These Terms and Conditions, together with any and all other documents referred to herein, set out the terms of use under which you may use 8LEGS (“Our Web App”). Please read these Terms and Conditions carefully and ensure that you understand them. You will be required to read and accept these Terms and Conditions when signing up for an Account and purchasing a Subscription. If you do not agree to comply with and be bound by these Terms and Conditions, you must stop using Our Web App immediately.

  1. Definitions and Interpretation

    1. In these Terms and Conditions, unless the context otherwise requires, the following expressions have the following meanings:
      "Account"Means an account required to access and use Our Web App, as detailed in Clause 4;
      "Content" means any and all text, images, audio, video, scripts, code, software, databases and any other form of information capable of being stored on a computer that appears on, or forms part of, Our Web App;
      "Contract" means the contract between Us and you for the purchase and sale of a Subscription to Our Web App, as explained in Clause 6;
      "Order"means your order for a Subscription;
      “Subscription Confirmation”means Our acceptance and confirmation of your Order;
      "Subscription" means a subscription to access Our Web App, purchased in accordance with these Terms and Conditions;
      "User"means a user of Our Web App;
      "User Content" means personal and/or company details and company website URL’s, email addresses, post codes and company names, created and/or uploaded by Users in or to Our Web App; and
      "We/Us/Our" means 8LEGS Technology Ltd, a limited company registered in England under company number 4938619, whose registered address is 3rd Floor, 5-10 Bury Street, London, EC3A 5AT, United Kingdom.
  2. Information About us

    Our Web App is owned and operated by 8LEGS Technology Ltd, a limited company registered in England under company number 4938619, whose registered address is 3rd Floor, 5-10 Bury Street, London, EC3A 5AT, United Kingdom. Our VAT number is 245 9568 63.
  3. Access and Changes to Our Web App

    1. Access to Our Web App requires a Subscription. Upon purchasing a Subscription, Our Web App will be available to you for the duration of that Subscription and any and all subsequent renewals.
    2. We may from time to time make changes to Our Web App:
      1. Minor changes may be required to make underlying technical alterations, for example, to fix an error or to address a security issue. We will inform you by email or by notification on our website support portal of any such changes (including, if applicable, anything that you need to do), however they will be unlikely to materially affect your use of Our Web App;
      2. Minor changes may be made to reflect changes in the law or other regulatory requirements. We will inform you by email or by notification on our website support portal of any such changes (including, if applicable, anything that you need to do), however they will be unlikely to materially affect your use of Our Web App; and
      3. As detailed in our website updates, information emails and support portal, we will continue to develop and improve our Web App over time, in some cases making significant changes to it. You will be kept fully informed of any and all such changes.
    3. We will always aim to ensure that Our Web App is available at all times. In certain limited cases, however, We may need to temporarily suspend availability to make certain changes outlined under sub-Clause 3.2. Unless We are responding to an emergency or an urgent issue, We will inform you in advance of any interruptions to the availability of Our Web App. If We need to suspend Our Web App for longer than 24 hours, We will add the corresponding time to the duration of your current Subscription period at no cost to you, rounded up to a full day in each case. If We need to suspend Our Web App for longer than 24 hours you may also have a right to cancel. Please refer to sub-Clause 8.4.5 for details.
  4. Accounts

    1. An Account is required to use Our Web App.
    2. You may not create an Account if you are utilising our Web App to re-sell the information provided by our service. We do not allow the use of our Web App by any 3rd party re-seller. We continually monitor the use of our Web App and will immediately close down any Account created which we deem to be in breach of our terms. No refund will be provided if these terms are breached.
    3. When creating an Account, the information you provide must be accurate and complete. If any of your information changes at a later date, it is your responsibility to ensure that your Account is kept up-to-date.
    4. We recommend that you choose a strong password for your Account, consisting of a combination of lowercase and uppercase letters, numbers, and symbols. It is your responsibility to keep your password safe. You must not share your Account with anyone else. If you believe your Account is being used without your permission, please contact Us immediately. We will not be liable for any unauthorised use of your Account.
    5. You must not use anyone else’s Account without the express permission of the User to whom the Account belongs. You must not use anyone else’s account if the account is not registered in your company name.
    6. Any personal information provided in your Account will be collected, used, and held in accordance with your rights and Our obligations under the Data Protection Act, as set out in Clause 21.
    7. If you wish to close and delete your Account, you may do so at any time by contacting us via our support portal or by email. Closing your Account will result in the removal of your information from Our system. If you have an active Subscription, your Account will remain active for the duration of the remainder of the Subscription period you are currently in. Closing your Account will cancel the auto-renewal of your Subscription, where applicable. Closing your Account will also remove any User Content that you have created or uploaded from Our system.
  5. Subscriptions, Pricing and Availability

    1. We make all reasonable efforts to ensure that all general descriptions of the services available from Us (specifically, Our Web App) correspond to the actual services that will be provided to you.
    2. All subscriptions are charged on a recurring monthly basis (unless otherwise stated) and you agree to have your debit/credit card debited each month. You will have available to you via your ‘My Account’ section on your portal, the ability to download your invoices which are added each month upon receipt of payment.
    3. Where appropriate, you may be required to select your required Subscription. Different types of Subscription provide access to different features in Our Web App. Please ensure that you select the appropriate Subscription when prompted.
    4. All pricing information is correct at the time of going online. We reserve the right to change prices and to add, alter, or remove special offers from time to time and as necessary. Changes will not affect Subscriptions that have already been purchased, but may affect renewals of Subscriptions.
    5. The pricing displayed does not include VAT and VAT will be added at the current at the checkout stage of the registration. VAT is only charged for UK customers and zero rate VAT is applied for European customers who hold a VAT registration number.
  6. Subscriptions – How Contracts Are Formed

