1.2 This notice applies to personal information provided by our clients, their authorised users and affiliated individuals (“Providers”) and personal information provided by users and prospective users of our Service (“Users”). In this notice “you” refers to any individual whose personal data we hold or process (i.e: to you as an individual User, client, or potential client, or to you as an individual affiliated with one of our clients, potential clients or Users).
1.3 This notice is governed by the EU General Data Protection Regulation (the “GDPR”) and the Data Protection Act 2018.
2.1 Personal data we hold about you will be processed either because:
2.1.1 you have consented to the processing for the specific purposes described in this notice;
2.1.2 the processing is necessary in order for us to comply with our obligations under a contract between you and us, specifically for the provision our Service; or to take steps at your request prior to entering into a contract; or
2.1.3 the processing is necessary in pursuit of a “legitimate interest” - a legitimate interest in this context means a valid interest we have or a third party has in processing your personal data which is not overridden by your interests in data privacy and security.
3.1 We may collect and process the following personal data (information that can be uniquely identified with you) about you:
3.1.1 information provided by a Provider in order to obtain a Listing on our Site, including information provided when signing up to our services (including log-in details such as names, contact addresses and numbers, email addresses, and content created or provided through the use of the Service) and other information we require in order to provide our services (“Provider Information”);
3.1.2 information provided by a User of our Service in order to make contact with or be referred to suitable Providers, including log-in details such as names, contact addresses and numbers and email addresses (“User Information”);
3.1.3 payment information we may use to collect payment (if applicable) (“Payment Information”);
3.1.4 a record of any correspondence or communication between you and us (for example, the number of communications you make with us, the number of introductions we make involving you, the number of trades or transactions you are involved with) and any information we may require from you when you reply to a survey or questionnaire, report a problem or submit a complaint (“Communication Information”);
3.1.5 technical information about how you have used or interacted with our Service (“Technical Information”).
3.2 Generally we will collect personal data directly, but we may obtain data from third parties from time to time. If we do obtain your personal data from a third party your privacy rights under this notice are not affected and you are still able to exercise the rights contained within this notice.
3.3 You do not have to supply any personal information to us but our Service may not be operable in practice without providing data to us. You may withdraw our authority to process your personal data (or request that we restrict our processing – see clause 9) at any time (but our Service may not be operable in practice should you do so).
4.1 A cookie is a piece of data stored locally on your computer and contains information about your activities on the Internet. The information in a cookie does not contain any personally identifiable information you submit to our Site.
4.3 Once you close your browser, our access to the cookie terminates. You have the ability to accept or decline cookies. Most web browsers automatically accept cookies, but you can usually modify your browser setting to decline cookies if you prefer. To change your browse settings you should go to your advanced preferences.
4.5 If you choose not to accept the cookies, this will not affect your access to the majority of information available on our Site. However, you will not be able to make full use of our online services.
4.6 An Internet Protocol (IP) address is a number assigned to your computer by your Internet Service Provider (ISP), so you can access the Internet. We may use your IP address to diagnose problems with our server, report aggregate information, and determine the fastest route for your computer to use in connecting to our Site, and to administer and improve the Site.
5.1 We process each category of data in the following ways:
5.1.1 Provider Information – we use this to register Providers with our Service and allow them to update details with us, make use of our Service and communicate with us.
5.1.2 User Information – we use this to give our Users information about our Service and/or connect Users with suitable Providers.
5.1.3 Communication Information – we use this when we communicate with you or you communicate with us.
5.1.4 Technical Information – we use this to administer or protect our business, undertake troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data, when we use data analytics to improve the Site, services, marketing, customer relationships and experiences.
5.1.5 Marketing Information – we use this promote or market our products or services to you.
5.2 The legal basis we rely on for the processing outlined above is our legitimate interest (see paragraph 2 above for more information about legitimate interest) and, in cases where we are providing our Service to you as a Provider or a User, the performance of a contract between us and you.
5.3 We may also use aggregated, anonymised data you have supplied to sell advertising space on the Site or market services to other Users.
6.1 Our current data retention policy is to delete or destroy (to the extent we are able to) the personal data we hold about you in accordance with the following: Category of personal data Length of retention Records relevant for tax purposes 8 years from the end of the tax year to which the records relate Personal data processed in relation to a contract between us and a Provider or User 7 years from either the end of the contract or the date you last used our Service, being the length of time following a breach of contract in which you are entitled to make a legal claim Personal data held on marketing or business development records 3 years, when the data subject identified by the data in question has not engaged with your marketing output during that time
6.2 For any category of personal data not specifically defined in this notice, and unless otherwise specified by applicable law, the required retention period for any personal data will be deemed to be 7 years from the date of receipt by us of that data or (if later) the end of the relevant contract, arrangement or interaction with that person.
