14th August 2024

1. Introduction

1.1) We are committed to safeguarding the privacy of our website visitors and Software Solutions Users and Candidates. In this policy, we explain how we will handle your personal data. 

1.2) By using our website and Software Solutions and agreeing to this policy, you consent to our use of cookies in accordance with the terms of this policy. 

1.3) Our website incorporates privacy controls which affect how we will process your personal data. By using the privacy controls, you can specify whether you would like to receive direct marketing. You can change privacy settings by contacting us by phone or online request from within your account on our website. 

2. How we use your personal data 

2.1) In this Section 2 we have set out: 
(a) the general categories of personal data that we may process; 
(b) in the case of personal data that we did not obtain directly from you, the source and specific categories of that data; 
(c) the purposes for which we may process personal data; and 
(d) the legal bases of the processing. 

2.2) We may process data about your use of our website and Software Solutions (“usage data”). The usage data may include your IP address, geographical location, browser type and version, operating system, referral source, length of visit, page views and website navigation paths, as well as information about the timing, frequency and pattern of your Software Solutions use. The source of the usage data is our analytics tracking system. This usage data may be processed for the purposes of analysing the use of the website and Software Solutions. The legal basis for this processing is our legitimate interests, namely monitoring and improving our website and Software Solutions. 

2.3) We may process your account data (“account data”). The account data may include your name and email address and any other information necessary to provide the Software Solutions. The source of the account data may be you, or any employment agency, contractor, intermediary or employer or with whom you have a relationship. The account data may be processed for the purposes of operating our website, providing our Software Solutions, ensuring the security of our website and Software Solutions, maintaining back-ups of our databases and communicating with you. Where you have provided us with this information, the legal basis for this processing is the performance of a contract between you and us and/or taking steps, at your request, to enter such a contract. Where a third party has provided us with your account data, the legal basis will our legitimate interests, namely the proper administration of our website, Software Solutions and business. 

2.4) We may process your information included in your personal profile on our website and Software Solutions (“profile data”). The profile data may include your name, address, telephone number, email address, identity pictures, gender, date of birth, educational and employment details. The source of the account data maybe you, or any employment agency, contractor, intermediary or employer or with whom you have a relationship. The profile data may be processed for the purposes of enabling and monitoring your use of our website and Software Solutions. Where you have provided us with this information, the legal basis for this processing is the performance of a contract between you and us and/or taking steps, at your request, to enter into such a contract. Where a third party has provided us with your account data, the legal basis will our legitimate interests, namely the proper administration of our website, Software Solutions and business. 

2.5) We may process your personal data that are provided in the course of the use of our Software Solutions (“service data”). The service data may include any information necessary for you to be placed in work and/or any information necessary for the correct processing of payments for such work, including any appropriate deductions and statutory reporting. The source of the account data may be you, or any employment agency, contractor, intermediary or employer or with whom you have a relationship. The service data may be processed for the purposes of operating our website, providing our Software Solutions, ensuring the security of our website and Software Solutions, maintaining back-ups of our databases and communicating with you. Where you have provided us with this information, the legal basis for this processing is the performance of a contract between you and us and/or taking steps, at your request, to enter into such a contract. Where a third party has provided us with your account data, the legal basis will our legitimate interests, namely the proper administration of our website, Software Solutions and business. 

2.6) We may process information contained in any enquiry you submit to us (“enquiry data”) for the purposes of providing information to you about our Software Solutions now or in the future and/or Software Solutions provided by third parties which may be of interest to you. You will have the right to decide whether your personal information is subsequently provided to such a third party. You may choose to opt-out of receiving this information by notifying us at info@engagetech.com. The legal basis for this processing is consent. 

2.7) We may process information that you provide to us for the purpose of subscribing to our email notifications and/or newsletters (“notification data”). The notification data may be processed for the purposes of sending you the relevant notifications and/or newsletters. The legal basis for this processing is the performance of a contract between you and us and/or taking steps, at your request, to enter into such a contract. 

2.8) We may process information contained in or relating to any communication that you send to us (“correspondence data”). The correspondence data may include the communication content and metadata associated with the communication. Our website and Software Solutions will generate the metadata associated with communications made using the website and Software Solutions contact forms. The correspondence data may be processed for the purposes of communicating with you and record-keeping. The legal basis for this processing is our legitimate interests, namely the proper administration of our website, Software Solutions and business and communications with users. 

2.9) We may process any of your personal data identified in the other provisions of this policy where necessary for the establishment, exercise or defence of legal claims, whether in court proceedings or in an administrative or out-of-court procedure. The legal basis for this processing is our legitimate interests, namely the protection and assertion of our legal rights, your legal rights and the legal rights of others. 

2.10) In addition to the specific purposes for which we may process your personal data set out in this Section 2, we may also process any of your personal data where such processing is necessary for compliance with a legal obligation to which we are subject, or in order to protect your vital interests or the vital interests of another natural person. 

2.11) Please do not supply any other person’s personal data to us, unless we prompt you to do so, for example where you have the other persons authority to do so for the purposes of a referral reward. 

3. Providing your personal data to others 

3.1) We may disclose your personal data to our insurers and/or professional advisers insofar as reasonably necessary for the purposes of obtaining and maintaining insurance coverage, managing risks, obtaining professional advice and managing legal disputes. 

3.2) We may disclose your personal data to our suppliers, subcontractors and clients insofar as reasonably necessary for performance of a contract between you and us and/or taking steps, at your request, to enter into such a contract. 

3.3) Financial transactions relating to our website and Software Solutions are handled by our payment services providers. We will share transaction data with our payment services providers only to the extent necessary for the purposes of processing your payments, dealing with complaints and queries relating to such payments. 

3.4) We may share your personal data with our service providers, who help us to provide the Software Solutions, such as cloud storage, security, application communications, document and identity verification, customer support, backup, and data analytics; and always under written contract ensuring that adequate safeguards are put in place to protect your personal data.  

3.5) In addition to the specific disclosures of personal data set out in this Section 3, we may also disclose your personal data where such disclosure is necessary for compliance with a legal obligation to which we are subject, or in order to protect your vital interests or the vital interests of another natural person. 

4. International transfers of your personal data 

4.1) We do not transfer data to countries outside of the European Economic Area (EEA). 

5. Retaining and deleting personal data 

5.1) This Section 5 sets out our data retention policies and procedure, which are designed to help ensure that we comply with our legal obligations in relation to the retention and deletion of personal data. 

5.2) Personal data that we process for any purpose or purposes shall not be kept for longer than is necessary for that purpose or those purposes. 

5.3) We will retain and delete your personal data as follows: 

(a) If we have processed a placement for you, we will retain your personal data for a period of seven years from the date of your last placement, at the end of which period it will be deleted from our systems. 

(b) If we have not processed a placement for you, but you have provided us with personal data and accepted our terms, we will retain your personal data for a period of two years from the date of your last recorded activity on our system, at the end of which period it will be deleted from our systems. 

(c) If we have not processed a placement for you, but you, or a third party (e.g. a recruitment agency),  have provided us with personal data and not accepted our terms, we will retain your personal data for a period of six months from the date of  the last recorded activity on your profile data on our system, at the end of which period it will be deleted from our systems. 

5.4) Notwithstanding the other provisions of this Section 5, we may retain your personal data where such retention is necessary for compliance with a legal obligation to which we are subject, or in order to protect your vital interests or the vital interests of another natural person. 

6. Amendments 

6.1) We may update this policy from time to time by publishing a new version on our website. 

6.2) You should check this page occasionally to ensure you are happy with any changes to this policy. 

6.3) We may notify you of changes to this policy by email or through the private messaging system on our website and Software Solutions. 

7. Your rights 

7.1) In this Section 7, we have summarised the rights that you have under data protection law. Some of the rights are complex, and not all the details have been included in our summaries. Accordingly, you should read the relevant laws and guidance from the regulatory authorities for a full explanation of these rights. 

7.2) Your principal rights under data protection law are: 

(a) the right to access; 
(b) the right to rectification; 
(c) the right to erasure; 
(d) the right to restrict processing; 
(e) the right to object to processing; 
(f) the right to data portability; 
(g) the right to complain to a supervisory authority; and 
(h) the right to withdraw consent. 

7.3) You have the right to confirmation as to whether or not we process your personal data and, where we do, access to the personal data, together with certain additional information. That additional information includes details of the purposes of the processing, the categories of personal data concerned and the recipients of the personal data. Providing the rights and freedoms of others are not affected, we will supply to you a copy of your personal data. The first copy will be provided free of charge, but additional copies may be subject to a reasonable fee. You can access your personal data by visiting the website address in the link provided at registration. 

7.4) You have the right to have any inaccurate personal data about you rectified and, taking into account the purposes of the processing, to have any incomplete personal data about you completed. 

7.5) In some circumstances you have the right to the erasure of your personal data without undue delay. Those circumstances include: the personal data are no longer necessary in relation to the purposes for which they were collected or otherwise processed; you withdraw consent to consent-based processing; the processing is for direct marketing purposes; and the personal data have been unlawfully processed. However, there are certain general exclusions of the right to erasure. Those general exclusions include where processing is necessary: for exercising the right of freedom of expression and information; for compliance with a legal obligation; or for the establishment, exercise or defence of legal claims. 

