In Touch networks Ltd and it’s trading styles is committed to ensuring that your privacy is protected.

This Privacy Notice sets out what personal data we collect from you and how we use it when you use the services provided by Intouch Networks Ltd or otherwise interact with us. This Privacy Notice also explains how we use cookies on our website. Please read this carefully.

Definitions

Language used in this privacy Notice	Definition
You, your, data subject	Relates to you as a natural living person
We, our	In Touch Networks Ltd & trading styles
Your representative	Someone or some people who legally acting on your behalf
Third party(ies)	Refers to external suppliers who your personal data may be shared with (E.G. Delivery companies)
Data	Any personal information we hold on you
GDPR	General Data Protection Regulation (2016)
ICO	Information Commissioner’s Office. The UK Data Protection Regulator
EEA/EU	European Economic Area/ European Union States
Legitimate Interest	ICO 3 elements: Identify a legitimate interest; show that the processing is necessary to achieve it; and balance it against the individual’s interests, rights and freedoms

Scope of this Privacy Notice

This Privacy Notice covers how we handle your data from this website and within our organisation. It does not include any website you have used to access this website or any website that you access from this website.

GDPR

Under GDPR, we act as a data controller (make decisions) for your personal data that we collect and a data processor (process your data) or data controller for any of your data shared with us by a third-party.

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Who collects your personal data and is responsible for its use?

In Touch Networks Ltd and all related group trading styles (E.G.NonExecutiveDirectors.com). We are responsible for looking after your personal data that we collect, use and process in accordance with the UK Data Protection Act (2018).

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Lawful basis for processing personal data

We will only process your personal data using the lawful definitions provided by the ICO:

Consent, Contractual, Legal Obligation, Vital Interest, Public Task and Legitimate Interests

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Special Category data

We will comply with section 9 of GDPR, ensuring that Special Category data is handled using both a lawful basis and that such data is processed in a more sensitive way. For example, information about an individual’s:

• race
• ethnic origin
• politics
• religion
• trade union membership
• genetics
• biometrics (where used for ID purposes)
• health
• sex life; or
• sexual orientation.

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What personal information do we collect?

In the course of our dealings with you, we will collect information about you. We refer to that information as personal information or personal data. This information may include:

• name and job title
• contact information, including email address, telephone numbers and postal address
• demographic information and information about your preferences and interests
• information contained in your CV or profile
• payment card information
• information contained in and records of communications between us, including recordings of telephone calls
• details of your visits to our website, including, but not limited to, traffic data, location data (including the country and telephone area code where your computer is located) and the resources that you access (including the pages of our website that you view).

Sometimes you may provide us with personal data about another person. If you do, you must ensure that before you provide us with their personal data, you have their agreement to do so and that they are aware of the ways in which we use personal data as set out in this Privacy Notice.

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How do we use the personal information that we collect?

We will use your information in the operation of our business and, in particular, we will use your personal information to:

• administer your relationship with us (including where necessary to take payment from you);
• provide recruitment services to you and any other services you decide to receive from us, such as training and development courses;
• enable you to submit your profile, apply online for vacancies or to subscribe to alerts about vacancies we think may be of interest to you;
• analyse your personal information in order to identify vacancies which may be of interest to you;
• in the event that you do not complete your registration, we may use any contact information you have provided to us to follow-up on your partial registration;
• provide you with marketing information in accordance with your preferences; this information may include reports, and information about products, services, promotions, offers and events, and general information about the industry sectors which we think might be of interest to you and may be provided by email, telephone, SMS, post and other electronic means;
• carry out research;
• help us review, develop and improve the products and services we offer; for example, your calls to and from us may be monitored and recorded for training and quality assurance purposes;
• answer your questions and enquiries;
• tailor our website and services to you; and
• comply with our legal and regulatory duties.

In addition to the above, we may anonymise your personal information and use it in the ways described below in the section 'How do we use anonymous information?'.

Where you have a members account with us, you can choose to make your profile accessible to the public or only to those other members with whom you are connected. You can control this through your account settings.

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How do we use anonymous information?

Anonymous information is information that does not identify you, but it may be created using personal information you have provided to us.

