This Privacy Policy sets out how we, Econoland Ltd trading as The Talent Keeper Specialists collect, store and use information about you when you use or interact with our website, www.comebackcommunity.co.uk (our website) and where we otherwise obtain or collect information about you. This Privacy Policy is effective from 1st July 2020.
Summary
Our details
Information we collect when you visit our website
Information we collect when you contact us
Information we collect when you interact with our website
How we collect or obtain information about you from third parties
Disclosure and additional uses of your information
How long we retain your information
How we secure your information
Transfers of your information outside the European Economic Area
Your rights in relation to your information
Your right to object to the processing of your information for certain purposes
Sensitive Personal Information
Changes to our Privacy Policy
View summary
This section summarises how we obtain, store and use information about you. It is intended to provide a very general overview only. It is not complete in and of itself and it must be read in conjunction with the corresponding full sections of this Privacy Policy.
Data controller
We are registered with the Information Commissioner’s Office. The data controller in respect of our website is The Talent Keeper Specialists (company registration number: 4179249). You can contact the data controller by writing to 13 Jerome Drive, St Albans, Hertfordshire, AL3 4LT, UK or sending an email to hello@talentkeepers.co.uk
If you have any questions about this Privacy Policy, please contact the data controller.
We collect and use information from website visitors in accordance with this section and the section entitled Disclosure and additional uses of your information.
Web server log information
We use a third party server to host our website WPEngine Inc., the privacy policy of which is available here: https://wpengine.com/legal/privacy/. Our website server automatically logs the IP address you use to access our website as well as other information about your visit such as [the pages accessed, information requested, the date and time of the request, the source of your access to our website (e.g. the website or URL (link) which referred you to our website and your browser version and operating system.
Our server is located in London, United Kingdom. For further information and information on the safeguards used, please see the section of this privacy policy entitled Transfers of your information outside the European Economic Area.
Use of website server log information for IT security purposes
We and our third-party hosting provider collect and store server logs to ensure network and IT security and so that the server and website remain uncompromised. This includes analysing log files to help identify and prevent unauthorised access to our network, the distribution of malicious code, denial of services attacks and other cyber-attacks, by detecting unusual or suspicious activity.
Unless we are investigating suspicious or potential criminal activity we do not make, nor do we allow our hosting provider to make, any attempt to identify you from the information collected via server logs.
Legal basis for processing: compliance with a legal obligation to which we are subject (Article 6(1)(c) of the General Data Protection Regulation).
Legal obligation: we have a legal obligation to implement appropriate technical and organisational measures to ensure a level of security appropriate to the risk of our processing of information about individuals. Recording access to our website using server log files is such a measure.
Legal basis for processing: our legitimate interests (Article 6(1)(f) of the General Data Protection Regulation).
Legitimate interests: we have a legitimate interest in using your information for the purposes of ensuring network and information security.
Use of website server log information to analyse website use and improve our website
We use the information collected by our website server logs to analyse how our website users interact with our website and its features. For example, we analyse the number of visits and unique visitors we receive, the time and date of the visit, the location of the visit and the operating system and browser used.
We use the information gathered from the analysis of this information to improve our website. For example, we use the information gathered to change the information, content and structure of our website and individual pages based according to what users are engaging most with and the duration of time spent on particular pages on our website.
Legal basis for processing: our legitimate interests (Article 6(1)(f) of the General Data Protection Regulation).
Legitimate interest: improving our website for our website users and getting to know our website users’ preferences so our website can better meet their needs and desires.
Cookies
Cookies are data files which are sent from a website to a browser to record information about users for various purposes.
We use cookies and similar technologies on our website, including essential, functional and analytical cookies. For further information on how we use cookies, please see our cookies policy
You can reject some or all of the cookies we use on or via our website by changing your browser settings, but doing so can impair your ability to use our website or some or all of its features. For further information about cookies, including how to change your browser settings and other ways in which you can reject cookies, please visit www.allaboutcookies.org or see our cookies policy.
We collect and use information from individuals who contact us in accordance with this section and the section entitled Disclosure and additional uses of your information.
When you send an email to the email address displayed on our website we collect your email address and any other information you provide in that email (such as your name, telephone number and the information contained in any signature block in your email).
Legal basis for processing: our legitimate interests (Article 6(1)(f) of the General Data Protection Regulation).
Legitimate interest(s): responding to enquiries and messages we receive and keeping records of correspondence.