    1. You will be guided through the Subscription process when you make a purchase. Before confirming a purchase, you will be given the opportunity to review your chosen Subscription and amend any errors in your Order. Please ensure that you check carefully before confirming your purchase.
    2. No part of Our Web App, website or any other material constitutes a contractual offer capable of acceptance. By purchasing a Subscription, you are making Us a contractual offer that We may, at Our sole discretion, accept. Our acceptance is indicated by Us sending you a Subscription Confirmation by email. Only once We have sent you a Subscription Confirmation will there be a legally binding contract between Us and you (“the Contract”).
    3. Subscription Confirmations contain the following information:
      1. Confirmation of your chosen Subscription including full details of the main characteristics and features of Our Web App available as part of that Subscription;
      2. Fully itemised pricing, including, where appropriate, taxes and other additional charges;
      3. Details of the duration of your Subscription including the start date and the end and/or renewal date;
    4. If We do not accept or cannot process your Subscription purchase for any reason, no payment will be taken under normal circumstances. If We have taken payment in such circumstances, the payment will be refunded to you as soon as possible and in any event within 5 working days.
    5. Subject to the cancellation provisions in Clause 8, once you have confirmed your Subscription purchase, your Subscription cannot be changed until the end or renewal date of that Subscription. Changes made to an auto-renewing Subscription will take effect when the Subscription is renewed.
    6. By purchasing a Subscription, you are expressly requesting that you wish access to Our Web App to be made available to you immediately. Please be aware that We do not offer any Subscriptions that do not begin immediately. For more details of cancellation, please refer to Clause 8.
  7. Payment

    1. Payment for Subscriptions will be due at the time of purchase. Your chosen payment method will be billed immediately upon confirmation of your Subscription.
    2. We accept all major credit and debit cards as methods of payment.
  8. Cancellation

    1. Subscriptions can be cancelled at any time, however, no refunds can be provided and you will continue to have access to Our Web App for the duration of the remainder of the Subscription period you are currently in. Cancelling a Subscription only prevents it from being auto-renewed.
    2. To cancel a Subscription for any reason, please inform us by email at support@8legs.com
    3. In certain limited circumstances where we deem that you are in breach of our terms We may cancel your Subscription and/or close your Account. If We take such action, you will be notified by email and we will provide an explanation for the cancellation and/or closure.
      1. If your Account is closed and your Subscription cancelled because you have breached these Terms and Conditions, you will not be entitled to a refund.
  9. Our Intellectual Property Rights and Licence

    1. We grant Users a limited, non-exclusive, revocable, worldwide, non-transferable licence to use Our Web App to collect job data displayed on company websites for business purposes, subject to these Terms and Conditions.
    2. Subject to the licence granted to Us under sub-Clause 12.3, Users retain the ownership of copyright and other intellectual property rights in their User Content (subject to any third party rights in that User Content and the terms of any licence under which you use such Content).
    3. All other Content included in Our Web App (including all user-facing material, and all underlying material such as code, software and databases) and the copyright and other intellectual property rights in that Content, unless specifically labelled otherwise, belongs to or has been licensed by Us. All Content is protected by applicable United Kingdom and international intellectual property laws and treaties.
    4. By accepting these Terms and Conditions, you hereby undertake:
      1. Not to copy, download or otherwise attempt to acquire any part of Our Web App;
      2. Not to disassemble, decompile or otherwise reverse engineer Our Web App;
      3. Not to allow or facilitate any use of Our Web App that would constitute a breach of these Terms and Conditions; and
      4. Not to embed or otherwise distribute Our Web App on any website, ftp server or similar.
  10. Links to Our Web App

    1. You may link to where Our Web App is hosted provided that:
      1. You do so in a fair and legal manner;
      2. You do not do so in a manner that suggests any form of association, endorsement or approval on Our part where none exists;
      3. You do not use any of Our logos or trade marks (or any others displayed on Our Web App) without Our express written permission; and
      4. You do not do so in a way that is calculated to damage Our reputation or to take unfair advantage of it.
    2. You may not link to any page other than the homepage of Our Web App www.8legs.com. Deep-linking to other parts of Our Web App requires Our express written permission.
    3. You may not link to Our Web App from any other website the content of which contains material that:
      1. Is sexually explicit;
      2. Is obscene, deliberately offensive, hateful or otherwise inflammatory;
      3. Promotes violence;
      4. Promotes or assists in any form of unlawful activity;
      5. Discriminates against, or is in any way defamatory of, any person, group or class of persons, race, sex, religion, nationality, disability, sexual orientation, or age;
      6. Is designed or is otherwise likely to threaten, harass, annoy, alarm, inconvenience, upset, or embarrass another person;
      7. Is calculated or is otherwise likely to deceive another person;
      8. Is designed or is otherwise likely to infringe (or threaten to infringe) another person’s privacy;
      9. Implies any form of affiliation with Us where none exists;
      10. Infringes, or assists in the infringement of, the intellectual property rights (including, but not limited to, copyright, trade marks, patents and database rights) of any other party; or
      11. Is made in breach of any legal duty owed to a third party including, but not limited to, contractual duties and duties of confidence.
    4. Please note that the content criteria described above in sub-Clause 10.2 OR 10.3 apply only to content over which the owner and/or operator of the website in question has direct control. You will not, therefore, be in breach of these Terms and Conditions if, for example, other users of a website on which you establish a link to Our Web App post content such as comments that violate the above criteria.
  11. Links to Other Content

    We may provide links to other content such as websites, web apps and downloadable apps. Unless expressly stated, this content is not under Our control. We neither assume or accept responsibility or liability for such third party content. The provision of a link by Us is for reference only and does not imply any endorsement of the linked content or of those in control of it.
  12. User Content

