Manolete Partners PLC – Website Privacy Policy

Manolete Partners Plc is a data controller for the purpose of Data Protection Legislation (as defined below), having its registered office at 2-4 Packhorse Road, Gerrards Cross, Buckinghamshire, SL9 7QE.

In this Privacy Policy, we describe how we process the personal data of our employees, officers and directors, website (“Site“) users and any other relevant individual that we engage with in the ordinary course of business (“Business Personnel“).

Introduction
We are committed to protecting and respecting personal data and handling personal information in an open and transparent manner.

This policy (“Privacy Policy“) explains what information Manolete Partners collect, or that is provided to us, what we will use it for and with whom we share that information. The policy also sets out your rights and who you can contact for more information. Please read the following carefully to understand our views and practices regarding your personal data and how we will treat it.

In this Privacy Policy, your information is sometimes called “personal data”. We may also sometimes collectively refer to handling, collecting, protecting and storing your personal data as “processing” such personal data.

In this Privacy Policy the term “Data Protection Legislation” means the EU General Data Protection Regulation 2016/679; together with all other applicable legislation relating to privacy or data protection.

What personal information do we collect you and how do we use it?

Users of our website Business personnel Employees and potential employees
Contact information: name, email address and telephone number (or any telephone number used to call our offices)

Technical information: IP address, your browser type and language and information about your visit to our website, including the full Uniform Resource Locators (URL), clickstream to, through and from our site (including date and time), 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

Insolvency practitioners: name, contact information

Supplier information: contact name and email address

Information in relation to insolvent companies: director information

Contact information: home address and contact details (including your mobile telephone number)

Recruitment: recruitment records including your CV, application form and any references received, information about your professional qualifications and education

Family: date of birth, marital/civil partnership status, details of dependents, next of kin and emergency contacts

Financial: pay records, bank and payment details, and national insurance number

Absence: holiday, sickness and other absence records

Performance: performance records, details of any complaints or concerns raised by you

Health: records and information relating to benefits such as pension and health insurance

Monitoring: information related to your use of email, the internet, and our telephone system. Images of you that are captured on CCTV systems that are in operation inside of and outside of our offices (whether operated by the Company, on our behalf or information collected in relation to use of your access card, fob or other token; and any other information gathering methods employed by the Company from time to time

Special categories of data:
Some of the personal data that the Company holds (such as details relating to physical or mental health or condition, ethnicity, criminal or alleged criminal offences) may be deemed special categories of personal data for the purposes of Data Protection Legislation. The Company may seek your consent to process special categories of personal data, however certain special categories of personal data (such as that relating to alleged offences) may be necessary for us to use to comply with our legal obligations.

How we collect information about you

Users of our website Business personnel Employees and potential employees
● information you give to us through the use of our website ● in the course of providing our services to you

● where you have provided information to us

● information that is received from you or which we gather about you prior to or during the course of your employment or engagement with us

How we use your information

The information we collect and process will be used:

Users of our website Business personnel Employees and potential employees
● for collecting user information to provide you with a safe, smooth, efficient, and customised experience

● to ensure that the content on our website is presented in the most effective manner

● to administer our site and for internal operations, including troubleshooting, data analysis, testing, research, statistical and survey purposes;

as part of our efforts to keep our site 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 consider your application where you have applied for a position with us

● to take instructions from you

● to communicate with you

● to confirm your or a third party’s identity and carry out background checks, including as part of our checks in relation to anti-money laundering, compliance screening and to prevent fraud and other crimes

● to follow up with you after you request information to see if we can provide any further assistance

● in order to perform our obligations under your employment agreement and administer your employment at the Company

● in order to monitor internet and email use

● in order to monitor sickness absences as part of our general business operations and which will usually be limited to the information provided on sickness absence forms or otherwise. If you fail to provide us with this information, or you object to us processing such information we may still be able to process your data where it is necessary for us to comply with our legal obligations

● in order to meet our legal, regulatory and professional obligations

● in order for incident management planning

● in order to conduct performance reviews

● in order to pursue the legitimate interests of the Company including assisting the Company in upholding or enforcing its professional, legal and regulatory obligations, working practices, standards, policies and procedures (including any sickness policy or working time policy) investigating acts or defaults (or alleged or suspected acts or defaults) in which you may have been involved to prevent and detect crime or fraud, and for security, management forecasting or planning and negotiations

● in connection with any merger, sale or acquisition of a company or business in which the Company or any other member of the Group is involved or any transfer or any business in which you perform your duties

● in order to deal with any problems or concerns you may have

● in order to provide references on request to prospective employers

● in connection with occupational health, maternity leave, family emergency leave, paternity leave or parental leave

● for disciplinary action purposes or vetting (where necessary)

Legal grounds for using your personal information

The law permits us to process your personal data in the way that it does because the processing is:

  • necessary for the purposes of the legitimate interests that we pursue, which are to run and administer our business, to discharge our legal obligations, to store and disclose information where necessary, to evaluate, develop and improve our services, to protect our business interests and to prevent fraud;
  • to ensure that complaints are investigated;
  • necessary for the performance of a contract; and/or
  • necessary in order to comply with a legal obligation to which we are subject.

To the extent that we process any special categories of data relating to you for any of the purposes outlined above, we will do so because either: (i) you have given us your explicit consent to process that personal data; (ii) you have made the personal data manifestly public; or (iii) the processing is necessary for the establishment, exercise or defence of legal claims.

