Effective Date 4 April 2022
1. Introduction
1.1 We are committed to safeguarding the privacy of our clients, candidates and website visitors.
1.2 This policy applies where we are acting as a data controller with respect to the personal data of our website visitors and service users; in other words, where we determine the purposes and means of the processing of that personal data.
1.3 We use cookies on our website. Insofar as those cookies are not strictly necessary for the provision of [clients, candidates and website visitors], we will ask you to consent to our use of cookies when you first visit our website.
2. Credit
2.1 This document was created using a template from SEQ Legal (https://seqlegal.com).
3. How we use your personal data
3.1 In this Section 3 we have set out:
(a) the general categories of personal data that we may process;
(b) in the case of personal data that we did not obtain directly from you, the source and specific categories of that data;
(c) the purposes for which we may process personal data; and
(d) the legal bases of the processing.
3.2 We may process data about your use of our website and services (“usage data”). The usage data may include your IP address, geographical location, browser type and version, operating system, referral source, length of visit, page views and website navigation paths, as well as information about the timing, frequency and pattern of your service use. The source of the usage data is our analytics tracking system. This usage data may be processed for the purposes of analysing the use of the website and services. The legal basis for this processing is our legitimate interests, namely monitoring and improving our website and services.
3.3 We may process your information included in your candidate or client registration form submitted on our website (“profile data”).The profile data may include your name, address, telephone number, email address, Skype, profile pictures, gender, date of birth, place of birth, relationship status, nationality, passport type, native language, interests and hobbies, educational details, employment details, job search requirements, current location, availability, additional languages spoken, visa type, personal statements, employment requests family requirements. The profile data may be processed for the purposes of monitoring your use of our website and services. The legal basis for this processing is our legitimate interests, namely the proper administration of our website, business, clients requests for services and candidate registrations and applications to seek and apply for new job opportunities.
3.4 We may process information contained in any enquiry you submit to us regarding services (“enquiry data”). The enquiry data may be processed for the purposes of offering, marketing and selling relevant services to you. The legal basis for this processing is consent.
3.5 We may process information received from references, including client contact information (“customer relationship data”). The customer relationship data may include your name, your employer type, your job title, your contact details, and information contained in communications between us, you and your employee. The customer relationship data may be processed for the purposes of assessing suitability of candidates, managing our relationships with customers, communicating with customers, keeping records of those communications and promoting our products and services to customers. The legal basis for this processing is our legitimate interests, namely the proper management of assessing candidates.
3.6 We may process information that you provide to us for the purpose of subscribing to our email notifications and/or newsletters (“notification data”). The notification data may be processed for the purposes of sending you newsletters. The legal basis for this processing is to inform you of an update of available services for you.
3.7 We may process information contained in or relating to any communication that you send to us (“correspondence data”). The correspondence data may include the communication content and metadata associated with the communication. Our website will generate the metadata associated with communications made using the website contact forms. The correspondence data may be processed for the purposes of communicating with you and record-keeping. The legal basis for this processing is our legitimate interests, namely the proper administration of our website and business and communications with users.
3.8 We may process any of your personal data identified in this policy where necessary for the establishment, exercise or defence of legal claims, whether in court proceedings or in an administrative or out-of-court procedure. The legal basis for this processing is our legitimate interests, namely the protection and assertion of our legal rights, your legal rights and the legal rights of others.
3.9 We may process any of your personal data identified in this policy where necessary for the purposes of obtaining or maintaining insurance coverage, managing risks, or obtaining professional advice. The legal basis for this processing is our legitimate interests, namely the proper protection of our business against risks.
3.10 In addition to the specific purposes for which we may process your personal data set out in this Section 3, we may also process any of your personal data where such processing is necessary for compliance with a legal obligation to which we are subject in order to protect your vital interests or the vital interests of another natural person.
3.11 Please do not supply any other person’s personal data to us, unless we prompt you to do so.
4. Providing your personal data to others
4.1 We may disclose your personal data to [our insurers and/or professional advisers insofar as reasonably necessary for the purposes of obtaining or maintaining insurance coverage, managing risks, obtaining professional advice, or the establishment, exercise or defence of legal claims, whether in court proceedings or in an administrative or out-of-court procedure.
4.2 In addition to the specific disclosures of personal data set out in this Section 4, we may disclose your personal data where such disclosure is necessary for compliance with a legal obligation to which we are subject, or in order to protect your vital interests or the vital interests of another natural person. We may also disclose your personal data where such disclosure is necessary for the establishment, exercise or defence of legal claims, whether in court proceedings or in an administrative or out-of-court procedure.
5. Retaining and deleting personal data
5.1 This Section 5 sets out our data retention policies and procedure, which are designed to help ensure that we comply with our legal obligations in relation to the retention and deletion of personal data.
5.2 Personal data that we process for any purpose or purposes shall not be kept for longer than is necessary for that purpose or those purposes.
5.3 Notwithstanding the other provisions of this Section 6, we may retain your personal data where such retention is necessary for compliance with a legal obligation to which we are subject, or in order to protect your vital interests or the vital interests of another natural person.
6. Your rights
6.1 In this Section 6, we have summarised the rights that you have under data protection law. Some of the rights are complex, and not all of the details have been included in our summaries. Accordingly, you should read the relevant laws and guidance from the regulatory authorities for a full explanation of these rights.
6.2 Your principal rights under data protection law are:
(a) the right to access;
(b) the right to rectification;
(c) the right to erasure;
(d) the right to restrict processing;
(e) the right to object to processing;
(f) the right to data portability;
(g) the right to complain to a supervisory authority; and
(h) the right to withdraw consent.