We may anonymise the information you provide to us and aggregate it with other anonymous user data we hold. We may use this anonymous information to better understand our users, develop and improve our services, create and publish reports, provide products and services for our clients and other third parties, and as we otherwise determine. We do not use this anonymous information in a way that you can be identified.

We may also use your information on an anonymised basis to monitor compliance with our equal opportunities policy.

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Who might we share your personal information with?

We may share your personal information with various third parties in connection with the purposes identified above. These third parties include the following:

• Client organisations in connection with recruitment for vacancies at those organisations;
• Third parties where we have retained them to provide services that you (or our client) have requested, such as references, qualifications and criminal reference checking services, verification of the details you have provided from third party sources, psychometric evaluation or skill testing;
• Third parties with whom we have a business relationship; and
• Regulatory or law enforcement agencies or other third parties if we believe that we are required by law to disclose it in connection with the detection of crime, the collection of taxes or duties, in order to comply with any applicable law or order of a court of competent jurisdiction, or in connection with legal proceedings.

Where we have your permission to do so, we may also share your information with third parties who provide products and services which we think may be of interest to you. These third parties will typically provide products and services that are of particular benefit to high net worth individuals, and the third parties include financial advisers, solicitors, accountants and insurance brokers. Those third parties may contact you in connection with these products and services by email, telephone, SMS, post or other electronic means.

In the event that we sell or buy any business or assets, we may disclose personal data held by us 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 (or subject to a reorganisation within our corporate group), personal data held by us will be one of the transferred assets.

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Do we use organisations to process personal data on our behalf?

Yes.  We sometimes delegate the personal information processing activities we undertake to third parties.  For instance, we use third parties to send marketing emails and process payments on our behalf.

We are required by data protection law to ensure that, where we use third party data processors, we use suitable third parties and have a contract in place with those third parties committing them to protect the personal information they receive and process on our behalf.

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Timescales that we keep your data for

The timescale for this will vary depending on the requirement. The criteria for this include:

• The reason we are using your data. We will keep the minimum amount of data required for that reason and for the timescale that that reason requires (E.G. contractual membership periods)
• Legal requirements and where a minimum timescale is set (E.G. Her Majesty's Revenue and Customs (HMRC))

We will keep your data for the term you have consented to, the contracted term between us or where there is a legitimate interest for us to remain in contact with you in case of any queries that you may have (E.G. copy of the original agreement) or for legally required reasons (E.G. HMRC), whichever is the longest period.

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How do we keep your data secure?

We are committed to ensuring that your information is secure.

In order to prevent unauthorised access or disclosure, we have put in place appropriate physical, electronic and managerial procedures to safeguard and secure the information we collect.

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Where do we process your personal information?

We work with third parties and business partners across the globe. As such, your personal information may be transferred and processed anywhere in the world, including countries that do not have data protection laws equivalent to those in the UK.

Where we transfer personal data outside the UK, we will do so in a way that complies with applicable data protection law.

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Do we monitor your communications with us?

To help us review, develop and improve the products and services we offer and to ensure that we meet the standards we set ourselves, we may monitor your communications with us.

For example, your calls to and from us may be monitored and recorded for training and quality assurance purposes.

In addition, emails and messages you send to us or via our website and platform will be scanned and reviewed (which may include a review by one of our members of staff) to confirm that the email or message does not contain spam or other inappropriate content.

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How can you choose not to receive marketing communications from us?

When we collect your data for marketing, we will provide you with an option to choose whether you receive marketing communications from us.

If you initially choose to receive marketing from us, but would like to change your mind, there are a number of ways to stop receiving marketing from us:

• All email and SMS marketing messages contain an "unsubscribe" option that allows you unsubscribe from further email or SMS marketing messages
• You can adjust your marketing preferences through your account with us (if you are a member)
• You can also send an unsubscribe request to customercare@intouchnetworks.com or by writing to us at the following address: 3 Hardman Square, Spinningfields, Manchester, M3 3EB

Please note that if you elect to stop receiving marketing communications from us, you may still receive important services messages from us.

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How can you get a copy of the personal information we hold about you or correct inaccurate information you think we may hold?