Legal basis for processing: necessary to perform a contract or to take steps at your request to enter into a contract (Article 6(1)(b) of the General Data Protection Regulation).
Reason why necessary to perform a contract: where your message relates to us providing you with goods or services or taking steps at your request prior to providing you with our goods and services (for example, providing you with information about such goods and services), we will process your information in order to do so).
Transfer and storage of your information
We use a third party email provider to store emails you send us. Our third party email provider is Microsoft. Their privacy policy is available here: https://privacy.microsoft.com/en-gb/privacystatement
Emails you send us will be stored within the European Economic Area on Microsoft’s servers.
Contact form
When you contact us using our contact form, we collect your name, company name, email, address and contact number. We also collect any other information you provide to us when you complete the contact form.
If you do not provide the mandatory information required by our contact form, you will not be able to submit the contact form and we will not receive your enquiry.
If you do not supply the optional information required by our contact form, we may be unable to respond to your enquiry.
Legal basis for processing: our legitimate interests (Article 6(1)(f) of the General Data Protection Regulation)
Legitimate interest(s): responding to enquiries and messages we receive and keeping records of correspondence.
Legal basis for processing: necessary to perform a contract or to take steps at your request to enter into a contract (Article 6(1)(b) of the General Data Protection Regulation).
Reason why necessary to perform a contract: where your message relates to us providing you with goods or services or taking steps at your request prior to providing you with our goods and services (for example, providing you with information about such goods and services), we will process your information in order to do so).
Transfer and storage of your information
Messages you send us via our contact form will be stored within the European Economic Area on our third-party hosting or email provider’s servers in the UK.
Phone
When you contact us by phone, we collect your phone number and any information provided to us during your conversation with us.
We do not record phone calls.
Legal basis for processing: our legitimate interests (Article 6(1)(f) of the General Data Protection Regulation)
Legitimate interest(s): responding to enquiries and messages we receive and keeping records of correspondence.
Legal basis for processing: necessary to perform a contract or to take steps at your request to enter into a contract (Article 6(1)(b) of the General Data Protection Regulation).
Reason why necessary to perform a contract: where your message relates to us providing you with goods or services or taking steps at your request prior to providing you with our goods and services (for example, providing you with information about such goods and services), we will process your information in order to do so).
Post
If you contact us by post, we will collect any information you provide to us in any postal communications you send us.
Legal basis for processing: our legitimate interests (Article 6(1)(f) of the General Data Protection Regulation)
Legitimate interest(s): responding to enquiries and messages we receive and keeping records of correspondence.
Legal basis for processing: necessary to perform a contract or to take steps at your request to enter into a contract (Article 6(1)(b) of the General Data Protection Regulation).
Reason why necessary to perform a contract: where your message relates to us providing you with goods or services or taking steps at your request prior to providing you with our goods and services (for example, providing you with information about such goods and services), we will process your information in order to do so).
We collect and use information from individuals who interact with particular features of our website in accordance with this section and the section entitled Disclosure and additional uses of your information.
E-Newsletter
When you sign up for our e-newsletter on our website we collect your name and email address.
Legal basis for processing: your consent (Article 6(1)(a) of the General Data Protection Regulation).
Consent: you give your consent to us sending you our e-newsletter by signing up to receive it using the steps described above.
Transfer and storage of your information
We use a third-party service to send out our e-newsletter and administer our mailing list, Mailchimp. Their privacy policy is available here.
Information you submit to subscribe for our e-newsletter will be stored outside the European Economic Area on our third-party mailing list provider’s servers in the United States. For further information about the safeguards used when your information is transferred outside the European Economic Area, see the section of this privacy policy below entitled Transfers of your information outside the European Economic Area.
Use of web beacons in emails
We use technologies such as web beacons (small graphic files) in the emails we send to allow us to assess the level of engagement our emails receive by measuring information such as the delivery rates, open rates and click through rates which our emails achieve
For more information about our third-party mailing list provider and they use web beacons, please see their privacy policy which is available here: https://privacy.microsoft.com/en-gb/privacystatement
Registering on our website
When you register and create an account on our website, we collect the following information to be able to send Comeback Community™ e-pulses at timely intervals on your leave/return journey: name, work e-mail address, alternative e-mail address (optional), reason for leave (from a pre-defined list), planned leave date, planned return date, line manager’s name and line manager’s work e-mail address.
If you do not provide the mandatory information required by the registration form, you will not be able to register or create an account on our website and we will not be able to send e-pulses.
