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Charisma Exec Privacy Policy  

Introduction

This Privacy Policy outlines Charisma Exec (" we ", " our " or " the Company ") practices with respect to information collected from users who access our website at CharismaExec.com(" Site ") or otherwise share personal information with us (collectively: " Users "). 

 TABLE OF CONTENTS
1. IMPORTANT INFORMATION AND WHO WE ARE 
2. THE DATA WE COLLECT ABOUT YOU 
3. HOW IS YOUR PERSONAL DATA COLLECTED? 
4. HOW WE USE YOUR PERSONAL DATA 
5. DISCLOSURES OF YOUR PERSONAL DATA 
6. INTERNATIONAL TRANSFERS 
7. DATA SECURITY 
8. DATA RETENTION 
9. YOUR LEGAL RIGHTS 
10. GLOSSARY 

 
Welcome to the Charisma Executive Recruitment (“Charisma Exec”) privacy policy.
Charisma Exec respects your privacy and is committed to protecting your personal data. This privacy policy will inform you as to how we look after your personal data when you visit our website (regardless of where you visit it from) and tell 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 policy.

1. IMPORTANT INFORMATION AND WHO WE ARE

PURPOSE OF THIS PRIVACY POLICY
This privacy policy aims to give you information on how Charisma Exec collects and processes your personal data through your use of this website and our services, including any data you may provide through this website or use our services.
Our services are not intended for children and we do not knowingly collect data relating to children.
It is important that you read this privacy policy together with any other privacy policy or fair processing policy or just-in-time notice we may provide, either orally or in writing, 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 policy supplements other notices and privacy policies where applicable and is not intended to override them.

CONTROLLER
Charisma Exec Recruitment is a sole proprietorship business, owned and operated by Carla Clunes of 27 Westville Oval, Harrogate, HG1 3JN and Carla Clunes the data controller who is responsible for your personal data, referred to as "we", "us" or "our" or “Charisma Exec” in this privacy policy).
We have appointed a data privacy manager who is responsible for overseeing questions in relation to this privacy policy. If you have any questions about this privacy policy, including any requests to exercise your legal rights, please contact the data privacy manager using the details set out below.

CONTACT DETAILS
If you have any questions about this privacy policy or our privacy practices, please contact our data privacy manager in the following ways:
Full name of legal entity: Carla Clunes trading as “Charisma Exec Recruitment” (sole proprietorship)
Email address: Carla@CharismaExec.com
Postal address: Charisma Exec, 27 Westville Oval, Harrogate, HG1 3JN
Telephone number: 01423 500014
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 POLICY AND YOUR DUTY TO INFORM US OF CHANGES
We keep our privacy policy under regular review. This version was last updated on 20 September 2018. Historic versions can be obtained by contacting us.
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 policy of every website you visit.


2. THE DATA WE COLLECT ABOUT YOU
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 as 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 contact address, email address and telephone numbers.
· Curriculum Vitae (CV) Data includes career history, details of previous employment and anything else contained within your CV or otherwise provided to Charisma Exec which you wish to inform prospective employers of.
· 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 our website.
· Marketing and Communications Data includes your preferences in receiving marketing from us, including any indication of the industry or sector you are interested in or are working in and your communication preferences.
We also collect, use and share Aggregated Data such as statistical or demographic data for any purpose. Aggregated Data could be derived from your personal data but is not considered personal data in law as this data will 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 policy.
We do not knowingly collect any Special Categories of Personal Data about you (this includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health, and genetic and biometric data). Nor do we collect any information about criminal convictions and offences. We do not generally require this kind of sensitive personal data to carry out our services and if you believe that the personal data you are sharing with us contains a “Special Category” as defined above, then you need to let us know as soon as possible. You should remove any Special Category of personal data from your CV before you provide it to us.

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.


3. HOW IS YOUR PERSONAL DATA COLLECTED?
We use different methods to collect data from and about you including through:
· Direct interactions. You may give us your Identity, Contact and CV Data by filling in forms or by corresponding with us by video chat, post, phone, email or otherwise. This includes personal data you provide when you:
• apply for our products or services;
• create an account on a public third party recruitment networking website;
• subscribe to our service or any publications;
• request marketing to be sent to you;
• enter a competition, promotion or survey; or
• give us feedback or contact us.
· Third parties or publicly available sources. We will receive personal data about you from various third parties and public sources as set out below:
• Identity, Contact and CV Data from providers of public recruitment networking services or websites such as Indeed.co.uk, Reed.co.uk, Drapersjobs.com, LinkedIn.com or any other website for the purpose of recruitment or finding work.
• Identity and Contact Data from publicly available sources such as Companies House and the Electoral Register based inside the EU.


