Privacy Policy

Pursuu must comply with UK General Data Protection Regulation (“UK GDPR”) and the Data Protection Act 2018 and will therefore process your data securely and transparently. In most cases, Pursuu is a Data Processor, by acting on our Client’s instructions as a recruitment agent who introduces, sifts and/or interviews suitable candidates for job opportunities for our professional recruiter Client (i.e. the employer). The Client is generally speaking, the Data Controller, who determines the purpose of the data and the means as we are acting on their behalf, as their recruitment agents. Our privacy policy also explains how we use information, how long the information is kept for and any other relevant information about your data.

1. Data Controller details Pursuu 86-90 Paul Street London EC2A 4NE Email address: info@pursuu.co.uk Contact number: 02080506325 Website: www.Pursuu.co.uk Registered company number: 14390429

2. Data protection principles In relation to personal data, we will: ● Process it fairly, lawfully and in a clear, transparent way; ● Collect personal data only for specific and legitimate reasons; ● Only use it in the way that we have told you about; ● Ensure it is correct and up to date; ● Keep your data for only as long as we require it; ● Process it in a way designed to ensure it will not be lost, destroyed or used for anything that you are not aware of.

3. Types of data we collect In accordance with UK GDPR and privacy law, our privacy policy outlines the types of data that we collect and hold about you. This includes our Client’s contact details including email address, postal address, first and last name of the main point of contact and your contact number. In relation to the Candidate, this will include your first and last name, home address, best contact number, email address and evidence of right to work such as passport/work permit visa.

We also have an optional equal opportunities form that we send to the Candidate which they may choose to complete and this will ask for their response to: gender, age, disability (if any), ethnicity/identity, sexual orientation and religion/beliefs (if any). We ask this information in order to embrace a diverse workforce with people from all backgrounds. Furthermore, this form allows Pursuu to analyse the data for statistical purposes and to ensure our talent management and recruitment processes are transparent and fair. This data is strictly confidential and will not be provided to our Client, as part of the selection and recruitment process. Neither will this data be published or utilised in any manner to identify a Candidate. Our equal opportunities form includes a consent statement to be signed and/or agreed by the Candidate if they are content on completing the same.

We collect this information either because it is necessary so that we can perform our contract and provide our services to you, and/or in our legitimate interests to do so and/or to meet our legal obligations. 4. How we collect your data If you are either our Client or Candidate, we collect data about you only as supplied by you and/or when you contact us. We collect personal information from you including any electronic devices (such as mobile phones, tablets and desktops) that you use when you: ● Use our services at Pursuu. ● Register for an account profile with us either as a Client or Candidate. ● Provide us information via our website, contact us form or when you communicate with us. ● Send us email communications. ● Complete Client or Candidate registration forms/account profile forms for our records in order to act on your behalf, as a recruitment agent.

IT systems Personal data is held securely on our website and email IT systems, which are password protected and access to the above information is restricted to Pursuu and its colleagues/agents or contractors who may require access to it to undertake their job duties. We treat the handling of this data seriously in order to ensure strict confidence. The website is protected and validated by an SSL (Secure Sockets Layer) certificate, a transport layer security and is enabled for HTTPS for our website. Marketing correspondence If you have subscribed to our newsletter (if and when we provide this), we will send you newsletter updates by email to share any updates to our business, services or other relevant information to keep you updated. This is the only time we will ever send marketing emails. You can stop receiving marketing emails from us at any time by contacting us via our website contact us function or you can simply email us.

Ways to opt out ● By clicking on the ‘unsubscribe’ link in any marketing email you receive. ● By emailing us to opt out. Simply say “opt out” or “unsubscribe” in the subject line or body of an email. We will never share or disclose your personal information to third parties for their own marketing purposes. 5. Why we collect your data ● To provide our recruitment and talent management services to the Client. ● To update and introduce our Client to suitable Candidates. ● To update the Candidate on suitable job opportunities and/or discuss their job application for a role they have applied for. ● To update you (whether Client or Candidate) on our services. This is in our legitimate interests to do so to enhance our services and also to grow our business. We, of course, provide the option of opting out of receiving our marketing communications. ● To allow you to use our website fully. ● To prevent and detect fraud against either you or us.

