Privacy & Cookies Policy
Version 2.1, May 2021
This privacy and cookies policy (Policy) sets out the basis on which any information that we collect from you, or that you provide to us, will be processed by us. Some of this information will be personal data, which is specifically protected under the Data Protection Act 1998.
By accessing and browsing our website, you confirm that you accept and give your consent to the processing of your personal data as described in this Policy.
You are advised to read this Policy carefully before using our website and the services provided through it.
Information about us
Full name of legal entity: SSG Recruitment Partnerships Ltd
Email address: firstname.lastname@example.org
Postal address: 2 The Waterhouse, Waterhouse Street, Hemel Hempstead, HP1 1ES
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.
- a) The content of our Website is protected by trademark, copyright, database and other intellectual property rights and you acknowledge that the material and content supplied as part of our Website shall remain with us or our licensors. You may display the content of the Website on a computer screen or mobile phone screen, store such content in electronic form on disk (but not any server or other storage device connected to a network) or print one copy of such content for your own personal, non-commercial use, provided you keep intact all and any copyright and proprietary notices. You indemnify us that you will not otherwise copy, scrape, modify, reproduce or distribute or use for any purposes any of the materials or content on our Website. Any breach of this indemnity will result in court proceedings and reporting such instances to the police and other authorities.
- loss of revenue;
- loss of contracts;
- loss of the use of money;
- loss of anticipated savings;
- loss of business;
- loss of opportunity;
- loss of goodwill;
- loss of reputation;
- loss of, damage to or corruption of Data; or
- any indirect or consequential loss,
in each case howsoever arising, whether such loss or damage was foreseeable or in the contemplation of the parties and whether arising in or caused by breach of contract, tort (including proven negligence), breach of statutory duty or otherwise.
- c) We do not exclude or limit in any way our liability to you where it would be unlawful to do so. This includes liability for death or personal injury caused by our proven negligence or the proven negligence of our employees, agents or subcontractors; for proven fraud or proven fraudulent misrepresentation; or any other liability which cannot be excluded or limited under applicable law.
- d) We will have no liability to you for any loss of profit, loss of business, business interruption, or loss of business opportunity.
- e) When you post information on our Website or our Social Media Websites, you must not infringe the rights of others (including but not limited to; any such contribution will being offensive, derogatory, defamatory, slanderous, libellous, unlawful, deliberately misleading, breach any moral rights, or breach a third party’s rights, trade mark or copyright and you will be liable to us and indemnify us for any breach of that warranty) and you should be aware that others may use, tag and/or re-publish your information in ways that you might not expect (including in ways that are unlawful). You understand that we and others may use and re-publish any Data you post online publicly, on our Website or our Social Media Websites.
Data We Collect From You
- a) We will collect and process the following Data about you:
Data you give us. This is Data about you that you give us via our Website or our “Social Media Websites” including Facebook, Google+, Instagram, LinkedIn, YouTube and Twitter or via Insycle, Zapier and Salesflow, including your comments, or by corresponding with us by phone, e-mail or otherwise including:
Identity Data includes first name, last name, username or similar identifier, marital status, and title.
Contact Data includes billing address, email address and telephone numbers.
Financial Data includes bank account.
Transaction Data includes details about payments to and from you and other details of products and services you have purchased from us.
Data We Collect About You
With regard to each of your visits to our Website we will automatically collect the following Data:
Technical Data, including but not limited to; the Internet protocol (IP) address used to connect your computer to the Internet, browser type and version, time zone setting, browser plug-in types and versions, operating system and platform;
information about your visit, including the full Uniform Resource Locators (URL), clickstream to, through and from our Website (including date and time), pages you viewed or searched for page response times, download errors, length of visits to certain pages, page interaction information (such as scrolling, clicks, and mouse-overs), methods used to browse away from the webpage.
Profile Data includes your username, purchases or orders made by you, your interests, preferences, feedback and survey responses.
Usage Data includes information about how you use our Website, products and services.
Data we receive from other sources. This is Data we receive about you if you use any of the other websites we operate or the other services we provide. In this case we will have informed you when we collected that Data if we intend to share those Data internally and combine it with Data collected on this Website. We will also tell you for what purpose we will share and combine your Data. We are working closely with third parties (including, for example; business partners, sub-contractors in technical, payment and delivery services, advertising networks, analytics providers, search information providers, credit reference agencies).
