Privacy Policy

About this Privacy Policy

This Privacy Policy explains how we treat personal information that we collect when you visit our website, use our platform, communicate with us, or when we process candidate information in connection with providing our services to customers.

Who we are

Liminal AI Ltd is a company incorporated in England and Wales.

Company number: 17403965

Registered office: 61 International House, Mosley Street, Manchester M2 3HZ United Kingdom

For the purposes of applicable data protection law, including the UK General Data Protection Regulation (“UK GDPR”) and the Data Protection Act 2018, Liminal may act as either a data controller or a data processor, depending on the nature of the processing.

Where we determine how and why personal information is processed, we generally act as a controller.

Where we process candidate or other personal information on behalf of a customer in accordance with that customer's instructions, we generally act as a processor. In those circumstances, the customer is responsible for determining the purposes and lawful basis for processing that information.

Information we collect

The information we collect depends on how you interact with Liminal.

Information you provide to us

This may include:

• your name and contact details;
• your company and job title;
• account and login information;
• information provided when you apply to participate in a Liminal pilot or contact us;
• information contained in communications with us; and
• billing and transaction information.

Information collected through our platform

When you use the Liminal platform, we may collect information such as:

• account and organisation information;
• searches, job requirements and hiring criteria entered into the platform;
• candidate information added to or processed through the platform;
• activity and usage information;
• technical information relating to your device and browser; and
• logs and information required to maintain the security and operation of the platform.

Candidate information

As part of providing our sourcing services, Liminal may process information relating to potential candidates.

This may include:

• name;
• job title and professional history;
• employer information;
• skills and experience;
• education and qualifications;
• professional location;
• publicly available professional information;
• professional contact information where available;
• information relating to a candidate's suitability for a particular role; and
• information generated or derived through our sourcing and matching processes.

Candidate information may be provided by our customers, obtained from third-party data providers, or collected from publicly available professional sources.

We seek to use information that is relevant to the sourcing purpose and avoid collecting information that is unnecessary for that purpose.

How we use personal information

We use personal information to:

• provide and operate the Liminal platform and services;
• identify and recommend potentially relevant candidates;
• match candidate information against role requirements;
• help recruitment teams search, qualify and prioritise candidates;
• generate sourcing recommendations and other hiring-related outputs;
• facilitate candidate outreach where this forms part of the service;
• communicate with customers and users;
• provide customer support;
• administer accounts and subscriptions;
• process payments and maintain business records;
• monitor, maintain and secure our systems;
• detect and prevent fraud, misuse and security incidents;
• improve the performance and reliability of our services; and
• comply with legal and regulatory obligations.

We may also use limited information to understand how our website and services are used and to improve the user experience.

AI and automated processing

Liminal uses artificial intelligence and automated technologies as part of its sourcing services.

These technologies may be used to analyse role requirements, identify potentially relevant candidates, assess relevance against a search, rank or prioritise candidates, and generate recommendations or other information for recruitment teams.

Liminal's services are intended to assist recruiters and hiring teams rather than make employment decisions on their behalf.

Liminal does not make employment decisions on behalf of customers. Decisions about whether to contact, interview or hire a candidate remain the responsibility of the customer.

Where Liminal processes candidate information on behalf of a customer, the customer remains responsible for determining how the resulting recommendations are used in its recruitment process and for complying with its obligations under applicable data protection and employment law.

We will not use customer or candidate information to train general-purpose AI models unless this is expressly agreed with the relevant customer or otherwise permitted by applicable law.

Legal bases for processing

Where we act as a controller, we process personal information only where we have a lawful basis to do so under applicable data protection law.

Depending on the circumstances, this may include:

• Contract: where processing is necessary to provide a service or manage our relationship with you;
• Legitimate interests: where processing is necessary for our legitimate business interests and those interests are not overridden by your rights and interests;
• Legal obligation: where processing is necessary to comply with a legal or regulatory requirement; and
• Consent: where we have asked for and obtained your consent.

