PRIVACY POLICY
This is an important notice regarding your privacy and the way in which Contrarian Investments Ltd (referred to as “we”, “our” or “us” in this policy) collects and makes use of your personal data. We want to be open and transparent with you, and therefore encourage you to contact us if you have any questions about this policy or the ways in which we use your personal data.
This policy applies to individuals outside of our organisation, for example, applicants for vacancies, customers, employees of our clients and suppliers, and the general public. We take our privacy responsibilities seriously and are committed to protecting and respecting your privacy.
This policy sets out the basis on which any personal data we collect from you, or that you provide to us, will be processed by us. 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 applicable privacy legislation, the data controller is Contrarian Investments Ltd of Springfield, The Hill, Winchmore Hill, Buckinghamshire HP7 0NY. Our company registration number is 12126091.
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Questions regarding this policy should be directed to our Data Protection Compliance Manager. The Data Protection Compliance Manager is responsible for ensuring compliance with relevant data protection legislation and with this policy. That post can be contacted using contact us section of our website. Any questions about the operation of this policy or any concerns that the policy has not been followed should be referred in the first instance to the Data Protection Compliance Manager.
What information do we hold about you?
We may collect, store and use personal data about you (referred to throughout this privacy policy as personal information):
Applicants & freelancers
Personal contact details such as the name, title, address, telephone number and e-mail address;
Recruitment information (including, for example, your driving licence, passport or visa information and other personal information included in an application form, CV or cover letter as part of your application for employment with us);
Personal information provided to us by our recruitment partners in relation to your application for employment with us;
Other personal information gathered during your application process.
Bank account details
Employees of our clients and suppliers
Contact details such as your name, title, business telephone number and business e-mail address.
Information you provide or we collect during our interactions with you or your employer, such as how long we have done business with you or how long you have worked at your company.
Customers
Personal details such as your name, title, personal telephone and e-mail address and your postal address.
Generally
Any personal information you provide to us during your interactions with us.
Information gathered by cookies used on our website. Our website uses cookies to distinguish you from other users of our website. This helps us to provide you with a good experience when you browse and also allows us to improve the way our website works. For detailed information on the cookies we use and the purposes for which we use them please refer to our Cookie Policy.
Information provided to us by third party service providers we work with, for example, payment service or analytics provider
How long will we use your personal information and what is the legal ground we rely on for doing so?
We will only use your personal information when the law allows us to. When we use your personal information, we must have a legal ground for doing so. The following are (amongst others) the legal grounds by which we can use your personal information:
Where you have provided us with your consent for us to do so.
Where we need to perform the contract we have entered into with you or to take steps to enter into a contract with you.
Where we need to comply with a legal obligation to which we are subject.
Where it is in pursuit of our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests.
More specifically, we will use your personal information in the following circumstances:
Applicants & freelancers:
To evaluate and progress your application for employment with us – to perform the contract with you or to take steps to enter into a contract with you, and in pursuit of our legitimate interests to verify your suitability for our vacancies.
To keep a record of your application – in pursuit of our legitimate interests in the event we wish to offer to place you in another role within our organisation.
To carry out right to work checks – to comply with a legal obligation to which we are subject.
To pay you – to perform the contract with you
Employees of our clients and suppliers:
Your contact details – in pursuit of our legitimate interests to facilitate business between your organisation and ours.
Your contact details to provide you with further information on our products and services. This may include technical information and/or marketing information – in pursuit of our legitimate interests (keeping you informed about our products, services and business updates).
Customers
Your contact details to facilitate your transaction or proposed transaction with us – to perform the contract with you or to take steps to enter into a contract with you.
To manage your customer account – to perform the contract with you or to take steps to enter into a contract with you.
Your personal details and payment information to facilitate your transaction with us – to perform the contract with you.
Your personal details and payment information to identify and prevent fraud – in pursuit of our legitimate interests (to prevent fraud for you and for us).
Your personal details to provide you with our marketing contents – with your consent.
Generally:
To ensure our premises are kept secure – in pursuit of our legitimate interests (site security and evidence).
Health and safety purposes – to comply with a legal obligation.
To administer our website and for internal operations, including troubleshooting, data analysis, testing, research, statistical and survey purposes – in pursuit of our legitimate interests (to better understand how people interact with our website and solve any issues it may have).
To improve our website to ensure that content is presented in the most effective manner for you and your computer – in pursuit of our legitimate interests (to improve our content and your experience).
To transfer to third party service providers – in pursuit of our legitimate interests (outsourcing for effectiveness and efficiency).
To contact you if we wish to use your personal information for a purpose not set out in this policy – to comply with a legal obligation.
What happens if there is a change of purpose?
We will only use your personal information for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If we need to use your personal information for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so.
Which type of third parties might we share your personal information with?
We require third parties to respect the security of your personal information and to treat it in accordance with the law. For example, where we instruct third party service providers, we carry out due diligence on those providers to ensure they treat your personal information as seriously as we do.
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We may share your personal information with the following types of third parties:
Technical support providers, for example, assisting us with our website.
Recruitment partners assisting us with employment related matters, for example, recruitment agencies and job boards.
Professional advisers such as lawyers, accountants and business analysts.
Our commercial partners in order to fulfil your contract with us.
Providers which help us collate and organise information effectively and securely.
Third party software hosting companies which provide us with software solutions such as our customer relationship management system.
Providers assisting us with payment and fraud prevention solutions.
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How long will you use my personal information for?
We will only retain your personal information for as long as necessary to fulfil the purposes we collected it for.
