Datalla Group 2018

Privacy Notice

This is the privacy notice of Datalla Group Ltd. We take your privacy seriously and this privacy notice sets out how we will handle your personal data securely and in accordance with your rights. In this document, “we”, “our”, or “us” refer to Datalla Group Ltd. Our registered office address is at 27 Old Gloucester Street, London, WC1N 1AX, UK. Company number 10292401 registered in England.

This privacy notice informs you about how we process information that we record about you, whether provided by you, or by another person or organisation. It applies to information that could identify you as an individual (“personal information”) and information that does not, including that which relates to your business. In the context of the law and this notice, “process” means collect, store, transfer, use or otherwise act on information.

We are committed to the protection of your privacy and confidentiality. We recognise that you are entitled to know that your data will not be used for any unintended purpose, and will not accidentally fall into the hands of a third party. We undertake to preserve the confidentiality of all information you provide to us, and hope that you reciprocate.

We have in place procedures and training for data protection, confidentiality and information security. These are regularly reviewed to ensure that they remain effective. Our policy complies with UK law accordingly implemented, including that required by the EU General Data Protection Regulation (GDPR).

The law requires us to tell you about your rights and our obligations to you in regards to the processing and control of your personal data. We do this now, by requesting that you read the information provided at www.knowyourprivacyrights.org. Except as set out below, we do not share, or sell, or disclose to a third party, any information collected through our website.

By using the Website (www.datalla.com)) and/or our Services (executive search, advisory and consulting) you will be regarded as having accepted the terms of this privacy notice. Please do not use the Website or our Services if you do not agree to the terms of this privacy notice.

Data we process

We provide a range of Services to businesses. We aim to process data, whether personal data or not, only to the extent necessary for us to provide our clients with our Services and for other agreed purposes. Often we may aggregate information in a general way and use it to provide class information. If we use it for this purpose, you as an individual will not be personally identifiable.

When you use the Website and / or our Services we may ask you to provide certain information such as, your name, date of birth and contact details (including your address, email address, and contact telephone number), details of your employment history, career experience, skills, copies of your CV, cover letter, supporting statement, suitable references from your employer or other third party referees.

We may also collect information on an ongoing basis about what pages you access or visit on the Website and information about your use of the Website including, for example, the job vacancies, sectors and locations you have viewed and any changes you make to information you supply to us, including by use of cookies.

In order to provide you with our Services we may also need to collect personal data which the Data Protection Act 1998 (DPA 1998) and the General Data Protection Regulation (GDPR) regards as sensitive or special categories of personal data, such as information relating to your racial or ethnic origin, political opinions, religious or philosophical beliefs, trade union membership, physical or mental health or sexual orientation (Background Information) and/or information relating to any criminal convictions you have or offences you may have committed (Criminal Records Information) (Background Information and Criminal Records Information, together, being Sensitive Data).

By completing our equal opportunities form (Equal Opportunities Form) which may form part of our Services (in respect of your Background Information) and/or by providing us with any Criminal Records Information requested for the purposes of providing our Services you will signify your explicit consent to such Sensitive Data being processed by us.

Please note that answers to all questions on our Equal Opportunities Form are optional and you can always provide a “prefer not to say” response. However, we may be required to obtain Criminal Records Information from you in order to assess your suitability for certain job roles; if you do not wish to provide your Criminal Records Information then we may be unable to process your application (including dealing with any in-flight applications) any further.

In most cases, your personal data will have been provided to us by you. However, with your consent, or if it is necessary in order to provide you with our Services, we may have obtained your personal data from a third party source.

We may be given your personal data by our clients or suppliers, or by third parties acting on the instructions of a client or a supplier or via a solicited or unsolicited referral from your professional network. We ask our clients and suppliers to bring this privacy notice to your attention as soon as they become aware that we process your personal data.

If you supply our business with goods or Services, including subcontracted services that we supply to our clients, then we may process your personal information. However, we do so only to the extent necessary to contract with you. In most cases, your personal data will have been provided to us by you. However, sometimes we use third parties such as credit rating agencies to make decisions regarding our relationship.

The bases on which we process personal information

The law requires us to determine under which of six defined bases we process different categories of your personal information, and to notify you of the basis for each category.

If a basis on which we process your personal information is no longer relevant then we shall immediately stop processing your data. If the basis changes then if required by law we shall notify you of the change and of any new basis under which we have determined that we can continue to process your information.

Information we process because we have a contractual obligation

We may process personal information when a contract has been formed with our business and processing is necessary to carry out our obligations under that contract, or when processing personal data is necessary in order to form a contract.

We shall continue to process this information until the contract between us ends or is terminated by either party under the terms of the contract.

Information we process with your consent

Only when you have given us explicit permission to do so, do we process your personal information under the basis of consent. For example, you might have agreed that we may pass your name and contact information to selected associates whom we consider may provide services or products you would find useful.

We continue to process your information on this basis until you withdraw your consent or it can be reasonably assumed that your consent no longer exists.

You may withdraw your consent at any time by instructing us info@datalla.com. However, if you do so, you may not be able to use our Website or our Services further.

Information we process for the purposes of legitimate interests

We may process information on the basis there is a legitimate interest, either to you or to us, of doing so. Where we process your information on this basis, we do after having given careful consideration to: whether the same objective could be achieved through other means; whether processing (or not processing) might cause you harm; whether you would expect us to process your data, and whether you would, in the round, consider it reasonable to do so.

For example, we may process your data on this basis for the purposes of: record-keeping for the proper and necessary administration of our business; responding to communication from you to which we believe you would expect a response; contacting you in relation to our Services; protecting and asserting the legal rights of any party; insuring against or obtaining professional advice that is required to manage business risk; protecting your interests where we believe we have a duty to do so.

Information we process because we have a legal obligation

Sometimes, we must process your information in order to comply with a statutory obligation. For example, we may be required to give information to legal or tax authorities if they so request or if they have the proper authorisation such as a search warrant or court order. This may include your personal information.

Specific uses of information you provide to us

When you contact us, whether by telephone, through our website or by e-mail, we collect the data you have given to us in order to reply with the information you need. We record your request and our reply in order to increase the efficiency of our business. We keep personally identifiable information associated with your message, such as your name and email address so as to be able to track our communications with you to provide a high quality service.

When we receive a complaint, we record all the information you have given to us. We use that information to resolve your complaint. If your complaint reasonably requires us to contact some other person, we may decide to give to that other person some of the information contained in your complaint. We do this as infrequently as possible, but it is a matter for our sole discretion as to whether we do give information, and if we do, what that information is.

If the complaint relates to information on our website and we feel it is justified or if we believe the law requires us to do so, we shall remove the information while we investigate. If we think your complaint is vexatious or without any basis, we shall not correspond with you about it. We may compile statistics from information relating to complaints to assess the level of service we provide, but not in a way that could identify you or any other person.

Office visitors

If you visit our office you will be required to sign in at reception. We keep a record of your visit in order to maintain the security of our premises, your safety and the safety of other visitors.

We keep the record of your visit only for as long as necessary, and in any case, for less than one year. Closed circuit television (CCTV) is used at our premises and surrounding area in order to deter and to help investigate crime.

We process personal information including images and behaviours on the basis of legitimate interests. This information may be shared with the data subject, our employees and agents and the police. Our landlords and their agents may also use CCTV.

Customer relationship management system

We use a GDPR compliant customer relationship management (CRM) system to process personal data. Data subjects include existing, former and prospective clients and their agents and representatives.

Personal data that we process includes the name of the person, information about his or her employer and job position, and contact information. We process this data on the basis of consent for purposes that include: managing and developing our business or services; informing clients and prospective clients about our services; determining relationships between clients and our partners and employees; analysing whether we provide clients with a high level of service

We do not sell or share any personal data with third parties unless we have explicit consent to do so from the data subject.

Job applications and employment

If you send us information in connection with a job application, we may keep it for up to three years in case we decide to contact you at a later date. If we employ you, we collect information about you and your work from time to time throughout the period of your employment. This information will be used only for purposes directly relevant to your employment. After your employment has ended, we will keep your file for six years before destroying or deleting it.

Cookies

Cookies are small text files that are placed on your computer’s hard drive by your web browser when you visit any website. They allow information gathered on one web page to be stored until it is needed for use on another, allowing a website to provide you with a personalised experience and the website owner with statistics about how you use the website so that it can be improved.

Some cookies may last for a defined period of time, such as one day or until you close your browser. Others last indefinitely. Your web browser should allow you to delete any you choose. It also should allow you to prevent or limit their use.

Our website uses cookies. They are placed by software that operates on our servers, and by software operated by third parties whose services we use. When you first visit our website, we ask you whether you wish us to use cookies. If you choose not to accept them, we shall not use them for your visit except to record that you have not consented to their use for any other purpose.

If you choose not to use cookies or you prevent their use through your browser settings, you will not be able to use all the functionality of our website. We use cookies in the following ways: to track how you use our website; to record whether you have seen specific messages we display on our website; to keep you signed in our site; to record your answers to surveys and questionnaires on our site while you complete them; to record the conversation thread during a live chat with our support team.

Google Analytics is used to analyse the use of this Website. Google Analytics generates statistical and other information about website use by means of cookies, which are stored on users’ computers. The information generated relating to our website is used to create reports about the use of the website. Google will store and use this information. Google’s privacy policy is available at: http://www.google.com/privacypolicy.html.

HubSpot is used to provide specific content to visitors of our Website and to create reports about the use of the Website. HubSpot’s privacy policy is available at: https://legal.hubspot.com/privacy-policy.

Personal identifiers from your browsing activity

Requests by your web browser to our servers for web pages and other content on our website are recorded. We record information that could identify your location, such as your IP address. We also record information reported by the software you are using to browse our website, such as the type of computer or device and the screen resolution.

We use this information in aggregate to assess the popularity of the webpages on our website and how we perform in providing content to you. If combined with other information we know about you from previous visits, the data possibly could be used to identify you personally, even if you are not signed in to our website. However, our policy is not to use such data for the purpose of personal identification.

Disclosure and sharing of your information

As part of using our Services, you consent to us sharing your personal information with the following parties: our data hosting/support service providers who process and store data on our behalf; our professional advisors and consultants; third party data providers for the purposes of validating the information provided by you and to check that the data we hold about you is accurate, consistent and up to date (including for the purposes of performing background/verification checks; your current employer and/or any other individuals who you nominate as referees to verify certain information; any of our group companies, including any companies which may be added to our group from time to time; any of our business partners and employers with whom we share information for the purposes of identifying suitable job vacancies in which we think you may be interested and assessing your suitability for any such role; and our trusted third-party emailing service provider whom we use to upload and send email communications with you.

We may also share your personal information with third parties: in the event that we or any of our group companies, our business, or substantially all of its assets are acquired by a third party (in which case personal information about customers will be one of the transferred assets); if we are under a duty to disclose or share your personal data in order to comply with any legal obligation, or in order to enforce or apply any contract with you or to protect our rights, property, or safety of our employees, customers, or others. This includes exchanging information with other companies and organisations for the purposes of fraud protection and credit risk reduction; or if such disclosure is necessary in connection with any law (including any investigation or complaint regarding your use of the Websites).

Transfers of personal data outside of the United Kingdom and the EEA

If you are using our Services from within the United Kingdom and the European Economic Area (EEA), then we will not transfer your personal data outside of the United Kingdom and the EEA; or outside of the United Kingdom and the EEA, then we may transfer your personal data outside of the United Kingdom and the EEA solely for the purposes of corresponding with you in relation to our Services.

We shall ensure that any such transfers outside of the United Kingdom and the EEA are lawful and with an adequate level of protection and that your personal is kept secure in accordance with the DPA 1998 (up to and including 24 May 2018) and the GDPR (from and including 25 May 2018).

Information we obtain from third parties

Although we do not disclose your personal information to any third party (except as set out in this notice), we sometimes receive data that is indirectly made up from your personal information from third parties whose services we use.

Data may be processed outside the European Union

Our websites are hosted in the United Kingdom. We may also use outsourced services in countries outside the European Union (EU) from time to time in other aspects of our business for example marketing platforms and customer relationship management platforms.

Accordingly, data obtained within the UK or any other country could be processed outside the EU. We use safeguards with respect to data transferred outside the EU. These include: the processor is within the same corporate group as our business or organisation and abides by the same binding corporate rules regarding data processing; the processor abides by the same corporate rules regarding data processing; processors comply with GDPR and Data Protection rules; we comply with a code of conduct approved by a supervisory authority in the European Union.

Access to your personal information

At any time you may review or update personally identifiable information that we hold about you. To obtain a copy of any information that is not provided through our website you may send us a request at info@datalla.com. After receiving the request, we will tell you when we expect to provide you with the information, and whether we require any fee for providing it to you.

Removal of your information

If you wish us to remove personally identifiable information, you may contact us at info@datalla.com. This may limit the service we can provide to you.

Verification of your information

When we receive any request to access, edit or delete personal identifiable information we shall first take reasonable steps to verify your identity before granting you access or otherwise taking any action. This is important to safeguard your information.

Retention period for personal data

Except as otherwise mentioned in this privacy notice, we keep your personal information only for as long as required by us: to provide you with the services you have requested; to comply with other law, including for the period demanded by our tax authorities; to support a claim or defence in court.

If you are not happy with our privacy policy

If you are not happy with our privacy policy or if have any complaint then you should tell us by contacting us at info@datalla.com. If a dispute is not settled then we hope you will agree to attempt to resolve it by engaging in good faith with us in a process of mediation or arbitration. If you are in any way dissatisfied about how we process your personal information, you have a right to lodge a complaint with the Information Commissioner’s Office. This can be done at https://ico.org.uk/concerns/

Compliance with the law

Our privacy policy has been compiled so as to comply with the law of every country or legal jurisdiction in which we aim to do business. If you think it fails to satisfy the law of your jurisdiction, we should like to hear from you.

Review of this privacy policy

We may update this privacy notice from time to time as necessary. The terms that apply to you are those posted here on our website on the day you use our website. We advise you to print a copy for your records.

If you have any question regarding our privacy policy, please contact us.

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