    1. You agree that you will be solely responsible for any and all User Content that you create or upload using Our Web App. Specifically, you agree, represent and warrant that you have the right to create or upload the User Content and the right to use all materials of which it is comprised and that it will not contravene any aspect of Our Acceptable Usage Policy, detailed in Clause 14.
    2. You agree that you will be liable to Us and will, to the fullest extent permissible by law, indemnify Us for any breach of the warranties given by you under sub-Clause 12.1. You will be responsible for any loss or damage suffered by Us as a result of such breach.
    3. You (or your licensors, as appropriate) retain ownership of your User Content and all intellectual property rights subsisting therein. By creating or uploading User Content, you grant Us an unconditional, non-exclusive, fully transferable, royalty-free, perpetual, worldwide licence to use, store, archive, syndicate, publish, transmit, adapt, edit, reproduce, distribute, prepare derivative works from, display, perform and sub-licence your User Content for the purposes of operating Our Web App.
    4. If you wish to remove User Content, you may do so by cancelling your account and subscription or downgrading to an alternative account. Removing User Content also revokes the licence granted to Us to use that User Content under sub-Clause 12.3. You acknowledge, however, that caching or references to your User Content may not be made immediately unavailable (or may not be made unavailable at all where they are outside of Our reasonable control).
    5. We may reject, reclassify, or remove any User Content created or uploaded using Our Web App where that User Content, in Our sole opinion, violates Our Acceptable Usage Policy, or if We receive a complaint from a third party and determine that the User Content in question should be removed as a result.
  13. Intellectual Property Rights and User Content

    1. You may only use Our Web App in a manner that is lawful and that complies with the provisions of this Clause 14. Specifically:
      1. You must ensure that you comply fully with any and all applicable local, national and international laws and/or regulations;
      2. You must not use Our Web App in any way, or for any purpose, that is unlawful or fraudulent;
      3. You must not use Our Web App to knowingly send, upload, or in any other way transmit data that contains any form of virus or other malware, or any other code designed to adversely affect computer hardware, software or any data of any kind; and
      4. You must not use Our Web App in any way, or for any purpose, that is intended to harm any person or persons in any way.
    2. The following types of User Content are not permitted on Our Web App and you must not create, submit, communicate or otherwise do anything that:
      1. is sexually explicit;
      2. is obscene, deliberately offensive, hateful, or otherwise inflammatory;
      3. promotes violence;
      4. promotes or assists in any form of unlawful activity;
      5. discriminates against, or is in any way defamatory of, any person, group or class of persons, race, sex, religion, nationality, disability, sexual orientation, or age;
      6. is intended or otherwise likely to threaten, harass, annoy, alarm, inconvenience, upset, or embarrass another person;
      7. is calculated or otherwise likely to deceive;
      8. is intended or otherwise likely to infringe (or threaten to infringe) another person’s right to privacy;
      9. misleadingly impersonates any person or otherwise misrepresents your identity or affiliation in a way that is calculated to deceive (obvious parodies are not included within this definition provided that they do not fall within any of the other provisions of this sub-Clause 14.2);
      10. implies any form of affiliation with Us where none exists;
      11. infringes, or assists in the infringement of, the intellectual property rights (including, but not limited to, copyright, patents, trade marks and database rights) of any other party; or
      12. is in breach of any legal duty owed to a third party including, but not limited to, contractual duties and duties of confidence.
    3. We reserve the right to suspend or terminate your Account and/or your access to Our Web App if you materially breach the provisions of this Clause 14 or any of the other provisions of these terms and conditions. Specifically, We may take one or more of the following actions:
      1. Suspend, whether temporarily or permanently, your Account and/or your right to access Our Web App (for more details regarding such cancellation, please refer to Clause 8);
      2. Remove any of your User Content which violates this Acceptable Usage Policy;
      3. Issue you with a written warning;
      4. Take legal proceedings against you for reimbursement of any and all relevant costs on an indemnity basis resulting from your breach;
      5. Take further legal action against you as appropriate;
      6. Disclose such information to law enforcement authorities as required or as we deem reasonably necessary; and/or
      7. Any other actions which We deem reasonably appropriate (and lawful).
    4. We hereby exclude any and all liability arising out of any actions (including, but not limited to, those set out above) that We may take in response to breaches of these Terms and Conditions.
  14. Advertising

    1. We may feature advertising within Our Web App and We reserve the right to display advertising on the same page as any User Content.
    2. You agree that you will not attempt to remove or hide any advertising using HTML/CSS or by any other method.
    3. We are not responsible for the content of any advertising in Our Web App. We will not be responsible for any advertising in Our Web App including, but not limited to, any errors, inaccuracies, or omissions.
  15. Problems with Our Web App

    If you have any questions or complaints regarding Our Web App, please email Us at support@8legs.com or by using any of the methods provided on Our contact page at www.support.8legs.com.
  16. Disclaimers

    1. No part of Our Web App or any accompanying documentation (whether provided in electronic form or otherwise) constitutes advice on which you should rely and is provided for general information purposes only.
    2. We make no representation, warranty, or guarantee that Our Web App will meet your requirements, that it will be fit for a particular purpose, that it will not infringe the rights of third parties, that it will be compatible with all software and hardware, or that it will be secure.
    3. We make reasonable efforts to ensure that the content contained within Our Web App is complete, accurate and up-to-date. We do not, however, make representations, warranties or guarantees (whether express or implied) that Our Web App (and the content therein) is complete, accurate or up-to-date.
    4. We are not responsible for the content or accuracy, or for any opinions, views, or values expressed in any User Content created or uploaded using Our Web App. Any such opinions, views, or values are those of the relevant User, and do not reflect Our opinions, views, or values in any way.
  17. Our Liability