Legal basis for processing: our legitimate interests (Article 6(1)(f) of the General Data Protection Regulation).
Legitimate interest: registering and administering accounts on our website to provide you access to content and updates you have purchased and facilitate the efficient running and operation of our business.
Transfer and storage of your information
Information you submit to us via the registration form on our website will be stored within the European Economic Area on our servers in London, UK where your third party provider stores your emails (usually where its servers are located). Our third party hosting provider WPEngine Inc located in the UK.
Legitimate interest: analysing the level of engagement and effectiveness of our marketing emails and content
This section sets out the circumstances in which will disclose information about you to third parties and any additional purposes for which we use your information.
Disclosure of your information to service providers
We use a number of third parties to provide us with services which are necessary to run our business or to assist us with running our business who process your information for us on our behalf. These include the following:
Your information will be shared with these service providers where necessary to provide you with the service you have requested, whether that is accessing our website or ordering goods and services from us.
We do not display the identities of all of our service providers publicly by name for security and competitive reasons. If you would like further information about the identities of our service providers, however, please contact us directly via our contact form or by email and we will provide you with such information where you have a legitimate reason for requesting it (where we have shared your information with such service providers).
Legal basis for processing: legitimate interests (Article 6(1)(f) of the General Data Protection Regulation).
Legitimate interest relied on: where we share your information with these third parties in a context other than where is necessary to perform a contract (or take steps at your request to do so), we will share your information with such third parties in order to allow us to run and manage our business efficiently.
Legal basis for processing: necessary to perform a contract and/or to take steps at your request prior to entering into a contract (Article 6(1)(b) of the General Data Protection Regulation).
Reason why necessary to perform a contract: we may need to share information with our service providers to enable us to perform our obligations under that contract or to take the steps you have requested before we enter into a contract with you.
Disclosure of your information to other third parties
We disclose your information to other third parties in specific circumstances, as set out below.
Providing information to third parties such as Google Inc.
Google collects information through our use of Google Analytics on our website. Google uses this information, including IP addresses and information from cookies, for a number of purposes, such as improving its Google Analytics service. Information is shared with Google on an aggregated and anonymised basis. To find out more about what information Google collects, how it uses this information and how to control the information sent to Google, please see the following page: https://www.google.com/policies/privacy/partners/
Legal basis for processing: our legitimate interests (Article 6(1)(f) of the General Data Protection Regulation).
Legitimate interest(s): meeting our contractual obligations to Google under our Google Analytics Terms of Service (https://www.google.com/analytics/terms/us.html)
You can opt out of Google Analytics by installing the browser plugin here: https://tools.google.com/dlpage/gaoptout
Transfer and storage of your information
Information collected by Google Analytics is stored outside the European Economic Area on Google’s servers in the United States of America.
For further information about the safeguards used when your information is transferred outside the European Economic Area, see the section of this privacy policy below entitled Transfers of your information outside the European Economic Area.
Sharing your information with third parties, which are either related to or associated with the running of our business, where it is necessary for us to do so. These third parties include our accountants, advisors, independent contractors
Further information on each of these third parties is set out below.
Legal basis for processing: our legitimate interests (Article 6(1)(f) of the General Data Protection Regulation).
Legitimate interest: running and managing our business efficiently.
Accountants
We share information with our accountants for tax purposes. For example, we share invoices we issue and receive with our accountants for the purpose of completing tax returns and our end of year accounts.
Our accountants are Naylor Wintersgill, Carlton House, Grammar School Street, Bradford, BD1 4NS. Their privacy policy is available here: https://www.naylorwintersgill.com/storage/app/media/Naylor_Wintersgill_Privacy_Policy.pdf
Insurers
We will share your information with our insurers where it is necessary to do so, for example in relation to a claim or potential claim we receive or make or under our general disclosure obligations under our insurance contract with them.
Our insurers are HCC International Insurance Company PLC. Their privacy policy is available here: https://www.tmhcc.com/en/legal/privacy-policy
Disclosure of your information for legal reasons
Indicating possible criminal acts or threats to public security to a competent authority
If we suspect that criminal or potential criminal conduct has occurred, we will in certain circumstances need to contact an appropriate authority, such as the police. This could be the case, for instance, if we suspect that a fraud or a cyber-crime has been committed or if we receive threats or malicious communications towards us or third parties.
