Privacy Policy

This is the privacy policy of ClearTalent Limited, a company incorporated in England and Wales under company number 08142795, and with registered office at Field End Cottage, Bradley, Hampshire SO24 9RY.

We are registered with the Information Commissioner’s Office in the UK (the “ICO”), and our registration number is ZA192930.

You have the right to make a complaint at any time to the ICO (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. 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.

1. What information do we collect?

We may collect, store and use the following kinds of personal data:

• information about your computer and about your visits to and use of this website (including your IP address, geographical location, browser type, referral source, length of visit and number of page views);
• information that you provide to us for the purpose of registering with us, including contact details;
• any information you choose to disclose to us about your reasonable adjustment and diversity needs at work.
• any other information that you choose to send to us via our enquiry and contact forms.

We may 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 it 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 will treat the combined data as personal data, which will be used in accordance with this privacy policy.

Where we collect 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 we are required to do so by the employer or potential employer on whose behalf we collect the data, we will obtain your specific consent, unless we have another lawful basis to do so.

2. Cookies

A cookie consists of information sent by a web server to a web browser, and stored by the browser. The information is then sent back to the server each time the browser requests a page from the server. This enables the web server to identify and track the web browser.

We use both ‘session’ cookies and ‘persistent’ cookies on the website. We will use the session cookies to transfer information between pages whilst you navigate the website. We use the persistent cookies to remember your display preferences.

Session cookies will be deleted from your computer when you close your browser. Persistent cookies will remain stored on your computer until deleted, or until they reach a specified expiry date.

We use Google Analytics to analyze the use of this website. Google Analytics generates statistical and other information about website use by means of cookies, which are stored on users’ computers. The information generated relating to our website is used to create reports about the use of the website. Google will store this information. Google’s privacy policy is available at: www.google.com/privacypolicy.html.

Most browsers allow you to refuse to accept cookies. This will, however, have a negative impact upon the usability of many websites, including this one.

3. Using your personal data

Personal data submitted on this website will only be used for the purposes specified in this privacy policy or in relevant parts of the website.

We may use your personal information to:

• administer the website;
• improve your browsing experience by personalising the website;
• enable your use of the services available on the website;
• send you email notifications which you have specifically requested;
• send to you our newsletter and other marketing communications relating to our business which we think may be of interest to you by post or, where you have specifically agreed to this, by email or similar technology (you can inform us at any time if you no longer require marketing communications);
• deal with enquiries and complaints made by or about you relating to the website.

We will not without your express consent provide your personal information to any third parties for the purpose of direct marketing.

We will ensure that your personal data is processed lawfully, fairly, and transparently, without adversely affecting your rights. We will only process your personal data if at least one of the following bases applies:

1. you have given consent to the processing of your personal data for one or more specific purposes;
2. processing is necessary for the performance of a contract to which you are a party or in order to take steps at the request of you prior to entering into a contract;
3. processing is necessary for compliance with a legal obligation to which we are subject;
4. processing is necessary to protect the vital interests of you or of another natural person;
5. processing is necessary for the performance of a task carried out in the public interest or in the exercise of official authority vested in the controller; and/or
6. processing is necessary for the purposes of the legitimate interests pursued by us or by a third party such as our financial payments, except where such interests are overridden by the fundamental rights and freedoms of the data subject, in particular where the data subject is a child.

If we receive personal information in the course of providing our services to you from another data subject, we expect you to have complete responsibility for ensuring that the contents of this privacy policy are brought to their attention and you have obtained their consent in the process.

In some instances, it may be appropriate for us to combine your information with other information that we may be holding about you, such as combining your name with your geographic location or your browsing or purchasing history.

4. Other disclosures

In addition to the disclosures reasonably necessary for the purposes identified elsewhere in this privacy policy, we may disclose information about you:

• to the extent that we are required to do so by law;
• in connection with any legal proceedings or prospective legal proceedings;
• in order to establish, exercise or defend our legal rights (including providing information to others for the purposes of fraud prevention and reducing credit risk);
• to any of our agents, suppliers or subcontractors (but only as reasonably necessary for our purposes as set out above); and
• to the purchaser (or prospective purchaser) of any business or asset which we are (or are contemplating) selling.

Except as provided in this privacy policy, we will not provide your information to third parties.

5. International data transfers

All information collected on this website is stored and processed on servers in UK data centers. No non-UK data storage will be used.

In those instances where express permission is given by way of requests by you for additional services from third party suppliers, some personally identifiable data may be securely transferred to those external third partys’ systems. In those instances the data will be subject to the data protection and security policies of those organizations.

6. Security of your personal data

We have taken all reasonable technical and organizational precautions to prevent the loss, misuse or alteration of your personal information.

All transmission of personally identifiable information over the internet is done using https (a secure internet protocol) and hence is extremely secure.

You are responsible for keeping your password and user details confidential. We will not ask you for your password.

7. Policy amendments

We may update this privacy policy from time-to-time by posting a new version on our website. You should check this page occasionally to ensure you are happy with any changes.

We may also notify you of changes to our privacy policy by email.

8. Your rights

You may instruct us to provide you with any personal information we hold about you.

You may instruct us not to process your personal data for marketing purposes by email at any time. (In practice, you will usually either expressly agree in advance to our use of your personal data for marketing purposes, or we will provide you with an opportunity to opt-out of the use of your personal data for marketing purposes.)

You also have the right to:

• request that your personal data be transferred to another person (data portability);
• be informed of what data processing is taking place;
• restrict processing;
• object to processing of personal data; and
• complain to a supervisory authority.

We do not carry out automated decision-making and profiling.

9. Third party websites

The website contains links to other websites. We are not responsible for the privacy policies or practices of third party websites.

10. Updating information

Please let us know if the personal information which we hold about you needs to be corrected or updated.

11. Contact

If you have any questions about this privacy policy or our treatment of your personal data, please write to us by email, or by post to ClearTalent Limited, Field End Cottage, Bradley, Hampshire, SO24 9RY