Privacy Policy - Airswift

DATA PROTECTION AND PRIVACY POLICY
AIRSWIFT – DATA PROTECTION AND PRIVACY POLICY

JANUARY 2016

BACKGROUND:
This Policy applies as between you, the User of this Website and Airswift the owner and provider of this Website. This Policy applies to our use of any and all Data collected by us in relation to your use of the Website.

1.Definitions and Interpretation
In this Policy terms defined in the Website Terms and Conditions shall have the same meanings and the following terms shall have the following meanings:

“Data”
means collectively all information that you submit to Airswift via the Website. This definition shall, where applicable, incorporate the definitions provided in the Data Protection Act 1998 (the Act);

“Cookie”
means a small text file placed on your computer by this Website when you visit certain parts of the Website and/or when you use certain features of the Website. Details of the cookies used by this Website are set out in Clause 12;

“UK and EU Cookie Law”
means the Privacy and Electronic Communications (EC Directive) Regulations 2003 as amended by the Privacy and Electronic Communications (EC Directive) (Amendment) Regulations 2011;

“Website Terms and Conditions”
means the terms and conditions of this Website which are available at Terms and Conditions.

2. Scope of this Policy
This Policy applies only to the actions of Airswift and Users with respect to this Website or where a User has otherwise provided any Data to Airswift by other means. It does not extend however to any websites that can be accessed from this Website including, but not limited to, any links we may provide to social media websites.

3. Data Collected and Use of Information
Without limitation, any of the following Data may be collected by this Website from time to time (and will frequently be collected by your submitting to us a copy of your CV):

3.1 personal data as defined in the Act;
3.2 sensitive personal data as defined in the Act;

4. Our Use of Data
4.1 Unless we are obliged or permitted by law to do so, and subject to the remainder of this Clause 4 and Clause 5, your Data will not be disclosed to third parties. This does not include our affiliates and / or other companies within our group.
4.2 All personal Data is stored securely in accordance with the principles of the Act. For more details on security see Clause 11 below.
4.3 Any or all of the above Data may be used by us from time to time in order to provide you with the best possible service. Specifically, Data may be stored, processed, used and disclosed by us for the following reasons and in the following ways:
a) to provide our recruitment and placement services to you and to facilitate the recruitment and placement processes;
b) to assess data about you against vacancies which we judge may be suitable for you;
c) to send your information to clients in order to seek a placement or employment or to assess your eligibility for a placement or employment;
d) to enable you to submit your CV online for placements or employment;
e) to answer your questions and enquiries;
f) to third parties where we have retained them to provide services that you or our client have requested, such as references, qualifications and criminal reference checking services, verification of the details you have provided from third party sources, psychometric evaluation or skill test;
g) to third parties who perform functions on our behalf and who also provide services to us, such as professional advisors and outsourcing partners, including business development advisers as well as IT consultants carrying out testing and development work on our business technology systems. These third parties comply with similar undertakings of privacy and confidentiality as Airswift; and
h) to regulatory or law enforcement agencies if we believe in good faith that we are required by law to disclose it in connection with the detection of crime, the collection of taxes or duties, in order to comply with any applicable law or order of a court of competent jurisdiction, or in connection with legal proceedings.

4.4 From time to time we may seek your consent to process, use or disclose your information for any other purpose not listed above. We may also pass your information to, or allow access to such information to other companies in our group, whose locations can be found at https://www.airswift.com in order that they may use your personal information in the same way as we process, use and disclose your information as described above.

5. Third Party Services

5.1 Airswift may, from time to time, employ the services of other parties for dealing with matters that may include, but are not limited to, payment and visa processing, relocation services, search engine facilities, advertising and marketing. The providers of such services have access to certain personal Data provided by Users of this Website.

5.2 Any Data used by such parties is used only to the extent required by them to perform the services that Airswift requests. Any use for other purposes is strictly prohibited. Furthermore, any Data that is processed by third parties shall be processed within the terms of this Policy and in accordance with the Act.

6. Links to Other Websites
This Website may, from time to time, provide links to other websites. Airswift has no control over such websites and is in no way responsible for the content thereof. This Policy does not extend to your use of such websites. Users are advised to read the privacy policy or statement of other websites prior to using them.

7. Controlling Use of Your Data

7.1 Wherever you are required to submit Data, you will be given options to restrict our use of that Data. This may include the following:
7.1.1 use of Data for direct marketing purposes; and
7.1.2 sharing Data with third parties.

8. Your Right to Withhold Information

8.1 You may access certain areas of the Website without providing any Data at all.
8.2 You may restrict your internet browser’s use of Cookies. For more information see Clause 11.

9. Use of Your Data
As highlighted above, the personal information that you provide to us (including sensitive personal information) may be accessible by Airswift, its other group companies, its clients, and the third parties specified above. Some of these group companies, clients and third parties are located outside of the European Economic Area. Accordingly your personal information will be sent to or be capable of being accessed from outside the European Economic Area. When we transfer your personal information outside the European Economic Area we will take steps with the aim of ensuring that your privacy rights continue to be protected as outlined in this Policy.

10. Accessing Your Own Data
You may request us to confirm what information we hold about you at any time and may request us to modify, update or delete such information. We may ask you to verify your identity and for more information about your request. We also have the right to charge an administrative fee for this service. Where we are legally permitted to do so, we may refuse your request and will give you reasons for doing so. We will seek to act on your request in the timescale required by applicable data protection laws. If you wish to contact us with respect to the above matters please email us at contactus@airswift.com.

11. Security
Data security is of great importance to Airswift and to protect your Data we have put in place suitable physical, electronic and managerial procedures to safeguard and secure Data collected when you upload your CV and any personal data via this Website or by other means.

12. Cookies

12.1 This Website uses analytics services provided by Google Analytics a web analytics service provided by Google, Inc. (Google).

12.2 Google Analytics uses “cookies”, which are text files placed on your computer, to help the Website analyse how users use the site. The information generated by the cookie about your use of the Website (including your IP address) will be transmitted to and stored by Google on servers in the United States. Google will use this information for the purpose of evaluating your use of the Website, compiling reports on website activity for website operators and providing other services relating to website activity and internet usage. Google may also transfer this information to third parties where required to do so by law, or where such third parties process the information on Google’s behalf. Google will not associate your IP address with any other data held by Google. You may refuse the use of cookies by selecting the appropriate settings on your browser, however please note that if you do this you may not be able to use the full functionality of the Website. By using the Website, you consent to the processing of data about you by Google in the manner and for the purposes set out above.

12.3 You can choose to enable or disable Cookies in your internet browser. Most internet browsers also enable you to choose whether you wish to disable all cookies or only third party cookies. By default, most internet browsers accept Cookies but this can be changed. For further details, please consult the help menu in your internet browser.

12.4 You can choose to delete Cookies at any time however you may lose any information that enables you to access the Website more quickly and efficiently including, but not limited to, personalisation settings.

12.5 It is recommended that you ensure that your internet browser is up-to-date and that you consult the help and guidance provided by the developer of your internet browser if you are unsure about adjusting your privacy settings.

13. Changes to this Policy

13.1 By submitting any personal information to Airswift (including the uploading of any CV on the Website), you are deemed to accept the terms and conditions of this Policy in respect of the processing and use of the information you provide.

13.2 Airswift reserves the right to change this Policy as we may deem necessary from time to time or as may be required by law. Any changes will be immediately posted on the Website and you are deemed to have accepted the terms of the Policy on your first use of the Website following the alterations.