6. Why we process your data Pursuu can process your data only for specific purposes due to data protection law: ● So that we can perform a legal contract that we are a party to with you; ● To ensure we can carry out legally required duties and/or ● To ensure we can promote the legitimate interests of Pursue, the Client and/or the Candidate, where necessary. All of the processing of data carried out by us falls into one of the legally permitted reasons above. 7. If you do not wish to provide your data to us Our main reason to process your data is so that we can carry out our contractual duties agreed with you, mailing list subscribers and/or Visitors of our website. If you do not provide us with the required data to be able to carry out our contractual duties, we cannot perform our obligations. However, providing this data is your sole decision and must be at all times.

8. Sharing your data We will never share any of your data/personal information with a third party, strictly subject to the below exceptions. Your data will only be shared with our colleagues/agents/contractors at Pursuu in order for them to undertake their duties and on very rare occasions, our website provider/IT support agents to manage and/or resolve technical issues on our online systems. We also will not share your data with bodies outside of the European Economic Area. We may also be required to share some of your data, if we are requested by the police or a regulatory or government authority investigating illegal activities to provide such information concerning your activities whilst using our website and online networks such as social media and email.

9. Protecting your data We acknowledge our obligation to ensure your data is protected against accidental loss or disclosure, destruction and abuse. We have implemented safeguarding processes for this. Pursuu has taken the following steps to protect personal data, which it holds or to which it has access: i. It may appoint or employ individuals with specific responsibilities for: · Processing and controlling of data. · The comprehensive reviewing and auditing of its data protection systems and procedures. · Overseeing the effectiveness and integrity of all the data that must be protected. ii. It provides its employees/agents/contractors (if any) with information and training to make them aware of the importance of protecting personal data, to teach them how to do this, and to understand how to treat information confidentially.

iii. It can account for all personal data it holds, where it comes from, who it is shared with and also who it might be shared with. iv. It carries out risk assessments to identify any vulnerability in its personal data handling and processing, and to take steps in reducing the risks of mishandling and potential breaches of data security. The process includes an assessment of the impact of both the use and potential misuse of personal data. v. It recognises the importance of seeking individuals’ consent (where appropriate) for obtaining, recording, using, sharing, storing and retaining their personal data, and regularly reviews its procedures for doing so, including the audit trails that are needed and are followed for all consent decisions.

Pursuu understands that consent given by the Client and Candidate must be freely given, specific, informed and unambiguous, at all times. Pursuu will seek consent on a specific and individual basis where appropriate. Full information will be given regarding the activities about which consent is sought. Relevant individuals have the absolute and unimpeded right to withdraw their consent at any time. vi. It has the appropriate safeguarding processes for detecting, reporting and investigating suspected or actual personal data breaches, including where these are caused by security breaches. It is aware of its duty to report breaches that cause significant harm to the affected individuals to the Information Commissioner Office and to the Data Subject (Client or Candidate), and is aware of the possible consequences. vii. To understand the implications of the transfer of personal data internationally. Where access to your data is required, the following apply:

i. The principle of least privilege is always applicable. Therefore those with access to such data will only have the minimum amount of access to a resource that is required for them to undertake their role. ii. Access to personal data is protected safely. Passwords that are used must meet the specified complexity requirements and must be kept confidential to the user and not shared with anyone else including colleagues/agents/contractors (if any). iii. We regularly monitor our system for possible vulnerabilities and attacks. iv. All emails to and from Pursuu will be sent using our web/email host. v. Where we share your data with third parties, we have a written agreement with them to ensure that your data is held securely and in line with UK GDPR requirements.

Third parties must implement appropriate technical and organisational measures to ensure the security of your data. Protecting your information As you know, the internet is not a 100% secure method for communication and so we are unable to guarantee the security of any information you send to us (or we send to you) via the internet. We are not responsible for any damages which you, or others, may suffer as a result of the loss of confidentiality of such information. We take reasonable precautions to protect your information. We cannot ensure or warrant the security of any information you transmit to us, and you do so at your own risk. We use our best endeavours to ensure it is secure on all our online and IT systems as outlined above.

