KANE POULTER | TALENT SOLUTIONS
Privacy Policy
Last updated: March 2026
1. Introduction
Kane Poulter Talent Solutions (“Kane Poulter”, “we”, “us” or “our”) is committed to protecting the personal data of everyone who interacts with us — whether as a prospective client, a candidate for a role we are managing, a visitor to our website, or a contact in our professional network.
This Privacy Policy explains what personal data we collect, why we collect it, how we use and protect it, and your rights in relation to it. It applies to all personal data collected through our website (kanepoulter.com), by email, through LinkedIn, and via our applicant tracking system RecruitCRM.
We operate in accordance with the Personal Data (Privacy) Ordinance (Cap. 486) of Hong Kong (“PDPO”) and, where applicable, the UK General Data Protection Regulation (“UK GDPR”) and related legislation for contacts based in the United Kingdom.
2. Who we are
Kane Poulter Talent Solutions is a Hong Kong-based HR and talent acquisition consulting and advisory firm. Our registered business address is:
Office 3906, 39th Floor, The Center
99 Queens Road Central
Central, Hong Kong
For any privacy-related enquiries, please contact us at:
Email: contact@kanepoulter.com
Phone: +852 5721 1900
Website: kanepoulter.com
3. Personal data we collect
We collect the following categories of personal data, depending on how you interact with us:
3.1 Prospective and existing clients
• Name, job title and company name
• Business email address and telephone number
• Information shared during conversations, meetings or correspondence relating to a potential or existing engagement
3.2 Candidates (individuals applying for roles we are managing)
• Name and contact details (email, phone number, LinkedIn profile)
• CV and career history, including employment history, qualifications and skills
• Information provided during interviews, assessments or correspondence
• Any additional information you choose to share with us in connection with a specific role
3.3 Website visitors
• Analytics data collected automatically via Google Analytics 4, including pages visited, time on site, device type, browser, approximate geographic location and traffic source
• Information submitted via our website contact form, including name, email address and the content of your message
3.4 LinkedIn contacts
• Name, job title, company and any information you share with us through LinkedIn messages or connection requests
4. How we collect personal data
We collect personal data through the following channels:
• Directly from you via our website contact form
• Directly from you via email correspondence
• Through LinkedIn when you connect with us, send a message or respond to our outreach
• Through RecruitCRM when you apply for a role we are managing, either directly or via a job board
• Automatically when you visit our website, via Google Analytics 4 (see Section 8 for details on cookies and analytics)
5. Why we use your personal data
We use personal data for the following purposes:
5.1 Clients and prospective clients
• To respond to your enquiry and discuss how we may be able to help
• To provide and manage our consulting and advisory services
• To send relevant market insights, service updates or information we believe may be of interest to you
• To fulfil our contractual and legal obligations
5.2 Candidates
• To assess your suitability for a specific role we are managing on behalf of a client
• To share your details with our client where you have consented or where it is necessary to progress your application
• To contact you regarding current or future opportunities that may be relevant to your experience
• To maintain a record of our interactions in RecruitCRM
5.3 Website visitors
• To understand how visitors use our website and improve its content and performance
• To respond to contact form enquiries
6. Legal basis for processing
Under the PDPO, we are required to collect personal data fairly and for lawful purposes. We rely on the following bases for processing:
• Contractual necessity — where processing is required to perform a contract with you or to take steps prior to entering into one
• Legitimate interests — where we have a legitimate business reason to process your data, such as maintaining client relationships or contacting candidates about relevant opportunities, and that interest is not overridden by your rights
• Consent — where you have actively provided your data to us for a specific purpose, such as submitting a contact form or applying for a role
• Legal obligation — where we are required to process data to comply with applicable law
For contacts based in the UK, we additionally rely on the lawful bases set out in the UK GDPR.
7. Who we share your data with
We do not sell personal data to any third party. We may share personal data in the following limited circumstances:
• With our clients, where you are a candidate and we are managing your application for a specific role — always with your knowledge and where appropriate your consent
• With our technology providers, including RecruitCRM (our applicant tracking system) and Google (Google Analytics), who process data on our behalf under data processing agreements
• With professional advisers (such as legal or financial advisers) where necessary
• Where required by law or a regulatory authority
All third parties who process data on our behalf are required to handle it securely and in accordance with applicable data protection law.
