address, telephone number, postal address, and

  professional social media profiles (such as LinkedIn)

• Professional Information: curriculum vitae or resume, work history, educational

  background, certifications, skills, salary expectations, availability, and professional

  references

• Client Engagement Information: business requirements, project briefs, organisational

  data shared during consulting engagements, financial information relevant to service

  delivery, and correspondence related to our services

• Account and Subscription Information: newsletter preferences, content download

  history, webinar registrations, and communication preferences

• Application Information: job applications, cover letters, assessment results, interview

  notes, and onboarding documentation for candidates applying through THCO Talent or

  the Learn2Earn programme

• Feedback and Communications: survey responses, testimonials, complaints,

  enquiries, and any other information you voluntarily provide to us

  
  

  1.2 Information We Collect Automatically

When you visit our website or interact with our digital platforms, we may automatically collect:

• Technical Information: IP address, browser type and version, operating system, device

  type, screen resolution, and language preferences

• Usage Information: pages visited, time spent on pages, click patterns, navigation

  paths, referring URLs, and download activity

• Cookie and Tracking Data: information collected through cookies, web beacons, pixels,

  and similar tracking technologies (see Section 14 for details)

• Location Information: approximate geographic location derived from your IP address

1.3 Information We Receive from Third Parties

We may receive personal information about you from third-party sources, including:

• Professional Networks and Databases: information from LinkedIn, professional

  directories, data enrichment services, and industry databases used in our recruiting and

  business development activities

• Client Organisations: information provided by our clients about their employees,

  contractors, or other individuals in connection with our service engagements

• Referral Partners: information shared by individuals or organisations who refer you to

  THCO for services or career opportunities

• Publicly Available Sources: information from public records, corporate websites,

  industry publications, and other publicly accessible sources

2. How we use your information

We use the personal information we collect for the following purposes:

2.1 Service Delivery

• Delivering consulting, advisory, and professional services engagements under THCO

  Advisory

• Conducting executive search, recruiting, talent sourcing, and workforce planning under

  THCO Talent

• Implementing technology solutions, process automation, and systems integration under

  THCO Technology

• Delivering training, assessment, certification, and Learn2Earn programmes under THCO

  Academy

• Providing managed services, outsourced operations, and ongoing support under THCO

  Operate

2.2 Business Operations

• Managing client relationships and maintaining accurate records of engagements

• Processing payments, invoicing, and financial administration

• Conducting business development and identifying opportunities to serve prospective

  clients

• Administering contracts, service agreements, and partnership arrangements

• Maintaining and improving the quality and effectiveness of our services

2.3 Communications and Marketing

• Sending newsletters, thought leadership content, industry reports, and updates about

  our services

• Responding to enquiries, requests, and communications from clients, candidates, and

  other stakeholders

• Promoting THCO’s services, events, and publications through email, social media, and

  other channels

• Personalising your experience with our content and communications based on your

  interests and engagement history

2.4 Recruitment and Talent Management

• Processing job applications and managing the recruitment lifecycle for positions within

  THCO

• Sourcing, evaluating, and placing candidates with our clients through THCO Talent

• Administering the Learn2Earn training-to-employment pipeline

• Conducting pre-employment screening, reference checks, and skills assessments where

  applicable and with appropriate consent

2.5 Analytics, Improvement, and Research

• Analysing website usage and engagement patterns to improve our digital platforms

• Conducting market research, industry benchmarking, and salary surveys (using

  anonymised and aggregated data)

• Developing and improving our proprietary technology platforms and service delivery

  methodologies

• Measuring the effectiveness of our marketing campaigns and content strategy

2.6 Legal and Compliance

• Complying with applicable legal and regulatory obligations

• Establishing, exercising, or defending legal claims

• Detecting, preventing, and responding to fraud, security incidents, and other harmful

  activities

• Conducting internal audits and compliance reviews

3. Information Sharing and Disclosure

We do not sell your personal data. We share personal information only in the following circumstances:

3.1 Within THCO

Personal data may be shared between THCO’s internal teams, departments, and regional entities (including THCO Americas, THCO EMEA, THCO APAC, and our sector-specific brands) where necessary to deliver services, manage client relationships, or support business operations. All internal sharing is subject to appropriate access controls and confidentiality obligations.

