EMPRESARIA GROUP PLC PRIVACY POLICY

Welcome to the Empresaria Group plc privacy policy.

Empresaria respects your privacy and is committed to protecting your personal data. This privacy policy will inform you as to how we look after your personal data when you visit our website (regardless of where you visit it from). This policy will also tell you about your privacy rights and how the law protects you.

1. IMPORTANT INFORMATION AND WHO WE ARE

PURPOSE OF THIS PRIVACY POLICY

This privacy policy aims to give you information on how Empresaria collects and processes your personal data through your use of this website.

This website is not intended for children and we do not knowingly collect data relating to children.

It is important that you read this privacy policy, together with any privacy notice that we may provide on specific occasions when we are collecting or processing personal data about you so that you are fully aware of how and why we are using your data. This privacy policy supplements the privacy notices and is not intended to override them.

CONTROLLER

Empresaria Group plc is the data controller and responsible for your personal data (referred to as "Empresaria", "we", "us" or "our" in this privacy policy).

We have appointed a data privacy manager who is responsible for overseeing questions in relation to this privacy policy. If you have any questions about this privacy policy, including any requests to exercise your legal rights, please contact the data privacy manager using the details set out below.

CONTACT DETAILS

Our full details are as follows:

Company Name: Empresaria Group plc

Data Privacy Manager: Alison Wilde

Email: wildea@empresaria.com

Address: Old Church House, Sandy Lane, Crawley Down, West Sussex RH10 4HS

Telephone: 01342 711430

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), or your own country's supervisory authority for data protection. We would, however, appreciate the chance to deal with your concerns before you approach the ICO so please contact us in the first instance.

Empresaria is a holding company. For information about how our operating companies and associated businesses process personal data, please refer to the privacy policy on each company's website.

CHANGES TO THE PRIVACY POLICY AND YOUR DUTY TO INFORM US OF CHANGES

This version was last updated on 23 May 2018 and historic versions can be obtained by contacting us.

THIRD-PARTY LINKS

This website may include links to third-party websites, plug-ins and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites and are not responsible for their privacy statements. When you leave our website, we encourage you to read the privacy policy of every website you visit.

2. THE DATA WE COLLECT ABOUT YOU

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:

  • Contact data including name, email address, address and phone number
  • Device and browser data, such as IP address, information about your device and browser settings
  • Communications data includes your communication preferences.

We do not collect any special categories or data, also known as 'sensitive' personal data.

We may collect, use and share Aggregated Data such as statistical or demographic data for any purpose. Aggregated Data may be derived from your personal data but is not considered personal data in law as this data does not directly or indirectly reveal your identity. For example, we may aggregate your Usage Data to calculate the percentage of users accessing a specific website feature. However, if we combine or connect Aggregated Data with your personal data so that it can directly or indirectly identify you, we treat the combined data as personal data which will be used in accordance with this privacy policy.

Where we collect or process any other categories of personal data (including sensitive personal data) about you that is not listed above, we will send you a separate Privacy Notice regarding the processing of such data by us.

IF YOU FAIL TO PROVIDE PERSONAL DATA

You are under no obligation to provide us with your personal data, and there will be no adverse consequences if you fail to provide us with your personal data, although we may be unable to respond to queries or provide you with information.

3. HOW IS YOUR PERSONAL DATA COLLECTED?

We may collect data about you when you visit our website, email us, call us or write to us.

We do not collect data about you from third parties.

4. HOW AND WHY WE USE YOUR PERSONAL DATA

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 we need to comply with a legal or regulatory obligation.
  • 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 you consent to our doing so. We need to process your personal data in order to pursue our legitimate business interests. Our business involves operating an international specialist staffing group, and so we may need to process your personal data in order to pursue our legitimate interests in achieving this. We may also need to retain personal data in case we need to establish or defend a legal claim. We will balance our legitimate interests against your rights and freedoms and your legitimate interests and expectations. We may rely upon your consent in certain circumstances, for example, to use cookies when you visit our website.

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 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.

5. DISCLOSURES OF YOUR PERSONAL DATA

Your personal information will be processed by our staff and our subcontractors (including IT providers) for the purposes of our operating our business. We may need to share certain categories of your personal data with other companies within the Empresaria Group. We may also need to share your data with our professional advisers, such as lawyers and accountants. We may also share your personal data with third parties to whom we may choose to sell, transfer, or merge parts of our business or our assets. Alternatively, we may seek to acquire other businesses or merge with them. If a change happens to our business, then the new owners may use your personal data in the same way as set out in this privacy policy. We will not share your personal data with any other organisation unless it is necessary and in connection with running our business. 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.

6. INTERNATIONAL TRANSFERS

Your personal data will be stored inside the European Economic Area (EEA) on either local or cloud-based servers and will be subject to technical and organisation safeguarding protection measures. The EEA comprises the European Union (EU) member states plus Norway, Iceland and Liechtenstein. If it is necessary to transfer your data to a country outside the EEA for the purposes of operating our business, we will take all reasonable steps to ensure that your data is subject to the same protection as that provided by the EU and that it is subject to technical and organisational safeguarding protection measures, as follows: We will only transfer your personal data to organisations located in countries outside the EEA, if the organisation:

  • is based in a country which has been deemed to provide an adequate level of protection for personal data by the European Commission, or
  • has entered into an agreement with us which contains specific contract clauses approved by the European Commission which give personal data the same protection that it has in Europe.

For further details, please see the following:

European Commission: Adequacy of the protection of personal data in non-EU countries

European Commission: Model contracts for the transfer of personal data to third 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.

7. DATA SECURITY

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 on a 'need to know' basis. They will only process your personal data on our instructions and they are subject to a duty of confidentiality.

We will only transfer personal data to a third party if they agree to comply with those procedures and policies, or put in place adequate measures prior to receiving it. Maintaining data security means guaranteeing the confidentiality, integrity and availability (for authorised purposes) of the personal data.

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.

8. DATA RETENTION

FOR HOW LONG WILL YOU USE OR RETAIN MY PERSONAL DATA?

We will only retain your personal data for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements.

We may retain your data for up to 7 years in order to pursue our legitimate business interests, for example if we need to establish or defend a legal claim.

9. YOUR LEGAL RIGHTS

Under certain circumstances, you have rights under data protection laws in relation to your personal data. These include the right to:

  1. request access to personal data we hold about you;
  2. object to the processing of your personal data;
  3. ask to have inaccurate data held about you removed or restricted;
  4. ask to have inaccurate data held about you or corrected;
  5. if processing of your personal data is based only on consent, to withdraw that consent;
  6. request that your personal data is shared with a third party in a commonly used, machine readable format.

If you wish to exercise any of the rights set out above, please contact us at wildea@empresaria.com or 01342 711430.

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 fee if requests are repeated or obviously excessive.


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