Privacy Policy

Data controller

Holden Creative Medya Ltd., Atatürk Mah. Ertuğrul Gazi Sk., Metropol Istanbul C1 Blok No: 2 B, İç Kapı N. 131 Ataşehir, 34400 Istanbul, Türkiye (Corporate Reg / Tax ID: TR4631402640). Contact: hello@holdentalent.com.

What data we process and why

• Inquiry form: name, company, role, business email, phone, country, talent of interest, budget and message. Purpose: to handle your commercial request and reply to it (Art. 6(1)(b) GDPR, pre-contractual measures). We also store the IP address and the time of submission to prevent abuse (Art. 6(1)(f), legitimate interest).
• Analytics: with your consent (Art. 6(1)(a)), we use Google Analytics 4 with IP anonymisation to measure how the website is used. See the Cookie Policy.
• Server logs: our hosting provider records technical data (IP address, browser, pages requested) for security purposes for a limited time.

Recipients

Inquiries are received by the Holden Talent commercial desk (Milan, Barcelona) and by the legal and talent operations team in Istanbul. We rely on technical providers (hosting, email delivery, Google LLC for analytics) acting as processors. Google may transfer data outside the EU under the EU-US Data Privacy Framework and standard contractual clauses.

Retention

Inquiry data is kept for as long as necessary to handle the request and, if a collaboration follows, for the duration of the contractual relationship and the applicable statutory limitation periods. Analytics data is retained according to the Google Analytics settings (14 months).

Your rights

You have the right to access, rectify and erase your data, to restrict or object to processing, to data portability and to withdraw consent at any time. Write to hello@holdentalent.com. You may also lodge a complaint with your supervisory authority.

Changes

We may update this policy; the date at the top indicates the latest version.