Foxden IT Ltd is committed to protecting and respecting your privacy.  This Privacy and Cookies Notice sets out the basis on which any personal data we collect from you, or that you provide to us, will be processed by us and the purpose for our collection of it.  Please read the following carefully to understand our views and practices regarding your personal data and how we will treat it.

For the purpose of the Data Protection Act 2018 (the Act) and the provisions of Regulation (EU) 2016/679 (the General Data Protection Regulation or GDPR), Foxden IT Ltd is the data controller of your personal information.

This Notice explains how we may collect and process personal data about:

• clients and      prospective clients
• visitors to      our Website and subscribers to our online services
• job and work      experience applicants and current employees

Depending on our relationship with you this notice may be supplemented with additional information relating to our use of your personal data included for example in our Terms of Business and Terms of Engagement letter (for clients) and our applicant form and employment contract (for job applicants and employees).

We may collect and process the personal information about you including information:

• that you      provide by filling in forms on our Website, posting material, requesting      further services or reporting a problem with our Website
• that you      provide when you use our professional services as a client
• received in correspondence      that you send to us
• provided to us      as part of a job or student placement application you make
• received      during certain calls to and from us (see under ‘Call Recording’ below)
• concerning      your visits to our Website (including but not limited to traffic data) and      the resources that you access

We may also collect information about you in other ways, for example:

• if you are a      customer of one of our clients, and we are undertaking services on our      client’s behalf
• if you have      any other dealings with one or more of our clients which are related to      services which we are providing to our client or on our client’s behalf
• indirectly,      through one of our people, a client or a third party
• if you are a      supplier of ours, from that supplier relationship
• from publicly      available sources, for example the electoral roll or Companies House
• from third      party data sources, including databases, where they have a legal basis for      providing information to us
• where you      attend events or functions that are organised or sponsored by us,      including where images of you are captured by photography or videography      during such events or functions

The way we process your personal data we collect as set out above varies depending on our relationship with you.  In each case the purposes for which we request the information will be clear from the context in which it is acquired. These include:

• providing our      services to you or an entity for which you work
• verifying your      identity
• keeping a      record of the services you have subscribed to and deliver services you may      have requested
• administration,      billing and record-keeping purposes
• communicating      with you by telephone, email, fax or post
• meeting our      legal, regulatory and contractual obligations arising from any our relationship      with you (for example under anti-money laundering legislation)
• providing and      improving customer service and support
• administering      our Website, enhancing operational capabilities and for internal      operations
• verifying or      enforcing compliance with this Notice and applicable laws
• to inform you      of legal developments that may affect you or to inform you of other      products, services or events which we think may be of interest to you      (unless you have opted out of receiving such marketing communications)

We will only disclose your personal information to another person or organisation where we:

• need to share      the information to provide a product or service you have requested
• need to send      the information to persons or organisations who engage us to conduct legal      services on their behalf, including where you are that third party’s      customer
• need to send      the information to persons or organisations that work on our behalf to      provide a product or service to you. Where such a person or organisation      does work on our behalf we will ensure that they are contractually      required to take appropriate technical and organisational measures to      protect your personal information against unauthorised or unlawful      processing and against accidental loss or destruction of, or damage to,      personal information and only use the information in order to provide a      product or service on our behalf
• are required      to disclose the information in order to comply with the law or the      requirements of a regulatory authority

Our use of your personal data as outlined above is subject to different legal bases for processing, including where necessary for:

• the purposes      of the performance of any contract we enter into with you or to take steps      at your request prior to entering into a contract with you
• our legitimate      interests, for example in providing services to an entity you work for,      managing and monitoring our website operation, preventing fraud and for      our business compliance purposes
• compliance      with our legal and regulatory responsibilities.

If you do not agree to provide your personal data to us we may not be able to provide you with services or process your application for other services or employment. Where our use of your data is not necessary for one of the purposes outlined above we may use it in a particular way with your consent (for example if you have registered to attend an event we are hosting or to receive updates). Where we ask for your consent you are free to refuse our use of your personal data for those purposes and you may withdraw your consent at any time by contacting us using the details set out below.  This shall not affect the lawfulness of any processing that was based on your consent before you withdrew it.

The personal information that we collect from you may be transferred to, and stored at, a destination outside the European Economic Area (EEA).  It may also be processed by staff operating outside the EEA who work for us or one of our suppliers or in circumstances where your instruction has international considerations and/or parties related to your matter are located overseas.  Before we transfer your personal data outside the EEA we will take all steps reasonably necessary to ensure that any such transfer is made securely and that there is adequate protection in place in order to protect your personal data, as required by the Act and Chapter V of the GDPR. Please contact us if you wish to obtain more information regarding relevant safeguards. By submitting your personal information, you agree to this transfer, storing or processing outside the EEA.

