Moda Recruitment Ltd’s privacy policy (GDPR version)

INTRODUCTION

Welcome to the MODA RECRUITMENT LTD’s privacy notice.

Moda Recruitment Ltd respects your privacy and is committed to protecting your personal data. This privacy notice 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.

  1. IMPORTANT INFORMATION AND WHO WE ARE
  1. THE DATA WE COLLECT ABOUT YOU
  1. HOW IS YOUR PERSONAL DATA COLLECTED
  1. HOW WE USE YOUR PERSONAL DATA
  1. DISCLOSURES OF YOUR PERSONAL DATA
  1. INTERNATIONAL TRANSFERS
  1. DATA SECURITY
  1. DATA RETENTION
  1. YOUR LEGAL RIGHTS
  1. GLOSSARY

 

  1. IMPORTANT INFORMATION AND WHO WE ARE

PURPOSE OF THIS PRIVACY NOTICE   

This privacy notice aims to give you information on how Moda Recruitment Ltd 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 notice together with any other privacy notice or fair processing notice 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 notice supplements the other notices and is not intended to override them.

CONTROLLER

Moda Recruitment Ltd is the controller and responsible for your personal data (collectively referred to as ”Moda Recruitment Ltd”, “we”, “us” or “our” in this privacy notice).

We have appointed a data privacy manager who is responsible for overseeing questions in relation to this privacy notice. If you have any questions about this privacy notice, 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:

Full name of legal entity: MODA RECRUITMENT LTD

Name or title of data privacy manager: Matteo Giussani (email: info@modarecruitment.co.uk)

Postal address: C/O G Teoli & Co Balfour House, 741 High Road, London, England, N12 0BP

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 NOTICE AND YOUR DUTY TO INFORM US OF CHANGES

This version was last updated on 20 May 2018.

The data protection law in the UK will change on 25 May 2018. Although this privacy notice sets out most of your rights under the new laws, we may not yet be able to respond to some of your requests (for example, a request for the transfer of your personal data) until May 2018 as we are still working towards getting our systems ready for some of these 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.

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 notice 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 follows:

  • Identity Data includes first name, maiden name, last name, username or similar identifier, marital status, title, date of birth and gender.
  • Contact Data includes billing address, delivery address, email address and telephone numbers, website.
  • Financial Data includes bank account, payment card details and information about your income and revenue.
  • Transaction Data includes details about payments to and from you and other details of products and services you have purchased from us.
  • 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.
  • Profile Data includes your username and password, purchases or orders made by you, your interests, preferences, feedback and survey responses.
  • Usage Data includes information about how you use our website and services.
  • Marketing and Communications Data includes your preferences in receiving marketing from us and our third parties and your communication preferences.

We also 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 notice.

We may 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) and process these in accordance with your instructions. We may also collect any information about criminal convictions and offences, if this is required to carry out our services to you in accordance with our letter of engagement and/or your instructions.

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 (i.e, to provide you with 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.

  1. HOW IS YOUR PERSONAL DATA COLLECTED?

We use different methods to collect data from and about you including through:

  • Direct interactions. You may give us your Identity, Contact and Financial Data by filling in forms or by corresponding with us by post, phone, email or otherwise. This includes personal data you provide when you:
  • Instruct us to provide you with our services;
  • request marketing to be sent to you;
  • enter a competition, promotion or survey; or
  • give us some feedback.
  • 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, server logs and other similar technologies. We may also receive Technical Data about you if you visit other websites employing our cookies.
  • 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:

(a)  analytics providers;

(b)  advertising networks; and

(c)  search information providers.

  • Contact, Financial and Transaction Data from providers of technical, payment and delivery services.
  • Identity and Contact Data from data brokers or aggregators.
  • Identity and Contact Data from publicly availably 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 are about to enter into or 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.

Click [here] to find out more about the types of lawful basis that we will rely on to process your personal data.

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 via email or text message. You have the right to withdraw consent to marketing at any time by Contacting us.

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. Please Contact us if you need details about the specific legal ground we are relying on to process your personal data where more than one ground has been set out in the table below.

Purpose/Activity

 

 Type of data

 

 Lawful basis for processing including basis of legitimate interest

 
To register you as a new client

 

 (a) Identity

(b) Contact

 

 Performance of a contract with you

 
To provide our services to you including:

(a) Store personal data and information and disclose these to external third parties, as defined in the Glossary below.