Data on your preferences. We may hold Data on interests and demographic categories inferred from your interactions with us in order to provide you a better service and to provide you with more focused information. When you use our Website, we receive the URL of both the site you came from and the one you go to next. We also get Data about your IP address, proxy server, operating system, web browser and add-ons, device identifier and features, and/or ISP or your mobile carrier. If you use our Website from a mobile device, your device will send us Data about your location. Most mobile devices allow you to prevent location Data from being sent to us if you set it.
Marketing and Communications Data includes your preferences in receiving marketing from us and our third parties and your communication preferences. In relation to emails we send you, we may collect Data on how you respond to such emails, for example, the number of times the email is opened or the links in them are clicked.
We do not 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). Nor do we collect any information about criminal convictions and offences.
- b) 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 (for example, to provide you with goods or services). In this case, we may have to cancel a product or service you have with us but we will notify you if this is the case at the time.
(c) 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:
- apply for our products or services;
- fill in a form on our Website;
- subscribe to our service or publications;
- request marketing to be sent to you;
- enter a competition, promotion or survey; or
- give us feedback or contact us.
Automated technologies or interactions. As you interact with our Website, we will 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. Please see Clause 4 below for further details.
Third parties or publicly available sources. We will receive personal Data about you from various third parties and public sources as set out below:
Technical Data from the following parties:
- analytics providers such as Google and Hubspot based outside the EU;
- advertising networks such as Google, LinkedIn and Facebook based outside the EU; and
- search information providers such as Google based outside the EU.
Contact, Financial and Transaction Data from providers of technical, payment and delivery services such as HubSpot based outside the EU.
Identity and Contact Data from publicly available sources such as Companies House and the Electoral Register based inside the EU.
- a) Our Website uses “Cookies” to distinguish you from other users of our Website. This helps us to provide you with a good experience when you browse our Website and also allows us to improve our Website. A “Cookie” is a simple text file that is stored on your computer or mobile device by a website’s server and only that server will be able to retrieve or read the contents of that Cookie. Each Cookie is unique to your web browser. It will contain some anonymous Data such as a unique identifier and the website name. It allows a website to remember things like your preferences.
Strictly Necessary Cookies.
These are Cookies that are required for the operation of our Website. They are necessary for the safety, security and integrity of the Website. For example, they help support the structure of the Website pages that are displayed to you, help to improve navigation and allow you to return to Website pages you have previously visited.
Performance Cookies or analytical Cookies.
They allow us to recognise and count the number of visitors and to see how visitors move around our 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.
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. These Cookies will remain on your computer or device until you choose to clear it. If you choose to do this, you will need to enter your details each time you visit the Website.
Our Cookies use:
- Ad Roll (https://www.adroll.com/en-GB/), Facebook ads (https://www.facebook.com/business/learn/facebook-ads-basics), LinkedIn ads (https://www.linkedin.com/help/linkedin/answer/a420420/get-started-with-campaign-manager?lang=en) , LinkedIn Profiles and Hubspot (https://www.hubspot.com/ ) and third party Cookies within our social media marketing and email campaigns, predominantly sent using third party marketing tools, as well as Google Analytics. Cookies are used to monitor open rates and improve your experience and also for the tracking of website activity initiated from hyperlinks within marketing campaigns.
- Session Cookies on our Website. These are temporary Cookies, which only exist in the period you access the Website (or more strictly, until you close the browser after accessing the Website). Session Cookies help the Website remember what you chose on the previous webpage, therefore avoiding having to re-enter information.
- Cookies used for customer email, customer name, customer id*, token*, customer profile link*, customer flags* (*= generated by our own system) and social media share.
The length of time a Cookie will remain on your Computer will depend on the type of Cookie as listed below. We use the following Cookies on our Website for the following uses:
||This Cookie carries out information about how the end-user uses our Website and any advertising that the end-user may have seen before visiting the said Website. It lasts for approximately 17 years.
||This Cookie keeps track of the number of times a visitor has been to the Website pertaining to the Cookie, when their first visit was, and when their last visit occurred. It lasts for 2 years
||Used by Facebook to deliver a series of advertisement products such as real-time bidding from third party advertisers. It lasts for 2 months.
|Enables the function of our web analytics software, Google Analytics, provided by Google. This software collects information about how visitors use our Website. The Data stored by these Cookies never shows any confidential information. It lasts for 2 years.
||Enables the function of our web analytics software, Google Analytics, provided by Google. This software collects information about how visitors use our Website. The Data stored by these Cookies never shows any confidential information. It lasts for 24 hours.