We will generally only need to process your information for this purpose if you were involved or affected by such an incident in some way.
Legal basis for processing: our legitimate interests (Article 6(1)(f) of the General Data Protection Regulation).
Legitimate interests: preventing crime or suspected criminal activity (such as fraud).
In connection with the enforcement or potential enforcement our legal rights
We will use your information in connection with the enforcement or potential enforcement of our legal rights, including, for example, sharing information with debt collection agencies if you do not pay amounts owed to us when you are contractually obliged to do so. Our legal rights may be contractual (where we have entered into a contract with you) or non-contractual (such as legal rights that we have under copyright law or tort law).
Legal basis for processing: our legitimate interests (Article 6(1)(f) of the General Data Protection Regulation).
Legitimate interest: enforcing our legal rights and taking steps to enforce our legal rights.
In connection with a legal or potential legal dispute or proceedings
We may need to use your information if we are involved in a dispute with you or a third party for example, either to resolve the dispute or as part of any mediation, arbitration or court resolution or similar process.
Legal basis for processing: our legitimate interests (Article 6(1)(f) of the General Data Protection Regulation).
Legitimate interest(s): resolving disputes and potential disputes.
For ongoing compliance with laws, regulations and other legal requirements
We will use and process your information in order to comply with legal obligations to which we are subject. For example, we may need to disclose your information pursuant to a court order or subpoena if we receive one or to the National Crime Agency in connection with suspected or potential money laundering matters
Legal basis for processing: compliance with a legal obligation (Article 6(1)(c) of the General Data Protection Regulation).
Legal obligation(s): legal obligations to disclose information which are part of the laws of England and Wales or if they have been integrated into the United Kingdom’s legal framework (for example in the form of an international agreement which the United Kingdom has signed).
Legal basis for processing: our legitimate interests (Article 6(1)(f) of the General Data Protection Regulation).
Legitimate interest: where the legal obligations are part of the laws of another country and have not been integrated into the United Kingdom’s legal framework, we have a legitimate interest in complying with these obligations.
This section sets out how long we retain your information. We have set out specific retention periods where possible. Where that has not been possible, we have set out the criteria we use to determine the retention period.
Retention periods
Server log information: we retain information on our server logs for 30 days.
Order information: when you place an order for services, we retain that information for six years following the end of the financial year in which you placed your order, in accordance with our legal obligation to keep records for tax purposes.
Correspondence and enquiries: when you make an enquiry or correspond with us for any reason, whether by email or via our contact form or by phone, we will retain your information for as long as it takes to respond to and resolve your enquiry, after which point we will delete your information.
E-Newsletter: we retain the information you used to sign up for our e-newsletter for as long as you remain subscribed (i.e. you do not unsubscribe) or if we decide to cancel our e-newsletter service, whichever comes earlier.
Criteria for determining retention periods
In any other circumstances, we will retain your information for no longer than necessary, taking into account the following:
Measures taken to secure your information
We take appropriate technical and organisational measures to secure your information and to protect it against unauthorised or unlawful use and accidental loss or destruction, including:
Transmission of information to use by email
Transmission of information over the internet is not entirely secure, and if you submit any information to us over the internet (whether by email, via our website or any other means), you do so entirely at your own risk.
We cannot be responsible for any costs, expenses, loss of profits, harm to reputation, damages, liabilities or any other form of loss or damage suffered by you as a result of your decision to transmit information to us by such means.
All of your information is stored in the following European Economic Area (EEA) countries; United Kingdom
Your information will be transferred and stored outside the European Economic Area (EEA) in the circumstances set out below. We will also transfer your information outside the EEA or to an international organisation in order to comply with legal obligations to which we are subject (compliance with a court order, for example). Where we are required to do so, we will ensure appropriate safeguards and protections are in place.
MailChimp, a popular mailing list provider, stores information on their servers in the US and the safeguard they use to do so is the EU-U.S. Privacy Shield.
E-Newsletter
Information you submit to us when you sign up for our e-newsletter is transferred outside the EEA and stored on our third party mailing list provider’s servers. Our third party mailing list provider is: Mailchimp.
Safeguard(s) used: our third party mailing list provider has self-certified its compliance with the EU-U.S. Privacy Shield.
Google Analytics
Information collected by Google Analytics (your IP address and actions you take in relation to our website) is transferred outside the EEA and stored on Google’s servers. You can access Google’s privacy policy here: https://www.google.com/policies/privacy/
Country of storage: United States of America. This country is not subject to an adequacy decision by the European Commission.
