Privacy Policy

Carbon Data Solutions (Pty) Ltd ("we", "us", "our") operates carbon.talent.

Last updated: 24 August 2026
Effective date: 17 August 2026

This Privacy Policy explains how we collect, use, store, and protect your personal information when you use carbon.talent. It applies to all users — companies (Clients) and data professionals (Consultants).

We comply with the following data protection laws, as applicable to your location:


1. Who we are

Data Controller / Responsible Party:
Carbon Data Solutions (Pty) Ltd
144 Fagan Street, Strand, Western Cape, South Africa
platform@carbondatasolutions.com

Information Officer (POPIA):
Danie Zeeman — platform@carbondatasolutions.com

EU Representative (GDPR Article 27):
If you are located in the European Union or European Economic Area and have questions about how we handle your data, contact us at platform@carbondatasolutions.com. We will appoint a formal EU representative as our EU user base grows.

UK Representative (UK GDPR Article 27):
If you are located in the United Kingdom and have questions about how we handle your data, contact us at platform@carbondatasolutions.com. We will appoint a formal UK representative as our UK user base grows.


2. Personal information we collect

From Consultants (Data Professionals)

Category Examples
Identity data Full name, SA ID number, nationality, date of birth
Contact data Email address, phone number
Professional data CV, job title, skills, years of experience, LinkedIn URL, GitHub URL, portfolio URL, work preferences, availability, hourly rate
Verification data Identity verification status, biometric data processed by Persona Identities, Inc. (United States), identity document type
Assessment data Evidence score, vetting tier (Bronze/Silver/Gold), assessment results, interview feedback
Profile data Professional summary, video introduction, profile photo
Usage data Login activity, pages visited, feature interactions
Communications Messages sent via platform chat or support

From Clients (Companies)

Category Examples
Identity data Contact person name, job title
Company data Company name, registration number, website, industry
Contact data Email address, phone number, billing address
Payment data Bank account details (EFT), card details (processed by PayFast — we do not store card numbers)
Job data Job descriptions, requirements, screening questions
Pipeline data Application notes, stage progression, hiring decisions
Usage data Login activity, pages visited, feature interactions

Automatically collected

We collect standard web analytics data including IP address, browser type, device type, referring URL, and pages visited. This is used to operate and improve the platform.


3. How and why we use your personal information

We process your personal information on the following lawful bases:

Purpose Lawful basis (GDPR) POPIA justification
Providing the platform (account creation, matching, pipeline) Performance of contract Contract
Identity verification Legal obligation / legitimate interest Legitimate purpose
Sending transactional emails (match notifications, stage updates, contract alerts) Performance of contract Contract
Processing payments Performance of contract / legal obligation Contract
Fraud prevention and platform security Legitimate interests Legitimate purpose
Improving the platform (analytics, error monitoring) Legitimate interests Legitimate purpose
Complying with legal obligations Legal obligation Legal obligation
Marketing communications (newsletter, platform updates) Consent Consent

You may withdraw consent for marketing communications at any time by unsubscribing or contacting us.


4. Identity verification and sensitive information

To maintain the integrity of our consultant catalog, we verify the identity of Consultants before they are matched with Clients. This involves:

SA ID numbers and biometric data are special personal information under POPIA and special category data under GDPR. We process this data only for identity verification purposes. We do not use this data for any other purpose. Results are stored as a verification status (verified/not verified) — not the raw biometric data.

You have the right to object to this processing, but we may be unable to admit you to the consultant catalog if verification cannot be completed.


5. Third-party services (sub-processors)

We use the following trusted third parties to operate the platform. Each has contractual data protection obligations with us:

Provider Purpose Location Safeguard
Supabase Database and authentication EU (Frankfurt) GDPR-compliant; DPA in place
Vercel Frontend hosting Global CDN (EU nodes available) GDPR-compliant; DPA in place
Railway Backend server hosting US (can be configured to EU) SOC 2 Type II
Resend Transactional email delivery US DPA in place
Persona Identities, Inc. Identity verification United States Standard Contractual Clauses (SCCs) in place; GDPR-compliant; POPIA-compliant where applicable
Sentry Error monitoring US GDPR-compliant; DPA in place
Crisp Customer support chat EU (France) GDPR-compliant
PayFast Payment processing (ZAR) South Africa PCI DSS compliant
Paddle Payment processing & Merchant of Record (USD, EUR, ZAR international) UK / EU GDPR-compliant; UK GDPR-compliant; PCI DSS; DPA in place
Anthropic AI features (job spec generation, interview guides) US Data processing agreement

We do not sell your personal information to any third party.


