Version 3.1 · Effective 14 July 2026 · Supersedes all earlier versions
The short version. We publish job listings, and we run an intelligence product (the GTM Talent Tracker) that maps the senior commercial roles that exist at European hard-tech companies. The Tracker is de-identified by design: it contains no personal names and no links to personal profiles. But we accept that a role such as “Chief Commercial Officer at Company X” can point to one identifiable person, so we treat that information as personal data and give you the full rights below — including a one-click way to be removed.
Want out? Use Your data rights or email ufukgur@hardtechcareers.com. We do not require you to prove you are in our data before we look.
HardTech Careers (“we”) is the controller of the personal data described here. Contact: ufukgur@hardtechcareers.com.
We have not appointed a Data Protection Officer. We keep this under review: if the scale or nature of our processing changes such that Article 37 GDPR requires one, we will appoint one and publish their details here. In the meantime, every data-protection question, request or complaint goes directly to ufukgur@hardtechcareers.com and is answered by us.
Where we have no establishment in a given region, we appoint an Article 27 representative for the EU and for the UK. Their details are available on request from the DPO address above.
For the GTM Talent Tracker we collect, from publicly accessible professional sources — company websites and leadership/team pages, company newsrooms and press releases, applicant-tracking systems and public job boards, industry press, and public company registers and funding announcements:
What we deliberately do NOT store or publish: personal names; links to personal profiles (e.g. LinkedIn /in/ URLs); photographs; personal email addresses or phone numbers; home addresses; salary; age, gender, ethnicity, health, religion, political opinions, trade-union membership, sexual orientation or any other special-category data.
This is enforced in code, not just in policy. Names are discarded at the point of collection and cannot be written to our database: the write layer rejects any record carrying a name, and a privacy check runs on every build and blocks publication if a name or a personal profile link is detected. On 14 July 2026 we completed a full minimisation pass, permanently erasing every remaining name from our working database and from all historical backups. Our records now contain no personal names at all.
We do not scrape private or logged-in areas of any website, we do not circumvent access controls or paywalls, and we do not buy personal-data lists.
Removing names does not, by itself, put our records outside data-protection law, and we do not claim that it does. A record such as “the Chief Commercial Officer of a named company” may still indirectly identify one individual, particularly at a small company where only one person holds that role. We therefore continue to treat Tracker records as personal data, apply the GDPR to them in full, and give you the rights set out in §6 — even though we hold no name for you.
What de-identification does achieve is data minimisation (Art. 5(1)(c)): we hold the least information capable of describing the market, and nothing that would let us — or a subscriber — build a profile of you as a person.
| Purpose | Legal basis |
|---|---|
| Publishing job listings and operating the site | Legitimate interests; contract where you subscribe |
| Operating the GTM Talent Tracker (market-structure intelligence: which commercial roles exist, where, and how they change) | Legitimate interests, Art. 6(1)(f) |
| Billing and account administration | Contract; legal obligation (tax) |
| Analytics | Consent (you can decline; the site works either way) |
We have carried out and documented a written Legitimate Interests Assessment (LIA) for the Tracker. In outline:
You can request a plain-English summary of the LIA from ufukgur@hardtechcareers.com.
Where we obtain information from public sources rather than from you, Article 14 would normally require us to notify you directly. We rely on the disproportionate-effort exemption in Article 14(5)(b), because we do not hold contact details for the people concerned and obtaining them would mean collecting more personal data than the product needs. The exemption is conditional, and we meet those conditions by (a) publishing this notice prominently and openly, and (b) operating a genuine, no-questions-asked objection and removal channel.
We do not evaluate individuals. We do not score, rank or rate any person, we make no automated decisions that produce legal or similarly significant effects, and we do not offer any “who is likely to leave” or similar predictive product about named individuals. Our hiring-likelihood signals apply to companies, never to people.
We maintain Records of Processing Activities (ROPA) under Article 30 and have completed a Data Protection Impact Assessment (DPIA) under Article 35 for the Tracker.
You have the right to access your data, to rectify it, to erase it, to restrict or object to our processing, and to data portability. Because we process the Tracker on legitimate interests, you have an absolute right to object under Article 21 — and we do not contest it.
To ask “am I in your data?” or to be removed: use the Your data rights form, or email ufukgur@hardtechcareers.com. We respond within 30 days, usually far sooner. We will not ask you to justify the request, and we will not ask for identity documents unless we genuinely cannot locate the record without them.
How we find your record when we hold no name. Because our records are de-identified, we cannot search for you by name — there is nothing to search. We locate a record instead by company and role (for example, “VP Sales at [company], 2024–2026”). So please tell us the employer and the position; that is all we need, and it is deliberately less information than a name would be. If a record matching that role exists, we will tell you exactly what it contains and, on request, delete it and suppress it from re-collection.
You may also complain to your national supervisory authority — in the UK, the Information Commissioner’s Office (ico.org.uk); in the EU, the authority in your country of residence.
We share the de-identified Tracker feed with paying subscribers, under terms that prohibit re-identification and redistribution (see Terms). We use processors for hosting, email and payments, each under a written Data Processing Agreement with appropriate transfer safeguards (SCCs / UK IDTA) where any processing occurs outside the EEA/UK. We do not sell personal data, and we do not permit advertising or ad-targeting against it.
The subscriber feed is served only through an access-gated endpoint. The underlying working database is never deployed to the public site and is excluded from every release build by an automated check. Access is limited to those who need it.
We will post material changes here and update the version and date at the top.
We do not use advertising or cross-site retargeting cookies, and we do not sell your data to advertisers. We use Google Analytics 4 to understand how the site is used; it sets first-party analytics cookies/identifiers and processes usage data (pages viewed, device and browser type, referral source, and an approximate location derived from a truncated IP address) on our behalf, with Google acting as a processor. Analytics is consent-gated using Google Consent Mode: on your first visit a cookie banner asks whether to allow analytics, and no analytics cookies are set unless you choose Accept analytics. If you decline, analytics stays off; you can change your mind by clearing your browser storage. We use your browser’s local storage to remember the roles you save and the companies you follow — this stays on your device and is never transmitted to us. You can opt out of analytics using Google’s opt-out browser add-on or your browser’s privacy controls, and you can clear all of this at any time by clearing your browser storage.
Listings and company profiles are compiled from publicly available sources (employer career pages, job boards, and public funding news). “Why this company” summaries reflect publicly expressed, positive sentiment and link to their sources. If you are an employer, recruiter, or individual and believe a listing or profile contains inaccurate information, or you would like it corrected or removed, contact us and we will act promptly.
This is a professional careers platform intended for adults. It is not directed at children, and we do not knowingly collect data from anyone under 16.
The Service is operated by The Strategic Narrative Advisory trading as HardTech Careers. Contact: ufukgur@hardtechcareers.com. Our earlier privacy policies (v1, v2) are superseded by this notice; the substantive protections in them — on cookies, job listings, corrections, children and security — are carried forward above.
This notice describes our practice; it is not legal advice. HardTech Careers is not a law firm.