We may collect and process the following types of personal data:

• Name, email address, phone number, and other contact details

• CV and career history

• Professional experience, skills, and qualifications

• Compensation expectations and availability

• Identification or compliance-related information (e.g. right to work, where required)

• National Insurance number (where required for payroll or compliance purposes)

• Any other information you choose to share with us

We do not routinely collect special category data (e.g. health information) or criminal conviction data. Where such data is processed, it will only be done where necessary and in accordance with applicable law.

We collect personal data:

• Directly from you (e.g. when you apply, register, or speak with us)

• From publicly available sources such as LinkedIn and other professional networking platforms

• Through referrals and recommendations

• From clients, other recruitment businesses, or third parties where relevant to a role

We use your personal data to:

• Provide recruitment and work-finding services

• Assess your suitability for roles and opportunities

• Introduce you to clients, prospective employers, and their portfolio companies

• Communicate with you about relevant opportunities

• Manage and develop our relationship with you

• Arrange payments where applicable

• Update and maintain our candidate database

• Meet legal, regulatory, and compliance obligations

We process your personal data under the following lawful bases:

• Legitimate interests — to provide recruitment and work-finding services, to match candidates with relevant opportunities, to keep our candidate database up to date, and to improve our services. We have assessed that these interests do not override your rights and freedoms as a data subject.

• Consent — where required, for example for marketing communications. You may withdraw consent at any time by contacting us.

• Legal obligation — where we are required to comply with applicable laws, including employment, tax, and immigration legislation.

• Contractual obligation — where processing is necessary to fulfil a contract with you, or to take steps at your request before entering into a contract.

We may share your personal data with:

• Clients and prospective employers, including private equity firms and their portfolio companies

• Referees and former employers, where appropriate and with your knowledge

• Payroll service providers and payment intermediaries

• Technology providers supporting our operations, including SourceWhale, FireFly, and Raise

• Professional advisers such as legal, accounting, and audit providers

We only share your data where it is relevant and necessary. All third parties are required to handle personal data in accordance with applicable data protection laws.

The Company may transfer your personal data to countries outside the UK and/or the European Economic Area (EEA) where necessary to provide work-finding services. Where this occurs, we will ensure appropriate safeguards are in place, such as Standard Contractual Clauses or adequacy decisions, to protect your personal data in accordance with UK GDPR.

We retain your personal data only for as long as necessary to provide our services and meet our legal obligations. Our typical retention periods are:

• Candidate data: up to 24 months from our last meaningful contact with you

• Contractor and financial records: 3–6 years, in line with tax and legal requirements

• Compliance records: as required by applicable law

Where appropriate, we may ask for your consent to continue holding your data beyond these periods. You may request deletion of your data at any time.

Under UK GDPR, you have the following rights in relation to your personal data:

• The right to be informed about how we use your personal data

• The right to access the personal data we hold about you

• The right to rectification of inaccurate or incomplete data

• The right to erasure of your data in certain circumstances

• The right to restrict processing of your data

• The right to data portability in certain circumstances

• The right to object to processing based on legitimate interests

• The right not to be subject to automated decision-making or profiling

• The right to withdraw consent at any time, where consent is the legal basis for processing

We do not carry out solely automated decision-making that produces legal or similarly significant effects.

To exercise any of these rights, please contact us at hello@inicio-talent.com

Our website may contain links to third-party websites. This privacy notice applies solely to information collected by Inicio Talent Limited. We are not responsible for the privacy practices of external sites.

If our business is sold or integrated with another business, your personal data may be disclosed to advisers and prospective purchasers, and transferred to new owners where appropriate.

We take appropriate technical and organisational measures to protect your personal data, including restricted access controls, secure systems, and internal data handling policies.

While we take reasonable steps to safeguard personal data, we cannot guarantee the security of information transmitted via email or the internet.

If you have concerns about how we handle your personal data, please contact us in the first instance:

Liam Grier
Inicio Talent Limited
hello@inicio-talent.com

71–75 Shelton Street, Covent Garden, London, WC2H 9JQ

You also have the right to raise concerns with the Information Commissioner’s Office (ICO):

• Telephone: 0303 123 1113

• Website: ico.org.uk/make-a-complaint

We may update this privacy notice from time to time. Any changes will be published on our website with an updated version date. This version is 1.0, dated April 2026.