    1. If you are a business, to the fullest extent permissible by law, We accept no liability for any foreseeable loss in contract, tort (including negligence), for breach of statutory duty, or otherwise arising out of or in connection with the use of (or inability to use) Our Web App or the use of or reliance upon any Content (whether that Content is provided by Us or whether it is User Content) included in Our Web App.
    2. To the fullest extent permissible by law, We accept no liability to businesses for loss or damage that is not foreseeable.
    3. To the fullest extent permissible by law, We exclude all representations, warranties, and guarantees (whether express or implied) that may apply to Our Web App or any Content (including User Content) included in Our Web App.
    4. If you are a business, We accept no liability for loss of profits, sales, business or revenue; loss of business opportunity, goodwill or reputation; loss of anticipated savings; business interruption; or for any indirect or consequential loss or damage.
    5. We exercise all reasonable skill and care to ensure that Our Web App is free from viruses and other malware. We accept no liability for any loss or damage resulting from a virus or other malware, a distributed denial of service attack, or other harmful material that may adversely affect your hardware, software, data or other material that occurs as a result of your use of Our Web App (including the downloading of any Content (including User Content) from it) or any other website or service that We may provide a link to.
    6. We neither assume nor accept responsibility or liability arising out of any disruption or non-availability of Our Web App resulting from external causes including, but not limited to, ISP equipment failure, host equipment failure, communications network failure, natural events, acts of war, or legal restrictions and censorship.
    7. Nothing in these Terms and Conditions excludes or restricts Our liability in any situation where it would be unlawful for us to do so including fraud or fraudulent misrepresentation, for death or personal injury resulting from negligence, or for any other forms of liability which cannot be excluded or restricted by law. For full details of applicable consumers’ legal rights, including those relating to digital content, please contact your local Citizens’ Advice Bureau or Trading Standards Office.
  18. Viruses, Malware and Security

    1. We exercise all reasonable skill and care to ensure that Our Web App is secure and free from viruses and other malware including, but not limited to, the scanning of any and all User Content for viruses and malware as it is uploaded. We do not, however, guarantee that Our Web App is secure or free from viruses or other malware and accept no liability in respect of the same, as detailed in sub-Clause 18.6.
    2. You are responsible for protecting your hardware, software, data and other material from viruses, malware and other internet security risks.
    3. You must not deliberately introduce viruses or other malware, or any other material which is malicious or technologically harmful either to or via Our Web App.
    4. You must not attempt to gain unauthorised access to any part of Our Web App, the server on which Our Web App is stored, or any other server, computer, or database connected to Our Web App.
    5. You must not attach Our Web App by means of a denial of service attack, a distributed denial of service attack, or by any other means.
    6. By breaching the provisions of sub-Clauses 19.3 to 19.5 you may be committing a criminal offence under the Computer Misuse Act 1990. Any and all such breaches will be reported to the relevant law enforcement authorities and We will cooperate fully with those authorities by disclosing your identity to them. Your right to use Our Web App will cease immediately in the event of such a breach and, where applicable, your Account will be suspended and/or deleted.
  19. Privacy and Cookies

    The Use of Our Web App is also governed by Our Privacy and Cookie Policies, displayed on our website at www.8legs.com. These policies are incorporated into these Terms and Conditions by this reference.
  20. Data Protection

    1. All personal information that We may collect (including, but not limited to, your name and contact details) will be collected, used, and held in accordance with the provisions of the Data Protection Act 1998 and your rights and Our obligations under that Act.
    2. We may use your personal information to:
      1. Reply to any communications that you send to Us;
      2. Send you important notices, as detailed in Clause 22;
    3. We will not pass your personal information on to any third parties.
  21. Communications from Us

    1. If you have an Account, We may from time to time send you important notices by email. Such notices may relate to matters including, but not limited to, service changes, changes to these Terms and Conditions, changes to Our Web App, and changes to your Account.
    2. We will never send you marketing emails of any kind without your express consent. If you do give such consent, you may opt out at any time. Any and all marketing emails sent by Us include an unsubscribe link. If you opt out of receiving emails from Us at any time, it may take up to 10 business days for Us to comply with your request. During that time, you may continue to receive emails from Us.
    3. For questions or complaints about email communications from Us (including, but not limited to, marketing emails), please contact Us at support@8legs.com or via our support portal at support.8legs.com.
  22. Other Important Terms

    1. We may transfer (assign) Our obligations and rights under these Terms and Conditions (and under the Contract, as applicable) to a third party (this may happen, for example, if We sell Our business). If this occurs, you will be informed by Us in writing. Your rights under these Terms and Conditions will not be affected and Our obligations under these Terms and Conditions will be transferred to the third party who will remain bound by them.
    2. You may not transfer (assign) your obligations and rights under these Terms and Conditions (and under the Contract, as applicable) without Our express written permission.
    3. The Contract is between you and Us. It is not intended to benefit any other person or third party in any way and no such person or party will be entitled to enforce any provision of these Terms and Conditions.
    4. If any of the provisions of these Terms and Conditions are found to be unlawful, invalid or otherwise unenforceable by any court or other authority, that / those provision(s) shall be deemed severed from the remainder of these Terms and Conditions. The remainder of these Terms and Conditions shall be valid and enforceable.
    5. No failure or delay by Us in exercising any of Our rights under these Terms and Conditions means that We have waived that right, and no waiver by Us of a breach of any provision of these Terms and Conditions means that We will waive any subsequent breach of the same or any other provision.
  23. Changes to these Terms and Conditions

    1. We may alter these Terms and Conditions at any time. Any such changes will become binding on you upon your first use of Our Web App after the changes have been implemented. You are therefore advised to check this page from time to time by visiting www.8legs.com.
    2. In the event of any conflict between the current version of these Terms and Conditions and any previous version(s), the provisions current and in effect shall prevail unless it is expressly stated otherwise.
  24. Contacting Us

    To contact Us, please email Us at support@8legs.com or by using the support portal at support.8legs.com.
  25. Law and Jurisdiction

    1. These Terms and Conditions and the relationship between you and Us (whether contractual or otherwise) shall be governed by, and construed in accordance with, English law.
    2. If you are a business, any disputes concerning these Terms and Conditions, the relationship between you and Us, or any matters arising therefrom or associated therewith (whether contractual or otherwise) shall be subject to the exclusive jurisdiction of the courts of England and Wales.

