This policy applies to information we collect when you choose to use this website, and also to personal data which we process further to supplying services to our clients and candidates.

Personal data is any information that can be used to identify an individual.

We take your privacy very seriously and we ask that you read this privacy policy carefully as it contains important information on the personal data we collect about you; what we do with your information and who your information might be shared with.

This website is owned by Bluetownonline Ltd. and our registered office is at 6 Hoxton Square, Shoreditch, London, N1 6NU.

Who we are

Bluetownonline Ltd. ('we' or 'us') are a 'data controller' for the purposes of the Data Protection Act 2018 and as of 1 January 2021, the UK General Data Protection Regulation ('GDPR') (as applicable the "Legislation") where we control the purposes for which we process your personal data and we comply with the Legislation.

Any questions about our data protection policy or how we handle your personal data should be addressed to Guy Simpson. (See 'How to contact us' below.)

What information do we collect?

Personal data provided by you

We collect personal data, meaning any information from which a natural person may be identified.

We may collect, use, store and transfer different kinds of personal data you provide us with including your name, address, contact details and additional information that may be required that is or may be required to enable us to undertake our services.

You may provide us with your identity, address and contact details through several methods including, when you directly correspond with us, make an enquiry, register your personal data with us or upload your CV to our website. We also collect personal data when you contact us via the online form.

Personal data provided obtained from third parties

We may obtain information about you from third parties, such as online job boards and social media sites including Linkedin, Facebook, Twitter and Instagram when you are looking for and/or you show an interest in a job listing. As a recruitment company we have a legitimate business interest to help you find work and to do this we need to process your personal data.

Sensitive personal data

We will not request or hold any type of sensitive personal data or special category data about you.

Use of cookies

A cookie is a small text file which is placed onto a computer (or other electronic device) when you are browsing our website. They are used to identify the user or device and to collect information during your visit to the website. We use cookies on our website.

Where applicable, this website uses a cookie control system allowing you on your first visit to the website to allow or disallow the use of cookies on your computer/device. This complies with recent legislation requirements for websites to obtain explicit consent from users.

For example, we may monitor information about your computer, including where available your IP address, operating system and browser type, how many times you visit the website, which pages you go to, traffic data, location data and the originating domain name of a user's internet service provider, to improve the user's experience whilst visiting the website, and better understand how you use it. This information helps us to build a profile of our users. Some of this data will be aggregated or statistical, which means that we will not be able to identify you individually.

We use cookies to keep track of your information during the time you view the website. We also use them to recognise return visitors and to track our promotions and projects. We gather this information for internal use only and will never authorise the release of this information outside of Bluetownonline.

You can set your browser not to accept cookies and the websites below tell you how to remove cookies from your browser. However, some of our website features may not function as a result.

For further information on cookies generally, you can visit www.aboutcookies.org or www.allaboutcookies.org.

How will we use the information about you?

We will only use your personal date when the law allows us to. Most commonly, we will use your personal data in the following circumstances:

• Where we need to perform a contract we are about to enter or have entered with you
• Where we need to comply with a legal or regulatory obligation
• 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

In compliance with the above legal bases, we plan to process your personal data for the following purposes:

• identify you and manage any accounts you hold with us
• provide the services requested
• subject to your prior approval, let you know about other products or services that may be of interest to you (see 'Marketing’ section below)
• detect and prevent fraud
• customise our website and its content to your particular preferences
• notify you of any changes to our website or to our services that may affect you
• improve our services

Marketing

We may send an email directly to you with a link to an application form for certain job vacancies. These will only be vacancies that you have registered your interest in and will only be sent if you have provided consent for us to contact you regarding roles you are interested in. Please inform us if you would like us to stop sending these emails to you.

Who your information might be shared with

We shall not share your persona data unless we are entitled to do so. The categories of recipients who we may share your personal information include:

• Any regulatory authority or any law enforcement agency in connection with any legal obligation that applies to us or pursuant to an investigation to help prevent unlawful activity.
• Our clients, recruiters, third party partners, job boards, job platforms and databases necessary for the provision of our recruitment services.
• Our third party service providers who perform functions on our behalf, including our advertisers, legal and professional advisers (such as our lawyers, insurers, auditors and accountants), as well as our providers of administrative, technical support and IT support.

Keeping your data secure

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 employees, agents and subcontractors who have a business need to know. They will only process your personal data on our instructions.