Safeguard(s) used: Google has self-certified its compliance with the EU-U.S. Privacy Shield which is available here: https://www.privacyshield.gov/welcome. The EU-U.S. Privacy Shield is an approved certification mechanism under Article 42 of the General Data Protection Regulation, which is permitted under Article 46(2)(f) of the General Data Protection Regulation. You can access the European Commission decision on the adequacy of the EU-U.S. Privacy Shield here: http://ec.europa.eu/justice/data-protection/international-transfers/adequacy/index_en.htm
Your rights
Subject to certain limitations on certain rights, you have the following rights in relation to your information, which you can exercise by writing to 13 Jerome Drive, St Albans, Hertfordshire, AL3 4LT, UK or sending an email to hello@talentkeepers.co.uk to request access to your information and information related to our use and processing of your information;
In accordance with Article 77 of the General Data Protection Regulation, you also have the right to lodge a complaint with a supervisory authority, in particular in the Member State of your habitual residence, place of work or of an alleged infringement of the General Data Protection Regulation.
For the purposes of the UK, the supervisory authority is the Information Commissioner’s Office (ICO), the contact details of which are available here: https://ico.org.uk/global/contact-us/
Further information about your rights
The above rights are provided in summary form only and certain limitations apply to many of these rights. For further information about your rights in relation to your information, including any limitations which apply, please visit the following pages on the ICO’s website:
You can also find out further information about your rights, as well as information on any limitations which apply to those rights, by reading the underlying legislation contained in Articles 12 to 22 and 34 of the General Data Protection Regulation, which is available here: http://ec.europa.eu/justice/data-protection/reform/files/regulation_oj_en.pdf
Verifying your identity where you request access to your information
Where you request access to your information, we are required by law to use all reasonable measures to verify your identity before doing so.
These measures are designed to protect your information and to reduce the risk of identity fraud, identity theft or general unauthorised access to your information.
How we verify your identity
Where we possess appropriate information about you on file, we will attempt to verify your identity using that information.
If it is not possible to identify you from such information, or if we have insufficient information about you, we may require original or certified copies of certain documentation in order to be able to verify your identity before we are able to provide you with access to your information.
We will be able to confirm the precise information we require to verify your identity in your specific circumstances if and when you make such a request.
Your right to object
You have the following rights in relation to your information, which you may exercise in the same way as you may exercise by writing 13 Jerome Drive, St Albans, Hertfordshire, AL3 4LT, UK or sending an email to hello@talentkeepers.co.uk:
You may also exercise your right to object to us using or processing your information for direct marketing purposes by:
For more information on how to object to our use of information collected from cookies and similar technologies, please see the section entitled How to accept or reject cookies in our cookies policy
What is ‘Sensitive Personal Information’
‘Sensitive personal information’ is information about an individual that reveals their racial or ethnic origin, political opinions, religious or philosophical beliefs, or trade union membership, genetic information, biometric information for the purpose of uniquely identifying an individual, information concerning health or information concerning a natural person’s sex life or sexual orientation.
Our policy on Sensitive Personal Information
We do not knowingly or intentionally collect sensitive personal information from individuals, and you must not submit sensitive personal information to us.
If, however, you inadvertently or intentionally transmit sensitive personal information to us, you will be considered to have explicitly consented to us processing that sensitive personal information under Article 9(2)(a) of the General Data Protection Regulation. We will use and process your sensitive personal information for the purposes of deleting it.
We update and amend our Privacy Policy from time to time.
Minor changes to our Privacy Policy
Where we make minor changes to our Privacy Policy, we will update our Privacy Policy with a new effective date stated at the beginning of it. Our processing of your information will be governed by the practices set out in that new version of the Privacy Policy from its effective date onwards.
Major changes to our Privacy Policy
Where we make major changes to our Privacy Policy or intend to use your information for a new purpose or a different purpose than the purposes for which we originally collected it, we will notify you by email (where possible) or by posting a notice on our website.
We will provide you with the information about the change in question and the purpose and any other relevant information before we use your information for that new purpose.
Wherever required, we will obtain your prior consent before using your information for a purpose that is different from the purposes for which we originally collected it.
For more details please email hello@talentkeepers.co.uk
or call +44 (0)1727 856169
You can also use the form below:
For more details please email hello@talentkeepers.co.uk
or call +44 (0)1727 856169
You can also use the form below: