Privacy Policy

This privacy policy outlines Papillon HR Limited’s (“we” “our” “the Company”) practices with respect to information collected from users who access our website at www.papillonhr.co.uk or otherwise share personal information with us (collectively “Users”).

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

Our website and Services may contain links to third party websites that are not covered by this Privacy Policy. We therefore ask you to review the privacy statements of other websites and applications to understand their information practices.

COLLECTION OF INFORMATION

Processing of your personal information (i.e., any information which may potentially allow your identification through reasonable means; hereinafter "Personal Information") is necessary for the performance of our contractual obligations towards you and providing you with our services, to protect our legitimate interests and for compliance with legal and financial regulatory obligations to which we are subject.

We encourage our Users to carefully read the Privacy Policy and use it to make informed decisions. Your acceptance of our Privacy Policy is deemed to occur upon your first use of our website. If you do not accept and agree with this Privacy Policy, you must stop using our website immediately. This Privacy Policy may change from time to time and your continued use of the website, or the Services is deemed to be acceptance of such changes, so please check periodically for updates.

WHAT INFORMATION DO WE COLLECT?

We collect two types of data and information from Users. 

The first type of information is un-identified and non-identifiable information pertaining to a User(s), which may be made available or gathered via your use of the Site (“Non-personal Information”). We are not aware of the identity of a User from which the Non-personal Information was collected. This type of information may include your aggregated usage information and technical information transmitted by your device, including certain software and hardware information (e.g., the type of browser and operating system your device uses, language preference, access time, etc.) in order to enhance the functionality of our Site. We may also collect information on your activity on the Site (e.g., pages viewed, online browsing, clicks, actions, etc.).

The second type of information is Personal Information which is individually identifiable information, namely information that identifies an individual or may with reasonable effort identify an individual. Such information includes:

• Device Information: We collect Personal Information from your device. Such information includes geolocation data, IP address, unique identifiers (e.g., MAC address and UUID) and other information which relates to your activity through the Site.
• Registration information: When you register to our Site you will be asked to provide us certain details such as: full name; e-mail or physical address, and other information. 
• Full name (First name and/ or Last name)
• Phone number
• Email address

COOKIES 

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 assign to your device while you are viewing a website. Cookies are helpful and can be used for various different purposes. These purposes include allowing you to navigate between pages efficiently, enable 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:

• '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; 
• '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; 
• '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.

HOW DO WE COLLECT INFORMATION?

We (or third-party data processors, agents and sub-contractors acting on our behalf) may collect, store, and use your personal information by way of different methods to collect data from and about you including through:

• Direct interactions. You may give us your information by filling in forms via our website or by corresponding with us by post, phone, email or otherwise. This includes personal data you provide when you present Website content, use any of our Services, create an account on our website, subscribe to our Services or publications, request marketing to be sent to you, enter a competition, promotion, or survey, or give us some feedback;
• 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.

HOW DO WE USE INFORMATION?

We do not rent, sell, or share Users’ information with third parties except as described in this Privacy Policy.  We may use the information for the following:

• To personalise your website experience and to allow us to deliver the type of content and product offerings in which you are most interested.
• If you have consented to receive our e-mail newsletter, we may send you periodic e-mails. If you would no longer like to receive promotional e-mail from us, please refer to the "How can you opt-out, remove or modify information you have provided to us?" section below. If you have not opted-in to receive e-mail newsletters, you will not receive these e-mails. Visitors who register or participate in other site features such as marketing programs and 'members-only' content will be given a choice whether they would like to be on our e-mail list and receive e-mail communications from us.
• Present Website content effectively to you.
• Conduct our contracts with you.
• Provide the relevant Services to you.

In addition to the different uses listed above, we may transfer or disclose Personal Information to our subsidiaries, affiliated companies, and subcontractors.

We may also share Personal Information with our trusted third-party providers, who may be located in different jurisdictions across the world, for any of the following purposes: 

• Hosting and operating our site.
• Performing research, technical diagnostics, or analytics.
• Providing you with our services, including providing a personalized display of our site;
• Storing and processing such information on our behalf. 
• Serving you with advertisements and assist us in evaluating the success of our advertising campaigns and help us retarget any of our users;
• Providing you with marketing offers and promotional materials related to our Site and services.

