Data Policy

Last updated: 1 June 2026

This Data Policy explains how Talentos handles Client Data, business information, performance information and related records shared with us during the use of our services.

This Policy should be read together with our Privacy Policy and Terms and Conditions.

1. Purpose of This Policy

Talentos works with growing teams to make performance clearer. This may require reviewing business information, performance routines, team structures, role expectations, manager follow-up, scorecards, issue records, notes and related information.

This Policy explains how we handle that information responsibly.

2. Scope

This Policy applies to:

  • Client Data shared with Talentos;
  • business documents;
  • audit answers;
  • Performance Clarity Check responses;
  • performance notes;
  • role or team information;
  • manager or employee information;
  • reports, findings and recommendations created during services;
  • information stored in tools used by Talentos to deliver services.

3. Types of Data We May Handle

Depending on the service, Talentos may handle:

  • company name and business details;
  • founder, director or manager contact details;
  • team structure;
  • roles and responsibilities;
  • performance expectations;
  • scorecards, targets or KPIs;
  • manager check-in notes;
  • issue records;
  • performance concerns;
  • review routines;
  • documents shared by the Client;
  • audit findings;
  • reports and recommendations;
  • communications between Talentos and the Client.

We aim to collect only what is relevant to the service.

4. Client Responsibility for Data Shared

The Client is responsible for ensuring that any information shared with Talentos is provided lawfully.

This includes ensuring that:

  • the Client has authority to share the information;
  • personal data is shared on a lawful basis;
  • sensitive or confidential information is shared only where necessary;
  • employees, managers or team members are informed where required;
  • the information provided is accurate and relevant.

Talentos is not responsible for unlawful disclosure by a Client before information reaches Talentos.

5. Talentos' Use of Client Data

Talentos uses Client Data only for legitimate service purposes, including:

  • delivering the Performance Clarity Audit;
  • reviewing performance clarity gaps;
  • preparing findings and recommendations;
  • creating practical performance structures;
  • supporting manager follow-up routines;
  • preparing reports, templates, notes or frameworks;
  • communicating with the Client;
  • improving service quality;
  • meeting legal, accounting or compliance obligations.

We do not sell Client Data.

6. Confidentiality

Talentos treats Client Data as confidential unless it is already public or disclosure is required by law.

We will not disclose Client Data to third parties except:

  • with the Client's permission;
  • where needed to provide the services;
  • to trusted service providers under appropriate obligations;
  • to professional advisers;
  • where required by law, court order, regulator or lawful authority;
  • where necessary to protect legal rights, safety or security.

7. Data Minimisation

Talentos aims to collect and use only the information needed for the relevant service.

Clients should avoid sharing unnecessary personal data, sensitive information or unrelated business documents.

Where possible, Client Data should be limited to what is relevant to performance clarity, accountability, follow-up and visibility.

8. Sensitive Information

Clients should not share sensitive personal data unless it is necessary for the agreed service and there is a lawful basis for doing so.

Sensitive information may include information about health, ethnicity, religion, political opinions, biometric data, disciplinary matters or other protected categories.

If such information is shared, Talentos will handle it with additional care.

9. Employee and Team Data

Talentos may receive information about employees, managers, supervisors, contractors or team members during an audit or service engagement.

Talentos uses this information only to understand performance clarity, role expectations, follow-up, records and visibility.

Talentos does not make employment decisions. The Client remains responsible for employment, disciplinary, promotion, termination or restructuring decisions.

10. Storage and Access

Client Data may be stored in secure digital systems used by Talentos for communication, documents, scheduling, reporting, storage and service delivery.

Access to Client Data is limited to people or service providers who need it for authorised purposes.

Talentos will take reasonable steps to protect Client Data against unauthorised access, loss, misuse, alteration or disclosure.

11. Third-Party Tools and Service Providers

Talentos may use trusted third-party tools and service providers, including:

  • Google Analytics;
  • WhatsApp;
  • Google Sheets;
  • website hosting providers;
  • email and communication tools;
  • forms and scheduling tools;
  • payment processors;
  • document storage tools;
  • automation and reporting tools;
  • productivity tools;
  • other service providers needed to operate the website and deliver the services.

This list is not exhaustive and may change as the business and services develop.

Where these tools process Client Data, Talentos will take reasonable steps to use reputable providers and appropriate safeguards.

12. AI-Assisted Tools

Talentos may use digital or AI-assisted tools to organise notes, draft documents, summarise information, improve internal workflows or support service delivery.

Talentos will not intentionally use confidential Client Data in public tools in a way that makes it available to unrelated third parties.

Where sensitive or confidential Client Data is involved, Talentos will take reasonable steps to minimise, anonymise or avoid unnecessary exposure.

Clients may request restrictions on the use of AI-assisted tools for their engagement, subject to what is practical and agreed in writing.

13. Data Ownership

Client Data remains owned by the Client or the relevant rights holder.

Talentos owns its methods, frameworks, templates, website content, tools, reports structure and original materials, unless otherwise agreed in writing.

Reports or documents created for a Client may be used internally by that Client according to the Terms and Conditions or relevant agreement.

14. Retention of Client Data

Talentos keeps Client Data only for as long as reasonably necessary for:

  • delivering the services;
  • maintaining business records;
  • responding to questions;
  • complying with legal, tax or accounting obligations;
  • resolving disputes;
  • enforcing agreements;
  • improving service quality.

After that period, data may be deleted, anonymised or securely archived.

Clients may request deletion of certain data, subject to legal, contractual or operational limits.

15. Data Accuracy

Clients are responsible for providing accurate and up-to-date information.

Talentos may rely on Client Data when preparing findings, reports or recommendations.

If information provided is incomplete, inaccurate or misleading, the quality of findings and recommendations may be affected.

16. Data Security Incidents

If Talentos becomes aware of a data security incident affecting Client Data, we will take reasonable steps to investigate, contain and respond to the incident.

Where required by law, Talentos or the relevant Client will notify affected individuals or the relevant authority.

The responsibility for notification may depend on the nature of the data, the role of each party and applicable law.

17. Cross-Border Processing

Some tools or service providers used by Talentos may process or store data outside Kenya.

Where this occurs, Talentos will take reasonable steps to ensure appropriate safeguards are used according to applicable law.

18. Client Requests

Clients may contact Talentos to request:

  • access to certain Client Data;
  • correction of inaccurate information;
  • deletion of certain data;
  • export of certain records;
  • clarification of how data is used;
  • restrictions on specific data handling practices.

Talentos will respond within a reasonable time, subject to legal, contractual, technical and operational limits.

19. Relationship With Privacy Policy

This Data Policy explains how Talentos handles Client Data and business information.

The Privacy Policy explains how Talentos handles personal data about identifiable individuals.

Where Client Data includes personal data, both this Data Policy and the Privacy Policy may apply.

20. Contact

For questions about this Data Policy, contact:

Talentos
Nairobi, Kenya
Email: hello@talentos.co.ke