CIRCLE RECRUITMENT PRIVACY POLICY

1. INTRODUCTION
   1. Welcome to Circle Recruitment's privacy policy (the “Privacy Policy”).
   2. Circle Recruitment respects your privacy and is committed to protecting your personal data. This Privacy Policy informs you how we look after your Personal Data (as defined below) when you visit our Website (as defined below), regardless of where you visit it from, and any other applications, including without limitation for smart devices, and/or use our Services (as defined below). It also tells you about your privacy rights and how the law in our jurisdiction protects you.
   3. We are recruitment experts who provide first class solutions, whether you are looking for that elusive candidate, or seeking your dream role (the “Services”).
   4. Please take the time to read and understand this Privacy Policy carefully to understand our views and practices regarding your Personal Data. By visiting the Website you are accepting and consenting to the practices described in this Privacy Policy.
2. TERMINOLOGY

Below is some quick guidance on terminology to help you clearly understand this Privacy Policy:

3. PURPOSE OF THIS PRIVACY POLICY
   1. This Privacy Policy, together with any documents referred to in it, aims to give you information on how Circle Group Ltd, a private limited company incorporated and registered in England and Wales trading from Top Floor Offices, 53 King Street, Manchester M2 4LQ and with company number 04857483, trading under the name of ‘Circle Recruitment’ (collectively referred to as  “Circle Recruitment”, "we", "us" or "our" in this Privacy Policy), as Data Controller, collects your Personal Data and how your Personal Data will be processed by us from you, through your use of our website, http://www.circlerecruitment.com and its associated sub-domains (the “Website”), including any Personal Data you may provide through the Website when you sign up to our newsletter, purchase any of our Services or take part in any competition. 
   2. We may use Personal Data provided to us for any of the purposes described in this Privacy Policy or as otherwise stated at the point of collection.
   3. When collecting and using Personal Data, our policy is to be fair, lawful and transparent about why and how we process Personal Data.
   4. The Website is not intended for Children and we do not knowingly collect data relating to Children.
   5. This Privacy Policy is aimed at both candidates and employers who use our Website.
   6. It is important that you read this Privacy Policy together with any other policies or fair processing policy we may provide on specific occasions when we are collecting or processing Person Data about you so that you are fully aware of how and why we are using your Personal Data. This Privacy Policy supplements other notices and privacy policies and is not intended to override them.
4. IMPORTANT INFORMATION AND WHO WE ARE
   1. This is the Privacy Policy for the Website. The Website is operated by or on behalf of Circle Recruitment. 
   2. For the purposes of the Data Protection Legislation, when you access the Website, we are acting as the Data Controller and we are responsible for your Personal Data. 
   3. We are registered under the Data Protection Act 2018 with the ICO. Our registration number is Z1015294 and our registration details can be viewed online at www.ico.org.uk.
   4. You have the right to make a complaint at any time to the ICO. We would, however, appreciate the chance to deal with your concerns before you approach the ICO so please contact us in the first instance. 
   5. By accessing or using the Website, you acknowledge and consent to the collection and use of your information in accordance with this Privacy Policy. By accessing the Website, you agree that we may treat your Personal Data as set out in this Privacy Policy. 
   6. If you do not agree with any of the terms of this Privacy Policy, you should refrain from using the Website.
   7. We have appointed Buckworths Limited who is responsible for overseeing questions in relation to this Privacy Policy. If you have any questions about this Privacy Policy, including any requests to exercise your legal rights, please contact us using the following details:

Full name of legal entity: Circle Group Ltd (company number: 04857483)

Postal address: One New Bailey, 4 Stanley Street, Salford, Manchester, England, M3 5JL

Name of DPO: Buckworths Limited

Email address of DPO: office@buckworths.com

5. YOUR DUTY TO INFORM US OF 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.

6. THIRD-PARTY LINKS

The 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 the Website, we encourage you to read the privacy policy of every website you visit.

7. THE DATA WE COLLECT ABOUT YOU
   1. 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).
   2. We may collect, use, store and transfer different kinds of Personal Data about you which we have grouped together as follows:

• Identity Data includes first name, last name and title.
• Contact Data includes full home and/or office address, email address and telephone number.
• Financial Data includes bank account and payment card details.
• Transaction Data includes details about payments to and from you and other details of 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 the Website. 
• Employment Data includes your education history, employment history, references, background checks, previous dealings with Circle Recruitment, interview and placements. 
• Marketing and Communications Data includes your preferences in receiving marketing from us and our third parties and your communication preferences.
  1. 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 Policy.
  2. 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.

