BAMBOO CROWD LIMITED
PRIVACY AND COOKIES POLICY
Bamboo Crowd Limited (“We“, “Us”) is committed to protecting and respecting your privacy. This Privacy and Cookies Policy (“Policy”) (together with and any other documents referred to therein) sets out the basis on which the personal data collected from you, or that you provide to Us will be processed by Us. Please read the following carefully to understand our views and practices regarding your personal data and how We will treat it.
For the purpose of the General Data Protection Regulation (“GDPR”) and the Data Protection Act 2018, (collectively the “Data Protection Laws”) the Data Controller is Bamboo Crowd Limited
YOUR PERSONAL INFORMATION
Information we collect from you
We collect and process some or all of the following types of information from you in the course of your use of the Website or providing our services:
- Information that you provide by filling in forms on the Website. This includes information provided when:
- you submit your details and any personal data contained within any attachments (e.g your curriculum vitae) when you apply for a vacancy published on our Website, or make a speculative application through our Website;
- you request further information about our services, are looking to engage us in relation to a vacancy your organisation may have (a customer), or are looking to enter into negotiations in respect of a service you would like to provide us (a supplier).
- We may also ask you for information when you report a problem with the Website.
- If you contact Us (via phone, e-mail, Skype, Slack or other means), We may keep a record of that correspondence.
- We may also ask you to complete surveys that We use for research purposes, although you do not have to respond to them.
- Details of your visits to the Website including, but not limited to, traffic data, location data, weblogs and other communication data, and the resources that you access.
- Details of your attendance to our events where you respond to our invitation by signing up to such event, including any information you provide us when you attend our events.
If you are an applicant, the provision of your name, email address, telephone number and career history is required from you to enable Us to contact you in relation to a suitable vacancy or to correspond with you in relation to your application for an existing vacancy. Certain other information may be required throughout the recruitment process and we will inform you at the point of collecting information from you, whether you are required to provide the information to Us.
If you are looking to engage us or provide us with your services, the provision of your name, company name, position, e-mail address and telephone number will be required for us to correspond with you in relation to negotiating or agreeing to a contract with us, and in relation to the performance of any such contract entered into with us. Certain other information may be required throughout any negotiations and discussions and we will inform you at the point of collecting information from you, whether you are required to provide the information to Us.
Information We Collect From Other Sources
We may also obtain your personal data from other sources as follows:
- Publically accessible sources such as public forums, social media sites (LinkedIn), and official institutions such as HMRC and Companies House;
- Referees to whom you have provided your consent.
USES MADE OF YOUR INFORMATION
Lawful basis for processing
We rely on “performance of a contract” where we collect, use and share your personal data in order to provide our services, including notifying you about changes to our service, sharing your personal data as part of providing our services and tracking and updating you of progress of your recruitment process. Where you are a candidate applying for jobs, we will share your personal information with relevant employers that match your skills and criteria.
We also rely on “performance of a contract” where we collect, use and share your personal data in order to receive your services pursuant to an agreement with you.
We rely on “consent” where we collect, use and share your personal data in relation to any surveys you participate to.
We rely on “legitimate interest” in the following circumstances:
- To provide our services pursuant to an agreement with an organisation that has engaged you.
- You have previously contacted us via the Website or by calling or e-mailing us, to correspond with you in order to create business relations.
- We collect and use your personal data to filter and deliver suitable vacancies. invitations to events and any other promotional materials or newsletters that may be of interest to you
- To ensure that content on the Website is presented in the most effective manner for you and for the device(s) you use to access, participate in interactive features, and view the Website.
- To provide you with information and offers that you request from Us or which We feel may interest you, including any job opportunities that may arise.
In addition to the above uses We may use your information, to notify you about goods or services which may be of interest to you. Where We do this, We will contact you by electronic means (e-mail or SMS) only if you have consented to such communication. If you do not want Us to use your data in this way please either; (i) do not tick the relevant box situated on the form on which We collect your data (for example, the application submission form) (i) unsubscribe from our electronic communications using the method indicated in the relevant communication; or (ii) inform Us at any time by contacting Us at the contact details set out below.
