About Us and this Notice

This Privacy Notice applies to personal data collected through our website http://ifyoucouldjobs.com/ if you are a visitor to the website and if you have an account on the website.

This Privacy Notice is provided by If You Could Jobs Limited ('we' or 'us'). We are a 'controller' for the purposes of the General Data Protection Regulation (EU) 2016/679 ("Data Protection Laws").

We take your privacy very seriously. We ask that you read this Privacy Notice carefully as it contains important information about our processing and your rights.

How to contact us

If you have any questions about this Privacy Notice, how we handle your personal data, or want to exercise any of your rights, please contact:

• HR Department: Sandip Gill

• Address: 21 Downham Road, Dalston, London, N1 5AA

• Telephone number: 020 7749 9912

• Email: [email protected]

If you would like this Privacy Notice in another format (for example: audio, large print, braille), please contact us.

Changes to the Privacy Notice

We may change this Privacy Notice from time to time. We will alert you emailing all active users when changes are made.

Current version: v1 August 2019

Useful Words and Phrases

Please familiarise yourself with the following words and phrases as they have particular meanings in the Data Protection Laws and are used throughout this Privacy Notice:

"controller" This means any person who determines the purposes for which, and the manner in which, any personal data is processed.

"Data Protection Laws" This means the laws which govern the handling of personal data. This includes the General Data Protection Regulation ((EU) 2016/679), the Data Protection Act 2018 and related statutory instruments as amended or in force from time to time.

"data subject" The person to whom the personal data relates.

"ICO" This means the UK Information Commissioner's Office which is responsible for implementing, overseeing and enforcing the Data Protection Laws.

"personal data" This means any information from which a living individual can be identified. This will include information such as telephone numbers, names, addresses, e-mail addresses, photographs and voice recordings. It will also include expressions of opinion and indications of intentions about data subjects (and their own expressions of opinion/intentions). It will also cover information which on its own does not identify someone but which would identify them if put together with other information which we have or are likely to have in the future.

"processing" This covers virtually anything anyone can do with personal data, including:

• obtaining, recording, retrieving, consulting or holding it;

• organising, adapting or altering it;

• disclosing, disseminating or otherwise making it available; and

• aligning, blocking, erasing or destroying it.

"processor" This means any person who processes the personal data on behalf of the controller.

What personal data do we collect and why?

Personal data provided by you

➢ Visitors only

If you are just browsing our website we will not collect personal data. We will collect information about your usage of our website through cookies. We collect this information so that we can:

1. tailor and personalise user experience;

2. monitor our website usage to improve its content, layout and performance; and

3. improve our services and products.

This information is statistical and aggregated and is not processed for the purpose of understanding your particular usage of the website.

➢ If you create an account as a job seeker

If you set up an account on our website we collect your email address so that we can administer your account.

➢ If you create an account as a recruiter

If you set up an account on our website as a recruiter we collect your name and email address so that we can administer your account.

➢ Other information you submit to us

o We process personal information about you (such as your name, email address and anything else that you provide to us) when you contact us by sending us an email.

➢ Newsletters

o If you sign up to receive our newsletters, we will use your email address to send you the material you have requested.

o You can unsubscribe at any time by contacting us at the details set out above or clicking the "unsubscribe" link in the emails that you receive. If you have an account you can edit your settings on your profile.

Purpose and legal basis for processing

We use your personal data for the purposes listed in this section. We are allowed to do so on certain legal grounds (please see section 'How is processing your data lawful' for further explanation of the legal grounds noted below).

Purpose: Administering your account

Explanation: We need certain information such as your email address and (if you are a recruiter), your name and contact details so that we can set up your account and then contact you. We will also use these details to send you alerts about jobs you have saved to your account.

Legal grounds for processing: Contract

Purpose: Responding to enquiries

Explanation: Respond to enquiries, complaints and requests in order to serve our customers. We will only use your personal data for this purpose.

Legal grounds for processing: Legitimate Interests

Purpose: Uploading a job specification

Explanation: We need your name and email address to make sure we can contact you and so our users can contact you about the job.

Legal grounds for processing: Contract

Purpose: Marketing

Explanation: We process your data to send newsletters and emails to you about jobs advertised on our website. For example, you may sign up to receive newsletters and alerts.

Legal grounds for processing: Consent

How is processing your personal data lawful?