||Enables the function of our web analytics software, Google Analytics, provided by Google. This software collects information about how visitors use our Website. The Data stored by these Cookies never shows any confidential information. It lasts until the session ends.
||This Cookie carries out information about how the end-user uses our Website and any advertising that the end-user may have seen before visiting the said Website. It lasts for 1 month.
||This Cookie is set by DoubleClick (which is owned by Google) to build a profile of the Website visitor’s interests and show relevant ads on other websites. It lasts for 6 months.
|This Cookie is used to check approximately how fast people leave: when a visit starts, and approximately ends. It lasts for 1 hour.
||This Cookie is used for user-custom variables in analytics. It lasts until the session ends.
||This Cookie takes a timestamp of the exact time you leave the Website. The information they provide helps us to understand whether pages are useful and engaging. It lasts until the session ends
||This Cookie provides us with the search term you typed into your search engine; which website you were on before you arrived; if the link was in an email, which email you received; if you clicked on an advert; or whether you typed our Website address directly into your browser. This Cookie gets updated with each subsequent page you visit, and is therefore the Cookie used to determine which pages you have visited on our site. It lasts for 6 months.
||Used to throttle request rate. It lasts for 10 minutes
||HubSpot: Set by HubSpot’s CDN provider, Cloudflare. It helps Cloudflare detect malicious visitors and minimizes blocking legitimate users. It lasts for 1 month.
||HubSpot: Used by HubSpot to keep track of sessions. It contains the domain, view count (increments each page view in a session), and session start timestamp. It lasts for 1 hour.
||HubSpot: Used by HubSpot to keep track of sessions and to determine if the visitor has restarted their browser. It lasts until the session ends.
||HubSpot: Used by HubSpot to keep track of visitors. It contains the domain, utk, initial timestamp (first visit), last timestamp (last visit), current timestamp (this visit), and session number (increments for each subsequent session). It lasts for 1 year.
||HubSpot: Used by HubSpot to keep track of a visitor’s identity. It lasts for 1 year.
||This is a Google advertising Cookie used for user tracking and ad targeting purposes. It lasts for 7 months.
||Hotjar Cookie. This Cookie is set when a visitor first lands on a page with the Hotjar script. It is used to persist the Hotjar User ID, unique to that site on the browser. This ensures that behaviour in subsequent visits to the same site will be attributed to the same user ID. It lasts for 1 year.
||This Cookie is used to collect performance Data about how people use the Website. It lasts for 1 year.
||With your consent this Cookies helps serve ads that aim to be timely and relevant to the interests of its users. To serve these “targeted” ads, the Cookies collects Data about your browsing activities when you visit the websites of businesses that work with us. It lasts for 1 year.
||This Cookie is associated with the DoubleClick advertising service from Google. Helps with tracking conversion rates for ads. It lasts for 24 hours.
||This Cookie collects anonymous Data about your Website visit and allows targeted advertising. It lasts for 1 year.
||This Cookie allow us to identify a user when receiving a call. Calls are recorded for training and quality purposes. It contains per installation tracking source cache. It lasts until the session ends.
||This Cookie allow us to identify a user when receiving a call. Calls are recorded for training and quality purposes. It contains per installation number replacement source cache. It lasts until the session ends.
||This Cookie allow us to identify a user when receiving a call. Calls are recorded for training and quality purposes. It stores the unique Visitor Reference. It lasts until the session ends.
||This Cookie identifies a new user’s first session. It stores a true/false value, indicating whether this was the first time Hotjar saw this user. It is used by recording filters to identify new user sessions. It lasts for 1 hour.
|Hj absolute session
||This Cookie is used to detect the first pageview session of a user. This is a True/False flag set by the Cookie. It lasts for 1 hour.
– provide you with the service you have asked for. Without Cookies our Website might forget you and you would have to continually log back in;
ICO and The Data Protection Legislation
We adhere to the following working principles:
- a) access to your data for our third party clients’ is restricted to our relevant staff members and HubSpot (https://www.hubspot.com/) only;
- b) where any hard copies are created, the hard copies of your Data and confidential documents are kept securely under lock and key.