DISCLOSURE OF YOUR INFORMATION
We routinely disclose your personal data to third parties as follows:
- We may pass your information to our third party service providers, agents, subcontractors and other associated organisations for the purposes of completing tasks and providing services to you on our behalf (e.g. to host our servers, store your data, process payments, track and maintain our recruiting process, deliver marketing materials).
- We will pass your information to the prospective employer whose vacancy your application relates.
We may disclose your personal data to any member of our corporate group, which means our subsidiaries, our ultimate holding company and its subsidiaries, as defined in section 1159 of the UK Companies Act 2006 (where applicable). Any data we collect for recruitment purposes is stored within our internal community database which is accessible by members of our corporate group (including Bamboo Crowd Inc in the US).
We may also disclose your personal data to third parties:
- in the event that We sell or buy any business or assets, in which case We may disclose your personal data to the prospective seller or buyer of such business or assets; or
- if We or substantially all of our assets are acquired by a third party, in which case personal data held by Us about our customers will be one of the transferred assets; or
- if We are under a duty to disclose or share your personal data in order to comply with any legal obligation, or in order to enforce or apply our Terms and Conditions and other agreements; or
- to protect Our rights, property, or safety or that of our affiliated entities and our users and any third party We interact with the to provide the Website; or
- in relation to selected third parties only, only to the extent that you have consented to such selected third parties notifying you about certain goods or services, which may be if interest to you.
Other than as set out above, and save insofar as is necessary in order for Us to carry out our obligations arising from any contracts entered into between you and Us, We will not share your data with third parties unless We have procured your express consent to do so.
STORING YOUR PERSONAL DATA
We take appropriate measures to ensure that any personal data are kept secure, including security measures to prevent personal data from being accidentally lost, or used or accessed in an unauthorised way. We limit access to your personal data to those who have a genuine business need to know it. Those processing your information will do so only in an authorised manner and are subject to a duty of confidentiality. Where We have given you (or where you have chosen) a password which enables you to access certain parts of the Website, you are responsible for keeping this password confidential.
We also have procedures in place to deal with any suspected data security breach. We will notify you and any applicable regulator of a suspected data security breach where We are legally required to do so.
Unfortunately, the transmission of information via the internet is not completely secure. Although We will do our best to protect your personal data, We cannot guarantee the security of your data transmitted to the Website; any transmission is at your own risk. Once We have received your information, We will use strict procedures and security features to try to prevent unauthorised access.
Keeping your personal data up to date
If your personal details change you may update them by accessing your account on the relevant page of the Website, or by contacting Us using the contact details below. If you have any questions about how We use data collected which relates to you, please contact Us by sending a request by email to the contact details below.
Where you contact in relation to updating your personal data, we will endeavour to update your personal data within seven (7) working days of any new or updated personal data being provided to Us, in order to ensure that the personal data We hold about you is as accurate and up to date as possible.
How long we keep your personal data
We will hold the data set out above for a reasonable time having regard to the nature of the personal data and the purpose for which it was collected. In particular:
- Where we hold your personal data in connection with the performance of a contract with one of our customers or suppliers, we will hold your data, and in particular any communications between you and us in relation to the negotiation or performance of the contract by either party for so long as that contract is in force and for a period of at least 7 years after.
- Where we hold your data in connection with an application you have submitted, we will hold such data for 7 years from the later of the following dates: the date we receive your application, or the date of your successful placement with a recruiting company who has engaged us.
- Where we hold your personal data in connection with discussions of potentially entering into a contract (whether to provide you with our services or to receive your services), we will hold such data for 3 years from our last correspondence with you.
Where we store your personal data
All information We hold about you is stored on our supplier’s secure servers in the United States.
The data that We collect from you may be transferred to, and stored at, a destination outside the European Economic Area (“EEA”). It may also be processed by staff operating outside the EEA who work for Us or for one of our suppliers. Such staff maybe engaged in, among other things, the fulfilment of your orders, the processing of your payment details and the provision of support services.
