Privacy Policy

Last updated: 06/05/2023

Dnevo Partners respects your privacy and is committed to protecting your personal data. This privacy notice 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.

1. Important Information and Who We Are

1.1 Purpose of this privacy notice

This privacy notice aims to give you information on how Dnevo Partners collects and processes your personal data through your use of this website, telephone and email including any data you may provide through this website.

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 notice together with any other privacy notice or fair processing notice 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 notice supplements the other notices and is not intended to override them.

1.2 Controller

Dnevo Partners Limited is the controller and responsible for your personal data (collectively referred to as “Dnevo Partners”, “we”, “us” or “our” in this privacy notice).

We have appointed a Data Privacy Manager who is responsible for overseeing questions in relation to this privacy notice. If you have any questions about this privacy notice, including any requests to exercise your legal rights, please contact the Data Privacy Manager using the details set out below.

1.3 Changes to the privacy notice and your duty to inform us of changes

This version was last updated on 06/05/2023 and historic versions can be obtained by contacting us.

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.

1.4 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 notice 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, maiden name, last name, marital status, title, date of birth and gender
• Contact Data includes address, email address and telephone numbers
• Transaction Data includes details of job applications you have made through us and surveys you have participated in
• 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
• Marketing and Communications Data includes your preferences in receiving marketing from us and third parties and your communication preferences
• Special Categories Data includes health and criminal convictions and offences

We may also contact you to obtain further personal data if this is required for job applications and we will process it in accordance with this privacy policy. If you provide additional personal data in your job application we will also process this in accordance with this privacy policy.

We may also collect, use and share Aggregated Data such as statistical or demographic data for any purpose. Aggregated Data may be derived from your personal data but is not considered personal data in law as this data does not directly or indirectly reveal your identity. 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 notice.

2.1 If you fail to provide personal data

Where we need to collect personal data by law or to provide our services and you fail to provide that data when requested, we may not be able to provide you with these services. In this case, we may have to suspend or stop the provision of our services 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 and Special Categories data by filling in forms or by corresponding with us by post, phone, email or otherwise. This includes personal data you provide when you:

• Apply for jobs
• Ask us to contact you through our website
• Subscribe to our service or publications
• Request marketing to be sent to you
• Give us some feedback

Automated technologies or interactions. As you interact with our website, we may automatically collect Technical and Usage 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 and Usage Data about you if you visit other websites employing our cookies.

Third parties or publicly available sources. We may receive personal data about you from various third parties as set out below:

• Technical and Usage Data from providers such as Google based outside the EU
• Identity, Contact, Special Categories and Marketing and Communications Data from affiliate companies such as payroll service providers, recruitment agencies and employment businesses
• Identity and Contact Data from publicly available sources such as recruitment websites

4. How We Use Your Personal Data

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 provide you with the services offered on our website
• 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

Generally we do not rely on consent as a legal basis for processing your personal data other than in relation to sending third party direct marketing communications to you via email or text message. You have the right to withdraw consent to marketing at any time by contacting us.

4.2 Purposes for which we will use your personal data

4.3 Marketing

We strive to provide you with choices regarding certain personal data uses, particularly around marketing and advertising. You can opt out of marketing communications from us by contacting us at any time.

4.4 Promotional offers from us

We may use your Identity, Contact, Transaction, Technical, and Usage 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 communications may be relevant for you (we call this marketing). You will receive marketing communications from us if you have requested information from us or applied for a role through us and, in each case, you have not opted out of receiving that marketing.

4.5 Third-party marketing

We will get your express opt-in consent before we share your personal data with any other company for marketing purposes.

4.6 Opting out

You can ask us or third parties to stop sending you marketing messages at any time by following the opt-out links on any marketing message sent to you or by contacting us at any time. Where you opt out of receiving these marketing messages, this will not apply to personal data provided to us as a result of a job application.

4.7 Cookies

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 our website and also allows us to improve our site. A cookie is a small file of letters and numbers that we store on your browser or the hard drive of your computer if you agree.

You can set your browser to refuse all or some browser cookies, or to alert you when websites set or access cookies. Please note that if you disable or refuse cookies some parts of this website may become inaccessible or not function properly.

We use the following types of cookies:

• Strictly necessary cookies – required for the operation of our website
• Analytical/performance cookies – allow us to recognise and count the number of visitors and see how visitors move around our website
• Functionality cookies – used to recognise you when you return to our website
• Targeting cookies – record your visit to our website, the pages you have visited and the links you have followed

5. Disclosures of Your Personal Data

We may have to share your personal data with third parties for the purposes set out in the table in paragraph 4 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 notice.

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.

6. International Transfers

Many of our external third parties are based outside the European Economic Area (EEA) so their processing of your personal data will involve a transfer of data outside the EEA. Where we use providers based in the US, we may transfer data to them if they are part of the Privacy Shield which requires them to provide similar protection to personal data shared between Europe and the US. Please contact us if you want further information on the specific mechanism used by us when transferring your personal data out of the EEA.

7. Data Security

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 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

We will only retain your personal data for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements.

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 requirements.

In some circumstances you can ask us to delete your data. You should be aware that we will retain some of your data should you ask us to remove you from our mailing list in order to ensure that we do not contact you again.

In some circumstances we may 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

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.

Under certain circumstances, you have rights under data protection laws in relation to your personal data:

• Request correction of the personal data that we hold about you
• Request erasure of your personal data
• Object to processing of your personal data
• Request restriction of processing of your personal data
• Request the transfer of your personal data to you or to a third party
• Withdraw consent at any time where we are relying on consent to process your personal data

If you wish to exercise any of the rights set out above, please contact us.

9.7 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 may refuse to comply with your request in these circumstances.

9.8 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.

9.9 Time limit to respond

We try to respond to all legitimate requests within one month. Occasionally it may 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

Legitimate Interest means the interest of our business in conducting and managing our business to enable us to give you the best service 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.

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 or regulatory obligation means processing your personal data where it is necessary for compliance with a legal or regulatory obligation that we are subject to.

Third parties

• Service providers acting as processors based in the USA who provide IT, cloud storage, mailing and system administration services
• Companies and organisations advertising vacancies
• Affiliate companies such as payroll service providers, employment businesses and recruitment agencies
• Professional advisers acting as processors or joint controllers including lawyers, bankers, auditors and insurers based in the UK who provide consultancy, banking, legal, insurance and accounting services
• HM Revenue and Customs, regulators and other authorities acting as processors or joint controllers based in the United Kingdom who require reporting of processing activities in certain circumstances