6. International data transfers

Our servers and some third-party providers are located outside South Africa. When we transfer personal information across borders, we ensure appropriate safeguards are in place:

If you are an EU/EEA data subject, your personal information may be transferred to South Africa, which does not currently have an EU adequacy decision. We rely on SCCs for these transfers.


7. Data retention

Data type Retention period
Active consultant profiles For the duration of your account + 3 years after last login
Active company accounts For the duration of your account + 3 years after last activity
Job applications 2 years from application date
Identity verification records 5 years (legal/audit requirement)
Signed contracts 7 years (statutory requirement for commercial records)
Payment records 5 years (SARS requirement)
Support chat logs 2 years
Server logs and analytics 90 days

You may request deletion of your account and personal information at any time (see Section 9). We may retain data where we have a legal obligation to do so.


8. Cookies

We use cookies and similar technologies to operate the platform. These include:

Type Purpose Examples
Essential Session management, authentication Hub_token, __session_ct
Functional Preferences, chat widget Crisp session cookie
Analytics Platform usage analytics Anonymous usage data

You can control cookies through your browser settings. Disabling essential cookies will prevent you from logging in.

We do not use advertising or tracking cookies. We do not share cookie data with advertisers.


9. Your rights

Depending on your location, you have the following rights regarding your personal information:

Under POPIA (South Africa)

Under GDPR (EU/EEA residents)

In addition to the POPIA rights above:

Under UK GDPR (UK residents)

UK residents have equivalent rights to those under EU GDPR above, enforceable under the UK GDPR and Data Protection Act 2018:

Under CCPA / CPRA (California residents)

If you are a California resident, you have the following rights under the California Consumer Privacy Act and California Privacy Rights Act:

To submit a CCPA request, email platform@carbondatasolutions.com with subject "CCPA Privacy Request". We will respond within 45 days (extendable by a further 45 days with notice). You may designate an authorised agent to make requests on your behalf.

We do not sell personal information and have not done so in the preceding 12 months.

Under PIPEDA / Law 25 (Canadian residents)

Canadian residents have rights under the Personal Information Protection and Electronic Documents Act (PIPEDA) and, for Quebec residents, Law 25 (Bill 64):

We collect, use, and disclose personal information only for purposes a reasonable person would consider appropriate in the circumstances. We obtain meaningful consent before or at the time of collection.

Under the Privacy Act 1988 (Australian residents)

Australian residents have rights under the Privacy Act 1988 (Cth) and the Australian Privacy Principles (APPs):

We will respond to access and correction requests within 30 days. Where we are unable to provide access, we will provide written reasons.

To exercise any right: Email platform@carbondatasolutions.com with the subject line "Privacy Request — [your jurisdiction]". We will respond within the timeframe required by your applicable law. We may need to verify your identity before fulfilling the request.


10. Data security

We implement appropriate technical and organisational measures to protect your personal information:

In the event of a personal data breach that is likely to result in a risk to your rights and freedoms, we will notify you and the relevant supervisory authority within 72 hours of becoming aware of the breach, as required by GDPR Article 33. Under POPIA, we will notify the Information Regulator and affected data subjects as required.


11. Children

carbon.talent is not directed at children under 18. We do not knowingly collect personal information from children. If you believe a child has provided us with personal information, contact us immediately and we will delete it.


12. Changes to this Privacy Policy

We may update this policy from time to time. Material changes will be notified to registered users by email at least 14 days before they take effect. The "Last updated" date at the top of this policy reflects the most recent revision.


13. Contact and complaints

For any privacy-related questions, access requests, or complaints:

Carbon Data Solutions (Pty) Ltd
Information Officer: Danie Zeeman
platform@carbondatasolutions.com
144 Fagan Street, Strand, Western Cape, South Africa

Information Regulator of South Africa (POPIA):
inforegulator.org.za | complaints.IR@justice.gov.za
JD House, 27 Stiemens Street, Braamfontein, Johannesburg, 2001

EU residents — supervisory authority (GDPR):
Contact the data protection authority in your EU member state.

UK residents — Information Commissioner's Office (UK GDPR):
ico.org.uk | 0303 123 1113
Wycliffe House, Water Lane, Wilmslow, Cheshire SK9 5AF, United Kingdom

California residents — California Privacy Protection Agency (CCPA/CPRA):
cppa.ca.gov

Canadian residents — Office of the Privacy Commissioner (PIPEDA):
priv.gc.ca | 1-800-282-1376

Quebec residents — Commission d'accès à l'information (Law 25):
cai.gouv.qc.ca

Australian residents — Office of the Australian Information Commissioner (Privacy Act 1988):
oaic.gov.au | 1300 363 992