7.6) In some circumstances you have the right to restrict the processing of your personal data. Those circumstances are: you contest the accuracy of the personal data; processing is unlawful but you oppose erasure; we no longer need the personal data for the purposes of our processing, but you require personal data for the establishment, exercise or defence of legal claims; and you have objected to processing, pending the verification of that objection. Where processing has been restricted on this basis, we may continue to store your personal data. However, we will only otherwise process it: with your consent; for the establishment, exercise or defence of legal claims; for the protection of the rights of another natural or legal person; or for reasons of important public interest. 

7.7) You have the right to object to our processing of your personal data on grounds relating to your particular situation, but only to the extent that the legal basis for the processing is that the processing is necessary for: the performance of a task carried out in the public interest or in the exercise of any official authority vested in us; or the purposes of the legitimate interests pursued by us or by a third party. If you make such an objection, we will cease to process the personal information unless we can demonstrate compelling legitimate grounds for the processing which override your interests, rights and freedoms, or the processing is for the establishment, exercise or defence of legal claims. 

7.8) You have the right to object to our processing of your personal data for direct marketing purposes (including profiling for direct marketing purposes). If you make such an objection, we will cease to process your personal data for this purpose. 

7.9) To the extent that the legal basis for our processing of your personal data is consent, and such processing is carried out by automated means, you have the right to receive your personal data from us in a structured, commonly used and machine-readable format. However, this right does not apply where it would adversely affect the rights and freedoms of others. 

7.10) If you consider that our processing of your personal information infringes data protection laws, you have a legal right to lodge a complaint with a supervisory authority responsible for data protection. You may do so in the EU member state of your habitual residence, your place of work or the place of the alleged infringement. 

7.11) To the extent that the legal basis for our processing of your personal information is consent, you have the right to withdraw that consent at any time. Withdrawal will not affect the lawfulness of processing before the withdrawal. 

7.12) You may exercise any of your rights in relation to your personal data by written notice to us. 

8. About cookies 

8.1) A cookie is a file containing an identifier (a string of letters and numbers) that is sent by a web server to a web browser and is stored by the browser. The identifier is then sent back to the server each time the browser requests a page from the server. 

8.2) Cookies may be either “persistent” cookies or “session” cookies: a persistent cookie will be stored by a web browser and will remain valid until its set expiry date, unless deleted by the user before the expiry date; a session cookie, on the other hand, will expire at the end of the user session, when the web browser is closed. 

8.3) Cookies do not typically contain any information that personally identifies a user, but personal information that we store about you may be linked to the information stored in and obtained from cookies. 

9. Cookies that we use 

9.1) We use cookies for the following purposes: 

(a) authentication – we use cookies to identify you when you visit our website and as you navigate our website; 
(b) status – we use cookies to help us to determine if you are logged into our website; 
(c) personalisation – we use cookies to store information about your preferences and to personalise the website and Software Solutions for you; 
(d) security – we use cookies as an element of the security measures used to protect user accounts, including preventing fraudulent use of login credentials, and to protect our website and Software Solution generally; 
(e) analysis – we use cookies to help us to analyse the use and performance of our website and Software Solutions; and 
(g) cookie consent – we use cookies to store your preferences in relation to the use of cookies more generally. 

10. Cookies used by our service providers 

10.1) Our service providers use cookies, and those cookies may be stored on your computer when you visit our website and Software Solutions. 

10.2) We use Google Analytics to analyse the use of our website and Software Solutions. Google Analytics gathers information about website use by means of cookies. The information gathered relating to our website and Software Solutions is used to create reports about the use of our website and Software Solutions. Google’s privacy policy is available at: https://www.google.com/policies/privacy 

11. Managing cookies 

11.1) Most browsers allow you to refuse to accept cookies and to delete cookies. The methods for doing so vary from browser to browser, and from version to version. You can however obtain up-to-date information about blocking and deleting cookies on the browser suppliers’ websites 

11.2) Blocking all cookies will have a negative impact upon the usability of many websites. 

11.3) If you block cookies, you will not be able to use all the features on our website. 

12. Our details 

12.1) This website is owned and operated by Engage Technology Partners Ltd. 

12.2) We are registered in England and Wales under registration number 08926632, and our registered office is at Number 22 Mount Ephraim, Tunbridge Wells, England, TN4 8AS. 

12.3) Our principal place of business is at Columba House, Adastral Park, Martlesham Heath, Martlesham, Ipswich, England, IP5 3 RH. 

12.4) You can contact us: 

(a) by post, using the postal address given above; or 
(b) using our website contact form. 

13. Data protection officer 

13.1) Our data protection officer’s contact details are: Eugenia Garcia, Engage Technology Partners (address as above).