10. How long do we keep your data? Pursuu keeps your data only for as long as it is necessary for us. You are entitled to exercise your right to erasure of this data by making a request verbally or in writing to us (phone call, post or email) though we recommend a written request. Once we no longer need your data, we will take steps to delete it. Pursuu conducts annual checks of personal data that we hold to ensure everything has been deleted at the end of its retention period. 11. Automated decision making No decision will be made about you solely on the basis of automated decision making (where a decision is taken about you using an electronic system without human involvement), which has a significant impact on you. 12. Your rights in respect of your data Data protection laws provide you with specific rights in relation to the data we hold about you. These rights are set out as follows: ● The right to be informed. This means that we must tell you how we use your data and this is the purpose of this privacy notice. ● The right of access. You have the right to access the data that we hold on you. To do so, you should make a subject access request by sending an email to us. This information will be provided free of charge, unless a request is manifestly unfounded or excessive, particularly if it is repetitive. In rare circumstances, Pursuu may charge a reasonable fee to respond or may need to refuse the request without fee payment for “very excessive” requests.

● The right for any inaccuracies to be corrected. If any data that we hold about you is incomplete or inaccurate, you are able to require us to correct it. ● The right to have information deleted. If you would like us to stop processing your data, you have the right to ask us to securely delete or destroy it from our systems where you believe there is no reason for us to continue processing it. ● The right to restrict the processing of the data. For example, if you believe the data we hold is incorrect, we will stop processing the data (whilst still holding it) until we have ensured that the data is correct. ● The right to data portability. You may transfer the data that we hold on you for your own purposes. ● The right to object to the inclusion of any information. You have the right to object to the way we use your data where we are using it for our legitimate interests. ● The right to regulate any automated decision-making and profiling of personal data. You have a right not to be subject to automated decision making in a way that adversely affects your legal rights. Where you have provided consent to our use of your data, you also have the unrestricted right to withdraw that consent at any time.

Withdrawing your consent means that we will stop processing the data that you had previously given us consent to use. There will be no consequences for withdrawing your consent. However, in some cases, we may continue to use the data where so permitted by having a legitimate reason for doing so. If you wish to exercise any of the rights explained above, please contact us as soon as possible. 13. Amendments to our privacy policy We reserve the right to amend our privacy policy and cookies policy, whilst of course ensuring it complies with relevant legislation and laws. We will ensure that our policy shows the most up to date information and may notify you of such changes by including the revised privacy policy on our website.

14. If you wish to make a complaint In the event you are unhappy or wish to make a complaint to Pursuu about your privacy or personal data concerns, please contact us so that we can investigate your complaint as soon as possible. We will try our best to provide you with an amicable resolution, where possible and will treat these matters seriously. The supervisory authority in the UK for data protection is the Information Commissioner Office (ICO). If you think that your data protection rights have been breached by us, please contact us in the first instance so we can look into this for you, otherwise you are entitled to make a complaint to the ICO. Their contact details can be found here: https://ico.org.uk/. 15. Data Protection Officer Our Data Protection Officer can be contacted at: dpo@pursuu.co.uk

COOKIES POLICY What is a cookie? A cookie is a piece of data sent from a website and stored on your computer’s hard drive. When you use the same website such as ours again in the future, the data stored in the cookie can be retrieved by the website to notify the same site of your previous activity. www.Pursuu.co.uk uses cookies for the below reasons: ● To remember your preferences and your past activity; ● To allow you to share our information on social media platforms; ● To improve the use of our website, content and services; ● To offer you a better service experience with Pursuu. Cookies are text-only pieces of information that a website transfers to an individual’s hard drive or other website-browsing equipment for record-keeping purpose. Cookies allow the site to remember important information that will make your use of the site more convenient. A cookie will typically contain the name of the domain from which the cookie has come, the “lifetime” of the cookie, and a randomly generated unique number or other value. Certain cookies will be used on the sites regardless of wether you are logged in to your account or not. Sessions cookies are temporary cookies that remain in the cookie file of your browser for much longer(though how long will depend on the lifetime of the specific cookie). We use session cookies to track the total number of visitors to our Sites. We may also employ cookies so that we remember your computer when it is used to return to the Sites to help customise your experience. Pursuu may associate personal Data with a cookie file in those instances.