3.2 With Clients

In our recruiting and talent placement services, we share candidate information with our clients to facilitate the hiring process. This sharing is conducted with your knowledge and, where required, your consent. We always refer to our client organisations as “our client” in external communications and never disclose client identities without authorisation.

3.3 With Service Providers

We engage trusted third-party service providers who process personal data on our behalf, including:

• Cloud hosting and data storage providers

• Customer relationship management (CRM) platform providers

• Email marketing and newsletter distribution services

• Website analytics and performance monitoring tools

• Data enrichment and professional networking platforms

• Payment processing and financial services providers

• IT security and infrastructure providers

All service providers are bound by data processing agreements that require them to processpersonal data only in accordance with our instructions and to maintain appropriate securitymeasures.

3.4 With Professional Advisors

We may share personal data with our legal advisors, auditors, accountants, and other professional consultants where necessary for the management of our business or the defence of legal claims.

3.5 For Legal and Regulatory Purposes

We may disclose personal data where required by law, regulation, court order, or governmental authority, or where disclosure is necessary to protect our rights, safety, or property, or the rights, safety, or property of others.

3.6 In Connection with Business Transactions

In the event of a merger, acquisition, joint venture, reorganisation, or sale of assets, personaldata may be transferred to the relevant parties. We will provide notice and, where required,seek your consent before any such transfer occurs.

4. Cookies & tracking technologies

Our website uses cookies and similar tracking technologies to enhance your browsing experience, analyse website performance, and support our marketing efforts. Cookies are small text files stored on your device when you visit our website.

4.1 Managing Your Cookie Preferences

You can manage your cookie preferences through your browser settings or through any cookie consent mechanism provided on our website. You may choose to block or delete cookies; however, doing so may affect the functionality of our website. Most web browsers allow you to control cookies through their settings, including the ability to accept or reject cookies, delete existing cookies, and set preferences for certain websites.

5. Data security

We take the security of your personal data seriously and implement appropriate technical and organisational measures to protect it against unauthorised access, alteration, disclosure, or destruction. Our security measures include:

• Encryption of personal data in transit and at rest using industry-standard protocols

• Access controls and authentication mechanisms to limit access to personal data to

  authorised personnel only

• Regular security assessments, vulnerability testing, and penetration testing of our

  systems and infrastructure

• Staff training on data protection, information security, and confidentiality obligations

• Incident response procedures to detect, investigate, and respond to data breaches

  promptly

• Secure disposal and destruction of personal data when it is no longer needed

• Physical security measures for our offices and facilities

While we take all reasonable steps to protect your personal data, no method of transmission over the internet or method of electronic storage is completely secure. We cannot guarantee absolute security, but we are committed to maintaining the highest practicable standards of data protection.

In the event of a personal data breach that is likely to result in a risk to your rights and freedoms, we will notify the relevant supervisory authority and, where required, the affected individuals, in accordance with the timelines and requirements set out in the NDPA, GDPR, and other applicable laws.

6. Third-Party Links and Services

Our website and communications may contain links to third-party websites, platforms, and services that are not operated by THCO. We are not responsible for the privacy practices or content of these third-party sites. We encourage you to read the privacy policies of any third-party services you access through links on our website.

Our social media presence on platforms such as LinkedIn, Twitter/X, and Instagram is subject to the respective privacy policies of those platforms. When you interact with our content on these platforms, your information may be collected and processed by the platform provider in accordance with their own policies.

7. Changes to this policy

We may update this Privacy Policy from time to time to reflect changes in our data processing practices, legal requirements, or business operations. When we make material changes to this policy, we will:

• Post the updated policy on our website with a revised effective date

• Notify you of significant changes through email, website notification, or other appropriate

  means

• Where required by law, seek your consent to any changes that affect how your personal

  data is processed

We encourage you to review this policy periodically to stay informed about how we protect your personal data. The date at the top of this policy indicates when it was last updated.

8. Contact us

If you have any questions, concerns, or requests regarding this Privacy Policy or our data processing practices, or if you wish to exercise any of your data protection rights, please contact us:

Organisation: THCO (Talentco Holding Company)

Email: Privacy@thcohq.com

Website: www.thcohq.com

We aim to respond to all privacy-related enquiries within 30 days of receipt. If your request is complex or involves a large volume of data, we may extend this period by an additional 60 days, in which case we will inform you of the extension and the reasons for it.