We may also disclose information if we have good faith to believe that disclosure of such information is helpful or reasonably necessary to: (a) comply with any applicable law, regulation, legal process or governmental request; (b) enforce our policies (including our Agreement), including investigations of potential violations thereof; (c) investigate, detect, prevent, or take action regarding illegal activities or other wrongdoing, suspected fraud or security issues; (d) to establish or exercise our rights to defend against legal claims; (e) prevent harm to the rights, property or safety of us, our users, yourself or any third party; or (f) for the purpose of collaborating with law enforcement agencies and/or in case we find it necessary in order to enforce intellectual property or other legal rights.

We will never make your personal data public unless required by exceptional legal circumstances, for example protecting our own interests in trying to recover an unpaid invoice, or aiding police in criminal investigations.

If we use personal data for the purposes of automated decision-making and those decisions have a legal (or similarly significant effect) on you, you have the right to challenge to such decisions under UK GDPR, requesting human intervention, expressing their own point of view, and obtaining an explanation of the decision from us.

This right does not apply in the following circumstances:

• the decision is necessary for the entry into, or performance of, a contract between the you and us; or
• the decision is authorised by law; or
• you have given you explicit consent.

Where we use your personal data for profiling purposes, the following shall apply:

• Clear information explaining the profiling will be provided, including its significance and the likely consequences.
• Appropriate mathematical or statistical procedures will be used.
• Technical and organisational measures necessary to minimise the risk of errors and to enable such errors to be easily corrected shall be implemented; and
• All personal data processed for profiling purposes shall be secured to prevent discriminatory effects arising out of profiling.

SAFE STORAGE OF YOUR DATA

We may transfer your collected data to storage outside the UK. It may be processed outside the UK to fulfil your order and to receive our Services and deal with payment. If we do store or transfer data outside the UK, we will take all reasonable steps to ensure that your data is treated as safely and securely as it would be within the UK and under the UK GDPR. Such steps may include, but not be limited to, the use of legally binding contractual terms between us and any third parties we engage with and the use of approved Model Contractual Arrangements. Your acceptance of this Privacy Policy shall be your consent permitting us to store or transfer data outside the UK if it is necessary for us to do so.

Data security is of great importance to us, and to protect your data we have put in place suitable physical, electronic, and managerial procedures to safeguard and secure data collected through our website. 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.

By giving us your personal data, you agree to this arrangement. We will do what we reasonably can to keep your data secure.

We have implemented security measures such as a firewall to protect any data and maintain a high level of security.

Notwithstanding the security measures that we take, it is important to remember that the transmission of data via the internet may not be completely secure and that you are advised to take suitable precautions when transmitting to us data via the internet and you take the risk that any sending of that data turns out to be not secure despite our efforts.

We will keep personal data for as long as is necessary which is usually the life of our relationship and up to a period of seven years after our relationship have ended. We may however be required to retain personal data for a longer period to ensure we comply with our legislative and regulatory requirements. We review our data retention obligations to ensure we are not retaining data for longer than we are legally obliged to.

USER RIGHTS

Under the  UK General Data Protection Regulation (UK GDPR) and The Data Protection Act 2018 (DPA) you have several rights with regard to your personal data. You have the right to access, update or to delete the information we hold about you, the right of rectification, the right to object, the right to portability and the right to withdraw consent.

You also have the right to ask us not to process your personal data for marketing purposes. We will usually inform you (before collecting your data) if we intend to use your data for such purposes or if we intend to disclose your information to any third party for such purposes.

In some cases, the collection of personal data may be a statutory or contractual requirement, and we will be limited in the services we can provide you if you don't provide your personal data in these cases.

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 or have entered 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 or regulatory obligation, for example compliance with health and safety, tax, or other statutory obligations.
• We will take all reasonable steps to ensure that we fully protect your rights and comply with our obligations under the UK GDPR and the Privacy and Electronic Communications (EC Directive) Regulations 2003, as amended. We receive your Personal Information from various sources.
• When you voluntarily provide us your personal details 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).

COMPLAINTS AND CONACT

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. 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.

To enforce any of the foregoing rights or if you have any other questions about our website or this Privacy Policy, please contact us at enquiries@papillonhr.co.uk.