Privacy Policy

Definitions and interpretation

In this privacy policy, the following definitions are used

Data	collectively all information that you submit to TALNT Limited via the Website. This definition incorporates, where applicable, the definitions provided in the Data Protection Laws;
Data Protection Laws	any applicable law relating to the processing of personal Data, including but not limited to the Directive 96/46/EC (Data Protection Directive) or the GDPR, and any national implementing laws, regulations and secondary legislation, for as long as the GDPR is effective in the UK;
GDPR	the General Data Protection Regulation (EU) 2016/679;
TALNT Limited, we or u	TALNT Limited, a company incorporated in England and Wales with registered number 13044137 whose registered office is at 60 Gresham Street, London, EC2V 7BB;
User or you	any third party that accesses the Website and is not either (i) employed by TALNT Limited and acting in the course of their employment or (ii) engaged as a consultant or otherwise providing services to TALNT Limited and accessing the Website in connection with the provision of such services;
Website	the website that you are currently using, www.talnt.sh, and any sub-domains of this site unless expressly excluded by their own terms and conditions.

In this privacy policy, unless the context requires a different interpretation
1. the singular includes the plural and vice versa;
2. references to sub-clauses, clauses, schedules or appendices are to sub-clauses, clauses, schedules or appendices of this privacy policy;
3. a reference to a person includes firms, companies, government entities, trusts and partnerships;
4. "including" is understood to mean "including without limitation";
5. reference to any statutory provision includes any modification or amendment of it;
6. the headings and sub-headings do not form part of this privacy policy.
Scope of this privacy policy
This privacy policy applies only to the actions of TALNT Limited and Users with respect to this Website, including any data you may provide through this Website when you sign up to our newsletter, or purchase a product or service. It does not extend to any websites that can be accessed from this Website including, but not limited to, any links we may provide to social media websites
For purposes of the applicable Data Protection Laws, TALNT Limited is the "data controller". This means that TALNT Limited determines the purposes for which, and the manner in which, your Data is processed.
Data collected
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:
1. Identity Data includes first name, maiden name, last name, username or similar identifier, marital status, title, date of birth and gender
2. Contact Data includes billing address, delivery address, email address and telephone numbers.
3. Financial Data includes bank account and payment card details
4. Transaction Data includes details about payments to and from you and other details of products and services you have purchased from us.
5. Technical Data includes internet protocol (IP) address, your login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform, and other technology on the devices you use to access this website
6. Profile Data includes your username and password, purchases or orders made by you, your interests, preferences, feedback and survey responses.
7. Usage Data includes information about how you use our website, products and services.
8. Marketing and Communications Data includes your preferences in receiving marketing from us and our third parties and your communication preferences.
9. We may 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 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
This website is not intended for children and we do not knowingly collect data relating to children
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 service you have with us but we will notify you if this is the case at the time.
How we collect Data
We use different methods to collect data from and about you in the following ways:
1. Direct interactions. You may give us your Identity, Contact and Financial Data by filling in forms or by any other forms of communication. This includes personal data you provide when you:
1. apply for our products or services;
2. create an account on our website;
3. subscribe to our service or publications;
4. request marketing to be sent to you;
5. enter a competition, promotion or survey; or
6. give us feedback or contact us.
Data that is given to us by you
TALNT Limited will collect your Data in a number of ways, for example:
1. when you contact us through the Website, by telephone, post, e-mail or through any other means;
2. when you register with us and set up an account to receive our products/services;
3. when you use our services; in each case, in accordance with this privacy policy.
Data that is collected automatically
To the extent that you access the Website, we will collect your Data automatically, for example:
1. we automatically collect some information about your visit to the Website. This information helps us to make improvements to Website content and navigation, and includes your IP address, the date, times and frequency with which you access the Website and the way you use and interact with its content.
Our use of Data
Any or all of the above Data may be required by us from time to time in order to provide you with the best possible service and experience when using our Website. Specifically, Data may be used by us for the following reasons:
1. internal record keeping;
2. improvement of our products / services;
3. transmission by email of marketing materials that may be of interest to you; in each case, in accordance with this privacy policy
4. We may use your Data for the above purposes if we deem it necessary to do so for our legitimate interests. If you are not satisfied with this, you have the right to object in certain circumstances (see the section headed "Your rights" below).
5. For the delivery of direct marketing to you via e-mail, we will need your consent, whether via an opt-in or soft-opt-in
1. soft opt-in consent is a specific type of consent which applies when you have previously engaged with us (for example, you contact us to ask us for more details about a particular product/service, and we are marketing similar products/services). Under "soft opt-in" consent, we will take your consent as given unless you opt-out.
2. for other types of e-marketing, we are required to obtain your explicit consent; that is, you need to take positive and affirmative action when consenting by, for example, checking a tick box that we'll provide.
3. if you are not satisfied about our approach to marketing, you have the right to withdraw consent at any time. To find out how to withdraw your consent, see the section headed "Your rights" below
When you register with us and set up an account to receive our services, the legal basis for this processing is the performance of a contract between you and us and/or taking steps, at your request, to enter into such a contract
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.
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 grounds, 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 User	Identity Contact	Performance of a contract with you
To process and deliver your order including: Manage payments, fees and charge Collect and recover money owed to us	Identity Contact Financial Transaction Marketing and Communications	Performance of a contract with you Necessary for our legitimate interests (to recover debts due to us)
To manage our relationship with you which will include: Notifying you about changes to our terms or privacy policy Asking you to leave a review or take a survey	Identity Contact Profile Marketing and Communications	Performance of a contract with you Necessary to comply with a legal obligation Necessary for our legitimate interests (to keep our records updated and to study how customers use our products/services)
To administer and protect our business and this website (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data)	Identity Contact Technical	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) Necessary to comply with a legal obligation
To deliver relevant website content and advertisements to you and measure or understand the effectiveness of the advertising we serve to you	Identity Contact Profile Usage Marketing and Communications Technical	Necessary for our legitimate interests (to study how customers use our products/services, to develop them, to grow our business and to inform our marketing strategy)
To use data analytics to improve our website, products/services, marketing, customer relationships and experiences	Technical Usage	Necessary for our legitimate interests (to define types of customers for our products and services, to keep our website updated and relevant, to develop our business and to inform our marketing strategy)
To make suggestions and recommendations to you about goods or services that may be of interest to you	Identity Contact Technical Usage Profile Marketing and Communications	Necessary for our legitimate interests (to develop our products/services and grow our business)

