Welcome to the Albert Bow Limited privacy notice.
Albert Bow Limited (Company number 11160789) respects your privacy and is committed to protecting the personal data of our candidates, clients and users of our website. This privacy notice will inform you as to how we look after your personal data which is collected from you when you:
• visit our website (regardless of where you visit it from);
• contact us to discuss our services;
• meet with us or our consultants; or
• receive services from us

It also tells you about your privacy rights and how the law protects you. Please also use the Glossary to understand the meaning of some of the terms used in this privacy notice.

Purpose of this privacy notice

This privacy notice aims to give you information on how the Company collects and processes your personal data, the purposes for which we use the data and the way in which the data is handled.

 

This website is not intended for children and we do not knowingly collect data relating to children.

 

It is important that you read this privacy notice together with any other privacy notice or fair processing notice we may provide on specific occasions when we are collecting or processing personal data about you so that you are fully aware of how and why we are using your data. This privacy notice supplements the other notices and is not intended to override them.

 

Controller

Albert Bow Limited is the controller and responsible for your personal data (collectively referred to as "Company", "we", "us" or "our" in this privacy notice). We have appointed a data privacy manager who is responsible for overseeing questions in relation to this privacy notice. If you have any questions about this privacy notice, including any requests to exercise your legal rights, please contact us using the details set out below.

 

Contact details

Our full details are:

Full name of legal entity: Albert Bow Limited

Name or title of data privacy manager: Harry Davies – Co-Founder

Email address: hello@albertbow.com

Postal address: 46-48 Red Lion Court, Park St, SE19EQ, London.

Telephone number: +442038541411

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.

Changes to the privacy notice and your duty to inform us of changes

This version was last updated on 25th May 2018.

The data protection law in the UK will change on 25 May 2018. Although this privacy notice sets out most of your rights under the new laws, we may not yet be able to respond to some of your requests (for example, are quest for the transfer of your personal data) until May 2018 as we are still working towards getting our systems ready for some of these 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.

 

Third-party links

This 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 our website, we encourage you to read the privacy notice of every website you visit.

 

We are not responsible for the protection and privacy of any information which you provide whilst visiting such sites and such sites are not governed by this privacy policy. You should exercise caution and look at the privacy policy applicable to the website in question.

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).

 

We may collect, use, store and transfer different kinds of personal data about you which we have grouped together follows:

Identity Data includes [first name, maiden name, last name, username or similar identifier, marital status, title, date of birth and gender].

Contact Data includes [billing address, delivery address, email address and telephone numbers].

Financial Data includes [bank account and payment card details].

Transaction Data includes [details about payments to and from you and other details of products and 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 this website].

Profile Data includes [your username and password, 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].

Marketing and Communications Data includes [your preferences in receiving marketing from us and our third parties and your communication preferences].

Employment Data includes your CV, any covering letter, remuneration and benefits information, employment history and other information relating to your employment, skills and experience.

 

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 notice.

[We may process, in accordance with data protection laws, certain Special Categories of Personal Data. For example, you may include or disclose this information to us in your CV, covering letter or in the course of our supplying services to you.]

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.

 

We use different methods to collect data from and about you including through:

• Direct interactions. You may give us your [Identity, Contact, Employment 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

o apply for our services;

o apply for a role we may have advertised;

o create an account on our website;

o subscribe to our service or publications;

o request marketing to be sent to you;

o enter a competition, promotion or survey; or

o 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 [http://www.aboutcookies.org/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

o Technical Data from the following parties:

analytics providers [such as Google based outside the EU];

advertising networks [such as Jobsite based [inside OR outside] the EU]; and

search information providers [such as Bing based [inside OR outside] the EU].

o Identity and Contact Data from publicly availably sources [such as Companies House and the Electoral Register based inside the EU]

PURPOSE/ACTIVITY	TYPE OF DATA	LAWFUL BASIS FOR PROCESSING INCLUDING BASIS OF LEGITIMATE INTEREST
To register you as a new customer	(a) Identity (b) Contact (c) Profile	[Performance of a contract with you.]
To supply our services to you including: (a) To send your details to prospective employers (b) Manage payments, fees and charges (c) Collect and recover money owed to us	(a) Identity (b) Contact (c) Financial (d) Transaction (e) Marketing and Communications	(a) [Performance of a contract with you] (b) [Necessary for our legitimate interests (to recover debts due to us)]
To manage our relationship with you which will include: (a) Notifying you of opportunities with potential employers (b) Notifying you about changes to our terms or privacy policy (c) Asking you to leave a review or take a survey	(a) Identity (b) Contact (c) Marketing and Communications (d) Profile	(a) [Performance of a contract with you] (b) [Necessary to comply with a legal obligation] (c) [Necessary for our legitimate interests (to keep our records updated and to study how customers use our products/services)]
To enable you to partake in a prize draw, competition or complete a survey	(a) Identity (b) Contact (c) Usage (d) Marketing and Communications	(a) [Performance of a contract with you] (b) [Necessary for our legitimate interests (to study how customers use our products/services, to develop them and grow our business)]
To administer and protect our business and this website (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data)	(a) Identity (b) Contact (c) Technical	(a) [Necessary for our legitimate interests (for running our business, provision of administration and IT services, network security, to prevent fraud and in the context of a business reorganisation or group restructuring exercise)] (b) [Necessary to comply with a legal obligation]
To deliver relevant website content and advertisements to you and measure or understand the effectiveness of the advertising we serve to you	(a) Identity (b) Contact (c) Usage (d) Profile (e) Marketing and Communications (f) Technical	[Necessary for our legitimate interests (to study how customers use our products/services, to develop them, to grow our business and to inform our marketing strategy)]
To use data analytics to improve our website, products/services, marketing, customer relationships and experiences	(a) Technical (b) Usage	[Necessary for our legitimate interests (to define types of customers for our products and services, to keep our website updated and relevant, to develop our business and to inform our marketing strategy)]
To make suggestions and recommendations to you about goods or services that may be of interest to you	(a) Identity (b) Contact (c) Technical (d) Usage (e) Profile	[Necessary for our legitimate interests (to develop our products/services and grow our business)]

