2to3days ltd data privacy policy
Introduction
This is the privacy policy for 2to3days Limited, a company headquartered at 26 Fourth Avenue, Hove BN3 2PJ, with company reg 9003523 and VAT reg 188512677.
2to3days Ltd (“2to3days” or “We”) espects 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.
This privacy policy is provided in a layered format so you can click through to the specific areas set out below. Please also use the Glossary 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 2to3days collects and processes your personal data through your use of this website, including any data you may provide through this website when you complete any forms on our site.
This website is 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 we may provide 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 and is not intended to override them.
We are the controller and responsible for your personal data. If you have any questions on this policy, including any requests to exercise your legal rights, please contact Benvon Crumpler using the details set out below:
Full name of legal entity: 2to3days Ltd
Email address: [email protected]
Postal address: 26 Fourth Avenue, Hove BN3 2PJ
You have the right to make a complaint at any time to the Information Commissioner's Office (ICO), the UK regulator 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 in December 2021.
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, last name, username, or similar identifier.
- Contact Data includes billing address, delivery address, email address and telephone numbers.
- Financial Data includes bank account and payment card details
- Transaction Data includes details about payments to and from you and other details of services you have purchased from us.
- 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.
- Usage Data includes information about how you use our website and services.
- Marketing and Communications Data includes your preferences in receiving marketing from us and our third parties and your communication preferences.
- Special categories of data include details about your race or ethnicity, religious or philosophical beliefs, sexual orientation, information about your health, including physical and mental disabilities. Please see in the section 4 for more information about this collection activity. Please refer to Section 4 which sets out how we use such data.
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.
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 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.
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, Financial Data and Special Category Data by filling in forms or by corresponding with us by post, phone, email or otherwise, including through social media. This includes personal data you provide when you:
- apply for a position on our website
- register as a candidate;
- register as an employer/ recruiter;
- subscribe to our publications;
- agree marketing to be sent to you;
- enter a competition, promotion, or survey; or
- give us feedback or contact us.
- Automated technologies or interactions. As you interact with our website, we will automatically collect Technical Data about your equipment, browsing actions and patterns. We collect this personal data by using cookies, server logs and other similar technologies. We may also receive Technical Data about you if you visit other websites employing our cookies. Please see our cookie policy for further details.
- Third parties or publicly available sources. We will receive personal data about you from various third parties and public sources as set out below:
- Technical Data from the following parties:
(a) analytics providers;
(b) advertising networks such as LinkedIn and Twitter based inside the UK; and
(c) search information providers such as Google, based outside the UK. - Contact, Financial and Transaction Data from providers of technical, payment and delivery services.
- Identity and Contact Data from publicly available sources such as Companies House and the Electoral Register based inside the UK.
- Technical Data from the following parties:
4. How we use your personal data
How we use your data will depend on who you are and the purposes for which you are engaging with us. In general, we will only use your personal data where 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.
Generally, we do not rely on consent as a legal basis for processing your personal data although we will get your consent (i) before sending direct marketing communications to you via email or text message or (ii) when collecting special category data. You have the right to withdraw consent to marketing at any time by contacting us at [email protected].
Candidate data
We generally use Candidate data in four ways:
- Recruitment activities;
- Marketing activities;
- Equal Opportunities Monitoring; and
- To help us to establish, exercise or defend legal claims.
In addition to our recruitment activities, unless you have clearly stated on the website that you do not wish to receive such communications, we may also send you information from time to time about roles or career programmes that you may find interesting and which we find to be in your legitimate interests. In particular, we may wish to use your data for the purposes listed below. Please note that this list is not exhaustive. To:
- enable us to develop and market other products and services;
- inform you of relevant events hosted by 2to3days or our trusted partners;
- market our full range of recruitment services (permanent, temporary, contract and returnships) to you; and
- display promotional excerpts from your details on 2to3days’ website as a success story (only where we have obtained your express consent to do so).
Please note that where you have previously engaged with us (for example by submitting a job application or CV, or registering a vacancy to be filled), and we are marketing other recruitment-related services that we believe to be of relevance to you, then we will do so in the view that it is in your legitimate interests to contact you further unless you have stated clearly that you do not wish us to contact you on the website. You can choose not to receive any further information from us at any time and we will use all reasonable endeavours to remove you from any further mailing lists.
You can unsubscribe from our marketing communications via the unsubscribe link in all our marketing e-news. Your request is handled instantly. If you are unable to manage this task, you can contact us directly at hello@2to3days and we will manually remove you from the marcomms database; in this instance, it might take a few days to expedite your request.
If you want to stop receiving job alerts via email, you should log-into your 2to3days account and edit your job alert settings. This takes minutes and your new settings will take effect immediately. If you would like to close your account, you can log-in and do so yourself or if unable you can contact us at hello@2to3days to request this; in this instance, it might take a few days to expedite your request
We are committed to ensuring that our recruitment processes are aligned with our approach to equal opportunities. Some of the data we may (in appropriate circumstances and in accordance with local law and requirements) request from you (and which you would provide at your discretion) comes under the umbrella of “diversity information”. This could be information about your ethnic background, gender, disability, age, sexual orientation, religion or other similar beliefs, and/or social-economic background. We may also disclose this as anonymised or generalised data, on a verbal or written basis, as part of general statistics within our sales or research process, to Clients where this is contractually required or the Client specifically requests such information to enable them to comply with their own employment processes.
Please note that in accordance with our statutory obligations we also have a legitimate interest to process your data and may share that data in connection with crime detection, tax collection or actual or anticipated litigation.
Client data
We use Client information for:
- Recruitment activities;
- Marketing activities; and
- To help us to establish, exercise or defend legal claims.
