GDPR Privacy Notice

Effective Date: 7/23/2026

Last Updated: 7/24/2026


Honey Sparks Holdings LLC ("Honey Sparks Holdings," "HSH," "we," "our," or "us") respects the privacy rights of individuals located in the European Economic Area ("EEA"), the United Kingdom ("UK"), and Switzerland. Honey Sparks Holdings LLC conducts recruiting and talent acquisition services under its registered fictitious name, HSH Talent. HSH Talent is not a separate legal entity. References to "HSH Talent" in this Notice refer to Honey Sparks Holdings LLC. This GDPR Privacy Notice supplements our Privacy Policy and explains how we process personal data when the General Data Protection Regulation ("GDPR"), the UK GDPR, or similar data protection laws apply. If there is any conflict between this Notice and our Privacy Policy regarding GDPR rights, this Notice will govern for individuals protected by applicable European privacy laws.


1. Who We Are

Data Controller

Honey Sparks Holdings LLC

Doing Business As HSH Talent

Website: www.honeysparksholdings.com

Email: info@honeysparksholdings.com


For purposes of applicable European privacy laws, Honey Sparks Holdings LLC generally acts as the Data Controller for personal data collected through our website, recruiting activities, consulting services, and business operations.


In some situations, we may process personal data on behalf of a client. In those cases, we may act as a Data Processor under the client's instructions.


2. Personal Data We Collect


Depending on your interaction with us, we may collect:

Identity Information

  • Name
  • Email address
  • Telephone number
  • Mailing address
  • Company
  • Job title

Recruiting Information

  • Résumé or CV
  • Employment history
  • Education
  • Professional certifications
  • Skills
  • References
  • Interview notes
  • Salary expectations
  • Employment preferences
  • Work authorization information
  • Candidate communications

Business Information

  • Client inquiries
  • Consultation requests
  • Project information
  • Contract information
  • Business correspondence

Technical Information

  • IP address
  • Browser type
  • Device type
  • Operating system
  • Website usage
  • Cookie identifiers
  • Analytics information

3. How We Collect Personal Data

We may collect personal data:

  • Directly from you
  • Through website forms
  • Through email or telephone communications
  • During consulting engagements
  • During recruiting activities
  • Through referrals
  • From publicly available professional sources
  • From prospective employers or clients
  • Through recruiting platforms
  • Through LinkedIn or similar professional networking platforms
  • Through cookies and website analytics

4. Lawful Bases for Processing

Where GDPR applies, we process personal data only when a lawful basis exists.

Consent

We process information when you voluntarily:

  • Submit a contact form
  • Apply for employment opportunities
  • Subscribe to communications
  • Consent to optional cookies

You may withdraw consent at any time.

Performance of a Contract

We process information when necessary to:

  • Perform consulting services
  • Deliver recruiting services
  • Take steps before entering into a contract
  • Manage client relationships

Legitimate Interests

We may process information for legitimate business interests including:

  • Recruiting activities
  • Candidate evaluation
  • Client relationship management
  • Website administration
  • Business development
  • Fraud prevention
  • Information security
  • Internal administration
  • Responding to inquiries
  • Improving our services

When relying on legitimate interests, we consider the rights and freedoms of affected individuals.

Legal Obligations

We may process information when necessary to:

  • Comply with applicable law
  • Meet regulatory obligations
  • Respond to lawful governmental requests
  • Protect legal rights
  • Resolve disputes

5. How We Use Personal Data

We may use personal data to:

  • Respond to inquiries
  • Provide consulting services
  • Recruit candidates
  • Match candidates with employers
  • Schedule meetings
  • Communicate regarding services
  • Manage client relationships
  • Maintain recruiting records
  • Improve our website
  • Improve our business operations
  • Detect fraud
  • Maintain security
  • Comply with legal obligations

6. Automated Processing

We may use technology to automate routine business processes, including:

  • Scheduling
  • Customer relationship management
  • Recruiting workflows
  • Applicant tracking
  • Administrative tasks
  • Business communications

We do not intend to make solely automated decisions that produce legal or similarly significant effects regarding employment opportunities without appropriate human involvement.

7. Who We Share Data With

We may share personal data with:

  • Clients
  • Prospective employers
  • Technology providers
  • Customer relationship management providers
  • Applicant tracking providers
  • Cloud hosting providers
  • Email providers
  • Analytics providers
  • Professional advisors
  • Legal authorities when required by law

Service providers process information under contractual obligations designed to protect personal data.

8. International Transfers

Our business operates primarily in the United States.

If you access our services from outside the United States, your personal data may be transferred to, processed, or stored in the United States or other countries where our service providers operate.

Where required by law, we implement appropriate safeguards, which may include:

  • Data Processing Agreements
  • Standard Contractual Clauses (where applicable)
  • Other legally recognized transfer mechanisms

9. Data Retention

We retain personal data only for as long as reasonably necessary to:

  • Provide requested services
  • Maintain recruiting records
  • Meet legal obligations
  • Resolve disputes
  • Enforce agreements
  • Protect legal rights

Retention periods vary depending upon the type of information collected and applicable legal requirements.

Additional information may be available in our Data Retention Policy.

10. Your GDPR Rights

Subject to applicable law, you may have the right to:

  • Request access to your personal data
  • Request correction of inaccurate information
  • Request deletion ("Right to be Forgotten")
  • Request restriction of processing
  • Object to processing based on legitimate interests
  • Withdraw consent
  • Request data portability
  • Object to direct marketing
  • Request human review of certain automated decisions where applicable
  • Lodge a complaint with your local supervisory authority

11. Exercising Your Rights

To exercise your privacy rights, contact us at:

Email: info@honeysparksholdings.com

Please include:

  • Your name
  • Your contact information
  • The nature of your request
  • Enough information for us to verify your identity

We may request additional information before fulfilling your request.

We will respond within the timeframes required by applicable law.

12. Cookies

Our website uses cookies and similar technologies.

Where required by GDPR, we request consent before placing non-essential cookies on your device.

For additional information, please review our:

  • Cookie Policy
  • Privacy Policy

13. Security

We use reasonable administrative, technical, and organizational safeguards designed to protect personal data.

These safeguards may include:

  • Access controls
  • Encryption where appropriate
  • Multi-factor authentication
  • Vendor due diligence
  • Security monitoring
  • Role-based permissions
  • Employee confidentiality obligations

No method of transmission or storage is completely secure, and we cannot guarantee absolute security.

14. Third-Party Websites

Our website may contain links to third-party websites and services.

We are not responsible for their privacy practices.

Please review the privacy policies of those third parties before providing personal information.

15. Updates to This Notice

We may update this GDPR Privacy Notice from time to time to reflect changes in:

  • Applicable law
  • Business practices
  • Technology
  • Services
  • Regulatory guidance

The revised version will be posted on this page with an updated "Last Updated" date.

16. Contact Information

Honey Sparks Holdings LLC

Doing Business As HSH Talent

Website: www.honeysparksholdings.com

Email: info@honeysparksholdings.com

If you believe we have not addressed your concerns, you may also have the right to lodge a complaint with the data protection authority in your country of residence within the European Economic Area, the United Kingdom, or Switzerland.