Marketing

We strive to provide you with choices regarding certain personal data uses, particularly around marketing and advertising.

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 a service purchase, product/service experience or other transactions.

Who we share Data with

We may share your Data with the following groups of people for the following reasons:

1. any of our group companies or affiliates - to ensure the proper administration of your website and business; in each case, in accordance with this privacy policy.
2. 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.

Keeping Data secure

We will use technical and organisational measures to safeguard your Data, for example:

1. access to your account is controlled by a password and a user name that is unique to you.
2. we store your Data on secure servers.

Technical and organisational measures include measures to deal with any suspected data breach. If you suspect any misuse or loss or unauthorised access to your Data, please let us know immediately by contacting us via this e-mail address: dataprotectionoffice@sheffieldhaworth.com 

If you want detailed information from Get Safe Online on how to protect your information and your computers and devices against fraud, identity theft, viruses and many other online problems, please visit www.getsafeonline.org. Get Safe Online is supported by HM Government and leading businesses.

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.

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.

Data retention

Unless a longer retention period is required or permitted by law, we will only hold your Data on our systems for the period necessary to fulfil the purposes outlined in this privacy policy or until you request that the Data be deleted.

Even if we delete your Data, it may persist on backup or archival media for legal, tax or regulatory purposes. In addition, 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.

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.

Your rights

Under certain circumstances, you have rights under data protection laws in relation to your Data

1. Right to access - the right to request (i) copies of the information we hold about you at any time, or (ii) that we modify, update or delete such information. If we provide you with access to the information we hold about you, we will not charge you for this, unless your request is "manifestly unfounded or excessive." Where we are legally permitted to do so, we may refuse your request. If we refuse your request, we will tell you the reasons why.
2. Right to correct - the right to have your Data rectified if it is inaccurate or incomplete.
3. Right to erase - the right to request that we delete or remove your Data from our systems.
4. Right to restrict our use of your Data - the right to "block" us from using your Data or limit the way in which we can use it.
5. Right to data portability - the right to request that we move, copy or transfer your Data.
6. Right to object - the right to object to our use of your Data including where we use it for our legitimate interests.

