1. Who we are

Noventis 26 Ltd trading as Cuebrix Group (“Cuebrix”, “we”, “us” or “our”) is a recruitment and talent acquisition business. For the purposes of UK data protection law, Noventis 26 Ltd is the data controller of the personal information described in this Privacy Notice unless we state otherwise.

Company number: 17410681

Registered office: 17, College House King Edwards Road, Ruislip, United Kingdom, HA4 7AE

Privacy contact: privacy@cuebrix.group

This Privacy Notice explains how we collect, use, share, retain and protect personal information relating to candidates, prospective candidates, clients, prospective clients, business contacts, website visitors and other individuals who interact with us.

2. Who this Privacy Notice applies to

This Privacy Notice applies to personal information we process about: candidates and prospective candidates, including people we identify or approach about employment or contract opportunities; individuals who apply for a role through Cuebrix or provide a CV or professional profile to us; employees, representatives and contacts of clients, prospective clients, suppliers and other business partners; people who contact us, attend our events, respond to our communications or subscribe to updates; visitors to cuebrix.group and users of our online forms, tools or services; and referees and other individuals whose details are provided to us in connection with recruitment.

Where a client or another organisation is independently responsible for deciding how your information is used, that organisation may also be a separate data controller and its own privacy notice will apply.

3. Personal information we may collect

Depending on how you interact with us, we may collect and process the following categories of personal information: Identity information: name, title, date of birth where relevant, and information used to verify identity. Contact information: email address, telephone number, postal address, location, company, job title and professional contact details.

Recruitment and professional information: CV, employment history, job titles, skills, qualifications, professional memberships, portfolio or work samples, career interests, preferred roles, availability, location preferences, salary or rate expectations and work eligibility information.

Application and assessment information: roles considered or applied for, interview notes, recruiter notes, client feedback, assessment results, communications and information used to assess suitability for opportunities.

Public professional information: information made available through professional networking sites, company websites, job boards, recruitment databases, professional directories and other lawful public sources.

Client and business contact information: organisation, role, business contact details, recruitment requirements, communications, meeting notes and details relating to our commercial relationship.

Marketing information: preferences, responses to campaigns, event attendance, newsletter subscriptions, opt-outs and suppression records. Technical and usage information: IP address, browser and device information, website activity, cookies and similar technologies where used. Special category information: information revealing matters such as health, racial or ethnic origin, religious or philosophical beliefs, trade union membership, sexual orientation or other protected information, but only where it is relevant, lawful and necessary for a specific purpose or where you choose to provide it.

Criminal offence information: only where lawful, necessary and appropriate for the role or service concerned and where the required legal conditions are met. Please avoid providing information that is not relevant to your recruitment or business interaction with us.

4. How we collect personal information

We may collect personal information directly from you when you submit a CV, complete a form, speak with a member of our team, communicate with us by email, telephone or social media, attend an event, apply for an opportunity or otherwise interact with us.

We may also obtain personal information from other lawful sources, including: professional networking platforms such as LinkedIn; job boards, recruitment databases and talent platforms; public company websites and professional directories; referrals and recommendations; clients, suppliers and business partners; references and background-check providers where appropriate; and other publicly available or commercially available sources that we are permitted to use.

Where we obtain your personal information from another source rather than directly from you, we will provide privacy information as required by law.

5. Why we use personal information and our lawful bases

We only process personal information where we have a lawful basis. Depending on the activity, we may rely on one or more of the following bases: consent; taking steps at your request before entering into a contract; performance of a contract; compliance with a legal obligation; and our legitimate interests or those of another organisation, provided those interests are not overridden by your rights and interests.

Our principal processing activities include:

Purpose	Typical information	Typical lawful basis
Identifying, sourcing and contacting potential candidates	Professional, contact and public profile information	Legitimate interests
Assessing suitability and matching candidates with opportunities	CV, skills, experience, preferences, recruiter notes and assessment information	Legitimate interests; pre-contract steps where applicable
Submitting or discussing candidates with clients	Relevant candidate profile and recruitment information	Legitimate interests; pre-contract steps; consent where specifically required
Managing applications, interviews and recruitment processes	Application, communication and assessment information	Legitimate interests; pre-contract steps
Verifying information, references and right to work where required	Identity, employment, qualification and verification information	Legal obligation; legitimate interests; pre-contract steps
Providing recruitment services to clients	Client requirements, contact details, candidate and placement information	Contract; legitimate interests
Managing client and supplier relationships	Business contact and commercial information	Contract; legitimate interests
Operating, securing and improving our website and systems	Technical, usage and security information	Legitimate interests; consent where required for non-essential cookies
Sending relevant business-to-business marketing	Business contact and marketing information	Legitimate interests where permitted; consent where required
Meeting legal, regulatory, accounting or compliance obligations	Relevant records depending on the obligation	Legal obligation; legitimate interests
Establishing, exercising or defending legal claims	Relevant business, recruitment and communication records	Legitimate interests; legal obligations where applicable

Where we rely on legitimate interests, our interests may include operating and developing our recruitment business, identifying and placing suitable talent, responding to client hiring requirements, maintaining business relationships, protecting our systems, preventing fraud and promoting relevant services. We assess whether the processing is necessary and proportionate and balance our interests against the rights and expectations of the individuals concerned.