Our employees, agents and subcontractors are also bound by obligations of confidentiality and trained in the protection of personal data. We comply with the Legislation and use the appropriate technical and organisational measures necessary to safeguard your personal data. We only share your personal data with third parties who reasonably deem to act in compliance with the Legislation.

While we will use all reasonable efforts to safeguard your personal data, you acknowledge that the use of the internet is not entirely secure and for this reason we cannot guarantee the security or integrity of any personal data that is transferred from you or to you via the internet. If you have any particular concerns about your information, please contact us (see ‘How to contact us?’ below).

We have put in place procedures to deal with any suspected personal data breach and we will notify you and any applicable regulator of a breach where we are legally required to do so.

The personal data that we collect from you may be transferred across international borders in order for us to supply our services. Whenever we transfer your personal data outside of the UK, we will ensure a similar degree of protection is in place by implementing the following safeguards:

• We will only transfer your personal data to third countries whose data protection laws have been approved as adequate under the Legislation for protecting personal data; and
• Where we use certain service providers, we have in place legal agreements which comply with the Legislation and give personal data the same protection it has in the UK.

What can I do to keep my information safe?

If you want detailed information 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.

Retention Periods

It is our policy to only store personal data for as long as is reasonably necessary for us to comply with our legal obligations and for our legitimate business interests.

We will store your personal data in our secure servers for the following periods:

• Candidates - nine months from the date of your last application with us.
• Clients/Suppliers - If you are one of our clients or suppliers we will hold your details for as long as we have a business requirement to hold such details. We regularly check our databases and will delete your records if we have not used your personal data for 5 years. Please inform us if you would like us to remove any details we hold of you from our records.

unless the law requires us to store the data for a longer period.

What rights do you have?

The UK GDPR provides the following rights for individuals whose personal data is processed:

1. The right to be informed
2. The right of access
3. The right to rectification
4. The right to erasure
5. The right to restrict processing
6. The right to data portability
7. The right to withdraw consent to processing
8. Rights in relation to automated decision making and profiling (We do not carry out automated decision making and profiling)

Right to access – i.e. to request a copy of your information

You can request a copy of your information which we hold (this is known as a subject access request). If you would like a copy of some or all of it, please:

• write to us at Bluetownonline Ltd., 6 Hoxton Square, Shoreditch, London, N1 6NU or email info@bluetownonline.co.uk;
• let us have proof of your identity (a copy of your driving licence or passport) so that we may confirm your right to access your personal data (or to exercise any of your other rights); and
• let us know what information you want.

You will not have to pay a fee to access your personal data (or to exercise any of your other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we could refuse to comply with your request in these circumstances.

Right to correct any mistakes in your information

You can require us to correct any mistakes in your information which we hold free of charge. If you would like to do this, please:

• email or write to us (see ‘How to contact us?’ below);
• let us have enough information to identify you; and
• let us know the information that is incorrect and what it should be replaced with.

Right to remove your details from our records or restrict how we use your information

You can ask us to stop contacting you for particular purposes or remove your information completely from our records. There may be a legal reason why we need to keep your personal data and, in that circumstance, we will destroy your personal data as soon as we are legally entitled to do so. If you would like us to stop contacting you with information about our services, please:

• email or write to us (see ‘How to contact us?’ below). You can also click on the ‘unsubscribe’ button at the bottom of the email and/or newsletter
• let us know what method of contact you are not happy with if you are unhappy with certain ways of contacting you only (for example, you may be happy for us to contact you by email but not by telephone).

Right to lodge a complaint with the Supervising Authority

If you have any concerns or complaints about how we use your personal data we hope you will alert us to these directly (see the Contact information below). If you are still unhappy you are entitled to complain to the Information Commissioners Office (ICO) which is the relevant supervising authority in the UK. Their contact details and the procedure can be found at www.ico.gov.uk

How to contact us

Please contact Guy Simpson, Bluetownonline Ltd. at 6 Hoxton Square, Shoreditch, London, N1 6NU, if you have any questions about this privacy policy or the information we hold about you.

If you wish to contact us about any other matter, please send an email to info@bluetownonline.co.uk or write to us at 6 Hoxton Square, Shoreditch, London, N1 6NU.

Changes to the privacy policy

We may change this privacy policy from time to time and we will do we all we can to ensure future compliance with the Legislation. You should check this policy occasionally to ensure you are aware of the most recent version that will apply each time you access this website or use our services.

Bluetownonline Ltd.
February 2021