Such countries do not have the same data protection laws as the United Kingdom and EEA. Whilst the European Commission has not given a formal decision that such countries provide an adequate level of data protection similar to those which apply in the United Kingdom and EEA, any transfer of your personal data will be subject to a written agreement with the supplier which we will have reviewed and negotiated to ensure that in contains appropriate protections to help safeguard your privacy rights and give you remedies in the unlikely event of a misuse of your personal data.
If you would like further information please contact our Data Protection Officer (see ‘Contact’ below). We will not otherwise transfer your personal data outside of the United Kingdom or EEA or to any organisation (or subordinate bodies) governed by public international law or which is set up under any agreement between two or more countries.
Under the General Data Protection Regulation you have a number of important rights free of charge. In summary, those include rights to:
- access to your personal data and to certain other supplementary information that this Policy is already designed to address
- require Us to correct any mistakes in your information which We hold
- require the erasure of personal data concerning you in certain situations
- receive the personal data concerning you which you have provided to Us, in a structured, commonly used and machine-readable format and have the right to transmit those data to a third party in certain situations
- object at any time to processing of personal data concerning you for direct marketing
- object to decisions being taken by automated means which produce legal effects concerning you or similarly significantly affect you
- object in certain other situations to our continued processing of your personal data
- otherwise restrict our processing of your personal data in certain circumstances
- claim compensation for damages caused by our breach of any data protection laws.
For further information on each of those rights, including the circumstances in which they apply, see the Guidance from the UK Information Commissioner’s Office (ICO) on individuals rights under the General Data Protection Regulation.
If you would like to exercise any of those rights, please:
- email, call or write to our Data Protection Officer
- let Us have enough information to identify you (eg account number, user name, registration details)
- let Us have proof of your identity and address (a copy of your driving licence or passport and a recent utility or credit card bill), and
- let Us know the information to which your request relates including any account or reference numbers, if you have them
HOW TO COMPLAIN
We hope that our Data Protection Officer can resolve any query or concern you raise about our use of your information.
The General Data Protection Regulation also gives you right to lodge a complaint with a supervisory authority, in particular in the European Union (or European Economic Area) state where you work, normally live or where any alleged infringement of data protection laws occurred. The supervisory authority in the UK is the Information Commissioner who may be contacted at https://ico.org.uk/concerns/ or telephone: 0303 123 1113.
We may collect information about your mobile phone, computer or other device from which you access the Website including where available your IP address, operating system and browser type, for systems administration. This is statistical data about our users’ browsing actions and patterns, and does not identify any individual. We may, however, use such information in conjunction with the data We have about you in order to track your usage of our services.
A cookie is a small file of letters and numbers that We store on your browser or the hard drive of your computer if you agree. Cookies contain information that is transferred to your computer’s hard drive.
The cookies We use include:
- “Analytical” They allow Us to recognise and count the number of visitors and to see how visitors move around the Website when they are using it. This helps Us to improve the way our Website works, for example, by ensuring that users are finding what they are looking for easily.
- “Strictly necessary” cookies. These are cookies that are required for the operation of our Website. They include, for example, cookies that enable you to log into secure areas of our Website, use a shopping cart or make use of e-billing services.
- “Functionality” cookies. These are used to recognise you when you return to our Website. This enables Us to personalise our content for you, greet you by name and remember your preferences (for example, your choice of language or region).
- “Targeting” cookies. These cookies record your visit to our Website, the pages you have visited and the links you have followed to our affiliates websites. We will use this information to make our Website, offers e-mailed to you and the advertising displayed on it more relevant to your interests. We may also share this information with third parties for this purpose.
All questions, comments and requests regarding this Privacy and Cookies Policy should be addressed to our Data Protection Officer firstname.lastname@example.org or write to Us at Bamboo Crowd Limited, Unit 10, 65 Rivington Street, London EC2A 3QQ.