Where we process candidate information on behalf of a customer as a processor, the customer is responsible for determining the appropriate lawful basis for that processing and meeting its applicable transparency obligations.

How we obtain candidate information

Candidate information may come from several sources, including:

• our customers;
• candidates themselves;
• publicly available professional information;
• third-party data providers; and
• other sources that lawfully make professional or recruitment-related information available.

Where we use third-party sources, we expect those sources to provide information in accordance with applicable law and their contractual terms.

Where required by applicable law, appropriate information will be provided to individuals about the processing of their personal information.

Sharing personal information

We may share personal information with:

• customers and organisations using Liminal's services;
• service providers that host, operate or support our platform;
• infrastructure, database and cloud providers;
• AI and machine-learning service providers;
• data and information providers used to provide sourcing services;
• communications and email service providers;
• professional advisers, such as lawyers, accountants and insurers;
• regulators, courts or law enforcement authorities where required by law; and
• a purchaser or successor to our business where necessary in connection with a merger, acquisition, financing or sale of assets.

We require service providers that process personal information on our behalf to comply with appropriate contractual and security requirements.

International transfers

Some of our service providers may process personal information outside the United Kingdom.

Where personal information is transferred outside the UK, we will take appropriate steps to ensure that the transfer is lawful under applicable data protection law. This may include relying on an adequacy decision or using appropriate contractual safeguards such as the UK International Data Transfer Agreement or UK Addendum to the EU Standard Contractual Clauses.

Data retention

We retain personal information only for as long as reasonably necessary for the purposes for which it was collected, including to provide our services, maintain appropriate business and financial records, resolve disputes and comply with legal obligations.

Retention periods may vary depending on the type of information and the purpose for which it is processed.

Where we process personal information on behalf of a customer, we will generally retain or delete that information in accordance with the customer's instructions and the applicable customer agreement.

Security

We take reasonable technical and organisational measures to protect personal information against unauthorised access, loss, destruction, alteration or disclosure.

These measures may include access controls, authentication, encryption where appropriate, monitoring, logging and restrictions on access to personal information.

No internet-based service can be guaranteed to be completely secure, and we cannot guarantee absolute security of personal information.

Your rights

Depending on the circumstances and applicable law, you may have rights in relation to your personal information, including the right to:

• request access to the personal information we hold about you;
• request correction of inaccurate or incomplete information;
• request deletion of your personal information;
• request restriction of processing;
• object to certain processing;
• request transfer of your information to another organisation where applicable;
• withdraw consent where processing is based on consent; and
• object to or request information about certain automated decision-making.

These rights are subject to certain legal exceptions and limitations.

If we process your information solely on behalf of one of our customers, we may refer your request to that customer as the relevant controller.

Marketing communications

We may send you information about Liminal and our services where permitted by applicable law.

You can opt out of marketing communications at any time by using the unsubscribe mechanism provided in the communication or by contacting us.

We will continue to send essential service and transactional communications where necessary to provide the service.

Cookies

Our website may use cookies and similar technologies that are necessary to operate the website and provide basic functionality.

Where we use non-essential cookies or similar technologies that require consent under applicable law, we will request consent before using them.

You can control cookies through your browser settings and, where applicable, our cookie preferences.

Children's information

Liminal's services are intended for businesses and working professionals and are not directed at children.

We do not knowingly collect personal information from children through our services.

Changes to this policy

We may update this Privacy Policy from time to time to reflect changes to our services, technology, legal requirements or business practices.

When we make material changes, we will update the date at the top of this policy and, where appropriate, provide additional notice.

Contact us

If you have questions about this Privacy Policy or how Liminal processes personal information, you can contact us at:

If you are a candidate whose information has been processed through Liminal on behalf of a recruitment customer, you may also contact the organisation responsible for the relevant recruitment process.

Complaints

If you have concerns about how we have handled your personal information, please contact us first so that we can try to resolve the issue.

You also have the right to complain to the UK's data protection regulator:

Information Commissioner's Office (ICO)
Website: https://ico.org.uk/

The ICO's helpline and other contact details are available on its website.