4. HOW WE USE YOUR PERSONAL DATA
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 with you.
· 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 obligation.
You can contact us if you want to find out more about the types of lawful basis that we will rely on to process your personal data.
Generally, we do not rely on consent as a legal basis for processing your personal data although we will get your consent before 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. We will ask for your approval before we share your personal data with a prospective employer, and we will keep a record of this as usually this approval will be communicated either orally or via video call.

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.


Purpose/Activity Type of data Lawful basis for processing including basis of legitimate interest
To register you as a new client/candidate (a) Identity Performance of a contract with you (to find a suitable role/candidate for a particular candidate/role)
(b) Contact
(c) CV Data
(d) Marketing and Communications
To process and deliver our services including:
(a) Researching suitable available roles and processing your application (including anonymising or standardising your CV Data where required). (a) Identity (a) Performance of a contract with you
(b) Sharing your information with prospective employers (b) Contact (b) Necessary for our legitimate interests (to recover debts due to us from employers)
(c) Informing you of roles you may be interested in now, and in the future. (c) CV Data (c) Necessary for your legitimate interests such as: finding you a suitable role, presenting your application to employers according to your or an employer’s specific requirements or keeping you informed of roles you might be interested in.
(d) Managing any commission or other fees we are due from employers as a result of filling a vacancy. (d) Marketing and Communications
To manage our relationship with you which will include:
(a) Notifying you about changes to our terms or privacy policy (a) Identity (a) Performance of a contract with you
(b) Asking you to leave a review or take a survey (b) Contact (b) Necessary to comply with a legal obligation
(c) Profile (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 (a) Performance of a contract with you
(b) Contact (b) Necessary for our legitimate interests (to study how customers use our products/services, to develop them and grow our business)
(c) Marketing and Communications
To administer and protect our business and this website (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data)
(a) Identity (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) Contact (b) Necessary to comply with a legal obligation
(c) Technical
To make suggestions and recommendations to you about services or vacancies/roles that may be of interest to you
(a) Identity Necessary for our legitimate interests (to develop our products/services and grow our business)
(b) Contact
(c) CV Data
(d) Marketing and Communications
Necessary for your legitimate interests in finding employment or keeping up-to-date with industry trends, salaries and vacancies.

MARKETING
We strive to provide you with choices regarding certain personal data uses, particularly around marketing and advertising. We provide an opt-out link (or unsubscribe) in our marketing emails. You can contact us directly at any time if you would like to change your preferences when it comes to marketing; alternatively, you can ask us to stop marketing to you at any time.

PROMOTIONAL OFFERS FROM US
We may use your Identity, Contact, Technical and Marketing and Communications 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 purchased services from us and 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 following the opt-out links on any marketing message sent to you or 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 performed by us, other transactions we describe in this policy If you want to opt-out of more than just marketing, you can contact us to do so at any time.

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.


5. DISCLOSURES OF YOUR PERSONAL DATA
We may share your personal data with the parties set out below for the purposes set out in the table Purposes for which we will use your personal data above.
· External Third Parties as set out in the Glossary.
· Specific third parties either listed in the table Purposes for which we will use your personal data above or the third parties we notify of expressly, whether orally or in writing, such as prospective employers whom you wish to make an application to work for.
· 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 policy.
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.


6. INTERNATIONAL TRANSFERS
We do not generally transfer your personal data outside the European Economic Area (EEA).
 If we share your personal data with a prospective employer who is not based in the EEA. This will involve transferring your data outside the European Economic Area (EEA).
Where we send your personal data outside of the EEA (for example, to a prospective Employer located in India), we will always ask you first if you wish to do this and we will make you aware of the name of the business so that you can check with that business how they handle your personal data. We are not responsible for the personal data that you provide to prospective employers and if you wish to restrict any personal data that is sent outside of the EEA, you must inform us of your wishes when we seek your permission to make an application or share your personal data with that prospective employer.

We will not share your personal data outside of the EEA without notifying you first and getting your approval to do so. We may do this in writing, over the phone or via video calling.


7. DATA SECURITY
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.


8. DATA RETENTION
HOW LONG WILL YOU USE MY PERSONAL DATA FOR?
We will only retain your personal data for as long as reasonably necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, regulatory, tax, accounting or reporting requirements. We may retain your personal data for a longer period in the event of a complaint or if we reasonably believe there is a prospect of litigation in respect to our relationship with you.
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, regulatory, tax, accounting or other requirements.
Details of retention periods for different aspects of your personal data are available in our retention policy which you can request from us by contacting us.
We will normally delete your CV Data either when we have found you a role which you have accepted or after we haven’t heard from you for three (3) months. After this time, we may keep your Identity, Contact and Marketing and Communications Preferences Data for a longer period of up to two (2) years, unless we have a good reason to retain your data for a longer period as set out above.

