SP
SprintPivot
Legal & Compliance

Privacy Policy & GDPR Notice

How SprintPivot Ltd collects, uses, and protects your personal data

Document version
1.0
Effective date
1 July 2025
Last reviewed
June 2025
Applicable law
UK GDPR, DPA 2018
Data controller
SprintPivot Ltd
ICO registered
Pending registration
About this notice: This Privacy Policy explains how SprintPivot Ltd ("SprintPivot", "we", "us", "our") collects, uses, shares, and protects personal data when you use our platform at sprintpivot.co.uk. We are committed to processing your data lawfully, transparently, and in accordance with the UK General Data Protection Regulation (UK GDPR) and the Data Protection Act 2018.

1. Who We Are

SprintPivot Ltd is a UK-registered company providing an AI-powered career transition platform. Our registered address is available upon written request. We act as the data controller for all personal data collected through our platform.

Contact us about data protection:
Email: privacy@sprintpivot.co.uk
Post: Data Protection Officer, SprintPivot Ltd, United Kingdom

2. Data We Collect

2.1 Data you provide directly

CategoryExamplesWho provides it
Account dataName, email address, password (hashed), roleAll users
Professional profileCurrent job title, target industry, years of experience, LinkedIn profileJob seekers, mentors
Company dataCompany name, job title, billing address, ATS integration URLRecruiters
Project submissionsWork files, submission links, notes, approach descriptionsJob seekers
Mentor feedbackReview scores, written feedback, grading decisionsMentors
Payment dataStripe customer ID, mandate reference (we never store raw card numbers)Job seekers
CommunicationsEmails sent to us, support queriesAll users

2.2 Data we collect automatically

2.3 Data we receive from third parties

3. Legal Basis for Processing

Under UK GDPR, we must have a valid legal basis for processing your personal data. The bases we rely on are:

Processing activityLegal basis (UK GDPR Article)
Creating and managing your accountPerformance of a contract (Art. 6(1)(b))
Delivering learning path, projects, and matchingPerformance of a contract (Art. 6(1)(b))
Processing payments and invoicingPerformance of a contract (Art. 6(1)(b))
Sending essential transactional emails (verification, password reset)Performance of a contract (Art. 6(1)(b))
Sending service updates and progress notificationsLegitimate interests (Art. 6(1)(f)) — improving user outcomes
Marketing communications (if opted in)Consent (Art. 6(1)(a))
Security monitoring, fraud prevention, and audit loggingLegitimate interests (Art. 6(1)(f))
Complying with legal obligations (tax, financial records)Legal obligation (Art. 6(1)(c))
Anonymous analytics and platform improvementLegitimate interests (Art. 6(1)(f))

4. How We Use Your Data

4.1 Job Seekers

4.2 Mentors

4.3 Recruiters

Candidate anonymisation: Employer-facing data deliberately excludes name, photograph, university, graduation year, demographic information, and employment history. Employers see only your SprintPivot candidate code (e.g. SP-A1B2C3D4), your performance score, project work, and skill profile. This is a core design principle, not just a policy.

5. Data Retention

Data categoryRetention periodReason
Active account dataDuration of account + 7 yearsContract, legal obligation
Financial and invoicing records7 years from transactionHMRC / Companies Act requirement
Project submissions and portfolio itemsDuration of account + 3 yearsContract, dispute resolution
Mentor review recordsDuration of account + 3 yearsContract, audit
Audit logs and security events2 yearsLegitimate interests (security)
Email communications3 yearsLegitimate interests (dispute)
Deleted account data30 days after deletion request, then purgedRight to erasure (UK GDPR Art. 17)
Anonymised analytics dataIndefinitely (no personal data retained)Legitimate interests (platform improvement)

6. Data Sharing

We do not sell your personal data. We share data only in the following circumstances:

6.1 Service providers (data processors)

All processors are subject to data processing agreements (DPAs) ensuring UK GDPR compliance.

6.2 Legal requirements

We may disclose personal data where required by law, court order, or regulatory authority (e.g. HMRC, ICO, FCA).

6.3 Business transfers

In the event of a merger, acquisition, or sale of assets, personal data may be transferred to the new entity, with notice provided to users.

6.4 What we never share

7. International Data Transfers

Your data is primarily stored and processed within the UK and European Economic Area. Where any data is transferred outside the UK/EEA (e.g. if a service provider has servers in the USA), we ensure adequate safeguards are in place, including:

8. Your Rights Under UK GDPR

You have the following rights regarding your personal data. To exercise any right, email privacy@sprintpivot.co.uk. We will respond within 30 days.

RightWhat it means
Right of access (Art. 15)Request a copy of all personal data we hold about you
Right to rectification (Art. 16)Correct inaccurate or incomplete data
Right to erasure (Art. 17)Request deletion of your data where there is no legal basis to retain it
Right to restrict processing (Art. 18)Request that we limit how we use your data in certain circumstances
Right to data portability (Art. 20)Receive your data in a structured, machine-readable format
Right to object (Art. 21)Object to processing based on legitimate interests, including direct marketing
Rights related to automated decision-making (Art. 22)Not be subject to solely automated decisions with significant effects — our AI grading is always supplemented by human mentor review
Right to withdraw consentWithdraw consent at any time where consent is the legal basis (e.g. marketing emails)

You also have the right to lodge a complaint with the Information Commissioner's Office (ICO) at ico.org.uk or by calling 0303 123 1113.

9. Cookies

SprintPivot uses the following cookies:

Cookie namePurposeDurationBasis
PHPSESSIDSession management — keeps you logged inSession (deleted on browser close)Strictly necessary
_ga, _gidGoogle Analytics — anonymous usage statisticsUp to 2 yearsConsent
__stripe_midStripe fraud detection1 yearLegitimate interests

You can manage cookie preferences in your browser settings. Blocking the PHPSESSID cookie will prevent you from logging in.

10. Security Measures

We implement the following security controls in line with UK Cyber Essentials and OWASP best practices:

11. Children's Data

SprintPivot is intended for adults aged 18 and over. We do not knowingly collect personal data from children under 18. If you believe a child has created an account, please contact us at privacy@sprintpivot.co.uk and we will delete the account immediately.

12. AI and Automated Decision-Making

SprintPivot uses AI systems to:

Important: No decision with significant legal or similarly significant effect is made by AI alone. AI grading is always reviewed and signed off by a human mentor before any outcome is recorded in your portfolio. If you disagree with an assessment, you may request human review by contacting support.

13. Changes to This Policy

We may update this Privacy Policy from time to time. When we make material changes, we will:

Continued use of the platform after changes are notified constitutes acceptance of the updated policy.

14. Contact Us

SprintPivot Ltd — Data Protection Team

Email: privacy@sprintpivot.co.uk
Website: www.sprintpivot.co.uk

To exercise any of your rights, or to raise a data protection concern, please email us. We aim to respond to all requests within 30 calendar days. For complex requests, we may extend this by a further two months and will notify you accordingly.