PanVenture Consulting Limited of Third Floor, 207 Regent Street, London, W1B 3HH, United Kingdom (company number: 10770443) (“we”/“us”/“our”) is committed to protecting and respecting your privacy.
This privacy notice (“Notice”) and any other documents referred to in it, and any other contractual terms that may be in place between us and you) sets out the basis on which any personal data we receive from you, or that we gather in any other way, will be processed by us. It applies to any data gathered due to your use of the following websites www.panventure.com (our “Platform”) or otherwise as a consequence of any dealings we may have with you.
For the purposes of the General Data Protection Regulation (“GDPR”) where we hold data for enabling or displaying content on the Platform, for business and marketing consultancy purposes, employment agency purposes, or any other purpose, we shall be the “controller”. Where we provide personal data to clients, it is provided only for the purposes explained to you prior to the transfer, or which are implicit from our relationship with you. We shall thereafter cease to be the controller of that data in respect of any further processing of the data by the recipient. The recipient of the personal data shall thereafter be controller of the data and shall ensure compliance with relevant laws.
- INFORMATION WE MAY COLLECT FROM YOU
We may collect and process data about you in the manner set out below.
You may give us information about you by filling in forms or by corresponding with us by phone, e-mail or otherwise. This includes information you provide when you register to use our services, or correspond or communicate with us. The information may include without limitation your name, address, e-mail address, social media account information, phone number, financial and credit card information, photograph, age, and other information. You acknowledge that we may make information provided by you available for the conduct of business consultancy services.
In certain cases we may receive information about you from third parties. For example, a third party may pass us details of a candidate that they think may be appropriate for a job that we are instructed on. This may contain information of any of the types set out above. Candidates may provide details of referees to us, in which case we shall hold only the name, job role and contact details. We are also working closely with third parties (including, for example, sub-contractors in technical, payment services, advertising networks, analytics providers, search information providers, credit reference agencies) and may receive information about you from them.
In certain cases we may gather information about you from public sources. For example we may gather data contained on a CV that has been made public by you on another website or platform. This may contain information of any of the types set out above. Where we retain or intend to share this data we will contact you within one month to inform you that we are holding your data. We may also gather information about you from any source with a view to publishing journalistic, academic or literary material. Where this is the case, many provisions of the GDPR, including the obligation to inform you regarding the data, and the applicability of many of your rights, do not apply where we reasonably believe that the application would be incompatible with these purposes.
With regard to each of your visits to or use of our Platform we may automatically collect the following information about you or your devices:
- technical information, including the type of device(s) you use, a unique device identifier, the Internet protocol (IP) address used to connect your device(s) to the Internet, network information, browser type and version, time zone setting, browser plug-in types and versions and operating system and platform;
- information and details about your use of our Platform (including but not limited to traffic data; location data; weblogs and other communication data; the full Uniform Resource Locators (URL) clickstream to, through and from our Platform (including date and time); what you viewed or searched for; page response times, download errors; length of visits to certain pages; page interaction information (such as scrolling, clicks, and mouse-overs); and methods used to browse away from the page)).
We may use the information we obtain from the cookie in the administration of our Platform, to improve our Platform’s usability and for marketing purposes. We may also use that information to distinguish you from other users of our Platform and to monitor traffic on our Platform.
If you do not want us to store cookies on your computer or other device for these purposes, you may change the settings on your internet browser to reject cookies. Please note that if you set your browser to reject cookies, you may not be able to use all of the features of our Platform and/or may be prevented from accessing certain parts of our Platform.
You can find more information about the individual cookies we use and the purposes for which we use them in the table below:
If you continue to use our Platform, we will take that as your consent to the relevant cookies being stored on your computer or other device.
- USES MADE OF THE INFORMATION
We will use the information you give to us:
- to carry out our obligations arising from any contracts entered into by you or in order to take steps at your request prior to entering into such a contract. This may include contracts between you and us whereby we provide services of an employment agency or business introduction. It may also include a contract of employment between you and the advertiser of a job via our Platform or as part of the PanVenture Staff Recruitment Service. This may include passing your personal data to a prospective employer to whom you have submitted, or instructed the submission of, a job application;
- where you have provided consent to the same (by signing up to our mailing list or quarterly publications), or where you have previously purchased services from us, to contact you via email or other electronic messaging to provide you with information about other services we offer that are similar to those that you have enquired about, or we are currently providing to you. Our publications may also include third party advertising;
- where you have provided consent to the same, or where businesses have published relevant contact information, and have not registered with the telephone preference service, or similar applicable scheme, to contact you by telephone to provide you with information about the services that we offer. This is done only where we have reason to believe that you may be interested in receiving information about such services, and where we have a legitimate interest in marketing these services to you;
- in accordance with our and/or your legitimate interests under any contract between you (or a party that you represent) and us, to facilitate, and if necessary, enforce any legal obligations you (or a party that you represent) may owe to us, in respect of that contract;
- in accordance with your and our legitimate interests, and the legitimate interests of other users of our services to ensure that our services are used in the most effective manner and for maximum benefit, to notify you about changes to our Platform or services and to ensure that content on our Platform is presented in the most effective manner for you and for your computer or mobile device;
- in accordance with your and our legitimate interests, and the legitimate interests of other users of our services in ensuring lawfulness of any conduct relating to the goods and services that we provide, to make you aware of regulatory obligations or changes in the law that may be relevant to you;
- in accordance with our legitimate interest in publishing journalistic, academic or literary material;
- where you have provided consent to the same, to feature quotes from you regarding our services on the Platform or within marketing material for our services;
- in accordance with our legitimate interest to invite you to awards or other similar events;
- in accordance with our legitimate interest, and the legitimate interest of any counterpart, to facilitate such sale or purchase as part of, or as reasonably necessary for the purpose of, any sale or purchase of any of our business or assets of which the provision or offering of goods or services to you forms part.
We will use the information we collect about you from the use of our Platform, in accordance with our and/or your legitimate interests, in order to improve your experience of our Platform:
- to administer our Platform and for internal operations, including troubleshooting, data analysis, testing, research, statistical and survey purposes;
- to allow you to participate in interactive features when you choose to do so;
- as part of our efforts to keep our Platform safe and secure;
- to measure or understand the effectiveness of advertising we serve to you and others, and to deliver relevant advertising to you;
- to make suggestions and recommendations to you and other users of our Platform about goods or services that may interest you or them.
We may combine the information we receive from other sources with information you give to us and information we collect about you. We may use this information and the combined information for the purposes set out above (depending on the types of information we receive).
We do not use your personal data as part of any automated decision-making, including profiling, which produces legal or similarly significant effects concerning you.
- DISCLOSURE OF YOUR INFORMATON
We may share your personal information with any member of our group, which means our subsidiaries, our ultimate holding company and its subsidiaries (if applicable).
We may share your information with selected third parties including:
- Prospective employers in respect of jobs that you have applied for;
- Our mailing partner, to deliver messages to you in accordance with the purposes set out above;
- Business partners, suppliers and sub-contractors for the performance of any contracts we enter into with you including payment processing, web-hosting and mailing services;
- Advertisers and advertising networks that require the data to select and serve relevant adverts to you and others. We do not disclose information about identifiable individuals to our advertisers, but we may provide them with anonymous aggregate information about our users (for example, we may inform them that 500 men aged under 30 have clicked on their advertisement on any given day). We may also use such aggregate information to help advertisers reach the kind of audience they want to target. We may make use of the personal data we have collected from you to enable us to comply with our advertisers’ wishes by displaying their advertisement to that target audience;
- Analytics and search engine providers that assist us in the improvement and optimisation of our Platform;
- Suppliers of IT systems and services for the purpose of ensuring the correct operation, or enhancing the operation of IT systems, or to ensure the safety and security of personal data;
We may disclose your personal information to third parties:
- in the event that we sell or buy any business or assets, in which case we may disclose your personal data to the prospective seller or buyer of such business or assets;
- if we or substantially all of our assets are acquired by a third party, in which case personal data held by us about our customers will be one of the transferred assets;
- if we are under a duty to disclose or share your personal data in order to comply with any legal obligation, and other agreements; or to protect our rights, property, or safety, our customers, or others. This includes exchanging information with other companies and organisations for the purposes of fraud protection and credit risk reduction.
Data shall be shared with third parties only to the extent compatible with the uses set out in part 4 of this Notice.
- WHERE AND HOW WE STORE YOUR PERSONAL DATA
Once we have received your information, we will use strict procedures and security features to try to prevent unauthorised access. For example, we and our suppliers use secure servers to store all information you provide to us. Unfortunately, the transmission of information via the internet is not completely secure. Although we will do our best to protect your personal data, we cannot guarantee the security of your data transmitted to our Platform; any transmission is at your own risk.
The data that we collect from or about you will be transferred to, and stored at, a destination outside the European Economic Area (“EEA”) as part of our information hosting arrangements, or where prospective employers are located outside of the EEA. Transfers to prospective employers outside of the EEA are made pursuant to your explicit consent to transfer your data to the prospective employer for their assessment. The data we collect from or about you may also be occasionally processed by staff operating outside the EEA who work for us or for a third party. We will take all steps reasonably necessary to ensure that your data is treated securely and in accordance with this Notice.
Where we have given you (or where you have chosen) a password that enables you to access certain parts of our Platform, you are responsible for keeping this password confidential. We ask you not to share a password with anyone.