9. YOUR LEGAL RIGHTS
You have the right to:

1. 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.

2. 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.

3. 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.

4. 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.

5. 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:
• If you want us to establish the data's accuracy.
• Where our use of the data is unlawful, but you do not want us to erase it.
• 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.
• You have objected to our use of your data, but we need to verify whether we have overriding legitimate grounds to use it.

6. 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.

7. 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.

If you wish to exercise any of the rights set out above, please contact us.

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 could 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 could take us longer than a month (up to three months in total) if your request is particularly complex or you have made a number of requests. In this case, we will notify you within the first month after you notify us, and we will keep you updated. 


10. GLOSSARY
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 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, including a contract of employment with a potential or prospective employer
Comply with a legal obligation means processing your personal data where it is necessary for compliance with a legal obligation that we are subject to.


THIRD PARTIES
EXTERNAL THIRD PARTIES
· Service providers acting as processors based in the United Kingdom who provide IT and system administration services.
· Professional advisers acting as processors or joint controllers including lawyers, bankers, auditors and insurers based in [the United Kingdom 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.
· Prospective employers who you have made applications to who require us to report on who we have referred to them, when and for which role.



When you use the Site, you consent to the collection, storage, use, disclosure and other uses of your Personal Information as described in this Privacy Policy.

We encourage our Users to carefully read the Privacy Policy and use it to make informed decisions. What information do we collect?

How do we receive information about you?

We receive your Personal Information from various sources:
  • When you voluntarily provide us with your personal details in order to register on our Site;
  • When you use or access our Site in connection with your use of our services;
  • From third-party providers, services and public registers (for example, traffic analytics vendors).

Cookies

Third-party collection of information

Our policy only addresses the use and disclosure of information we collect from you. To the extent you disclose your information to other parties or sites throughout the internet, different rules may apply to their use or disclosure of the information you disclose to them. Accordingly, we encourage you to read the terms and conditions and privacy policy of each third party that you choose to disclose information to. 

This Privacy Policy does not apply to the practices of companies that we do not own or control, nor to individuals whom we do not employ or manage, including any of the third parties which we may disclose information to as set out in this Privacy Policy. 

How do we safeguard your information?

We and our trusted partners use cookies and other technologies in our related services, including when you visit our Site or access our services. 

A "cookie" is a small piece of information that a website assigns to your device while you are viewing a website. Cookies are very helpful and can be used for various different purposes. These purposes include allowing you to navigate between pages efficiently, enabling automatic activation of certain features, remembering your preferences and making the interaction between you and our Services quicker and easier. Cookies are also used to help ensure that the advertisements you see are relevant to you and your interests and to compile statistical data on your use of our Services. 

The Site uses the following types of cookies:

a. 'session cookies' which are stored only temporarily during a browsing session in order to allow normal use of the system and are deleted from your device when the browser is closed; 

b. 'persistent cookies ' which are read only by the Site, saved on your computer for a fixed period and are not deleted when the browser is closed. Such cookies are used where we need to know who you are for repeat visits, for example to allow us to store your preferences for the next sign-in; 

c. 'third-party cookies' which are set by other online services who run content on the page you are viewing, for example by third-party analytics companies who monitor and analyse our web access.

Cookies do not contain any information that personally identifies you, but Personal Information that we store about you may be linked, by us, to the information stored in and obtained from cookies. You may remove the cookies by following the instructions of your device preferences; however, if you choose to disable cookies, some features of our Site may not operate properly and your online experience may be limited.

We also use a tool called “Google Analytics” to collect information about your use of the Site. Google Analytics collects information such as how often users access the Site, which pages they visit, when they do so, etc. We use the information we obtain from Google Analytics only to improve our Site and services. Google Analytics collects the IP address assigned to you on the date you visit sites, rather than your name or other identifying information. We do not combine the information collected through the use of Google Analytics with personally identifiable information. Google’s ability to use and share information collected by Google Analytics about your visits to this Site is restricted by the Google Analytics Terms of Use and the Google Privacy Policy.

Updates or amendments to this Privacy Policy

We reserve the right to periodically amend or revise the Privacy Policy; material changes will be effective immediately upon the display of the revised Privacy policy. The last revision will be reflected in the "Last modified" section. Your continued use of the Platform, following the notification of such amendments on our website, constitutes your acknowledgment and consent of such amendments to the Privacy Policy and your agreement to be bound by the terms of such amendments.

How to contact us

If you have any general questions about the Site or the information we collect about you and how we use it, you can contact us at Info@CharismaExec.com

Charisma Exec - Tel. 01423 500014
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