bestpeople Privacy Policy

Effective Date: [27/11/2025]

Last Updated: [27/11/2025]

Introduction

BESTPEOPLE AI LTD, company number 16490804, registered at 111 Buckingham Palace Road, London, England, SW1W 0SR (the “Company”, “we”, “us” or “our”), is committed to protecting your privacy.

This Privacy Policy explains how we collect, use and share personal data when you use bestpeople, our expert referral and recruitment platform (the “Service”). The Service enables Experts to earn referral fees by sharing LinkedIn connection data, approving contacts and recommending candidates for roles. We then contact approved individuals, manage the recruitment process and pay referral bonuses when conditions are met.

We recognise the importance of privacy and comply with all applicable data protection laws, including the UK General Data Protection Regulation (UK GDPR), the EU GDPR, the Data Protection Act 2018 and the California Consumer Privacy Act (CCPA) where applicable.

By using the Service, you acknowledge that you have read and understood this Privacy Policy.

1. Scope

This Privacy Policy applies to the personal data we collect through:

• the bestpeople website, service, and platform.

• expert applications and onboarding processes.

• the LinkedIn data export (connections.csv) provided by Experts.

• referrals submitted by Experts.

• our communications with Experts and candidates.

• candidate information obtained from public LinkedIn profiles.

This Privacy Policy does not apply to any third party platforms such as LinkedIn or other career sites. You should review their privacy policies separately.

2. Information We Collect

To operate the Service, we collect and process the following types of personal data.

A. Expert Data

Expert profile data

• Full name.

• Email address.

• Location.

• Areas of expertise.

• LinkedIn profile URL.

• Information submitted during your application or onboarding.

  
  

LinkedIn connection data provided by Experts

Experts are required to request a data export from LinkedIn and provide us with the file called connections.csv. This contains:

• names of connections.

• job titles.

• company names.

• industries.

• connection dates.

• any other information included by LinkedIn in the export.

This data is your personal data, which you are entitled to share. Providing this file is essential for us to generate referral recommendations for you.

Referral activity

• names of individuals you approve or refer.

• communications you send in response to our referral emails.

• referral status and outcomes.

• payment history and eligibility.

B. Candidate Data

We collect candidate data from:

• Experts who recommend or approve them.

• Publicly available LinkedIn profiles.

• Communications between candidates and our team.

This may include:

• name, job title and career history.

• contact information if provided to us.

• publicly available LinkedIn data.

• recruitment notes, interview progression and hiring outcomes.

We retain candidate data to support referrals, improve role matching and operate the Service.

3. How We Use Your Information

We process personal data in order to:

• operate and provide the Service.

• generate personalised referral suggestions for Experts.

• enable Experts to approve or refer contacts.

• contact approved candidates about roles.

• communicate updates and progress notifications to Experts.

• track referrals, hiring outcomes and payments.

• prevent misuse or unauthorised access.

• comply with legal obligations and resolve disputes.

We do not use Expert data or candidate data for advertising, credit evaluation, resale or unrelated purposes.

4. Legal Bases for Processing (UK and EU GDPR)

We rely on the following legal bases:

Consent

You give explicit consent when you:

• submit an Expert application.

• upload your LinkedIn connections.csv file.

• approve individuals for outreach.

• opt in to identification as the referring Expert.

Legitimate interests

We process data to:

• improve and personalise the Service.

• contact approved candidates.

• maintain the security and integrity of the platform.

Contractual necessity

Certain processing is required to operate the referral programme and issue referral fees.

Legal obligations

We retain payment and referral records where required by law.

5. Candidate Outreach and Referrer Identity

When we contact a candidate, we normally inform them of the referring Expert’s name because this typically improves the response rate and establishes trust.

Experts may opt out of having their identity disclosed at any time by emailing support@findbestpeople.ai. In this case, we will anonymise your identity before contacting candidates.

6. Data Sharing

We do not sell personal data. We only share data as described below.

A. Clients

We may share:

• candidate information (CVs, LinkedIn profiles, notes).

• the referring Expert’s name, unless the Expert has opted out.

B. Payment providers

• To issue referral fees, we share necessary data with:

Stripe or any replacement secure payment processor.

C. Service providers

We may use third party tools for:

• secure data storage.

• analytics.

• email delivery.

• infrastructure hosting.

These providers process data strictly on our behalf and are not permitted to use it for their own purposes.

D. Business transfers

If we undergo a merger or acquisition, personal data may be transferred to the acquiring company under the same protections.

E. Legal requirements

We may disclose data where required by law or to protect our rights, property or the safety of users.

7. International Data Transfers

We may transfer personal data outside the UK and EU. Whenever this occurs, we implement appropriate safeguards such as:

• Standard Contractual Clauses (SCCs).

• the UK International Data Transfer Addendum.

• equivalent protections for other jurisdictions.

8. Your Rights and Choices

Depending on your location, you may have the following rights.

UK and EU GDPR rights

• Right of access to your personal data.

• Right of rectification of inaccurate data.

• Right of erasure in certain circumstances.

• Right to restrict processing.

• Right to object to certain types of processing.

• Right to data portability.

US privacy rights (where applicable)

• Right to know what data we collect.

• Right to request deletion.

• Right to opt out of the sale of data (we do not sell data).

• Right to non discrimination for exercising privacy rights.

To exercise any right, contact: support@findbestpeople.ai

9. Data Retention

We retain personal data only for as long as necessary for the following purposes:

• providing the Service.

• operating the referral and tracking system.

• complying with legal, accounting and tax obligations.

• resolving disputes and preventing fraud.

• maintaining a history of past referrals.

If you request deletion of your account, we will:

• delete your profile and connection data.

• retain only the minimal referral and payment history required for compliance or outstanding referral rights.

Candidate data may also be retained where this is necessary for the operation of the Service and matching accuracy.

10. Security

We implement commercially reasonable technical and organisational measures to protect personal data, including:

• secure access controls.

• limited employee access to data.

• regular system monitoring.

• secure infrastructure hosting.

Although we take reasonable precautions, no method of transmission is completely secure. You should take care when deciding what information to submit.

11. Changes to This Privacy Policy

We may update this Privacy Policy periodically. We will notify you of any material changes by email or through the Service.

Continued use of the Service after changes take effect constitutes acceptance of the updated Privacy Policy.

12. Contact Us

If you have questions, concerns or requests relating to your personal data, please contact:

Email: support@findbestpeople.ai

Address: 111 Buckingham Palace Road, London, England, SW1W 0SR

Data Protection Officer: Angus Hills

Email: angus@findbestpeople.ai