We have registered with the Information Commissioner’s Office (“ICO”) (www. ico.org.uk) and adhere to the following principles:
- a) all our relevant employees have received training in how to handle your Data. This includes ensuring they are aware of the importance of handling your Data safely and securely, and understanding the procedures in place to ensure this happens;
- b) once every year we will evaluate our database and securely delete any Data no longer engaged or any information no longer needed by us;
- c) we have measures in place to keep your Data we hold safe and secure;
- d) all Data is stored in a secure web server hosted site to which access is only granted to our key personnel. Where your Data is downloaded to be updated, and as a backup to the cloud (based in Europe), it is only stored on our personal drives, only accessible via our individual log in;
- e) the Data Controller can be contacted via email on email@example.com please but the topic of your enquiry in the header title; and
- f) the Data Controller acknowledges possible recipients of your Data include; our employees, agents, consultants, third parties and Data processors.
Uses Made of the Data
- a) We use Data held about you in the following ways:
Data you give to us. We will use this Data :
– to carry out our obligations arising from any contracts entered into between you and us and to provide you with the information, products and services that you request from us;
– to provide you with information about other goods and services we offer that are similar to those that you have enquired about;
– 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 obligation;
– to provide you, or permit selected third parties to provide you, with information about goods or services we feel may interest you. If you are an existing customer, we will only contact you by electronic means (e-mail or SMS) with information about goods and services similar to those which were the subject of a previous enquiry. Where you want us to use your Data in this way, or to pass your details on to third parties for marketing purposes, please tick the relevant box situated on the form on which we collect your Data. Where we permit selected third parties to use your Data, we (or they) will contact you by electronic means, only if you have consented to this;
– to notify you about changes to our service and products; and
– to ensure that content from our Website is presented in the most effective manner for you and for your computer or device.
Data we collect about you
We will use this Data :
– to administer our Website and for internal operations, including troubleshooting, Data analysis, testing, research, statistical and survey purposes;
– to improve our Website to ensure that content is presented in the most effective manner for you and for your computer;
– to allow you to participate in interactive features of our service, when you choose to do so;
– as part of our efforts to keep our Website safe and secure;
– to measure or understand the effectiveness of advertising we serve to you and others, and to deliver relevant advertising to you;
– to make suggestions and recommendations to you and other users of our Website about goods or services that may interest you or them;
– to prevent misuse of our or third parties intellectual property, or fraud (including credit card fraud and fraud we think has happened during a competition or promotion) or other crimes; and
– to protect the security of our company, employees, our clients, customers, third parties and/or our/their property as permitted by law.
Data we receive from other sources. We will combine this Data with Data you give to us and Data we collect about you. We will use this Data and the combined Data for the purposes set out above (depending on the types of Data we receive).
Marketing. We strive to provide you with choices regarding certain personal Data uses, particularly around marketing and advertising. 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 and 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 third party for marketing purposes.
Opting out. You can ask us or third parties to stop sending you marketing messages at any time. You may stop our marketing by following the opt-out links on any marketing message sent to you or by contacting us at any time. Alternatively, you can email us at firstname.lastname@example.org and highlighting your comment in the heading section “unsubscribe”. Where you opt out of receiving these marketing messages, this will not apply to personal Data provided to us as a result of a product/service purchase, product/service experience or other transactions.
Disclosure of your Data
- a) You agree that we have the right to share your personal Data with:
– Any member of our group, which means our subsidiaries, our ultimate holding company and its subsidiaries, as defined in section 1159 of the UK Companies Act 2006;
– Selected third parties including;
business partners, suppliers and sub-contractors for the performance of any contract we enter into with them or you;
advertisers and advertising networks that require the Data to select and serve relevant adverts to you and others. We do not disclose Data about identifiable individuals to our advertisers, but we will provide them with aggregate Data about our users (for example, we may inform them that 500 men aged under 30 have clicked on their advertisement on any given day). We may also use such aggregate Data to help advertisers reach the kind of audience they want to target (for example, women in SW1). We may make use of the personal Data we have collected from you to enable us to comply with our advertisers’ wishes by displaying their advertisement to that target audience; and
analytics and search engine providers that assist us in the improvement and optimisation of our Website.
- b) We will disclose your personal Data to third parties:
– In the event that we sell or buy any business or assets, in which case we will disclose your personal Data to the prospective seller or buyer of such business or assets;
– If SSG Recruitment Partnerships Ltd or substantially all of its assets are acquired by a third party, in which case personal Data held by it about its customers will be one of the transferred assets; and
– 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 of and other agreements; or to protect the rights, property, or safety of SSG Recruitment Partnerships Ltd, our clients, or others. This includes exchanging information with other companies and organisations for the purposes of prevention of crime including but not limited to fraud protection, credit risk reduction and prevention of terrorism.