8LEGS Technology Ltd understands that your privacy is important to you and that you care about how your information is used and shared online. We respect and value the privacy of everyone who visits Our Site and will only collect and use information in ways that are useful to you and in a manner consistent with your rights and Our obligations under the law.

This Policy applies to Our use of any and all data collected by us in relation to your use of Our Site. Please read this Privacy Policy carefully and ensure that you understand it. [Your acceptance of Our Privacy Policy is deemed to occur upon your first use of Our Site. If you do not accept and agree with this Privacy Policy, you must stop using Our Site immediately.

  1. Definitions and Interpretation

    In this Policy the following terms shall have the following meanings:
    "Account"means an account required to access and/or use certain areas and features of Our Site;
    "Cookie" means a small text file placed on your computer or device by Our Site when you visit certain parts of Our Site and/or when you use certain features of Our Site. Details of the Cookies used by Our Site are set out in section 12, below;
    "Our Site"means this website, www.8legs.com;
    "UK and EU Cookie Law" means the relevant parts of the Privacy and Electronic Communications (EC Directive) Regulations 2003 as amended in 2004, 2011 and 2015; and]
    "We/Us/Our" means 8LEGS Technology Ltd, a limited company registered in England under 4938619, whose registered address is 3rd Floor, 5-10 Bury Street, London, EC3A 5AT, United Kingdom.
  2. Information About Us

    Our Site, www.8legs.com, is owned and operated by 8LEGS Technology Ltd, a limited company registered in England under 4938619, whose registered address is 3rd Floor, 5-10 Bury Street, London, EC3A 5AT, United Kingdom. Our VAT number is 245 9568 63.
  3. Scope – What Does This Policy Cover?

    This Privacy Policy applies only to your use of Our Site. It does not extend to any websites that are linked to from Our Site (whether We provide those links or whether they are shared by other users). We have no control over how your data is collected, stored or used by other websites and We advise you to check the privacy policies of any such websites before providing any data to them.
  4. What Data Do We Collect?

    Some data will be collected automatically by Our Site for further details, please see Our Cookie Policy displayed on our website at www.8legs.com, other data will only be collected if you voluntarily submit it, for example, when signing up for an Account. Depending upon your use of Our Site, We may collect some or all of the following data:
    1. name;
    2. business/company name;
    3. job title;
    4. profession;
    5. contact information such as email addresses and telephone numbers;
    6. demographic information such as post/zip code, preferences and interests;
    7. financial information such as credit / debit card numbers;
    8. IP address (automatically collected);
    9. web browser type and version (automatically collected);
    10. operating system (automatically collected);
    11. a list of URLs starting with a referring site, your activity on Our Site, and the site you exit to (automatically collected);
  5. How Do We Use Your Data?

    1. All personal data is stored securely in accordance with the principles of the Data Protection Act 1998. For more details on security see section 6, below.
    2. We use your data to provide the best possible [products and] services to you. This includes:
      1. Providing and managing your Account;
      2. Providing and managing your access to Our Site;
      3. Personalising and tailoring your experience on Our Site;
      4. Supplying Our services to you;
      5. Personalising and tailoring Our services for you;
      6. Responding to communications from you;
      7. [Supplying you with email marketing & notification emails that you have subscribed to (you may unsubscribe or opt-out at any time by sending an email to support@8legs.com;
      8. Market research;
    3. With your permission and/or where permitted by law, We may also use your data for marketing purposes which may include contacting you by email AND/OR telephone AND/OR [post] with information, news and offers on Our services. We will not, however, send you any unsolicited marketing or spam and will take all reasonable steps to ensure that We fully protect your rights and comply with Our obligations under the Data Protection Act 1998 and the Privacy and Electronic Communications (EC Directive) Regulations 2003, as amended in 2004, 2011 and 2015.
  6. How and Where Do We Store Your Data?

    1. We only keep your data for as long as We need to in order to use it as described above in section 5, and/or for as long as We have your permission to keep it.
    2. Some or all of your data may be stored or transferred outside of the European Economic Area (“the EEA”) (The EEA consists of all EU member states, plus Norway, Iceland and Liechtenstein). You are deemed to accept and agree to this by using Our Site and submitting information to Us. If We do store or transfer data outside the EEA, We will take all reasonable steps to ensure that your data is treated as safely and securely as it would be within the EEA and under the Data Protection Act 1998. Such steps may include, but not be limited to, the use of legally binding contractual terms between Us and any third parties We engage and the use of the EU-approved Model Contractual Arrangements. If We intend at any time to transfer any of your data outside the EEA, We will always obtain your consent beforehand.
    3. Data security is of great importance to Us, and to protect your data We have put in place suitable physical, electronic and managerial procedures to safeguard and secure data collected through Our Site.
    4. Notwithstanding the security measures that We take, it is important to remember that the transmission of data via the internet may not be completely secure and that you are advised to take suitable precautions when transmitting to Us data via the internet.
  7. Do We Share Your Data?