6.4 We review the personal data (and the categories of personal data) we are holding on a regular basis to ensure the data we are holding is still relevant to our business and is accurate. If we discover that certain data we are holding is no longer necessary or accurate, we will take reasonable steps to correct or delete this data as may be required.
6.5 If you wish to request that data we hold about you is amended or deleted, please refer to clause 9 below, which explains your privacy rights.
7.1 We do not disclose any information you provide to any third parties other than as follows:
7.1.1 When we transfer your data for technical reasons (servers, storage) to companies using servers located in EU (eg: Salesforce and Digital Ocean)
7.1.2 When we share your data with our Providers in order to perform our Services
7.1.3 where you have opted to share any of your content with any other user of the Service, Provider or third party, you authorise us to deliver that content via email, SMS or other electronic messaging or communication system;
7.1.4 where information such as email addresses is passed to a supplier that may provide technical support or other services in the provision of our Service;
7.1.5 where necessary in the course of engaging the services of professional advisers (including legal advisers and accountants);
7.1.6 where we carry out research to gain an insight into the use of our services, the results of this research (but not your personal data itself) may be transferred to interested third parties;
7.1.7 if we are under a duty to disclose or share your personal data in order to comply with any legal obligation (for example, if required to do so by a court order or for the purposes of prevention of fraud or other crime);
7.1.8 in order to enforce any terms and conditions or agreements for our Services that may apply;
7.1.9 we may transfer your personal information to a third party as part of a sale of some or all of our business and assets to any third party or as part of any business restructuring or reorganisation, but we will take steps with the aim of ensuring that your privacy rights continue to be protected;
7.1.10 to protect our rights, property and safety, or the rights, property and safety of our users or any other third parties. This includes exchanging information with other companies and organisations for the purposes of fraud protection and credit risk reduction.
7.2 Other than as set out above, we shall not disclose any of your personal information to third parties in a systematic way without notifying you. If we do supply your personal information to a third party we will take steps to ensure that your privacy rights are protected and that third party complies with the terms of this notice.
8.1 We will take all reasonable steps to ensure that appropriate technical and organisational measures are carried out in order to safeguard the information we collect from you and protect against unlawful access and accidental loss or damage. These measures may include (as necessary):
8.1.1 protecting our servers by both hardware and software firewalls;
8.1.2 locating our data processing storage facilities in secure locations;
8.1.3 encrypting all data stored on our server with an industry standard encryption method that encrypts the data between your computer and our server so that in the event of your network being insecure no data is passed in a format that could easily be deciphered;
8.1.4 when necessary, disposing of or deleting your data so it is done so securely;
8.1.5 regularly backing up and encrypting all data we hold.
8.2 We will ensure that our employees are aware of their privacy and data security obligations. We will take reasonable steps to ensure that the employees of third parties working on our behalf are aware of their privacy and data security obligations.
8.3 This notice and our procedures for handling personal data will be reviewed as necessary.
8.4 Unfortunately, the transmission of information via the internet is not completely secure. Although we will do our best to protect your personal data, we cannot guarantee the security of your data transmitted to the Site; any transmission is at your own risk. Once we have received your information, we will use the strict procedures and security features referred to in this clause to try to prevent unauthorised access.