We will store your data for as long as necessary to fulfil the purposes for which it is originally collected, as explained in this Notice, or any other lawful purpose subsequently communicated to you, and for other essential purposes such as complying with legal obligations and enforcing our rights, such as those arising under any agreement with you. The retention period may therefore vary for different types of data, and depending on how and why it was gathered. Criteria relevant to determine retention periods include:
- If the data is necessary for the performance of a contract, we will retain it while performance under that contract remains active, and for a period thereafter in which that data may still be relevant to dispute resolution, enforcement of rights under the contract, or where additional connected contracts are likely to arise.
- If the data is held with a view to enabling you to enter into a contract with a prospective employer, we will hold it until such time as you inform us, or we otherwise consider, that you are no longer seeking new opportunities.
- If the data is processed pursuant to consent only, and consent is withdrawn, we may delete the data immediately, or we may cease processing and retain the data for a period if we have a need to keep it for dispute resolution or enforcement of rights.
- In certain cases we may be legally obliged to hold data for a certain period of time, or to delete the data at a certain time, including in accordance with the exercise of your rights as data subject as explained in this Notice.
- YOUR RIGHTS
We will not use your personal data to send direct marketing electronic messages unless you have provided your consent to us, or to a third party via which we have received the data, or you have previously purchased similar goods or services from us. We may contact you by telephone for direct marketing purposes in the circumstances described earlier in this notice. You have the right to ask us not to process your personal data for these purposes.
The GDPR provides you with various further rights. Note however that these rights will not apply where we process data with a view to publishing journalistic, academic or literary material to the extent that we reasonably believe that the application would be incompatible with these purposes.
Your rights under the GDPR include the right to:
- request from us confirmation of whether or not your personal data is being processed and where that is the case, confirmation of the information set out in this Notice;
- request from us a copy of your data that is undergoing processing, including, in relation to data provided to us by you, and which is processed by automatic means pursuant to a contract with you, or pursuant to your consent, a right to request that data in a structured, commonly used and machine readable format;
- request that we rectify or complete your personal data, where it is inaccurate or incomplete for the purposes of our processing of the data;
- request that we erase your personal data in the following circumstances:
- the personal data is no longer necessary in relation to the purposes for which it is processed;
- you withdraw consent and there is no other legal ground for the processing;
- you successfully object to the processing pursuant to your right of objection explained below;
- the personal data has been unlawfully processed;
- the erasure is necessary for compliance with a relevant legal obligation that applies to us;
- request that we restrict the processing of your personal data in the following circumstances:
- you contest the accuracy of the personal data, for a period enabling us to verify the same;
- the processing is unlawful, but you request restriction rather than erasure;
- we no longer need the data, but it is required by you in respect of legal claims;
- you have objected to the processing, until such that that we verify that there are legitimate purposes that justify such processing;
- object to any processing that is based on our, or a third party’s legitimate interests, upon which event we shall suspend processing until we demonstrate legitimate purposes that justify that processing. We may at all times continue to use data for the purpose of establishment, exercise or defence of legal claims;
- withdraw your consent for future processing (where the processing is based on that consent);
- lodge a complaint with the Information Commissioner’s Office, which is the data protection supervisory authority in the UK.
We will comply with any valid request for information under the rights explained above within one month, though we may tell you that this period is to be extended by a further two months where necessary, taking into account the complexity and number of the requests. This will normally be provided free of charge. If the request is manifestly unfounded, excessive or repetitive we may charge a reasonable fee or refuse to action the request.
The provision of personal data to us is not a statutory requirement. Where the provision of data is a contractual requirement, or a requirement necessary to enter into a contract, we will make that clear as part of the process by which the contract is concluded, which may include by way of terms of the contract. These provisions will also make clear the consequences of failure to provide such data.
Where the data is not a contractual requirement, you are not obliged to provide the data, but if you do not do so, we may be unable to offer certain benefits and functionality to you. For example, you may not be able to access part of the Platform.
Our Platform may, from time to time, contain links to and from the websites of our partner networks, advertisers and affiliates (including, but not limited to, websites on which our Platform is advertised). If you follow a link to any of these websites, please note that these websites and any services that may be accessible through them have their own privacy notices and that we do not accept any responsibility or liability for these notices or for any personal data that may be collected through these websites or services. Please check these notices before you submit any personal data to these websites or use these services.
- CHANGES TO OUR PRIVACY NOTICE
Any changes we may make to our Privacy Notice in the future will be posted on this page and, where appropriate, notified to you by e-mail or when you next use our Platform. The new terms may be displayed on-screen and you may be required to read and accept them to continue your use of our Platform. Alternatively, please check back frequently to see any updates or changes to our Privacy Notice.
Questions, comments and requests regarding this Privacy Notice are welcomed and should be addressed to Chris Bayley at firstname.lastname@example.org.