(b) Manage payments, fees and charges

(c) Collect and recover money owed to us

 

 (a) Identity

(b) Contact

(c) Financial

(d) Transaction

(e) Marketing and Communications

 

 (a) Performance of a contract with you

(b) Necessary for our legitimate interests (to recover debts due to us)

 
To manage our relationship with you which will include:

(a) Notifying you about changes to our terms or privacy policy

(b) Asking you to leave a review

 

 (a) Identity

(b) Contact

(c) Profile

(d) Marketing and Communications

 

 (a) Performance of a contract with you

(b) Necessary to comply with a legal obligation

(c) Necessary for our legitimate interests (to keep our records updated and to study how customers use our products/services)

 
To administer and protect our business and this website (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data)

 

 (a) Identity

(b) Contact

(c) Technical

 

 (a) Necessary for our legitimate interests (for running our business, provision of administration and IT services, network security, to prevent fraud and in the context of a business reorganisation or group restructuring exercise)

(b) Necessary to comply with a legal obligation

 
To use data analytics to improve our website, products/services, marketing, client relationships and experiences

 

 (a) Technical

(b) Usage

 

 Necessary for our legitimate interests (to define types of customers for our products and services, to keep our website updated and relevant, to develop our business and to inform our marketing strategy)

 
To make suggestions and recommendations to you about services that may be of interest to you

 

 (a) Identity

(b) Contact

(c) Technical

(d) Usage

(e) Profile

 

 Necessary for our legitimate interests (to develop our products/services and grow our business)

 

MARKETING

We strive to provide you with choices regarding certain personal data uses, particularly around marketing and advertising.

PROMOTIONAL OFFERS FROM US

We may use your Identity, Contact, Technical, Usage and Profile Data to form a view on what we think you may want or need, or what may be of interest to you. This is how we decide which products, services and offers may be relevant for you (we call this marketing).

You will receive marketing communications from us if you have requested information from us or purchased [goods or services] from us [or if you provided us with your details when you entered a competition or registered for a promotion] and, in each case, you have not opted out of receiving that marketing.

THIRD-PARTY MARKETING

We will get your express opt-in consent before we share your personal data with any company outside MODA RECRUITMENT LTD for marketing purposes.

OPTING OUT

You can ask us or third parties to stop sending you marketing messages by Contacting us at any time.

 

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 www.modarecruitment.co.uk 

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 you wish to get an explanation as to how the processing for the new purpose is compatible with the original purpose, please Contact us.

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.

  1. DISCLOSURES OF YOUR PERSONAL DATA

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

  • External Third Parties as set out in the Glossary.
  • 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 notice.

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. 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.

  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 clients (including Contact, Identity, Financial and Transaction Data) for six years after they cease being clients.

In some circumstances you can ask us to delete your data: see Request erasure 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. Please click on the links below to find out more about these rights:

  • Request access to your personal data.
  • Request correction of your personal data.
  • Request erasure of your personal data.
  • Object to processing of your personal data.
  • Request restriction of processing your personal data.
  • Request transfer of your personal data.
  • Right to withdraw consent.

If you wish to exercise any of the rights set out above, please Contact us.

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 this case, we will notify you and keep you updated.

  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

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.

EXTERNAL THIRD PARTIES

  • Service providers acting as processors based in the United Kingdom who provide IT and system administration services, including billing.
  • Professional advisers acting as processors or joint controllers including lawyers, bankers, auditors, agents and insurers based in the United Kingdom or abroad.
  • Professional advisers acting as legal representatives of counterparties.
  • HM Revenue & Customs, regulators and other authorities and agencies acting as processors or joint controllers based in the United Kingdom or abroad who require reporting of processing activities in certain circumstances.

YOUR LEGAL RIGHTS

You have the right to:

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 the personal data that we hold about you. 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 of 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; (b) where our use of the data is unlawful but you do not want us to erase it; (c) where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims; or (d) 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.

Cookies notice
When you create or log in to an online account you agree to a cookie banner which provides a link to the Privacy
and Cookies notice. Otherwise, by continuing to use our websites, content, products or services, you agree to the
use of cookies as described in this notice.

You should be aware that when you access or use our content, products and services, we may collect information
from the devices you use to receive Moda Recruitment Ltd content, products and services by using ‘cookies’. We
also collect such information from third party websites, mobile sites and from apps where we show our own
adverts, using cookies and related ad technology.

If you’d like to learn how to manage these cookies and choose whether or not to receive information of different
types, please see the section “Controlling My Cookies” below.

What are cookies and how do they work?
Cookies are small bits of text that are downloaded to the devices you use to receive Moda Recruitment Ltd content,
products and services and access online information. Your browser makes these cookies available every time you
visit the website again, so it can recognise you and can then tailor what you see on your device.

What do you use cookies for?
Cookies are an important part of the internet. They make using devices and accessing online information much
smoother and affect lots of the useful features of websites. There are many different uses for cookies, but they fall
into four main groups.

