- Important information and who we are................................................................................................ 1
- The data we collect about you................................................................................................................ 2
- How is your personal data collected?................................................................................................... 4
- How we use your personal data............................................................................................................. 4
- Disclosures of your personal data....................................................................................................... 10
- International transfers.......................................................................................................................... 10
- Data security.......................................................................................................................................... 11
- Data retention........................................................................................................................................ 11
- Your legal rights.................................................................................................................................... 13
- Glossary.............................................................................................................................................. 14
- IMPORTANT INFORMATION AND WHO WE ARE
- THE DATA WE COLLECT ABOUT YOU
- HOW IS YOUR PERSONAL DATA COLLECTED?
- HOW WE USE YOUR PERSONAL DATA
- DISCLOSURES OF YOUR PERSONAL DATA
- INTERNATIONAL TRANSFERS
- DATA SECURITY
- DATA RETENTION
- YOUR LEGAL RIGHTS
Important information and who we are.
This website is not intended for children and we do not knowingly collect data relating to children.
Privacy Manager: Felix Samuels
Email address: firstname.lastname@example.org
You have the right to make a complaint at any time to the Information Commissioner's Office (ICO), the UK supervisory authority for data protection issues (www.ico.org.uk). We would, however, appreciate the chance to deal with your concerns before you approach the ICO so please contact us in the first instance.
It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during your relationship with us.
Personal data, or personal information, means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymous data).
We may collect, use, store and transfer different kinds of personal data about you which we have grouped together as follows:
- Identity Data includes first name, last name, username or similar identifier, and gender.
- Contact Data includes home address, office address, email address and telephone numbers.
- Technical Data includes internet protocol (IP) address, your login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform, and other technology on the devices you use to access this website, including the type of mobile device you use, a unique device identifier (for example, your computer device’s IMEI number, the address of the computer device’s wireless network interface, or the mobile phone number used by the computer device), mobile network information, your mobile operating system, the type of mobile browser you use and time zone setting (“Technical Info”);
- Profile Data includes your username and password, your interests, preferences, feedback and survey responses.
- Usage Data includes information about how you use our website, products and services including, but not limited to, traffic data and location data (“Use Data”).
- Marketing and Communications Data includes your preferences in receiving marketing from us and our third parties and your communication preferences.
We may also collect, store and use the following types of more sensitive personal information:
- Information about your race or ethnicity, disabilities, sexual orientation, state educated, first generation university/ college attendee, right to work in UK.
We will use your particularly sensitive personal information in the following ways:
- We will use information about your disability status to consider whether we need to provide appropriate adjustments during the recruitment process, for example whether adjustments need to be made during a test or interview.
- We will use information about your race or national or ethnic origin, or your sexual life or sexual orientation, to ensure meaningful equal opportunity monitoring and reporting.
If you fail to provide personal data
Where we need to collect personal data by law, or under the terms of a contract we have with you, and you fail to provide that data when requested, we may not be able to perform the contract we have or are trying to enter into with you (for example, to showcase you opportunities of employment). In this case, you may miss out on products or services that may have been appropriate.
We use different methods to collect data from and about you including through:
- Direct interactions. You may give us your Identity and Contact by registering or filling in forms or by corresponding with us by phone, email or otherwise. This includes personal data you provide when you
- create an account & register to our site
- list your preferences or highlight your interest to roles, companies, sectors
- apply for employment opportunities or specific company or industry events
- request marketing to be sent to you;
- enter a competition, promotion or survey; or
- give us feedback or contact us.
- Third parties or publicly available sources. We may receive personal data about you from various third parties and public sources as set out below: Via the internet and social media channels including but not limited to Instagram, Twitter, LinkedIn & Facebook
Technical Data from the following parties:
- analytics providers such as Google based outside the EU;
- advertising networks based inside the EU; and
- search information providers based inside the EU.
We will only use your personal data when the law allows us to. Most commonly, we will use your personal data in the following circumstances:
- Where we need to perform the contract we are about to enter into or have entered into with you.
- Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests.
- Where we need to comply with a legal obligation.
Click here GLOSSARY to find out more about the types of lawful basis that we will rely on to process your personal data.
Generally, we do not rely on consent as a legal basis for processing your personal data although we will get your consent before sending third party direct marketing communications to you via email or text message. You have the right to withdraw consent to marketing at any time by contacting us.
Automated decision making
You will not be subject to decisions that will have a significant impact on you based solely on automated decision-making.
Data Protection Principles
We will comply with data protection law and principles including the Data Protection Act 2018, which means that your data will be:
- Used lawfully, fairly and in a transparent way.
- Collected only for valid purposes that we have clearly explained to you and not used in any way that is incompatible with those purposes.
- Relevant to the purposes we have told you about and limited only to those purposes.
- Accurate and kept up to date.
- Kept only as long as necessary for the purposes we have told you about.
- Kept securely.
Purposes for which we will use your personal data
We have set out below, in a table format, a description of all the ways we plan to use your personal data, and which of the legal bases we rely on to do so. We have also identified what our legitimate interests are where appropriate.
Note that we may process your personal data for more than one lawful ground depending on the specific purpose for which we are using your data. Please contact us if you need details about the specific legal ground we are relying on to process your personal data where more than one ground has been set out in the table below.
Type of data
Lawful basis for processing including basis of legitimate interest
To register you as a new customer
Performance of a contract with you
To process and match you with employment services and job opportunities, including processing & filtering your data to showcase roles where a potential match occurs
(e) Marketing and Communications
(a) Performance of a contract with you
(b) Necessary for our legitimate interests
To manage our relationship with you which will include:
(b) Asking you to undertake a review or complete a survey
(d) Marketing and Communications
(a) Performance of a contract with you
(b) Necessary to comply with a legal obligation
(c) Necessary for our legitimate interests (to keep our records updated and to study how customers use our products/services)
To enable you to partake in a prize draw, competition or complete a survey
(e) Marketing and Communications
(a) Performance of a contract with you
(b) Necessary for our legitimate interests (to study how customers use our products/services, to develop them and grow our business)
To administer and protect our business and this website (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data)
(a) Necessary for our legitimate interests (for running our business, provision of administration and IT services, network security, to prevent fraud and in the context of a business reorganisation or group restructuring exercise)
(b) Necessary to comply with a legal obligation
To deliver relevant website content and employment opportunities to you and measure or understand the effectiveness of these opportunities of employment we make available to you
(e) Marketing and Communications
Necessary for our legitimate interests (to study how customers use our products/services, to develop them, to grow our business and to inform our marketing strategy)
To use data analytics to improve our website, products/services, marketing, customer relationships and experiences
Necessary for our legitimate interests (to define types of customers for our products and services, to keep our website updated and relevant, to develop our business and to inform our marketing strategy)
To make suggestions and recommendations to you about employment opportunities that may be of interest to you
(f) Marketing and Communications
Necessary for our legitimate interests (to develop our products/services and grow our business)
We will also use the personal information we collect about you to:
- To build out your own bespoke ‘shop window’ (your own bespoke profile) that will showcase you in the best possible way to perspective employers;
- Assess your skills, qualifications, and suitability for specific roles where add-victor is running a job search on behalf of an employer;
- Communicate with you via telephone, email or our online platform or any other form of digital communication about the recruitment process;
- Keep records related to the recruitment processes;
- Comply with legal or regulatory requirements;
- Invite you to certain applicable events such as conference calls and interviews as part of the services we provide;
- Offer you the opportunity to have any application auto-populated using the information provided by you;
- Use your Technical Info and Use Data for our understanding of how you use our platforms, to ensure that it is optimised for your use and that we are targeting the right users;
- We may associate any category of information with any other category of information and will treat the combined information as personal data in accordance with this policy for as long as it is combined. Other than to employers who are advertising roles via our platforms, we do not disclose information about identifiable individuals to other third parties, but we may provide them with anonymous aggregate information about our users. We may make use of the personal data we have collected from you to enable us to comply with our third parties’ wishes by displaying their information to that target audience;
- To aggregate your personal data with others personal data into a non – identifiable form in order to carry our analysis of our users for internal business purposes.