Sharing your information

Users of our website Business personnel Employees and potential employees
● analytics and search engine providers that may assist us in the improvement and optimisation of our Site

● third parties who support our information technology or handle mailings or events on our behalf

● third party companies, agents, contractors, service providers or related companies (including payment processors) if this is necessary to provide you with our services, respond to your inquiries or for any other related purposes

● other companies we have instructed to provide services for us

● third parties who support our information technology or handle mailings on our behalf

● courts, law enforcement agencies, other governmental agencies or third parties if we are required by law to do so or in performance of our legal obligations, or in other limited circumstances (for example if required by a court order or regulatory authority, or if we believe that such action is necessary to protect our business interests, our technology assets or the rights, property or personal safety of any person)

● other third parties for those purposes that may be reasonably ascertained from the circumstances in which the information was submitted

● other business entities should we plan to merge with or be acquired by that business entity, or if we undergo a re-organisation with that entity

●any successor in interest, in the event of a liquidation or administration of Manolete Partners

● employee personal data is not usually disclosed to anybody outside the Company

● courts, law enforcement agencies, other governmental agencies or third parties if we are required by law to do so or in performance of our legal obligations, or in other limited circumstances (for example if required by a court order or regulatory authority, our business interests, technology assets or the rights, property or personal safety of any person)

Links to Other Sites
The Site contains links to other websites. Manolete Partners is not responsible for the privacy policies of third party websites to which links are provided. You should check the privacy policies on these sites before providing any personal information. This privacy statement relates only to information contained on, or gathered via, the Site.

How we protect your information
We take your data security seriously and take all reasonable steps to keep your information secure and confidential including by monitoring appropriate technical security measures.

Once we have received your information we will ensure that the collection and use of your information is in accordance with Data Protection Legislation.

How long we keep your information
We will only keep personal data and other information for as long as it is required either to perform our obligations or to comply with any legal obligations to which we are subject. This will involve us regularly reviewing our files to check that information is accurate and up-to-date and still required.

In other cases we will have a legal obligation to keep certain documents for a specific period of time, tax records must be kept for a minimum of six years after the end of the relevant tax year and records of working hours must be kept for a minimum of two years.

Transferring data outside of the EEA
Data that you submit via our website is sent to and stored on secure servers owned by or operated for us. Your personal data may be transferred to, and stored at, a destination outside the European Economic Area (“EEA“) to a country not deemed to provide adequate protection of your information by the European Commission, and may also be processed by staff operating outside the EEA who work for us, or for one of our service providers, related companies, agents or contractors. Such transfers may be made in order to improve the Site or to assist in our security or fraud protection activities.

When we, or our permitted third parties, transfer your information outside the EEA, we or they will impose contractual obligations on the recipients of that data to protect your information to the standard required in the EEA. We or they may also require the recipient to subscribe to international frameworks intended to enable secure data sharing. We do not generally rely on your consent as the legal basis for transferring your personal data to outside the EEA, however where we feel it is necessary or appropriate we may seek to rely on your consent as the legal basis for such processing. Where we do, you may withdraw your consent at any time in the manner described below.

Your rights

At any time, you have the right:

  • to be informed about the processing of your personal data (i.e. for what purposes, what types, to what recipients it is disclosed, storage periods, any third party sources from it was obtained, confirmation of whether we undertake automated decision-making, including profiling, and the logic, significance and envisaged consequences);
  • to request access to or a copy of any personal data which we hold about you;
  • to rectification of your personal data, if you consider that it is inaccurate;
  • to ask us to delete your personal data, if you consider that we do not have the right to hold it;
  • to withdraw consent to our processing of your personal data (to the extent such processing is based on previously obtained consent);
  • to ask us to stop or start sending you marketing messages (e.g. our newsletter) at any time by using the below contact details;
  • to restrict processing of your personal data;
  • to data portability (moving some of your personal data elsewhere) in certain circumstances;
  • to object to your personal data being processed in certain circumstances; and
  • to not to be subject to a decision based on automated processing and to have safeguards put in place if you are being profiled based on your personal data.

Any request for access to or a copy of your personal data must be in writing and we will endeavour to respond within a reasonable period and in any event within one month in compliance with Data Protection Legislation. We will comply with our legal obligations as regards your rights as a data subject.

We will correct any incorrect or incomplete information and will stop processing your personal data, or erase it, where there is no legal reason for us to continue to hold or use that information.

We aim to ensure that the information we hold about you is accurate at all times. To assist us in ensuring that your information is up to date, do let us know if any of your personal details change.

Changes to this Privacy Policy
Any changes we make to our Privacy Policy in the future will be posted on this page of the Site and, where appropriate, notified to you by e-mail.

We would encourage users to check the Privacy Policy each time they use the Site. If our Privacy Policy changes in any way, we will place an updated version on this page. Regularly reviewing this page ensures that you are always aware of what information we collect, how we use it and under what circumstances, if any, we will share it with other parties.

Contacting us
Questions, comments and requests regarding this Privacy Policy are welcomed and should be addressed to Manolete Partners Plc, 21 Gloucester Place, London W1U 8HR. You may also use these contact details if you wish to make a complaint to us relating to your privacy.

If you have any concerns about our use of your information, you also have the right (as a UK resident) to make a complaint to the Information Commissioner’s Office, which regulates and supervises the use of personal data in the UK, via their helpline on 0303 123 1113.

Version: 28 November 2018