    1. We may share your data with other companies in Our group. This includes Our subsidiaries AND/OR Our holding company and its subsidiaries.
    2. We may sometimes contract with third parties to supply services to you on Our behalf. These may include payment processing, delivery of goods, search engine facilities, advertising and marketing. In some cases, the third parties may require access to some or all of your data. Where any of your data is required for such a purpose, We will take all reasonable steps to ensure that your data will be handled safely, securely, and in accordance with your rights, Our obligations, and the obligations of the third party under the law.
    3. We may compile statistics about the use of Our Site including data on traffic, usage patterns, user numbers, sales and other information. All such data will be anonymised and will not include any personally identifying information. We may from time to time share such data with third parties such as prospective investors, affiliates, partners and advertisers. Data will only be shared and used within the bounds of the law.
    4. In certain circumstances We may be legally required to share certain data held by Us, which may include your personal information, for example, where We are involved in legal proceedings, where We are complying with the requirements of legislation, a court order, or a governmental authority. We do not require any further consent from you in order to share your data in such circumstances and will comply as required with any legally binding request that is made of Us.
  8. What Happens If Our Business Changes Hands?

    1. We may, from time to time, expand or reduce Our business and this may involve the sale and/or the transfer of control of all or part of Our business. Data provided by users will, where it is relevant to any part of Our business so transferred, be transferred along with that part and the new owner or newly controlling party will, under the terms of this Privacy Policy, be permitted to use the data for the purposes for which it was originally collected by Us.
    2. In the event that any of your data is to be transferred in such a manner, you will be contacted in advance and informed of the changes.
  9. Your Right to Withhold Information

    1. You may access certain areas of Our Site without providing any data at all. However, to use all features and functions available on Our Site you may be required to submit or allow for the collection of certain data.
    2. You may restrict your internet browser’s use of Cookies. For more information, see section 12 and Our Cookie Policy displayed on our website at www.8legs.com.
  10. Contacting Us

    If you have any questions about Our Site or this Privacy Policy, please contact Us by email at support@8legs.com.
  11. Changes to Our Privacy Policy

    We may change this Privacy Policy as we may deem necessary from time to time, or as may be required by law. Any changes will be immediately posted on Our Site and you will be deemed to have accepted the terms of the Privacy Policy on your first use of Our Site following the alterations. We recommend that you check this page regularly to keep up-to-date.

This website www.8legs.com (“Our Site”) uses cookies and similar technologies in order to distinguish you from other users. By using cookies, We are able to provide you with a better experience and to improve Our Site by better understanding how you use it. Please read this Cookie Policy carefully and ensure that you understand it. Your acceptance of Our Cookie Policy is deemed to occur if you continue using Our Site. If you do not agree to Our Cookie Policy, please stop using Our Site immediately.

  1. Definitions and Interpretation

    1. In this Cookie Policy, unless the context otherwise requires, the following expressions have the following meanings:
      "cookie"means a small file consisting of letters and numbers that Our Site downloads to your computer or device;
      "web beacon" means a small, transparent image file (usually only 1-pixel x 1-pixel in size) used for tracking user behaviour and activity around Our Site;
      "We/Us/Our" means 8LEGS Technology Ltd, a company registered in England under 4938619, whose registered address is 3rd Floor, 5-10 Bury Street, London, EC3A 5AT.
  2. How Does Our Site Use Cookies?

    1. We may use cookies on Our Site for a number of reasons, all of which are designed to improve your experience of using it. Cookies allow you to navigate around Our Site better and enable Us to tailor and improve Our Site by saving your preferences and understanding your use of it.
    2. We use the following types of cookie:
      1. Strictly Necessary Cookies

        A cookie falls into this category if it is essential to the operation of Our Site, supporting functions such as logging in, your shopping basket, and payment transactions.

      2. Analytics Cookies

        It is important for Us to understand how you use Our Site, for example, how efficiently you are able to navigate around it, and what features you use. Analytics cookies enable us to gather this information, helping Us to improve Our Site and your experience of it.

      3. Functionality Cookies

        Functionality cookies enable Us to provide additional functions to you on Our Site such as personalisation and remembering your saved preferences.

      4. Targeting Cookies

        It is also important for Us to know when and how often you visit Our Site, and which parts of it you have used (including which pages you have visited and which links you have clicked on). As with analytics cookies, this information helps us to better understand you and, in turn, to make Our Site and advertising more relevant to your interests.

      5. Persistent Cookies

        Any of the above types of cookie may be a persistent cookie. Persistent cookies are those which remain on your computer or device for a predetermined period and are activated each time you visit Our Site.

      6. Session Cookies

        Any of the above types of cookie may be a session cookie. Session cookies are temporary and only remain on your computer or device from the point at which you visit Our Site until you close your browser. Session cookies are deleted when you close your browser.

    3. We also use web beacons on Our Site to track your navigation around it. As with analytics cookies described above, web beacons help Us to understand how you use Our Site and enable us to improve it in the future.
  3. How You Can Control Cookies

    1. Internet browsers normally accept cookies by default. You can change these settings if you wish, however please be aware that this is not generally a per-site setting and will prevent all websites from using cookies, not just Ours. Please also be aware that by disabling cookies in your browser, you may impair the functionality of Our Site.
    2. The links below provide instructions on how to control cookies in all mainstream browsers:
      1. Google Chrome: https://support.google.com/chrome/answer/95647?hl=en-GB
      2. Microsoft Internet Explorer: https://support.microsoft.com/en-us/kb/278835
      3. Microsoft Edge: https://support.microsoft.com/en-gb/products/microsoft-edge (Please note that there are no specific instructions at this time, but Microsoft support will be able to assist)
      4. Safari (OSX): https://support.apple.com/kb/PH21411?viewlocale=en_GB&locale=en_GB
      5. Safari (iOS): https://support.apple.com/en-gb/HT201265
      6. Mozilla Firefox: https://support.mozilla.org/en-US/kb/enable-and-disable-cookies-website-preferences
      7. Android: https://support.google.com/chrome/answer/95647?co=GENIE.Platform%3DAndroid&hl=en (Please refer to your device’s documentation for manufacturers’ own browsers)
  4. How Do We Use Cookies in Emails?