Having registered on our technology platform & created your own profile, it is in our legitimate interests to use your personal information to promote you for employment opportunities. This is beneficial to you as the candidate. Likewise it is the object of our recruitment business to place successful candidates with our customer employers. However, we will never provide your personal information to a potential employer without your express consent.
Should you be interested and having received your CV and covering letter and/or your application form we will then process that information to decide whether you meet the basic requirements to be shortlisted for the role. If you do, with your agreement we will make your information available via to the employer who may decide whether your application is strong enough to invite you for an interview: We may disclose some or all the personal information and/or your contact details that we collect from you when you register or use our platforms to the prospective employers, to allow them to contact you directly in respect of job opportunities.
If prospective employers decide to call you for an interview, they will use the information you provide through your registration/CV/covering letter or other. Following a successful interview process they will extend an offer for that particular opportunity. If the customer employer decides to extend an offer, they may (and are likely to) take up references and/or carry out a criminal record and/or carry out other background checks before confirming your appointment. We do not envisage that we will process information about criminal convictions
We may need to process your personal information to help our customer employers to decide whether to enter into a contract of employment with you. It is necessary to process your personal information for procuring the entering into or performing a contract with you and processing personal data in connection with an application for work will be a pre-requisite for entering into a contract in future with the potential employer.
We strive to provide you with choices regarding certain personal data uses, particularly around marketing and advertising. We have established the following personal data control mechanisms:
Promotional offers from us
We may use your Identity, Contact, Technical, Usage and Profile Data to form a view on what we think you may want or need, or what may be of interest to you. This is how we decide which products, services and offers may be relevant for you (we call this marketing).
We will get your express opt-in consent before we share your personal data with any third party for marketing purposes except as set out below.
You can ask us or third parties to stop sending you marketing messages at any time by contacting us at any time at email@example.com.
Change of purpose
We will only use your personal data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If you wish to get an explanation as to how the processing for the new purpose is compatible with the original purpose, please contact us.
If we need to use your personal data for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so.
Please note that we may process your personal data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.
We may share your personal data with the parties set out below:
We may disclose some or all information we receive about you to prospective employers but will only do so with your agreement first.
We may disclose your personal data to third parties:
- if we sell or license our business or its assets, in which case we may disclose your personal data to a prospective purchaser;
- under legal or regulatory obligations;
- to protect the rights, property or safety of Add-Victor, our customers, or others. This includes exchanging information with other companies and organisations for the purposes of fraud protection and credit risk reduction
We offer a range of services to prospective employers therefore the personal information we share about you with prospective employers may vary from some to all of your personal data.
We require all third parties to respect the security of your personal data and to treat it in accordance with the law. We do not allow our third-party service providers to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our instructions.
We do not transfer your personal data outside the European Economic Area (EEA).
Some of our external third parties may be based outside the EEA so their processing of your personal data might involve a transfer of data outside the EEA.
Whenever we transfer your personal data out of the EEA, we endeavour to ensure a similar degree of protection is afforded to it by ensuring at least one of the following safeguards is implemented.
We will only transfer your personal data to countries that have been deemed to provide an adequate level of protection for personal data by the European Commission. For further details, see European Commission: Adequacy of the protection of personal data in non-EU countries. Please contact us if you want further information on the specific mechanism used by us when transferring your personal data out of the EEA.
We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal data on our instructions, and they are subject to a duty of confidentiality.
We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.
Where we have given you (or where you have chosen) a password that enables you to access certain parts of our platforms, you are responsible for keeping this password confidential. We ask you not to share a password with anyone.
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 us; any transmission is at your own risk. Once we have received your information, we will use strict procedures and security features to try to prevent unauthorised access.
How long will you use my personal data for?
