Privacy Policy

1.0 PURPOSE OF THIS PRIVACY POLICY

This privacy policy aims to inform you how We collect and process your Personal Data. It is important that you read this privacy policy to fully understand how and why We are using your data.

Scede Limited, or the applicable group company named below, acts as te Controller and is responsible for your Personal Data (collectively referred to as “Company“, “We“, “Us“, or “Our” in this privacy policy).

For the purposes of this privacy policy, the following definitions shall have the following meanings:

• “Comply With A Legal Obligation” means processing your Personal Data where it is necessary for compliance with a legal or regulatory obligation that We are subject to;
• “Controller” means the organisation that exercises overall control over the purposes and means of processing Personal Data;
• “Data Protection Laws” means the UK Data Protection Act 2018 and all other globally applicable legislation relating to privacy or data protection (including the EU General Data Protection Regulation.
• “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;
• “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” or “Contractual Necessity” 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;
• “Personal Data” means any information relating to natural persons who can be identified or who are identifiable directly from the information in question; or who can be indirectly identified from that information in combination with other information; and
• “Special Category” or “Special Categories” of Personal Data means: (a) Personal Data revealing racial or ethnic origin; (b) Personal Data revealing political opinions; (c) Personal Data revealing religious or philosophical beliefs; (d) Personal Data revealing trade union membership; (e) genetic data; (f) biometric data (where used for identification purposes); (g) data concerning health; (h) data concerning a person’s sex life; and (i) data concerning a person’s sexual orientation.

2.0 CONTACT DETAILS

Scede Limited

• Full name of legal entity (Controller): Scede Limited
• Registered Office Address: Cambridge House, 16 High Street, Saffron Walden, Essex, England, CB10 1AX 
• Name of appointed Data Protection Officer: Formiti Datta International UK Ltd
• DPO Email address privacy@scede.io
• Name of appointed EU Representative: Formiti Data International UK Ltd
• EU Representative Email Address: eurepscede@formiti.com

Scede People Limited

• Full name of legal entity (Controller): Scede People Limited
• Registered Office Address: Cambridge House, 16 High Street, Saffron Walden, Essex, England, CB10 1AX 
• Name of appointed Data Protection Officer: Formiti Datta International UK Ltd
• DPO Email address privacy@scede.io
• Name of appointed EU Representative: Formiti Data International UK Ltd
• EU Representative Email Address: eurepscede@formiti.com

Scede Technology Limited

• Full name of legal entity (Controller): Scede Technology Limited
• Registered Office Address: Cambridge House, 16 High Street, Saffron Walden, Essex, England, CB10 1AX 
• Name of appointed Data Protection Officer: Formiti Datta International UK Ltd
• DPO Email address privacy@scede.io
• Name of appointed EU Representative: Formiti Data International UK Ltd
• EU Representative Email Address: eurepscede@formiti.com

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: Information Commissioner’s Office, Wycliffe House, Water Lane, Wilmslow, Cheshire, SK9 5AF Tel: 0303 123 1113 (local rate) or 01625 545 745 if you prefer to use a national rate number Fax: 01625 524 510 Live Chat Link

If you’re a customer within the EU, you can file a complaint to your local member state data protection authority listed here.

We would, however, appreciate the chance to deal with your concerns before you approach the ICO or local DPA, so please get in touch with Us in the first instance.

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).

PROCESSOR
Scede also operates under certain contracts as a Data Processor. When we operate as a Data Processor, we only process personal data under the strict instructions of the Data Controller. Secured by a data processing agreement between the Data Controller and Scede.

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 above.

3.0 YOUR DUTY TO INFORM US OF CHANGES

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.

4.0 THIRD-PARTY LINKS

This website includes 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.

5.0 THE DATA WE COLLECT ABOUT YOU

We collect, use, store and transfer different categories of Personal Data about you, which We have grouped together as follows:

• Identity Data includes but is not limited to first name, last name, username or similar identifier, title, and date of birth;
• Contact Data includes postal address, email address and telephone numbers;
• Financial Data includes bank account, payment card details, and payroll data;
• Marketing and Communications Data include your preferences in receiving marketing from Us and Our third parties and your communication preferences.
• Technical Data commonly known as online identifiers and includes internet protocol (IP) address, unique mobile device identification numbers (such as your Media Access Control (MAC) address, Identifier For Advertising (IDFA), type of device, browser type and version, time zone setting and geolocation, browser plug-in types and versions, operating system and platform and other technology on the devices you use to access this website;
• Transaction Data includes details about payments to and from you and other details of services you have purchased from Us;
• Usage Data includes information about how you use Our website, services (including text you disclose when communicating within our social media profiles
• We also collect Special Categories of Personal Data about you (this may  include 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). We also may  collect any information about criminal convictions and offences. Special categories of data are only collected where needed for a role you have applied for and only at the correct stage of your application.

Third parties or publicly available sources. We may receive personal data about you from various third parties as set out below:

• Identity, Contact and Profile Data from third parties and publicly available sources such as job boards (including, but not limited to CV Library, CW Jobs, Jobsite, Reed, Total Jobs, Monster, Indeed), your social media accounts and business networking accounts including, but not limited to, LinkedIn, and GitHub.
  • Identity and Contact Data from data brokers or aggregators based inside AND outside the UK.
  • Identity and Contact Data from publicly available sources such as Companies House and the Electoral Register based inside the UK.
• Identity and Contact Data from data brokers or aggregators based inside and outside the UK.
• Identity and Contact Data from publicly available sources such as Companies House and the Electoral Register based inside the UK.

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 provide you with recruitment related services). In this case, we may have to cancel a service you have with us, but we will notify you if this is the case at the time.

6.0 LEGAL BASIS FOR PROCESSING

Our legal basis for processing your personal information varies depending on the type of information We collect and the context in which We collect it.

If you are a resident of the United Kingdom or of a jurisdiction where similar legal requirements may apply, such as Brazil, Switzerland, and the European Union, We rely on several legal bases to process information about you. We will process information about you where We have your consent, where We have a Legitimate Interest to do so, where the processing is necessary for the Performance of a Contract with you, and where We have a legal obligation to process your information. For example, We typically rely on the following:

• Consent when placing cookies on your device on the web (through Our cookie consent manager) to send you email marketing or to deliver third-party targeted advertising to you on Our services;
• Our Legitimate Interests to process your information when providing you with customer service support, to serve targeted marketing of Our services and
• Contractual Necessity to process information when you purchase a service or apply as a candidate for a position we to enable Us to provide you with Our services.

7.0 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.

• 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.

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.

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 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 service or contract.

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 

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.

8.0 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.

9.0 INTERNATIONAL TRANSFERS

Some of our external third parties are based outside the United Kingdom so their processing of your personal data will involve a transfer of data outside the UK.

Whenever we transfer your personal data out of the UK, 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 UK Government
• Where we use certain service providers, we may use specific contracts approved by the UK Government, which give personal data the same protection it has in the K.
• Where we use providers based in the US, we may transfer data to them once we have put in place the appropriate contracts with them and carried out a data transfer impact assessment.

10.0 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, and a data processing agreement

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.

We carry out an annual Data Privacy Maturity Assessment  to the global GAAP standard to ensure continuous improvement and accountability

11.0 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.

12.0 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 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 complete our online Data Subject Access Request form by Clicking here.

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.

13.0 Changes To The Privacy Policy And Your Duty To Inform Us Of Changes

This version was last updated on 13/03/2025 and historic versions can be obtained by contacting us.