You may request details of the personal information which we hold about you under the Data Protection Act 1998. A small fee will be payable. If you would like a copy of the information held on you, please write to:

The Data Protection Officer
3 Hardman Square
Spinningfields
Manchester
M3 3EB

If you believe that any information we are holding on you is incorrect or incomplete, please write to us at the above address or email us at data.controller@intouchnetworks.com as soon as possible. We will promptly correct any information found to be incorrect.

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How can you exercise your other rights under data protection law?

Your Data Protection & Privacy Rights

There are various rights that you have as a UK natural living person (individual) under the GDPR. Below are the abbreviated ICO definitions and include:

• The right to be informed - Individuals have the right to be informed about the collection and use of their personal data
• The right of access - Individuals have the right to access their personal data and supplementary information
• The right to rectification - Individuals have the right to have inaccurate personal data rectified, or completed if it is incomplete
• The right to erasure - The right for individuals to have personal data erased. This is also known as ‘the right to be forgotten. Please note this right is not absolute and only applies in certain circumstances
• The right to restrict processing - The right to request the restriction or suppression of their personal data. Please note this is not an absolute right and only applies in certain circumstances
• The right to data portability - The right to data portability allows individuals to obtain and reuse their personal data for their own purposes across different services
• The right to object - Individuals have the right to object to processing based on legitimate interests or the performance of a task in the public interest/exercise of official authority (including profiling), direct marketing (including profiling) and processing for purposes of scientific/historical research and statistics

The full ICO rights under GDPR can be seen at the Internet link below or calling them on 0303 123 1113:

https://ico.org.uk/for-organisations/guide-to-the-general-data-protection-regulation-gdpr/individual-rights

If you wish to exercise your other rights, please write to us at the below address or email us at data.controller@intouchnetworks.com:

The Data Protection Officer
In Touch Networks Ltd
3 Hardman Square
Spinningfields
Manchester
M3 3EB

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Do we use cookies and similar technologies on our website?

Yes.

A cookie is a small file which is placed on your computer’s hard drive. The cookies we use allow our website to recognise your device when you visit our website. We use the following cookies on our website:

• Strictly necessary cookies: these cookies are essential for the use of the features and services on our website. For instance, we use these cookies to identify you as being logged in to the site.
• Performance cookies: these cookies collect information about how the website is used so that we can improve the site. For instance, these cookies enable us to count the number of unique visitors to our website.
• Functional cookies: these cookies allow our website to remember choices you make such as remembering your user name and any customisations you make to pages on the website.
• Targeting / advertising cookies: these cookies collect information about your internet browsing habits in order to make advertising and marketing more relevant to you and your interests (both on this website and other websites).

By using our website you agree to our use of cookies, including setting and reading cookies on your device.

Most web browsers automatically accept cookies, but you can usually modify your browser setting to decline cookies if you prefer. For more information about how to do this, and about cookies in general, you can visit www.allaboutcookies.org. Removing or blocking cookies may prevent you from taking full advantage of the website. Please note that certain cookies may be set as soon as you visit our website, but you can remove them using your browser settings.

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Does our website contain links to other sites and who is responsible for the data collected by those sites?

Yes.

Our website may contain links to other third party websites of interest. However, once you have used these links to leave our site, you should note that we do not have any control over that other website. Therefore, we cannot be responsible for the protection and privacy of any information which you provide whilst visiting such sites and such sites are not governed by this Privacy Notice. You should exercise caution and look at the privacy and cookies policies applicable to the website in question.

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Children Under Thirteen

Our products and services are not intended to be used by children under 13 years old. We will never knowingly collect data from or on children below 13 years old. If you become aware of such a child (or another person) supplying data on that child to us, please contact using the details shown in the ‘Contact us’ section at the end of this Privacy Notice.

Complaints

We would always welcome the opportunity to rectify any complaints that you have about your data and privacy held with us and can be contacted as shown in the ‘How can you exercise your other rights under data protection law?’ section above. If you would like to make a complaint to the ICO, their contact details are:

By phone - 0303 123 1113

Online - https://ico.org.uk/concerns

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Will this Privacy Notice change?

We may need to change this Privacy Notice from time to time to ensure that it accurately reflects the ways in which we process your personal data. Any changes will be posted on this webpage. Please check this page from time to time so that you aware of the ways in which we process your personal data.

This Privacy Notice was last updated on 1st May 2018.