We will only retain your personal data for as long as reasonably necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, regulatory, tax, accounting or reporting requirements. We may retain your personal data for a longer period in the event of a complaint or if we reasonably believe there is a prospect of litigation in respect to our relationship with you.
To determine the appropriate retention period for personal data, we consider the amount, nature and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal, regulatory, tax, accounting, or other requirements.
We will retain your personal information for a minimum period of 6 years after you have indicated you no longer wish to be a member of our technology recruitment platform. We retain your personal information for that period so that we can show, in the event of a legal claim, that among other defences, we have not discriminated against candidates on prohibited grounds and that we have conducted the recruitment exercise in a fair and transparent way. After this period, we will securely destroy your personal information in accordance with our data retention policy and applicable laws and regulations. By law we have to keep basic information about our customers (including Contact, Identity, Financial and Transaction Data) for at least six years after they cease being customers for tax purposes.
If we wish to retain your personal information on file, on the basis that a further opportunity may arise in future and we may wish to consider you for that, we may seek your explicit consent to retain your personal information for a fixed period on that basis. In some circumstances you can ask us to delete your data: see your legal rights below for further information. In some circumstances we will anonymise your personal data (so that it can no longer be associated with you) for research or statistical purposes, in which case we may use this information indefinitely without further notice to you.
Under certain circumstances, you have rights under data protection laws in relation to your personal data. Under certain circumstances, by law you have the right to:
- Request access to your personal information (commonly known as a “data subject access request”). This enables you to receive a copy of the personal information we hold about you and to check that we are lawfully processing it.
- Request correction of the personal information that we hold about you. This enables you to have any incomplete or inaccurate information we hold about you corrected.
- Request erasure of your personal information. This enables you to ask us to delete or remove personal information where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal information where you have exercised your right to object to processing (see below).
- Object to processing of your personal information where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground. You also have the right to object where we are processing your personal information for direct marketing purposes.
- Request the restriction of processing of your personal information. This enables you to ask us to suspend the processing of personal information about you, for example if you want us to establish its accuracy or the reason for processing it.
- Request the transfer of your personal information to another party.
If you want to review, verify, correct or request erasure of your personal information, object to the processing of your personal data, or request that we transfer a copy of your personal information to another party, please contact firstname.lastname@example.org .
No fee usually required
You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we could refuse to comply with your request in these circumstances.
What we may need from you
We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.
Time limit to respond
We try to respond to all legitimate requests within one month. Occasionally it could take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.
Legitimate Interest means the interest of our business in conducting and managing our business to enable us to give you the best service/product and the best and most secure experience. We make sure we consider and balance any potential impact on you (both positive and negative) and your rights before we process your personal data for our legitimate interests. We do not use your personal data for activities where our interests are overridden by the impact on you (unless we have your consent or are otherwise required or permitted to by law). You can obtain further information about how we assess our legitimate interests against any potential impact on you in respect of specific activities by contacting us.
Performance of Contract means processing your data where it is necessary for the performance of a contract to which you are a party or to take steps at your request before entering into such a contract.
Comply with a legal obligation means processing your personal data where it is necessary for compliance with a legal obligation that we are subject to.
If you fail to provide personal information
If you fail to provide information when requested, which is necessary for us or a customer employer to consider your application (such as evidence of qualifications or work history), we or they will not be able to process your application successfully. For example, if a prospective employer requires a credit check or references for a role and you fail to provide them with relevant details, they will not be able to take your application further.
Internal Third Parties
Other companies in the Group acting as joint controllers or processors and who are based in the UK provide IT and system administration services and undertake leadership reporting.
External Third Parties
- Service providers acting as processors based in the UK who provide IT and system administration services.
- Professional advisers acting as processors or joint controllers including lawyers, bankers, auditors and insurers based in the UK who provide consultancy, banking, legal, insurance and accounting services.
- HM Revenue & Customs, regulators and other authorities acting as processors or joint controllers based in the United Kingdom who require reporting of processing activities in certain circumstances.
- Prospective employer customers acting as processors or joint controllers based in the United Kingdom.