8. Cookies and website analytics
Our website uses Google Analytics 4 to collect anonymised data about how visitors use the site. This includes information such as pages viewed, time spent on the site, traffic sources and approximate location. This data is aggregated and does not identify you personally.
Google Analytics uses cookies — small text files placed on your device — to collect this information. You can opt out of Google Analytics tracking by using the Google Analytics Opt-out Browser Add-on, available at tools.google.com/dlpage/gaoptout.
Our website may also use functional cookies necessary for the site to operate correctly. You can manage your cookie preferences through your browser settings at any time.
9. How long we keep your data
We retain personal data only for as long as necessary for the purposes for which it was collected, or as required by law. Our standard retention periods are:
• Client data: for the duration of the engagement and up to seven years thereafter, in accordance with our legal and contractual obligations
• Candidate data: up to two years from the date of last contact, after which data is reviewed and deleted unless there is an ongoing legitimate reason to retain it
• Website enquiries: up to two years from the date of your enquiry
• Website analytics data: as governed by Google Analytics retention settings (default 14 months)
You may request deletion of your data at any time — see Section 11 for your rights.
10. How we protect your data
We take the security of your personal data seriously and implement appropriate technical and organisational measures to protect it against unauthorised access, loss, destruction or disclosure. These measures include:
• Secure, password-protected systems for storing client and candidate data
• Use of reputable third-party platforms (RecruitCRM, Google Workspace) with their own security certifications and data processing agreements
• Limiting access to personal data to those who need it to perform their role
In the event of a data breach that is likely to result in a risk to your rights or interests, we will notify you and the relevant authorities as required by applicable law.
11. Your rights
Under the PDPO and, where applicable, UK GDPR, you have the following rights in relation to your personal data:
• Right of access — to request a copy of the personal data we hold about you
• Right of correction — to request that inaccurate or incomplete data is corrected
• Right to erasure — to request that we delete your personal data, subject to any overriding legal obligations
• Right to object — to object to our processing of your data for direct marketing or where we rely on legitimate interests
• Right to restriction — to request that we restrict processing of your data in certain circumstances
• Right to data portability — to receive your data in a structured, commonly used format (UK GDPR contacts)
To exercise any of these rights, please contact us at matt@kanepoulter.com. We will respond to your request within 30 days. We may need to verify your identity before processing your request.
12. International data transfers
Kane Poulter operates primarily in Hong Kong and APAC. Where personal data is transferred outside Hong Kong — for example, to clients or candidates located in the UK or other jurisdictions — we ensure that appropriate safeguards are in place in accordance with PDPO requirements and, where applicable, UK GDPR transfer mechanisms.
Our third-party platforms (RecruitCRM, Google Analytics) may process data on servers located outside Hong Kong. Each of these providers operates under appropriate data protection frameworks and standard contractual clauses where required.
13. Third-party links
Our website may contain links to third-party websites including LinkedIn. We are not responsible for the privacy practices of those websites and encourage you to review their privacy policies before providing any personal data.
14. Changes to this policy
We may update this Privacy Policy from time to time to reflect changes in our practices, technology or legal requirements. The date at the top of this page will always reflect when it was last updated. We encourage you to review this policy periodically.
Continued use of our website or services after any update constitutes acceptance of the revised policy.
15. Contact us and how to make a complaint
If you have any questions about this Privacy Policy or how we handle your personal data, please contact us:
Kane Poulter Talent Solutions
Office 3906, 39th Floor, The Center
99 Queens Road Central, Central, Hong Kong
Email: contact@kanepoulter.com
Phone: +852 5721 1900
Website: kanepoulter.com
If you are based in Hong Kong and believe we have not handled your personal data in accordance with the PDPO, you have the right to lodge a complaint with the Office of the Privacy Commissioner for Personal Data (PCPD):
Office of the Privacy Commissioner for Personal Data
Website: www.pcpd.org.hk
Phone: +852 2827 2827
If you are based in the United Kingdom, you have the right to lodge a complaint with the Information Commissioner’s Office (ICO):
Information Commissioner’s Office
Website: www.ico.org.uk
Phone: 0303 123 1113
Kane Poulter Talent Solutions | contact@kanepoulter.com | +852 5721 1900 | kanepoulter.com | Hong Kong