6. Recruitment, candidate sourcing and referrals

Cuebrix may identify prospective candidates even where they have not applied directly to us. We may use professional information from sources such as LinkedIn, job boards, recruitment platforms, professional directories, referrals and publicly available business information to identify people whose skills or experience may be relevant to a role.

We may contact prospective candidates about specific or potentially relevant opportunities. We will provide appropriate privacy information and respect requests not to be contacted.

We will not normally provide a full candidate profile or CV to a prospective employer without taking reasonable steps to ensure that the disclosure is appropriate and connected to a genuine recruitment purpose. The extent of information shared will depend on the stage and nature of the recruitment process.

7. AI, talent intelligence and automated technologies

Cuebrix may use artificial intelligence, machine learning, search, matching, ranking, analytics and other automated technologies to support recruitment and talent acquisition activities. These tools may help us identify potentially relevant candidates, structure or enrich professional information, compare skills and experience with role requirements, prioritise search results, generate summaries, support communications or reduce administrative work.

Where these tools are used to support a recruitment decision, Cuebrix aims to maintain appropriate human oversight and to use automation in a fair, proportionate and transparent manner. We do not intend to make a decision that has a legal or similarly significant effect on an individual solely by automated means without applying the safeguards required by law.

If we use solely automated decision-making in circumstances where the law requires additional safeguards, we will provide appropriate information about the decision, enable you to make representations, provide access to human intervention where required and allow you to contest the decision.

We also seek to assess the suitability of technology used in recruitment, including risks relating to accuracy, bias, security, transparency and the use of personal information. We do not intentionally use candidate personal information to train public generative AI models unless this has been specifically assessed, lawfully justified and transparently communicated.

8. Special category and criminal offence information

We will only process special category personal information or criminal offence information where we have both a lawful basis and the additional legal condition required by UK data protection law.

This may arise, for example, where information is needed to make reasonable adjustments, meet employment or equality obligations, undertake legally permitted vetting, establish or defend legal claims, or where you have given explicit consent and consent is an appropriate legal basis.

We will not use protected characteristics as a basis for unfairly excluding candidates from opportunities.

9. Marketing communications

We may send relevant information about Cuebrix services, events, recruitment insights or other business communications to clients, prospective clients and professional business contacts where permitted by law.

For business contacts at limited companies and other corporate organisations, we may rely on legitimate interests for relevant business-to-business marketing where electronic marketing consent is not required. Where the law requires consent, including in relation to certain individual subscribers, sole traders or partnerships, we will obtain the appropriate consent or use another legally permitted route.

Every individual has the right to object to the use of their personal information for direct marketing. You can opt out at any time using the unsubscribe option in a marketing email or by contacting hello@cuebrix.group. We may retain limited information on a suppression list so that we can respect your preference and avoid contacting you again for marketing.

10. Who we share personal information with

We may share personal information where necessary and lawful with: clients and prospective employers in connection with genuine recruitment opportunities; technology providers supporting our website, email, cloud hosting, CRM, applicant tracking, analytics, communications, recruitment and talent-search activities; job boards, professional networking platforms and recruitment technology providers where relevant; professional advisers such as accountants, lawyers, insurers and auditors; background screening, reference, identity or right-to-work providers where appropriate; regulators, courts, law enforcement, government authorities or other parties where disclosure is required or permitted by law; potential buyers, investors or advisers in connection with a merger, acquisition, reorganisation or sale of all or part of our business; and other parties where you ask us to share information or where we have another lawful basis to do so.

Where a supplier processes personal information on our behalf, we require appropriate contractual and security protections. Some recipients, such as clients considering a candidate for a role, may process the information as independent data controllers.

11. International transfers

Some of the organisations and technology providers we use may process personal information outside the United Kingdom. Where personal information is transferred internationally, we take steps to ensure that an appropriate legal transfer mechanism is used where required, such as UK adequacy regulations, the UK International Data Transfer Agreement, the UK Addendum to approved Standard Contractual Clauses or another lawful safeguard.