We will retain your personal information for a minimum of six years and so long as is reasonably necessary for the purpose for which it was obtained and in accordance with our legal obligations and follow our data destruction policy and processes thereafter.

This Notice only extends to our Website, which is owned and operated by Foxden IT Ltd and does not, therefore, extend to your use of, provision of information to and collection of information on any website not connected to Foxden IT Ltd to which you may link by using the hypertext links within our Website.

Your personal information is protected under data protection law and you have a number of rights (see below) which you can seek to exercise. Please contact us in writing, by email or telephone using the details shown under ‘Contact and Complaints’ below if you wish to do so, or if you have any queries in relation to your rights. Please note these rights do not apply in all circumstances.

Right of access – subject to certain exceptions, you have the right of access to your personal data that we hold.

Right to rectify your personal information – if you discover that the information we hold about you is inaccurate or incomplete, you have the right to have this information rectified (i.e. corrected).

Right to be forgotten – you may ask us to delete information we hold about you in certain circumstances. This right is not absolute and it may not be possible for us to delete the information we hold about you, for example, if we have an ongoing contractual relationship or are required to retain information to comply with our legal obligations.

Right to restriction of processing – in some cases you may have the right to have the processing of your personal information restricted. For example, where you contest the accuracy of your personal information, its use may be restricted until the accuracy is verified.

Right to object to processing – you may object to the processing of your personal information (including profiling) when it is based upon our legitimate interests. You may also object to the processing of your personal information for the purposes of direct marketing and for the purposes of statistical analysis.

Right to data portability – you have the right to receive, move, copy or transfer your personal information to another controller when we are processing your personal information based on consent or on a contract and the processing is carried out by automated means.

We may collect information about your computer, including where available your IP address, operating system and browser type, for system administration and to collect aggregate information for us to use.  This is statistical data about our users’ browsing actions and patterns, and does not identify any individual.

Cookies are small text files that are created and stored on your browser or the hard drive of your computer by websites that you visit. Cookies are often placed on your computer to enable the website to operate properly, to ‘remember’ who you are, and to monitor website traffic and usage.  Cookies are generally only visible to the website that serves them and not to other websites.

Most internet browsers accept cookies automatically. However, you can accept, delete or disable cookies through your browser if you wish. To learn more about controlling the placement of cookies through your browser settings, please review the options available in your internet browser’s ‘Help’ menu.

Unless strictly necessary for the functioning of the site or for the transmission of communications, we will only place cookies where you have previously provided your consent. If you do not provide your consent then you can still access and use our site, however certain functions or features may be disabled which could negatively affect your user experience.

Foxden IT Ltd sometimes advertises products, services and vacancies on third party websites such as LinkedIn. To enable us to target and monitor such advertising we use cookies from those third parties on our websites to tell us which pages you’ve clicked on and interacted with. Each third party website uses its own tracking cookies. These cookies are not under our control so if you are on any third party websites which carry advertisements or otherwise promote Foxden IT Ltd, you should check their cookie policies for details of how you can manage your cookie preferences. If you don’t want to be shown targeted advertising, some third party sites allow you to request not to see messages from specific advertisers.

Foxden IT Ltd takes great care to ensure the security of our Website and your personal information.  Only authorised personnel and contractors have access to your information.  We will keep your information secure by taking appropriate technical and organisational measures against unauthorised or unlawful processing, accidental loss, destruction and damage.

Unfortunately, the transmission of information via the internet is not completely secure.  Although we will do our best to protect your personal information we cannot guarantee the security of your personal information transmitted to our Website; any transmission is at your own risk.  Once we have received your information, we will use strict procedures and security features to try to prevent unauthorised access.

We may change this Notice at any time by amending this page.  You are expected to check this page from time to time to take notice of any changes we have made, as they are binding on you.  If we make any substantial changes in the way we use your personal information we will notify you by posting a prominent notice on our Website.

If you have any questions about how we treat your personal data and protect your privacy, or if you have any comments or wish to seek to exercise any of your rights as outlined above, to opt-out of receiving marketing communications from us or to complain about our use of your personal data, please contact us.

This website, www.foxden-it.com (our Website) is provided by Foxden IT Ltd, a limited company registered in England and Wales.

All rights reserved.  Design and content © Foxden IT Ltd 2020.

Last updated: 18 December 2020