Privacy Policy

Sky Talent ApS · CVR 43796003 · Effective: 13 May 2026

This Privacy Policy explains how Sky Talent ApS ("Sky Talent", "we", "us", or "our") collects, uses, discloses and protects personal data when you use our website skytalent.ai, our SaaS platform app.skytalent.ai (the "Service") and any related services.

We are committed to processing personal data in accordance with the EU General Data Protection Regulation (Regulation (EU) 2016/679, "GDPR"), the Danish Data Protection Act (databeskyttelsesloven) and other applicable laws.

1. Data Controller

The data controller responsible for processing your personal data is:

We have not appointed a Data Protection Officer (DPO), as we are not required to do so under Article 37 GDPR. You can contact us about any privacy matter at the email above.

2. Our Role: Controller and Processor

Depending on the relationship, Sky Talent acts in different roles under the GDPR:

  • Data controller: When you visit our website, contact us, create a customer account, subscribe to our Service, receive marketing from us, or apply for a job with us, we determine the purposes and means of the processing and act as data controller.
  • Data processor: When our business customers ("Customers") use the Service to assess candidates, employees or other test takers ("Test Takers"), the Customer is the data controller and Sky Talent processes the Test Taker's personal data on behalf of the Customer. The terms of that processing are governed by a separate Data Processing Agreement (DPA) entered into with the Customer.

If you are a Test Taker and want to exercise your rights regarding test data, please contact the Customer (the employer or organisation) that invited you to take the test. We will assist them as required by the DPA.

3. What Personal Data We Process

3.1 Visitors to our website

  • Technical data: IP address, browser type, device type, operating system, referrer, pages visited, time stamps.
  • Cookie and analytics data — see our Cookie Policy / consent banner for details.
  • Information you voluntarily submit via contact forms, demo requests or newsletter sign-up (name, email, company, message).

3.2 Customers and customer contacts

  • Identification and contact data: name, job title, company name, business email, business phone, address.
  • Account data: username, password (hashed), language preference, role/permissions.
  • Billing data: company name, VAT number, billing address, transaction history. Card details are processed directly by our payment provider and are not stored by Sky Talent.
  • Communication data: support requests, correspondence, meeting notes.
  • Usage data: log-ins, actions in the Service, feature usage, IP address, technical metadata.

3.3 Test Takers

When acting as data processor on behalf of a Customer, we typically process the following categories of Test Taker data:

  • Identification and contact data: name, email, and any identifier provided by the Customer (e.g. candidate ID).
  • Test data: responses to questions, time spent, completion status, scores, scale results (e.g. Big Five personality scores, AI readiness scores, aptitude scores) and derived reports.
  • Technical data: IP address, browser, device, log-in time stamps, session metadata.
  • Communication data: invitation and reminder emails.

Psychometric assessment results may, depending on context, be considered sensitive in nature. We do not process special categories of personal data (Article 9 GDPR) as part of our standard Service, and we instruct Customers not to upload such data to the Service.

4. Purposes and Legal Bases

We process personal data for the following purposes and on the following legal bases under Article 6 GDPR:

  • Providing the Service: to operate, maintain, and deliver the Service to Customers, including hosting tests, generating reports and providing access to results. Legal basis: performance of a contract (Article 6(1)(b)) for Customers; for Test Takers, the Customer's legal basis applies (typically legitimate interest or consent).
  • Account administration and support: to create and manage Customer accounts, authenticate users, and provide customer support. Legal basis: performance of a contract (Article 6(1)(b)).
  • Billing and accounting: to invoice Customers and comply with bookkeeping obligations under Danish law (bogføringsloven). Legal basis: legal obligation (Article 6(1)(c)) and performance of a contract (Article 6(1)(b)).
  • Service improvement and analytics: to analyse usage, troubleshoot, develop new features and improve the Service. We use aggregated and pseudonymised data where possible. Legal basis: legitimate interests (Article 6(1)(f)) — operating and improving our Service.
  • Security and abuse prevention: to detect, prevent and respond to fraud, abuse, security incidents and violations of our terms. Legal basis: legitimate interests (Article 6(1)(f)) and legal obligation (Article 6(1)(c)).
  • Marketing communications: to send newsletters and product updates to existing Customers and to prospects who have given consent. Legal basis: consent (Article 6(1)(a)) or legitimate interests (Article 6(1)(f)) within the limits of the Danish Marketing Practices Act (markedsføringsloven). You can unsubscribe at any time.
  • Compliance with legal obligations: to comply with applicable laws, court orders and requests from public authorities. Legal basis: legal obligation (Article 6(1)(c)).