6.3 You have the right to confirmation as to whether or not we process your personal data and, where we do, access to the personal data, together with certain additional information. That additional information includes details of the purposes of the processing, the categories of personal data concerned and the recipients of the personal data. Providing the rights and freedoms of others are not affected, we will supply to you a copy of your personal data. The first copy will be provided free of charge, but additional copies may be subject to a reasonable fee.
6.4 You have the right to have any inaccurate personal data about you rectified and, taking into account the purposes of the processing, to have any incomplete personal data about you completed.
6.5 In some circumstances you have the right to the erasure of your personal data without undue delay. Those circumstances include: the personal data is no longer necessary in relation to the purposes for which they were collected or otherwise processed; you withdraw consent to consent-based processing; you object to the processing under certain rules of applicable data protection law; the processing is for direct marketing purposes; and the personal data have been unlawfully processed. However, there are exclusions of the right to erasure. The general exclusions include where processing is necessary: for exercising the right of freedom of expression and information; for compliance with a legal obligation; or for the establishment, exercise or defence of legal claims.
6.6 In some circumstances you have the right to restrict the processing of your personal data. Those circumstances are: you contest the accuracy of the personal data; processing is unlawful but you oppose erasure; we no longer need the personal data for the purposes of our processing, but you require personal data for the establishment, exercise or defence of legal claims; and you have objected to processing, pending the verification of that objection. Where processing has been restricted on this basis, we may continue to store your personal data. However, we will only otherwise process it: with your consent; for the establishment, exercise or defence of legal claims; for the protection of the rights of another natural or legal person; or for reasons of important public interest.
6.7 You have the right to object to our processing of your personal data on grounds relating to your particular situation, but only to the extent that the legal basis for the processing is that the processing is necessary for: the performance of a task carried out in the public interest or in the exercise of any official authority vested in us; or the purposes of the legitimate interests pursued by us or by a third party. If you make such an objection, we will cease to process the personal information unless we can demonstrate compelling legitimate grounds for the processing which override your interests, rights and freedoms, or the processing is for the establishment, exercise or defence of legal claims.
6.8 You have the right to object to our processing of your personal data for direct marketing purposes (including profiling for direct marketing purposes). If you make such an objection, we will cease to process your personal data for this purpose.
6.9 To the extent that the legal basis for our processing of your personal data is:
(a) consent; or
(b) that the processing is necessary for the performance of a contract to which you are party or in order to take steps at your request prior to entering into a contract, and such processing is carried out by automated means, you have the right to receive your personal data from us in a structured, commonly used and machine-readable format. However, this right does not apply where it would adversely affect the rights and freedoms of others.
6.10 If you consider that our processing of your personal information infringes data protection laws, you have a legal right to lodge a complaint with a supervisory authority responsible for data protection. You may do so in the EU member state of your habitual residence, your place of work or the place of the alleged infringement.
6.11 To the extent that the legal basis for our processing of your personal information is consent, you have the right to withdraw that consent at any time. Withdrawal will not affect the lawfulness of processing before the withdrawal.
6.12 You may exercise any of your rights in relation to your personal data [by written notice to us] OR [by [methods]][, in addition to the other methods specified in this Section 8].
7. Our cookies policy
Cookies do lots of different jobs, like letting you navigate between web pages efficiently, remembering your preferences, and generally improving your experience of our Sites. They can also help to ensure that advertisements and content you see online are more relevant to you and your interests.
The cookies used on the Sites have been categorised based on function. Here are the main types of cookies we use and why we use them:
- Essential Cookies
These cookies are necessary in order to enable you to move around our Sites and use their features, such as accessing secure areas of our Sites. Without these cookies services you may have asked for, cannot be provided.
- Performance Cookies
These cookies collect information about how you use our Sites. For instance, they tell us which pages you visit most often, and if you receive any error messages from our web pages. These cookies do not identify you. All information they collect is aggregated and therefore anonymous. We use these cookies to measure and analyse how our customers use our Sites and to improve their functionality and the user experience.
- Functionality Cookies
These cookies allow our sites to remember choices you make (such as your user name, language or the region you are in) and provide enhanced, personalised features. These cookies can also be used to remember changes you have made to customisable parts of our Sites. The information these cookies collect may be anonymised and they cannot track your browsing activity on other websites.
- Targeting & Advertising Cookies
These cookies are used to deliver marketing and communications more relevant to you and your interests. They are also used to limit the number of times you see an advertisement as well as to help measure the effectiveness of advertising campaign.
- What Cookies Do We Use?
Cookies are text files containing small amounts of information. They are downloaded to your computer or device when you visit a Site. They don’t tell us who you are but they do enable us to recognise your device and where you have made various preferences or actions they enable us to remember them.
- Disabling Cookies
Some web browsers may give you the ability to enable a “do not track” feature that sends signals to the Sites you visit, instructing that you do not want your online activities to be tracked. Be aware that this is different from blocking or deleting cookies. Browsers with “do not track” features enabled may still accept cookies.
- Changes to our Cookie Policy
We may change this Cookie Policy from time to time. If we make changes, we will notify you by revising the date at the top of this policy and in some cases by adding notices on our homepage or other Sites or sending you email updates.
If you have any questions about our Cookie Policy you can contact us at info@superstarnannies.co.uk
8. Our details
8.1 This website is owned and operated by Celebrity recruitment Ltd trading name of SuperstarNanny
8.2 We are registered in England and Wales under registration number 08391525, and our registered office is at 7 Bell Yard, London, WC2A 2JR, United Kingdom
8.3 You can contact us:
(a) by post, to the postal address given above;
(b) using our website contact form;
(c) by telephone, on the contact number published on our website or
(d) by email, using the email address published on our website.