– Professional advisers acting as processors or joint controllers including legal advisers, bankers, auditors, accountants and insurers based in the UK who provide consultancy, banking, legal, insurance and accounting services.
– HM Revenue & Customs, regulators and other authorities acting as processors or joint controllers based in the UK who require reporting of processing activities in certain circumstances.
Where we store your personal data
– All Data you provide to us is stored on secure servers using SSL technology.
– We will only transfer Your Data to countries that have been deemed to provide an adequate level of protection for Data by the European Commission. For further details, see European Commission: Adequacy of the protection of personal Data in non-EU countries.
– Where we use certain service providers, we may use specific contracts approved by the European Commission which give Data the same protection it has in Europe. For further details, see European Commission: Model contracts for the transfer of personal Data to third countries.
– Where we use certain service providers, based in the US, such as HubSpot. HubSpot participates in and has certified its compliance with the EU-U.S. Privacy Shield Framework and the Swiss–U.S. Privacy Shield Framework. The following affiliated entities adhere to the Privacy Shield principles: HubSpot Ireland Limited, HubSpot Germany GmbH, HubSpot France S.A.S, HubSpot Australia Pty Ltd, HubSpot Asia Pte. Ltd., HubSpot Latin America S.A.S, and HubSpot Japan KK. HubSpot is committed to subjecting all personal data received from European Union (EU) member countries, the United Kingdom and Switzerland, in reliance on the Privacy Shield Framework, to the Framework’s applicable Principles. To learn more about the Privacy Shield Frameworks, visit the U.S. Department of Commerce’s Privacy Shield List at https://www.privacyshield.gov. Where Hubspot cannot apply the Privacy Shield laws it must transfer the Data on the strict conditions that Hubspot abides by Article 49 of GDPR and provide similar protection to Data shared between UK and the US.
– Unfortunately, the transmission of Data 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 our Website; any transmission is at your own risk. Once we have received your Data , we will use strict procedures and security features to try to prevent unauthorised access.
You have the following rights in relation to Your Data:
- a) Right to access Data – the right to request known as a “Data Subject Request” (i) copies of the Data we hold about you at any time, or (ii) that we modify, update or delete such Data. If we provide you with access to the Data, we hold about you, we will not charge you for this, unless we believe in our sole discretion that your request is “manifestly unfounded or excessive”. Where we are legally permitted to do so, we may refuse your request. If we refuse your request, we will tell you the reasons why in writing (email to suffice);
- b) Right to correct Data– the right to have your Data rectified if it is inaccurate or incomplete;
- c) Right to erase Data– the right to request that we delete or remove your Data from our systems;
- d) Right to restrict our use of your Data – the right to “block” us from using your Data or limit the way in which we can use it;
- e) Right to Data transfer – the right to request that we move, copy or transfer your Data; and
- f) Right to object – the right to object to our use of your Data including where we use it for our legitimate interests.
To make enquiries, exercise any of your rights set out above, or withdraw your consent to the processing of your Data (where consent is our legal basis for processing your Data), please contact us via this e-mail address: email@example.com. We try to respond to all legitimate requests within one (1) month of receipt of notice. Occasionally it could 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.
If you are not satisfied with the way we have handled your Data, you may be able to refer your complaint to the relevant Data protection authority. For the UK, this is the Information Commissioner’s Office (ICO). The ICO’s contact details can be found on their website at https://ico.org.uk/. We are registered under the ICO.
It is important that the Data we hold about you is accurate and current. Please keep us informed if your Data changes during the period for which we hold it.
How long will you use my personal data for?
We will only retain your personal Data for as long as reasonably necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, regulatory, tax, accounting or reporting requirements. We may retain your personal Data for a longer period in the event of a complaint or if we reasonably believe there is a prospect of litigation in respect to our relationship with you.
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, regulatory, tax, accounting or other requirements
By law we have to keep personal Data about our customers (including Contact, Identity, Financial and Transaction Data) for six years after they cease being customers for tax purposes.
In some circumstances you can ask us to delete your Data, see Your Rights above, for further information.
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 Data indefinitely without further notice to you.
Links to other websites
Nothing herein contained shall give rise to a partnership, joint venture or a contract of employment between you and us.
No waiver or affirmation of any breach of or non-compliance with any term hereof by the parties shall be deemed to be a waiver or affirmation of any preceding or succeeding breach of or non-compliance with the same or any other term.