    1. In addition to using cookies on Our Site, we use cookies and similar technologies in some of the emails we send to you. Just like the cookies on Our Site, these are used to help Us understand your use of Our Site and to keep improving it.
    2. We use web beacons in some of Our emails. We use web beacons to detect when (or whether) you open an email and how you have interacted with it, and other information such as your email client, web browser, computer or device, and IP address. Web beacons may also be used to serve up emails in a particular format that is best suited to your computer or device.
    3. Emails from Us may contain links. Each one of those links will contain a unique tag which enables Us to track which links are being used and by whom. This information can then be used to improve and tailor our emails in the future.
  5. Changes to this Cookie Policy

    1. We may alter this Cookie Policy at any time. Any such changes will become binding on you on your first use of Our Site after the changes have been made. You are therefore advised to check this page from time to time.
    2. In the event of any conflict between the current version of this Cookie Policy and any previous version(s), the provisions current and in effect shall prevail unless it is expressly stated otherwise.
  6. Further Information

    1. If you would like to know more about how We use cookies, please contact Us at support@8legs.com.
    2. For more information about cookies, please visit www.aboutcookies.org (this is an external link and We are not responsible for its content).
    3. For more information about privacy, data protection and our terms and conditions, displayed on our website at www.8legs.com.
  1. Introduction

  2. This Policy sets out the obligations of 8LEGS Technology Ltd, a company registered in England under number : 10283839, whose registered office is at 3rd Floor 5-10 Bury Street, London, England, EC3A 5AT, United Kingdom (“the Company”) regarding data protection and the rights of candidates and clients (“data subjects”) in respect of their personal data under EU Regulation 2016/679 General Data Protection Regulation (“GDPR”).

    The GDPR defines “personal data” as any information relating to an identified or identifiable natural person (a “data subject”); an identifiable natural person is one who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier, or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural, or social identity of that natural person.

    This Policy sets the Company’s obligations regarding the collection, processing, transfer, storage, and disposal of personal data. The procedures and principles set out herein must be followed at all times by the Company, its employees, agents, contractors, or other parties working on behalf of the Company.

    The Company is committed not only to the letter of the law, but also to the spirit of the law and places high importance on the correct, lawful, and fair handling of all personal data, respecting the legal rights, privacy, and trust of all individuals with whom it deals.

  1. The Data Protection Principles

  2. This Policy aims to ensure compliance with the GDPR. The GDPR sets out the following principles with which any party handling personal data must comply. All personal data must be:

    1. Processed lawfully, fairly, and in a transparent manner in relation to the data subject.

    2. Collected for specified, explicit, and legitimate purposes and not further processed in a manner that is incompatible with those purposes. Further processing for archiving purposes in the public interest, scientific or historical research purposes or statistical purposes shall not be considered to be incompatible with the initial purposes.

    3. Adequate, relevant, and limited to what is necessary in relation to the purposes for which it is processed.

    4. Accurate and, where necessary, kept up to date. Every reasonable step must be taken to ensure that personal data that is inaccurate, having regard to the purposes for which it is processed, is erased, or rectified without delay.

    5. Kept in a form which permits identification of data subjects for no longer than is necessary for the purposes for which the personal data is processed. Personal data may be stored for longer periods insofar as the personal data will be processed solely for archiving purposes in the public interest, scientific or historical research purposes, or statistical purposes, subject to implementation of the appropriate technical and organisational measures required by the GDPR in order to safeguard the rights and freedoms of the data subject.

    6. Processed in a manner that ensures appropriate security of the personal data, including protection against unauthorised or unlawful processing and against accidental loss, destruction, or damage, using appropriate technical or organisational measures.

  1. The Rights of Data Subjects

  2. The GDPR sets out the following rights applicable to data subjects (please refer to the parts of this policy indicated for further details):

    1. The right to be informed (Part 12).

    2. The right of access (Part 13);

    3. The right to rectification (Part 14);

    4. The right to erasure (also known as the ‘right to be forgotten’) (Part 15);

    5. The right to restrict processing (Part 16);

    6. The right to data portability (Part 17);

    7. The right to object (Part 18); and

    8. Rights with respect to automated decision-making and profiling (Parts 19 and 20).

  1. Lawful, Fair, and Transparent Data Processing

    1. The GDPR seeks to ensure that personal data is processed lawfully, fairly, and transparently, without adversely affecting the rights of the data subject. The GDPR states that processing of personal data shall be lawful if at least one of the following applies:

        1. The data subject has given consent to the processing of their personal data for one or more specific purposes;

        2. The processing is necessary for the performance of a contract to which the data subject is a party, or in order to take steps at the request of the data subject prior to entering into a contract with them;

        3. The processing is necessary for compliance with a legal obligation to which the data controller is subject;

        4. The processing is necessary to protect the vital interests of the data subject or of another natural person;

        5. The processing is necessary for the performance of a task carried out in the public interest or in the exercise of official authority vested in the data controller; or

        6. The processing is necessary for the purposes of the legitimate interests pursued by the data controller or by a third party, except where such interests are overridden by the fundamental rights and freedoms of the data subject which require protection of personal data, in particular where the data subject is a child.