Unless you have stated clearly that you do not wish us to contact you on the website, 2to3days will also market our wider range of services to you, where we believe such marketing is relevant to you and in your legitimate interests to do so. If you are not happy about this, you have the right to opt out of receiving marketing materials from us and can find out more about how to do so by contacting 2to3days in writing either at [email protected].
Again, if you are unhappy at any time with the way we use your data, then you have the right to withdraw your consent at any time. Please contact us at the following address: [email protected]
Special Category Data
In addition to “diversity information” that we may need to collect, there may also be a need to collect other sensitive personal data about you, such as health-related information, religious affiliation, or details of any criminal convictions. This information is what is called ‘sensitive’ personal information, or Special Category Data, and therefore we need to obtain your explicit consent before we can use it. We’ll ask for your consent by offering you an opt-in and any information provided to us is on a completely voluntary basis, which means that you must explicitly and clearly tell us that you agree to us collecting and using this information. We will use your particularly sensitive personal information in the following ways:
- We will use information about your disability status to consider whether we need to provide appropriate adjustments during the recruitment process, for example whether adjustments need to be made to your interviewing or application process.
- We will use anonymised information (i.e. with your personal identity removed) about your race or nationality or ethnic origin, religious, philosophical or moral beliefs, or sexual orientation, or mental (neurodiversity) and physical disability to ensure meaningful equal opportunity monitoring and reporting.
We will always ask for your consent when collecting and using any Special Category Data. In addition, when we process such data, we will:
- Systematically conduct a Data Processing Impact Assessment for any processing that is likely to be high risk;
- Keep a record of our processing activities in an anonymised form that relate to Special Category Data for a period of 6 years; and
- Erase all Special Category Data after 3 months, post recruitment and; store securely with restricted access.
You may at any time request the restriction of processing of your “sensitive” personal information. This enables you to ask us to suspend the processing of personal information about you, for example if you want us to establish its accuracy or the reason for processing it.
Promotional offers from us
We may use your Identity, Contact, Technical, Usage and Profile 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 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.
Change of purpose
We will only use your personal data for the purposes for which we collected it. However, if such purposes change over time or we would like to use such data for a new purpose which we did not originally anticipate, we will only go ahead if:
- the new purpose is compatible with the original purpose;
- we get your specific consent for the new purpose; or
- we can provide clear evidence of a legal provision requiring or allowing the new processing in the public interest – for example, a new function for a public authority.
If our new purpose is compatible, we do not require a new lawful basis for the further processing. However, where we have originally collected the data on the basis of consent, we will use all reasonable endeavours to obtain fresh consent to ensure such new processing is fair and lawful. 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.
- Internal Third Parties as set out in the Glossary.
- External Third Parties as set out in the Glossary.
- Specific third parties listed in the table Purposes for which we will use your personal data above.
- 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.
Third Party Processors: Our carefully selected partners and service providers may process personal information about you on our behalf as described below.
Digital Marketing Service Providers
We periodically appoint digital marketing agents to conduct marketing activity on our behalf, such activity may result in the compliant processing of personal information. Our appointed data processors include:
(i)Prospect Global Ltd (trading as Sopro) Reg. UK Co. 09648733. You can contact Sopro and view their privacy policy here: http://sopro.io. Sopro are registered with the ICO Reg: ZA346877 their Data Protection Officer can be emailed at: [email protected].
6. International transfers
Many of our external third parties are based outside the UK so their processing of your personal data will involve a transfer of data outside the UK. It may also be processed by staff operating outside the EU who work for us or for one of our suppliers. If your personal data is transferred to, stored at, or otherwise processed in a country or territory outside the EU, and that country or territory has not been recognised as providing an adequate level of data protection, we will put in place additional safeguards to protect your personal data, based on standard contractual clauses.
Please contact us if you want further information on the specific mechanism used by us when transferring your personal data out of the UK.
7. Data security
Unfortunately, the transmission of information via the internet is not completely secure. Although we will take reasonable steps to protect your personal data, we cannot guarantee the security of your data transmitted to our site; any transmission is at your own risk.
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 request that our third-party contractors and site service providers follow similar standards of security and 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.
In some circumstances you can ask us to delete your data: see your legal rights below for further information.
In some circumstances we will anonymise your personal data (so that it can no longer be associated with you) for research or statistical purposes, in which case we may use this information indefinitely without further notice to you.
9. Your legal rights
Under certain circumstances, you have rights under data protection laws in relation to your personal data. Please click on the links below to find out more about these rights:
- Request access to your personal data.
- Request correction of your personal data.
- Request erasure of your personal data.
- Object to processing of your personal data.
- Request restriction of processing your personal data.
- Request transfer of your personal data.
- Right to withdraw your consent. Please contact us for more information.
If you wish to exercise any of the rights set out above, please contact us at [email protected].
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 if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.
10. Glossary
LAWFUL BASIS
Consent means when you freely provide a specific, informed and unambiguous indication of your wishes through a written statement or clear affirmative action, inter alia, to being contacted by our marketing teams, or being asked to participate in a market research project which would be collected on our behalf by us or our third-party recruiters.
Legitimate Interest means the interest of our business in conducting and managing our business to enable us to give you the best service/product 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.
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 US who provide IT and system administration services.
- Professional advisers including lawyers, bankers, auditors, and insurers who provide consultancy, banking, legal, insurance and accounting services.
- HM Revenue & Customs, regulators and other authorities based in the United Kingdom who require reporting of processing activities in certain circumstance].
- Market Research qualitative and quantitative processors, Vimeo, , and Zoom, WeTransfer and Mailchimp.
YOUR LEGAL RIGHTS
You have the right to:
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.
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.
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.
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.
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.
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.
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.