We are allowed to process your personal data for the following reasons and on the following legal bases:

• Legitimate Interests: We are permitted to process your personal data if it is based on our 'legitimate interests' i.e. we have good, sensible, practical reasons for processing your personal data which is in the interests of us. To do so, we have considered the impact on your interests and rights, and have placed appropriate safeguards to ensure that the intrusion on your privacy is reduced as much as possible. You can object to processing that we carry out on the grounds of Legitimate Interests. See the section headed "Your Rights" to find out how.

• Contract: It is necessary for our performance of the contract you have agreed to enter with us. If you do not provide your personal data to us, we will not be able to carry out our obligations under the terms of your contract.

• Consent: Sometimes we want to use your personal data in a way that is entirely optional for you, such as sending you marketing material. On these occasions, we will ask for your consent to use your information. You can withdraw this consent at any time.

Who will have access to your personal data?

Like any business, we use service providers to operate our website. Some of these service providers will process your data as part of the services they offer to us. We take steps to ensure that our service providers treat your data in accordance with the law, only use it in accordance with our contract with them and keep it secure. Our website hosting provider is Digital Ocean. If you would like to know the names of our other service providers, please contact us using the details at the start of this Privacy Notice.

How we keep your data secure

We strive to implement appropriate technical and organisational measures in order to protect your personal data against accidental or unlawful destruction, accidental loss or alteration, unauthorised disclosure or access and any other unlawful forms of processing. We aim to ensure that the level of security and the measures adopted to protect your personal data are appropriate for the risks presented by the nature and use of your personal data. We follow recognised industry practices for protecting our IT environment and physical facilities.

When will we delete your data?

The table below provides details about how long we will process your data.

Data we process: Contact information for your account

How long this will be held for: Until your account is no longer active and is closed.

Data we process: Subscription / marketing requests

How long this will be held for: Until you tell us that you no longer wish to receive the subscription or marketing material.

Data we process: Information from enquires

How long this will be held for: Until the enquiry has been completed and no further responses are received for a reasonable period. We check and remove this data as required every 6 months.

Data we process: Complaints data

How long this will be held for: For a period of up to 6 years after resolution of the complaint.

Data we process: Information from job specifications

How long this will be held for: This remains on the website until the job specification is deleted either by request of the recruiter or in a database clearance carried out every 12 months.

Your Rights

You have the rights set out in the sections below under the Data Protection Laws.

We will respond to any rights that you exercise within a month of receiving your request, unless the request is particularly complex, in which case we will respond within three months. Please be aware that there are exceptions and exemptions that apply to some of the rights which we will apply in accordance with the Data Protection Laws.

• Right to object to processing of your personal data: You may object to us processing your personal data where we rely on a Legitimate Interest as our legal grounds for processing. If you object to us processing your personal data we must demonstrate compelling grounds for continuing to do so. We believe we have demonstrated compelling grounds in the section headed "How is processing your personal data lawful".

• Right to access personal data relating to you: You may ask to see what personal data we hold about you.

• Right to correct any mistakes in your information: You can require us to correct any mistakes in your information which we hold.

• Right to restrict processing of personal data: You may request that we stop processing your personal data temporarily if:

o you do not think that your data is accurate. We will start processing again once we have checked whether or not it is accurate;

o the processing is unlawful but you do not want us to erase your data;

o we no longer need the personal data for our processing, but you need the data to establish, exercise or defend legal claims; or

o you have objected to processing because you believe that your interests should override our Legitimate Interests.

• Right to data portability: You may ask for an electronic copy of your personal data which we hold electronically and which we process when we have entered into a contract with you. You can also ask us to provide this directly to another party.

• Right to withdraw consent: You may withdraw any consent that you have given us to process your personal data at any time.

• Right to erasure: You can ask us to erase your personal data where:

o you do not believe that we need your data in order to process it for the purposes set out in this Privacy Notice;

o if you had given us consent to process your data, you withdraw that consent and we cannot otherwise legally process your data;

o you object to our processing and we do not have any Legitimate Interests that mean we can continue to process your data; or

o your data has been processed unlawfully or have not been erased when it should have been.

What will happen if your rights are breached and complaints to the regulator

You may be entitled to compensation for damage caused by contravention of the Data Protection Laws. It is important that you ensure you have read this Privacy Notice - and if you do not think that we have processed your data in accordance with this notice - you should let us know as soon as possible. You may also complain to the ICO. Information about how to do this is available on his website at www.ico.org.uk.