To make enquiries, exercise any of your rights set out above, or withdraw your consent to the processing of your Data (where consent is our legal basis for processing your Data), please contact us via this e-mail address: dataprotectionoffice@sheffieldhaworth.com 

If you are not satisfied with the way a complaint you make in relation to your Data is handled by us, you may be able to refer your complaint to the relevant data protection authority. For the UK, this is the Information Commissioner's Office (ICO). The ICO's contact details can be found on their website at https://ico.org.uk 

It is important that the Data we hold about you is accurate and current. Please keep us informed if your Data changes during the period for which we hold it.

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.

Transfers outside the European Economic Area

Data which we collect from you may be stored and processed in and transferred to countries outside of the European Economic Area (EEA). For example, this could occur if our servers are located in a country outside the EEA or one of our service providers is situated in a country outside the EEA. We also share information with our group companies, some of which are located outside the EEA.

We will only transfer Data outside the EEA where it is compliant with data protection legislation and the means of transfer provides adequate safeguards in relation to your data, eg by way of data transfer agreement, incorporating the current standard contractual clauses adopted by the European Commission, or by signing up to the EU-US Privacy Shield Framework, in the event that the organisation in receipt of the Data is based in the United States of America.

To ensure that your Data receives an adequate level of protection, we have put in place appropriate safeguards and procedures with the third parties we share your Data with. This ensures your Data is treated by those third parties in a way that is consistent with the Data Protection Laws.

Please contact us if you want further information on the specific mechanism used by us when transferring your personal data out of the EEA.

Links to other websites

This Website may, from time to time, provide links to other websites. We have no control over such websites and are not responsible for the content of these websites. This privacy policy does not extend to your use of such websites. You are advised to read the privacy policy or statement of other websites prior to using them.

In addition, 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.

Cookies

You can set your browser to refuse all or some browser cookies, or to alert you when websites set or access cookies. If you disable or refuse cookies, please note that some parts of this website may become inaccessible or not function properly.

A list of the cookies we use are listed below:

1. Google Analytics: these are multiple cookies internal to Google
2. Images: from 3rd party sites that may add some cookies.
3. SH-GA_userID: Internal ID of a user
4. SH-userHasSignedUp: boolean to check signup status
5. SH-lockSite: boolean to check site lock status
6. SH-rememberMe: boolean to check user remember status
7. prevHistory: previous page visited by a user
8. SH-token: Auth token

Changes of business ownership and control

TALNT Limited may, from time to time, expand or reduce our business and this may involve the sale and/or the transfer of control of all or part of TALNT Limited. Data provided by Users will, where it is relevant to any part of our business so transferred, be transferred along with that part and the new owner or newly controlling party will, under the terms of this privacy policy, be permitted to use the Data for the purposes for which it was originally supplied to us.

We may also disclose Data to a prospective purchaser of our business or any part of it.

In the above instances, we will take steps with the aim of ensuring your privacy is protected.

General

You may not transfer any of your rights under this privacy policy to any other person. We may transfer our rights under this privacy policy where we reasonably believe your rights will not be affected.

If any court or competent authority finds that any provision of this privacy policy (or part of any provision) is invalid, illegal or unenforceable, that provision or part-provision will, to the extent required, be deemed to be deleted, and the validity and enforceability of the other provisions of this privacy policy will not be affected.

Unless otherwise agreed, no delay, act or omission by a party in exercising any right or remedy will be deemed a waiver of that, or any other, right or remedy.

This Agreement will be governed by and interpreted according to the law of England and Wales. All disputes arising under the Agreement will be subject to the exclusive jurisdiction of the English and Welsh courts.

Changes to this privacy policy

TALNT Limited reserves the right to change this privacy policy as we may deem necessary from time to time or as may be required by law. Any changes will be immediately posted on the Website and you are deemed to have accepted the terms of the privacy policy on your first use of the Website following the alterations.

You may contact TALNT Limited by email at dataprotectionoffice@sheffieldhaworth.com