9.1 The GDPR gives you the following rights in respect of personal data we hold about you: The right to be informed You have a right to know about our personal data protection and data processing activities, details of which are contained in this notice. The right of access You can make what is known as a Subject Access Request (“SAR”) to request information about the personal data we hold about you (free of charge, save for reasonable expenses for repeat requests). If you wish to make a SAR please contact us as described below. The right to correction Please inform us if information we hold about you is incomplete or inaccurate in any way and we will update our records as soon as possible, but in any event within one month. We will take reasonable steps to communicate the change to any third parties to whom we have passed the same information. The right to erasure (the ‘right to be forgotten’) Please notify us if you no longer wish us to hold personal data about you (although in practice it is not possible to provide our Service without holding your personal data). Unless we have reasonable grounds to refuse the erasure, on receipt of such a request we will securely delete the personal data in question within one month. The data may continue to exist in certain backup, but we will take steps to ensure that it will not be accessible. We will communicate the erasure to any third parties to whom we have passed the same information. The right to restrict processing You can request that we no longer process your personal data in certain ways, whilst not requiring us to delete the same data. However again, elements of our Service will not be available if processing is restricted. The right to data portability You have the right to receive copies of personal data we hold about you in a commonly used and easily storable format (please let us know a format which suits you). You may also request that we transfer your personal data directly to a third party (where technically possible). The right to object Unless we have overriding legitimate grounds for such processing, you may object to us using your personal data for direct marketing purposes (including profiling) or for research or statistical purposes. Please notify your objection to us and we will gladly cease such processing. Rights with respect to automated decision-making and profiling You have a right not to be subject to automated decision-making (including profiling) when those decisions have a legal (or similarly significant effect) on you. You are not entitled to this right when the automated processing is necessary for us to perform our obligations under a contract with you, it is permitted by law, or if you have given your explicit consent. Right to withdraw consent If we are relying on your consent as the basis on which we are processing your personal data, you have the right to withdraw your consent at any time. Even if you have not expressly given your consent to our processing, you also have the right to object (see above).
9.2 All SARs and other requests or notifications in respect of your above rights must be sent to us in writing to 3rd Floor, 14 Hanover Street, London, England, W1S 1YH or email@example.com.
9.3 We will endeavour to comply with such requests as soon as possible but in any event we will comply within one month of receipt (unless a longer period of time to respond is reasonable by virtue of the complexity or number of your requests).
10.1 If personal data we hold about you is subject to a breach or unauthorised disclosure or access, we will report this to the Information Commissioner’s Office (ICO) and/or our data protection officer (if one has been appointed).
10.2 If a breach is likely to result in a risk to your data rights and freedoms, we will notify you as soon as possible.
11.1 Our Site may contain links and references to other websites. Please be aware that this notice does not apply to those websites.
11.2 We cannot be responsible for the privacy policies and practices of sites that are not operated by us, even if you access them via the Site and/or any other service that is operated by us. We recommend that you check the policy of each site you visit and contact its owner or operator if you have any concerns or questions.
11.3 In addition, if you came to this Service via a third party site, we cannot be responsible for the privacy policies and practices of the owners or operators of that third party site and recommend that you check the policy of that third party site and contact its owner or operator if you have any concerns or questions.
12.1 As part of the Service offered to you the information you provide to us may be transferred to, processed and stored at, countries or international organisations outside of the EEA.
12.2 We have Users and Providers who are outside of the EEA and in those circumstances personal data may be transferred outside of the EEA.
12.3 We will not transfer any data in a systematic way outside of the EEA but there may be circumstances in which certain personal information is transferred outside of the EEA, in particular:
12.3.1 We may communicate with individuals or organisations outside of the EEA in delivering our services, and those communications may include personal information (such as contact information);
12.3.2 From time to time your information may be stored in devices which are used by our staff outside of the EEA (but staff will be subject to our cyber-security policies);
12.3.3 We may also share information with other equivalent national bodies, which may be located in countries worldwide. These countries may not have similar data protection laws to the UK.
12.4 If we transfer your information outside of the EEA in this way, and the third country or international organisation in question has not been deemed by the EU Commission to have adequate data protection laws, we will provide appropriate safeguards and we will be responsible for ensuring your privacy rights continue to be protected as outlined in this notice. If you would like to obtain details of the safeguards we have put in place then please contact us at: firstname.lastname@example.org.
12.5 If you use our Service while you are outside the EEA, your information may be transferred outside the EEA in order to provide you with those services.
12.6 By submitting your personal information to us you agree to the transfer, storing or processing of your information outside the EEA in the manner described above.
We will post details of any changes to our policy on the Site and the Apps to help ensure you are always aware of the information we collect, how we use it, and in what circumstances, if any, we share it with other parties.
The Service is not intended for and should not be accessed by individuals under 16. Our policy is not to intentionally or knowingly collect, process, maintain or use personal information from any individual under the age of 18.
If at any time you would like to contact us with your views about our privacy practices, or with any enquiry or complaint relating to your personal information or how it is handled, you can do so via the following email address: email@example.com.
If we are unable to resolve any issues you may have or you would like to make a further complaint, you can contact the Information Commissioner’s Office by visiting http://www.ico.org.uk/ for further assistance.