You may contact us if you would like further information about the safeguards applying to a relevant international transfer.

12. How long we keep personal information

We do not keep personal information for longer than we reasonably need it. Retention periods depend on the purpose, the nature and sensitivity of the information, legal or regulatory requirements, the risk of harm from unauthorised use or disclosure and whether the purpose can be achieved in another way.

Unless a different period is required or justified, our intended retention approach is: candidate and prospective candidate records: generally up to 24 months after the last meaningful recruitment interaction, unless we agree or have a lawful reason to keep the information for longer; placement, contractual, invoicing and core client transaction records: generally up to six years after the relevant relationship or transaction, where needed for contractual, tax, accounting or legal purposes; prospective client and business-development records: kept while the relationship or opportunity remains relevant, subject to periodic review and any objection or opt-out; marketing suppression records: retained as necessary to ensure that an opt-out or objection continues to be respected; website and technical records: retained according to operational, security and cookie-management requirements; and legal or compliance records: retained for as long as reasonably necessary to meet the relevant obligation or establish, exercise or defend legal claims.

We may anonymise information so that it can no longer identify you. Anonymised information may be retained and used for statistical, analytical and business-improvement purposes.

13. Cookies and website technologies

Our website may use cookies and similar technologies to operate essential functionality, improve performance, understand website usage and support relevant marketing or analytics. Where consent is required for non-essential cookies or similar technologies, we will request it through our cookie controls.

Our Cookie Notice or cookie-management tool should provide further information about the technologies actually used on cuebrix.group and how preferences can be changed.

14. Data security

We use appropriate technical and organisational measures designed to protect personal information against accidental or unlawful destruction, loss, alteration, unauthorised disclosure or access. Measures may include access controls, authentication, encryption where appropriate, backups, supplier controls, security monitoring and policies governing the handling of personal information.

No internet or information system can be guaranteed to be completely secure. We therefore continually assess security risks and adjust safeguards where appropriate.

15. Your data protection rights

Depending on the circumstances, UK data protection law may give you the right to: ask whether we process your personal information and obtain a copy of it; ask us to correct inaccurate or incomplete personal information; ask us to erase personal information in certain circumstances; ask us to restrict the processing of personal information in certain circumstances; object to processing based on legitimate interests; object at any time to the use of your personal information for direct marketing; receive certain personal information in a portable format where the right to data portability applies; withdraw consent at any time where we rely on consent, without affecting processing carried out before withdrawal; and exercise rights and safeguards that apply to qualifying automated decisions, including making representations, requesting human intervention where applicable and contesting a decision.

These rights are not absolute and may be subject to legal exceptions. We may need to verify your identity before responding to a request.

16. How to exercise your rights or complain

To exercise a data protection right or ask a question about this Privacy Notice, contact us at privacy@cuebrix.group.

You also have the right to complain to the UK Information Commissioner’s Office (ICO). We would welcome the opportunity to address your concern first, but you are not required to contact us before raising a concern with the ICO. Current contact and complaints information is available at ico.org.uk.

17. Links and third-party services

Our website or communications may contain links to websites, platforms or services operated by third parties. Their handling of personal information is governed by their own privacy notices and is not controlled by Cuebrix unless we expressly state otherwise.

18. Cloudflare Turnstile

We use Cloudflare Turnstile on certain forms and areas of our website to help protect Cuebrix Group against spam, automated submissions, abuse and other malicious activity.

Turnstile operates in the background and may process limited technical information about your device and connection, including your IP address, browser and user-agent information, technical connection characteristics and information relating to the website page being accessed. This information is used to assess whether website activity is likely to originate from a legitimate user or an automated bot.

Cloudflare processes this information on our behalf to provide the Turnstile security service and may also process certain technical signals for its own legitimate interests in improving its bot-detection technology.

Turnstile is used for website security purposes and is not used by Cuebrix Group to advertise to you, profile you for marketing purposes or make recruitment decisions about you.

For further information about how Cloudflare processes information through Turnstile, please see Cloudflare’s Turnstile Privacy Addendum.

19. Changes to this Privacy Notice

We may update this Privacy Notice from time to time to reflect changes to our services, technology, legal obligations or processing activities. The latest version will be published on our website with the date of the most recent update. Where a change materially affects how we use personal information, we will take additional steps to bring it to the attention of affected individuals where appropriate.

20. Contact

Noventis 26 Ltd trading as Cuebrix Group

Company number: 17410681

Registered office: 17, College House King Edwards Road, Ruislip, United Kingdom, HA4 7AE

Email: hello@cuebrix.group

Website: https://www.cuebrix.group

Cuebrix Group | Privacy Notice | 8 September 2026