Cookies that are needed to provide the content, product or service you have asked for

Some cookies are essential to help your devices download or stream the information, or so you can move around
websites and use their features. Without these cookies, content, products or services you’ve asked for can’t be
provided.

Here are some examples of essential cookies:

• Positioning information on a smartphone screen, tablet device or other screen so that you can see the website
and use its functionality.
• Keeping you logged in during your visit or enabling you to stream content. Without cookies, you might have
to log in on every website you visit or repeatedly adjust your volume and viewing settings.
• When you add something to the online shopping basket, cookies make sure it’s still there when you get to the
checkout.
• Some are session cookies which make it possible to navigate through the website smoothly.

Improving your browsing experience

Cookies allow the application or website to remember choices you make, such as your language or region and
they provide improved features.

Here are a few examples of just some of the ways that cookies are used to improve your experience on our
applications and websites:
• Remembering your preferences and settings, including marketing preferences, such as choosing whether you
wish to receive marketing information.
• Remembering if you’ve filled in a survey, so you’re not asked to do it again.
• Remembering if you’ve been to the application or website before.
• Restricting the number of times you’re shown a particular advertisement. This is sometimes called ‘frequency
capping’.
• Showing you information that’s relevant to content, products or services that you receive.
• Giving you access to content provided by social-media sites like Facebook or Twitter.
• Showing ‘related article’ links that are relevant to the information you’re looking at.
• Remembering an application or website you’ve entered, such as weather forecasts.

Analytics

We like to keep track of what websites, information and links are popular and which ones don’t get used so much,
to help us keep our information relevant and up to date. It’s also very useful to be able to identify trends of how
people navigate (find their way through) our information and when and where ‘error messages’ may originate.

This group of cookies, often called ‘analytics cookies’ are used to gather this information. The information
collected is grouped with the information from everyone else’s cookies. We can then see the overall patterns of
usage rather than any one person’s activity. Analytics cookies are used to improve how an application, a website
and its pages work.

Our applications, web locations, websites and communications you get from us contain small invisible images
known as ‘web beacons’ or ‘ pixels’. These are used to manage the interaction between you and the online
information or email and allow us to assess the effectiveness of the communication.

How we show advertising and marketing that is relevant to your interests

We sell space on some of our websites, mobile sites and apps to advertisers. The resulting adverts often contain
cookies and related ad technology that is placed by third party partners such as ad servers, ad agencies, ad network
providers and research firms. These partners use the browsing information collected from these cookies to:

• Restrict the number of times you see the same ad (frequency capping) and

• Help show other advertisements that are relevant to you while you’re accessing our information. This

information about your browsing activity may be grouped with information about what is being accessed by
other users, into interest groups, and then used to show you advertisements based on those interests. This is
often called online behavioural advertising (OBA). OBA is a way of using information about your webbrowsing activity, collected by using cookies, to group you with other users into interest groups and show you
advertisements based on those interests.

Sometimes our websites contain advertisements for our own Moda Recruitment Ltd products. These
advertisements use cookies in the same way as described above. We may also use cookies and related ad
technology on third party websites, mobile sites and apps to show you OBA ads based on data collected by those
cookies.

Cookies explained

We do not sell personal data collected from cookies to any other organisations. If you want to know about data
collected by third parties when you click on their adverts, you should check their privacy notices to find out what
they collect, how they process it and what they use it for.

It’s easy to choose not to receive behavioural advertising and manage your cookies if you want to.

Controlling my cookies

Virtually all modern browsers allow you to see what cookies you’ve got, and to clear them individually or clear
all of them. To find out how to do this, go to aboutcookies.org, which contains comprehensive information on
how to do this on a wide variety of desktop browsers.

How can I choose not to receive Online Behavioural Advertising and other tracking cookies?

In addition to the controls available on your computer, there are other ways of choosing not to receive Online
Behavioural Advertising and other tracking cookies.

Please note that most of these choices work by setting a cookie that overrides the behavioural advertising cookie.
If you clear all your cookies, you will also clear these opt-out cookies, therefore changing your preferences. In
this instance you would need to choose again.

Organisations which provide more information on Online Behavioural Advertising

• Evidon is a provider of privacy solutions.

• Internet Advertising Bureau (IAB) “Your Online Choices” page allows you to choose not to receive
behavioural advertising from each of the advertising networks represented by the IAB.

• Network Advertising Initiative (NAI) opt out page allows you to choose not to receive behavioural
advertising from each of the ad networks represented by the NAI.

• Digital Advertising Alliance’s self-regulatory program for online behavioural advertising choices page