5. Cookies and Tracking

Our website uses cookies and similar technologies. Non-essential cookies (analytics, marketing) are set only with your consent, which you can manage through our cookie banner. Essential cookies necessary for the Service to function may be used without consent under the ePrivacy rules. See our separate Cookie Policy for details.

6. Recipients and Disclosure

We may share personal data with the following categories of recipients:

  • Sub-processors and IT service providers: hosting providers, email delivery providers, payment providers, analytics providers, customer support tools, and similar processors who act on our instructions.
  • Customers: when we act as processor, we make Test Taker data available to the Customer who invited the Test Taker.
  • Professional advisors: lawyers, auditors, accountants under duty of confidentiality.
  • Public authorities: where required by law (e.g. SKAT, courts, police).
  • Successors: in connection with a sale, merger, restructuring or similar transaction involving Sky Talent, subject to appropriate safeguards.

We do not sell personal data to third parties.

7. International Transfers

We primarily process personal data within the European Economic Area (EEA). If we transfer personal data to a country outside the EEA, we ensure an adequate level of protection by relying on one of the following:

  • An adequacy decision from the European Commission;
  • Standard Contractual Clauses (SCCs) adopted by the European Commission;
  • Other appropriate safeguards under Chapter V GDPR, supplemented by technical and organisational measures where required.

You can obtain a copy of the relevant safeguards by contacting us at [email protected].

8. Retention

We retain personal data only for as long as necessary for the purposes for which it was collected, including to comply with legal obligations.

  • Customer account data: for the duration of the subscription and for up to 12 months after termination, unless a longer period is required.
  • Test Taker data: retained for the period instructed by the Customer in the DPA. By default, Test Taker data is deleted or anonymised within 12 months after test completion, unless the Customer specifies otherwise.
  • Accounting and invoice data: retained for 5 years from the end of the financial year, as required by the Danish Bookkeeping Act (bogføringsloven).
  • Marketing data: retained until you withdraw consent or object.
  • Log data: typically retained for up to 12 months for security and troubleshooting purposes.

9. Your Rights

Subject to applicable law, you have the following rights regarding your personal data:

  • Right of access (Article 15): obtain confirmation of whether we process your data and receive a copy.
  • Right to rectification (Article 16): have inaccurate or incomplete data corrected.
  • Right to erasure (Article 17): have your data deleted in certain circumstances.
  • Right to restriction (Article 18): request restriction of processing in certain circumstances.
  • Right to data portability (Article 20): receive your data in a structured, commonly used, machine-readable format.
  • Right to object (Article 21): object to processing based on legitimate interests or direct marketing.
  • Right to withdraw consent: where processing is based on consent, you may withdraw consent at any time without affecting the lawfulness of prior processing.

To exercise your rights, contact us at [email protected]. We may need to verify your identity before responding. We will reply within one month, with the possibility of a two-month extension for complex requests.

If you are a Test Taker, please address requests concerning test data to the Customer (the employer or organisation that invited you to the test). We will assist the Customer in fulfilling your request.

10. Right to Lodge a Complaint

You have the right to lodge a complaint with a supervisory authority. In Denmark, the competent authority is:

  • Datatilsynet (the Danish Data Protection Agency)
  • Carl Jacobsens Vej 35, 2500 Valby, Denmark
  • Phone: +45 33 19 32 00
  • Email: [email protected]
  • Website: www.datatilsynet.dk

11. Security

We implement appropriate technical and organisational measures to protect personal data against accidental or unlawful destruction, loss, alteration, unauthorised disclosure or access. Measures include encryption in transit (TLS/HTTPS), encryption at rest where appropriate, access controls, logging, regular backups, security testing and staff training. No method of transmission or storage is completely secure; we cannot guarantee absolute security.

12. Children

The Service is intended for use by businesses and adult professionals. We do not knowingly collect personal data from children under 16. If you believe we have collected data from a child, please contact us so we can delete it.

13. Changes to This Policy

We may update this Privacy Policy from time to time. The latest version will always be available at skytalent.ai. Where changes are material, we will notify Customers by email or via the Service before they take effect.

14. Contact

If you have questions or concerns about this Privacy Policy or our processing of personal data, please contact us: