PRIVACY POLICY

Version 0.1

Date September 10, 2018.

Scede Limited 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) and tell you about your privacy rights and how the law protects you.

The General Data Protection Regulation (EU) 2016/679 (“GDPR”) is a regulation in EU law on data protection and privacy for all individuals within the European Union (EU) and the European Economic Area (EEA). It also addresses the export of personal data outside the EU and EEA areas. The GDPR aims primarily to give control to citizens and residents over their personal data and to simplify the regulatory environment for international business by unifying the regulation within the EU

This privacy policy should be read alongside, and in addition to, our Terms and Conditions, which can be found at: https://scede.io/terms-and-conditions/.

  1. IMPORTANT INFORMATION AND WHO WE ARE

PURPOSE OF THIS PRIVACY POLICY

This privacy policy aims to give you information on how Scede collects and processes your personal data through your use of this website, including any data you may provide through this website when you decide to contact us through our website, apply to any roles to become a member of our team, subscribe to our newsletter or ask a copy of our “The Go To Guide For Recruiting Metrics”.

You must be at least 18 years of age to use our website and we do not knowingly collect data relating to anyone under 18 years old.

It is important that you read this privacy policy together with any other policies 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 other policies and is not intended to override them.

CONTROLLER

Scede Limited is the controller and responsible for your personal data (collectively referred to as “COMPANY”, “we”, “us” or “our” in this privacy policy).

We have appointed an external data protection officer (DPO) 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 external DPO using the details set out below.

CONTACT DETAILS

Our full details are:

Full name of legal entity: Scede Limited

Name of external DPO: Robert Healey

Email address: privacy@scede.io

Postal address: Suite 511, The Greenhouse, The Custard Factory, Gibb Street, Birmingham, B9 4AA.

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.

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

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

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.

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.

  1. 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:

  • Identity Data includes first name and last name.
  • Contact Data includes 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.
  • Marketing and Communications Data includes your preferences in receiving marketing from us and our third parties and your communication preferences.

We do not collect any data about you relating to: (i) Transaction Data and Financial Data, such as bank account and payment card details, as you cannot purchase using our website any goods, services or products from us; (ii) Profile Data, such as username and password, as we do not ask you your feedback, interests, preferences through or website; (iii) Usage Data, as we do not collect information about how you use our website.

We also do not collect any Special Categories of Personal Data about you (this includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health and genetic and biometric data). Nor do we collect any information about criminal convictions and offences.

  1. HOW IS YOUR PERSONAL DATA COLLECTED

We use different methods to collect data from and about you including, but not limited to:

  • Direct interactions. You may give us your Identity, Contact and Marketing and Communication Data by filling in forms or by corresponding with us by post, phone, email or otherwise. This includes personal data you provide when you:
    • contact us through our website;
    • apply for roles available on our website;
    • subscribe to our newsletter; or
    • ask a copy of our “The Go To Guide For Recruiting Metrics”.
  • Automated technologies or interactions. As you interact with our website, we may automatically collect Technical Data about your equipment, browsing actions and patterns. We collect this personal data by using cookies, pixels, server logs and other similar technologies. We may also receive Technical Data about you if you visit other websites employing our cookies. Please see our Cookie Policy for further details.
  • Third parties or publicly available sources. We may receive personal data about you from various third parties and public sources as set out below:
    • Technical Data from the following parties:
  1. analytics providers such as Google based inside AND outside the EU;
  2. advertising networks such as Facebook based inside AND outside the EU; and
  3. search information providers such as Google based inside AND outside the EU.
    • Identity and Contact Data from data brokers or aggregators based inside AND outside the EU.
    • Identity and Contact Data from publicly available sources such as Companies House and the Electoral Register based inside the EU.
  1. HOW 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 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 or regulatory obligation.

Generally, we do not rely on consent as a legal basis for processing your personal data other than in relation to sending third party direct marketing communications to you. You have the right to withdraw consent to marketing at any time by contacting us at privacy@scede.io.

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.

Purpose/Activity Type of data Lawful basis for processing including basis of legitimate interest
Contact Us through our website (a) Identity

(b) Contact

(c) Technical

Necessary for our legitimate interest to communicate with you.
To process your job application to work with us (a) Identity

(b) Contact

Performance of a contract with you
Subscribe to our newsletter (a) Identity

(b) Contact

Necessary for our legitimate interests to grow our business
Ask a copy of our “The Go To Guide For Recruiting Metrics” (a) Identity

(b) Contact

Necessary for our legitimate interests to grow our business
To manage our relationship with you (for example, to notify you about changes to our terms or privacy policy) (a) Identity

(b) Contact

(c) Technical

Performance of a contract with you

Necessary to comply with a legal obligation

To make suggestions and recommendations to you about roles that may be of interest to you (a) Identity

(b) Contact

(c) Marketing and Communications

Necessary for our legitimate interests to grow our business
To process and deliver your order marketing preferences, by obtaining your consent for marketing activities performed by third parties (a) Identity

(b) Contact

(c) Marketing and Communications

Explicit consent

 

MARKETING

We provide you with choices regarding certain personal data uses, particularly around marketing and advertising. We have established the following personal data control mechanisms:

THIRD-PARTY MARKETING

We will get your explicit opt-in consent before we share your personal data with any company outside Scede for marketing purposes.

OPTING OUT

You can ask us or third parties to stop sending you marketing messages at any time by logging into the website and checking or unchecking relevant boxes to adjust your marketing preferences or by following the opt-out links on any marketing message sent to you or by contacting us at privacy@scede.io at any time.

Where you opt out of receiving these marketing messages, this will not apply to personal data provided to us as a result of a product/service purchase, product/service experience or other transactions.

COOKIES

You can set your browser to refuse all or some browser cookies, or to alert you when websites set or access cookies. If you disable or refuse cookies, please note that some parts of this website may become inaccessible or not function properly. For more information about the cookies we use, please see our Cookie Policy.

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 that 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.

  1. DISCLOSURES OF YOUR PERSONAL DATA

We may have to share your personal data with third parties set out below for the purposes set out in the table in paragraph 4 above.

  • Specific marketing partners listed here.
  • 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 may also disclose your personal data to a prospective purchaser of our business or any part of it. We will take steps with the aim of ensuring your privacy is protected.

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.

  1. INTERNATIONAL TRANSFERS

Some of our external third parties are based outside the European Economic Area (EEA) so their processing of your personal data will involve a transfer of data outside the EEA.

Whenever we transfer your personal data out of the EEA, we 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.
  • Where we use certain service providers, we may use specific contracts approved by the European Commission, which give personal data the same protection it has in Europe.
  • Where we use providers based in the US, we may transfer data to them if they are part of the Privacy Shield, which requires them to provide similar protection to personal data shared between the Europe and the US.
  1. 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 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.

If you want detailed information from Get Safe Online on how to protect your information and your computers and devices against fraud, identity theft, viruses and many other online problems, please visit www.getsafeonline.org. Get Safe Online is supported by HM Government and leading businesses.

  1. DATA RETENTION

HOW LONG WILL YOU USE MY PERSONAL DATA FOR?

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.

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 requirements.

By law we have to keep basic information about our customers (including Contact, Identity, Financial and Transaction Data) for six years plus current year after they cease being customers for tax purposes.

In some circumstances you can ask us to delete your data: please see “Request erasure of your personal data” below for further information.

In some circumstances we may 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.

  1. YOUR LEGAL RIGHTS

Under certain circumstances, you have rights under data protection laws in relation to your personal data. We set out below a brief description of such rights:

  • Request access to your personal data (commonly known as a “data subject access request”): This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it.
  • Request correction of your personal data: This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.
  • Request erasure of your personal data: This enables you to ask us to delete or remove personal data 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 data where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your personal data to comply with local law. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons, which will be notified to you, if applicable, at the time of your request.
  • Object to processing of your personal data: 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 as you feel it impacts on your fundamental rights and freedoms. You also have the right to object where we are processing your personal data for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms.
  • Request restriction of processing your personal data: This enables you to ask us to suspend the processing of your personal data in the following scenarios: (a) if you want us to establish the data’s accuracy; or (b) you have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.
  • Request the transfer of your personal data to you or to a third party: We will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.
  • Withdraw consent at any time where we are relying on consent to process your personal data: However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain products or services to you. We will advise you if this is the case at the time you withdraw your consent.

If you wish to exercise any of the rights set out above, please contact us at privacy@scede.io.

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 may 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 may take us longer than a month if your request is particularly complex or you have made a number of requests, in which case we will inform you of an extension period of up to 2 months. In this case, we will keep you informed on progress.

  1. GLOSSARY

LAWFUL BASIS

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 at privacy@scede.io.

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 or regulatory obligation means processing your personal data where it is necessary for compliance with a legal or regulatory obligation that we are subject to.

Explicit consent for external marketing means your personal data will not be disclosed to any third party unless you have given your explicit consent to such disclosure.

  1. POLICY UPDATES

We may update our Privacy Policy from time to time to reflect changes in technology, legislation, our operations, or as we otherwise determine is necessary or appropriate. Any such changes will become effective when we make the revised policy available on our website. We encourage you to review the date above frequently to ensure you are aware of when our policy was last revised, and to help you better understand the nature of your interactions with us.