 

To Identity, Contact and Employment Data from External Third Parties such as clients of Albert Bow Limited or your previous employers where you have authorised us to contact them for references etc.

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:

• Where we need to perform the contract we are about to enter into or have entered into– including, but not limited to, the following circumstances:

o To submit your CV for vacancies;

o You subscribe for job alerts;

o To match your details with potential vacancies;

o To retain your details for the purposes of notifying you of vacancies which may be suitable for you;

o To answer any queries you may have;

o To fulfil contracts with our clients.

• 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 or regulatory obligation.

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 or text message. You have the right to withdraw consent to marketing at any time by contacting us.

 

Purposes for which we will use your personal data

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.

 

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

 

Marketing

We strive to provide you with choices regarding certain personal data uses, particularly around marketing and advertising. We have established the following personal data control mechanisms:

 

Promotional offers from us

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 have been supplied with goods or 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.

[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 by contacting us at any time.

Where you opt out of receiving these marketing messages, this will not apply to personal data provided to us as a result of services we have supplied to you.

 

Cookies

What is a Cookie?

A cookie is a small file placed on your computer’s hard drive. It enables our website to identify your computer and you view different pages on our website

Cookies allow websites and applications to tore your preferences in order to present content, options, functions that are specific to you. The also enable is to see information like many people use the website and what pages they tend to visit.

 

Performance Cookies

We utilise other cookies to analyse how our visitors use our websites and to monitor website performance. This allows us to provide a high quality experience by customising our offering and quickly identifying and fixing any issues that arise. For example, we might use performance cookies to keep track of which pages are most popular, which method of linking between pages is most effective, and to determine why some pages are receiving error messages. We might also use these cookies to highlight articles or site services that we think will be of interest to you based on your usage of the website.

 

Functionality Cookies

We use functionality cookies to allow us to remember your preferences. For example, cookies save you the trouble of typing in your username every time you access the site (if you do so), and recall your customisation preferences, such as the latest version of a product that you saw.

 

Third-Party Cookies

Our website also uses the Twitter, LinkedIn and Facebook tools, those sites set a variety of cookies. You should visit the providers’ websites for more details about these third party cookies.

 

Your Choice Regarding 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 this website may become inaccessible or not function properly.

 

Find More Information About Cookies

For more information about the cookies we use, please see http://www.aboutcookies.org/

 

Change of purpose

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.

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.

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.

We may have to share your personal data with the parties set out below for the purposes set out in the table above.

 

* External Third Parties as set out in the Glossary.

 

* Specific third parties such as prospective employers to increase the chances of your chances of securing the job you want.

 

* 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 notice. 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.

 

We do not transfer your personal data outside the European Economic Area (EEA).

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.

How long will you use my personal data for?

 

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.

 

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 cases, we may support candidates throughout their careers. We will conduct regular data-cleansing and updating exercises to ensure that any data we retain is accurate and necessary.

 

By law we have to keep basic information 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 or 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.

 

Under certain circumstances, you have rights under data protection laws in relation to your personal data. Further details of these rights are set out below.

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.

 

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.

 

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.

 

LAWFUL BASIS

Legitimate Interest means the interest of our business in conducting and managing our business to enable us to give you the best service/product and the best and most secure experience. We make sure we consider and balance any potential impact on you (both positive and negative) and your rights before we process your personal data for our legitimate interests. We do not use your personal data for activities where our interests are overridden by the impact on you (unless we have your consent or are otherwise required or permitted to by law). You can obtain further information about how we assess our legitimate interests against any potential impact on you in respect of specific activities by contacting us.

 

Performance of Contract means processing your data where it is necessary for the performance of a contract to which you are a party or to take steps at your request before entering into such a contract.

 

Comply with a legal or regulatory obligation means processing your personal data where it is necessary for compliance with a legal or regulatory obligation that we are subject to.

 

THIRD PARTIES

External Third Parties

Clients of the Company, who are employers looking to recruit candidates for certain roles within their business.

 

Service providers

Professional advisers acting as processors or joint controllers including lawyers, bankers, auditors and insurers 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 United Kingdom who require reporting of processing activities in certain circumstances.

 

Employment reference checks with previous employers.

Qualification checks with appropriate bodies.

Psychometric and skills test providers.

YOUR LEGAL RIGHTS

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 local law. 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.

 

• 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.