We assess the appropriate retention period for different information based on the size, volume, nature and sensitivity of that information, the potential risk of harm to you from unauthorised use or disclosure of that information, the purposes for which we are using that information, applicable legal requirements for holding that information, and whether we can achieve those purpose(s) through other means.
Applicants & freelancers
Where your application for employment with us is successful, we will provide further information during the course of your employment as to how we use your personal information.
Where your application for employment with us is unsuccessful, we will keep your personal information for 12 months only.
Where you are a freelancer providing services to us, we will hold your information for as long as you continue providing services to us and thereafter in accordance with our legal obligations.
Employees of our clients and suppliers
Where we have collected your personal information during the course of your and our organisations doing business, we will keep your information for as long as this business carries on, or for as long as we have a commercial interest in holding your personal information, for example, with a view to doing business in the future.
Where you use our website and one of our cookies are activated, that cookie will operate for the duration set out in our Cookie Policy.
Customers
Where we have collected your personal information as a result of you requesting Contrarian Investments Ltd services, we will keep your personal information until you have requested it be deleted from our account, or it has been inactive and archived for 6 years.
Where we store your personal information
Electronic versions of your personal information are stored on the servers of our website hosting company which are currently located around the world. As they are able to change the location of the storage we use we cannot commit to your data being kept in any one location. We have taken steps to ensure that they respect your personal information and treat it in accordance with the law.
Where we use third party service providers to assist us, your personal information may also be stored in accordance with their practices and procedures. We require third parties to respect your personal information and to treat it in accordance with the law.
Rights of access, correction, erasure and restriction
Your rights in connection with your personal information
Under certain circumstances, by law you have the right to:
Request access to your personal information (commonly known as a “data subject access request”). This enables you to receive a copy of the personal information we hold about you and to check that we are lawfully processing it.
Request correction of the personal information that we hold about you. This enables you to have any incomplete or inaccurate information we hold about you corrected.
Request the erasure of your personal information. This enables you to ask us to delete or remove personal information where there is no good reason for us continuing to process it. You also have the right to ask us to stop processing personal information where we are relying on a legitimate interest and there is something about your particular situation which makes you want to object to processing on this ground.
Request the restriction of processing of your personal information. This enables you to ask us to suspend the processing of your personal information, for example if you want us to establish its accuracy or the reason for processing it.
Request the transfer of your personal information to another party.
If you want to review, verify, correct or request erasure of your personal information, object to the processing of your personal information, or request that we transfer a copy of your personal information to another party, please contact our Data Protection Compliance Manager in writing using the contact details set out at the beginning of this privacy policy.
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No fee usually required
You will not have to pay a fee to access your personal information (or to exercise any of the other rights). However, we may charge a reasonable fee if your request for access is clearly unfounded or excessive.
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Alternatively, we may refuse to comply with the request in such 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 the information (or to exercise any of your other rights). This is a security measure to ensure that personal information is not disclosed to another person who has no right to receive it.
Marketing
Where we are providing you with marketing information, you can also change your marketing preferences by using the unsubscribe button at the bottom of our marketing e-mails to you.
What happens if you fail to provide personal information?
If you fail to provide certain information when requested, we may not be able to perform the contract we have entered into with you (such as providing you with our products or services), or we may be prevented from complying with our legal obligations (such as to ensure the health and safety of visitors to our offices).
Right to complain
You have a right to make a complaint if you wish to do so. The organisation with oversight of our processing is the Information Commissioner’s Office which can be contacted in writing at Information Commissioner’s Office, Wycliffe House, Water Lane, Wilmslow, Cheshire, SK9 5AF, by telephone (0303 123 1113) or by e-mail (casework@ico.org.uk).
Changes to this privacy notice
We may change, modify, add or remove portions of this privacy policy at any time, and any changes will become effective immediately.
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Any changes we make to our privacy policy will be posted on this page and, where appropriate, notified to you.
Cookie Policy
1. Information about our use of cookies
1.1 Our site uses cookies to distinguish you from other users of our site. This helps us to provide you with a good experience when you browse our site and also allows us to improve our site. When you use our site, a banner will be displayed asking you for your consent to our use of cookies.
2. What are cookies?
2.1 A cookie is a small file of letters and numbers that is saved onto your computer, smartphone, tablet or other device when you visit our site.
2.2 Cookies store small pieces of information. For example, one type of cookie will remember that you have visited our site before.
2.3 Cookies help us to improve your visit and experience when browsing our site by, for example, storing certain information so you don’t have to re-enter it on subsequent visits.
2.4 Cookies also assist us in tracking which pages of the website you have visited. We will not store credit card details in cookies we create.
2.5 We use both persistent cookies (which stay with your computer and will work until their expiry date, unless detected by you beforehand) and session cookies (which expire when you close your browser).
3. We use the following cookies:
3.1 Analytical/ performance cookies
They allow us to recognise and count the number of visitors and to see how visitors move around our site when they are using it. This helps us to improve the way our site works, for example, by ensuring that users are finding what they are looking for easily.
3.2 Functionality cookies
These are used to recognise use when you return to our site. This enables us to personalise our content for you and remember your preferences.
3.3 Targeting cookies
These cookies record your visit to our site, the pages you have visited and the links you have followed. We will use this information to make our site and the advertising displayed on it more relevant to your interests. We may also share this information with third parties for this purpose.
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4. Your interaction with cookies
4.1 It is possible to disable and remove cookies from your computer or device by activating the setting on your browser that allows you to do so. You will need to know what browser you are using and what version you have.
4.2 You can refer to your browser’s help section or visit the www.aboutcookies.org/ website for further information and assistance with cookies.
4.3 Please be aware that if you use your browser settings to block or amend certain cookies, your browsing experience may change for the worse.