Legal

Privacy Policy

Last updated: 1 May 2026  ·  Turtle Technologies Ltd

Privacy Policy

Turtle Technologies Ltd ("Clearbridge", "we", "us", "our") is committed to protecting your privacy. This Privacy Policy explains how we collect, use, share, and protect your personal data when you use the Clearbridge platform. It applies to all users — candidates and employers — and to visitors who browse the Platform without registering.

We are the data controller for personal data collected through this Platform. Our contact details are: jobs@clearbridgetalent.co.uk.

1. What personal data we collect

Registration data: full name, email address, phone number, password (stored in encrypted form), and account type (candidate or employer).

Profile data: headline, biography, location, skills, work experience, education history, CV (uploaded document), profile photo, portfolio URL, and open-to-work status.

Application data: job applications you submit, Atlas AI scores and feedback generated for those applications, your responses to application questions, and the status of your applications.

Employer data: company name, company description, industry, website, and job postings created.

Usage data: pages visited, features used, search queries, device type, browser, operating system, IP address, and session duration. This data is collected automatically via cookies and similar technologies.

Communications: messages sent through the Platform's messaging system, notification history, and any correspondence with Clearbridge support.

2. How we use your personal data

  • To create and manage your account and provide access to Platform features.
  • To match candidates to relevant job opportunities and surface suitable candidates to employers.
  • To process job applications and provide Atlas AI scoring and feedback.
  • To send transactional emails — application confirmations, status updates, and platform notifications.
  • To operate the Platform's messaging system between candidates and employers.
  • To improve the Platform, analyse usage patterns, and fix technical issues.
  • To detect and prevent fraud, abuse, and misuse of the Platform.
  • To comply with our legal and regulatory obligations.

3. Atlas AI and automated decision-making

Applications submitted through Clearbridge are processed by Atlas AI, which generates a match score (0–100) and personalised feedback. This constitutes automated processing under UK GDPR Article 22. Atlas scoring is used to assist employers in reviewing applications — it does not automatically accept or reject candidates.

You have the right to request human review of any Atlas AI decision. To exercise this right, email jobs@clearbridgetalent.co.uk with the subject line "Human Review Request".

We do not train AI models on candidate data without consent. Atlas AI processing is performed using Anthropic's Claude API under a data processing agreement that prohibits use of your data for model training.

4. Legal basis for processing

  • Contract performance — processing necessary to provide the service you registered for (e.g. processing applications, sending status emails).
  • Legitimate interests — processing necessary for our legitimate interests in operating and improving the Platform, provided those interests are not overridden by your rights (e.g. fraud prevention, usage analytics).
  • Legal obligation — processing necessary to comply with UK law (e.g. responding to subject access requests).
  • Consent — where we rely on your consent, you may withdraw it at any time without affecting the lawfulness of processing before withdrawal.

5. Who we share your data with

Employers: When you apply for a job, your profile and application data (including your CV, contact details, Atlas score, and feedback) is shared with the employer who posted the role.

Infrastructure providers: We use Supabase for database and authentication infrastructure, and Vercel for hosting. Both are bound by data processing agreements.

Email delivery: We use Resend to send transactional emails. Email content and recipient addresses are processed by Resend under a data processing agreement.

AI processing: Application data is processed by Anthropic's Claude API to generate Atlas AI scores and feedback. This processing is governed by a data processing agreement.

We do not sell your personal data to any third party. We do not share your data with advertisers.

6. International data transfers

Some of our service providers (including Anthropic and Vercel) are based in the United States. Where we transfer personal data outside the UK, we ensure appropriate safeguards are in place in accordance with UK GDPR, including standard contractual clauses approved by the Information Commissioner's Office (ICO).

7. Data retention

We retain your personal data for as long as your account is active. If you delete your account, we will delete your personal data within 30 days, except where we are required to retain it to comply with a legal obligation, resolve disputes, or enforce our agreements.

Application data (including Atlas scores and feedback) is retained for 48 months from the date of application to allow employers and candidates to reference historical applications.

8. Your rights under UK GDPR

You have the following rights over your personal data:

  • Right of access — request a copy of all personal data we hold about you.
  • Right to rectification — request correction of inaccurate or incomplete data.
  • Right to erasure — request deletion of your personal data in certain circumstances.
  • Right to restrict processing — request that we limit how we use your data in certain circumstances.
  • Right to data portability — receive your data in a structured, machine-readable format.
  • Right to object — object to processing based on legitimate interests or for direct marketing.
  • Rights related to automated decisions — request human review of any Atlas AI automated decision.

To exercise any of these rights, email jobs@clearbridgetalent.co.uk. We will respond within 30 days and may need to verify your identity first.

9. Cookies

We use cookies to operate the Platform. See our Cookie Policy for full details.

10. Security

We implement commercially reasonable technical and organisational measures to protect your personal data against unauthorised access, disclosure, alteration, and destruction. These include encryption in transit (TLS 1.3), encrypted data storage, and strict access controls. No system is completely secure — please protect your account with a strong, unique password.

11. Children

The Platform is not intended for children under 16. We do not knowingly collect personal data from anyone under 16. If you believe we have inadvertently collected such data, please contact us immediately.

12. Changes to this policy

We may update this Privacy Policy from time to time. We will notify you of material changes by email or via a prominent notice on the Platform. Continued use of the Platform after changes take effect constitutes your acceptance of the updated policy.

13. How to complain

If you are unhappy with how we have handled your personal data, you have the right to lodge a complaint with the Information Commissioner's Office (ICO) at ico.org.uk or by calling 0303 123 1113. We would appreciate the opportunity to resolve your concern directly first — please contact us at jobs@clearbridgetalent.co.uk.