8. 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 the 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. 

9. 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:
• apply for our Services or submit a CV to us;
• complete a form on our Website;
• 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. Please see our cookie policy for further details.
• 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:
  1. analytics providers; 
  2. advertising networks; and
  3. search information providers.
• Contact, Financial and Transaction Data from providers of technical, payment and delivery services.
• Identity, Employment and Contact Data from job sites where you have responded to a job advert submitted by us, where you have uploaded your CV, or where you have posted a job.
• Identity, Contact Data and Employment Data from data brokers or aggregators.
• Identity and Contact Data from publicly available sources such as Companies House.

10. HOW WE USE YOUR PERSONAL DATA
    1. 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:
    2. Where we need to perform the contract we are about to enter into or have entered into with you;
    3. 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; and
    4. Where we need to comply with a legal or regulatory obligation.
    5. 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. You have the right to withdraw consent to marketing at any time by contacting us.
11. PURPOSES FOR WHICH WE WILL USE YOUR PERSONAL DATA
    1. 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.
    2. 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. 
    3. For the avoidance of doubt, this table is not exhaustive of the ways in which we may use your Personal Data, and there may be occasions where we require additional information.

12. MARKETING AND PROMOTIONAL OFFERS FROM US 
    1. 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 Services and offers may be relevant for you. 
    2. You will receive marketing communications from us if you have requested information from us or purchased 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.
13. THIRD-PARTY MARKETING 

We will get your express opt-in consent before we share your Personal Data with any company for marketing purposes. 

14. OPTING OUT
    1. You can ask us or third parties to stop sending you marketing messages at any time by following the opt-out links on any marketing message sent to you or by contacting us at any time. 
    2. Where you opt out of receiving these marketing messages, this will not apply to Personal Data provided to us as a result of you purchasing Services from us.
15. 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 the Website may become inaccessible or not function properly.

16. CHANGE OF PURPOSE 
    1. 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. 
    2. 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.
    3. 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.
17. DISCLOSURES OF YOUR PERSONAL DATA
    1. We may have to share your Personal Data with the parties set out below for the purposes set out in the table in paragraph 11 above.

• External Third Parties, including service and analytics providers acting as processors and sub-processors who we use to help us run our business and provide the Services, including: Eploy, Azure UK, Cloudfare, DHM Stallard, Hubspot, Capsule CRM, Woodpecker, Heroku, Amazon Web Services, Cloudinary, Lastpass and Dropbox.
• 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 Policy.
  1. 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.

18. INTERNATIONAL TRANSFERS
    1. Some of our external third parties are based outside the European Economic Area (“EEA”) so their processing of your Personal Data will involve a transfer of data outside the EEA. 
    2. Whenever we transfer your Personal Data out of the EEA, we ensure a similar degree of protection is afforded to it by ensuring at least one of the following safeguards is implemented: 

• Where we use certain service providers, we may use specific contracts approved by the European Commission which give Personal 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 providers based in the US, we may transfer data to them if they are part of the Privacy Shield which requires them to provide similar protection to Personal Data shared between Europe and the US. For further details, see European Commission: EU-US Privacy Shield.
  1. Please contact us if you want further information on the specific mechanism used by us when transferring your Personal Data out of the EEA. 

19. 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.

20. DATA RETENTION
    1. 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. 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.
    2. 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. 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. 
21. YOUR LEGAL RIGHTS
    1. Under certain circumstances, you have rights under Data Protection Legislation in relation to your Personal Data. 
    2. 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 Data Protection Legislation. 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; and

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.

1. If you wish to exercise any of the rights set out above, please contact us, marking your query for the attention of the DPO. 
22. 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.

23. 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.

24. 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. 

25. CONTACT DETAILS 

Full name and details of legal entity: Circle Group Ltd (company number: 04857483); 

Email address: office@buckworths.com; and

Postal address: One New Bailey, 4 Stanley Street, Salford, Manchester, England, M3 5JL.

26. CHANGES TO THIS PRIVACY POLICY
    1. We keep this Privacy Policy under regular review. Any changes we may make to this Privacy Policy will be posted on the Website and, where we believe that the changes to the Privacy Policy are material, we will notify you by e-mail. Please check back frequently to see any updates or changes to this Privacy Policy.
    2. This Privacy Policy was last updated on 4^th July 2022.