    2. If the personal data in question is “special category data” (also known as “sensitive personal data”) (for example, data concerning the data subject’s race, ethnicity, politics, religion, trade union membership, genetics, biometrics (if used for ID purposes), health, sex life, or sexual orientation), at least one of the following conditions must be met:

        1. The data subject has given their explicit consent to the processing of such data for one or more specified purposes (unless EU or EU Member State law prohibits them from doing so);

        2. The processing is necessary for the purpose of carrying out the obligations and exercising specific rights of the data controller or of the data subject in the field of employment, social security, and social protection law (insofar as it is authorised by EU or EU Member State law or a collective agreement pursuant to EU Member State law which provides for appropriate safeguards for the fundamental rights and interests of the data subject);

        3. The processing is necessary to protect the vital interests of the data subject or of another natural person where the data subject is physically or legally incapable of giving consent;

        4. The data controller is a foundation, association, or other non-profit body with a political, philosophical, religious, or trade union aim, and the processing is carried out in the course of its legitimate activities, provided that the processing relates solely to the members or former members of that body or to persons who have regular contact with it in connection with its purposes and that the personal data is not disclosed outside the body without the consent of the data subjects;

        5. The processing relates to personal data which is clearly made public by the data subject;

        6. The processing is necessary for the conduct of legal claims or whenever courts are acting in their judicial capacity;

        7. The processing is necessary for substantial public interest reasons, on the basis of EU or EU Member State law which shall be proportionate to the aim pursued, shall respect the essence of the right to data protection, and shall provide for suitable and specific measures to safeguard the fundamental rights and interests of the data subject;

        8. The processing is necessary for the purposes of preventative or occupational medicine, for the assessment of the working capacity of an employee, for medical diagnosis, for the provision of health or social care or treatment, or the management of health or social care systems or services on the basis of EU or EU Member State law or pursuant to a contract with a health professional, subject to the conditions and safeguards referred to in Article 9(3) of the GDPR;

        9. The processing is necessary for public interest reasons in the area of public health, for example, protecting against serious cross-border threats to health or ensuring high standards of quality and safety of health care and of medicinal products or medical devices, on the basis of EU or EU Member State law which provides for suitable and specific measures to safeguard the rights and freedoms of the data subject (in particular, professional secrecy); or

        10. The processing is necessary for archiving purposes in the public interest, scientific or historical research purposes, or statistical purposes in accordance with Article 89(1) of the GDPR based on EU or EU Member State law which shall be proportionate to the aim pursued, respect the essence of the right to data protection, and provide for suitable and specific measures to safeguard the fundamental rights and the interests of the data subject.

  1. Specified, Explicit, and Legitimate Purposes

    1. The Company collects and processes the personal data set out in Part 21 of this Policy. This includes:

        1. Personal data collected directly from data subjects

    2. The Company only collects, processes, and holds personal data for the specific purposes set out in Part 21 of this Policy (or for other purposes expressly permitted by the GDPR).

    3. Data subjects are kept informed at all times of the purpose or purposes for which the Company uses their personal data. Please refer to Part 12 for more information on keeping data subjects informed.

  1. Adequate, Relevant, and Limited Data Processing

  2. The Company will only collect and process personal data for and to the extent necessary for the specific purpose or purposes of which data subjects have been informed (or will be informed) as under Part 5, above, and as set out in Part 21, below.

  1. Accuracy of Data and Keeping Data Up-to-Date

    1. The Company shall ensure that all personal data collected, processed, and held by it is kept accurate and up-to-date. This includes, but is not limited to, the rectification of personal data at the request of a data subject, as set out in Part 14, below.

    2. The accuracy of personal data shall be checked when it is collected and at regular intervals thereafter. If any personal data is found to be inaccurate or out-of-date, all reasonable steps will be taken without delay to amend or erase that data, as appropriate.

  1. Data Retention

    1. The Company shall not keep personal data for any longer than is necessary in light of the purpose or purposes for which that personal data was originally collected, held, and processed.

    2. When personal data is no longer required, all reasonable steps will be taken to erase or otherwise dispose of it without delay.

  1. Secure Processing

  2. The Company shall ensure that all personal data collected, held, and processed is kept secure and protected against unauthorised or unlawful processing and against accidental loss, destruction, or damage. Further details of the technical and organisational measures which shall be taken are provided in Parts 22 to 27 of this Policy.

  1. Accountability and Record-Keeping

    1. The Company’s Data Protection Officer is Mark Lennard.

    2. The Data Protection Officer shall be responsible for overseeing the implementation of this Policy and for monitoring compliance with this Policy, the Company’s other data protection-related policies, and with the GDPR and other applicable data protection legislation.

    3. The Company shall keep written internal records of all personal data collection, holding, and processing, which shall incorporate the following information:

        1. The name and details of the Company, its Data Protection Officer, and any applicable third-party data processors;

        2. The purposes for which the Company collects, holds, and processes personal data;

        3. Details of the categories of personal data collected, held, and processed by the Company, and the categories of data subject to which that personal data relates;

        4. Details of any transfers of personal data to non-EEA countries including all mechanisms and security safeguards;

        5. Details of how long personal data will be retained by the Company (please refer to the Company’s Data Retention Policy); and

        6. Detailed descriptions of all technical and organisational measures taken by the Company to ensure the security of personal data.

  1. Data Protection Impact Assessments

    1. The Company shall carry out Data Protection Impact Assessments for any and all new projects and/or new uses of personal data which involve the use of new technologies and the processing involved is likely to result in a high risk to the rights and freedoms of data subjects under the GDPR.

    2. Data Protection Impact Assessments shall be overseen by the Data Protection Officer and shall address the following:

        1. The type(s) of personal data that will be collected, held, and processed;

        2. The purpose(s) for which personal data is to be used;

        3. The Company’s objectives;

        4. How personal data is to be used;

        5. The parties (internal and/or external) who are to be consulted;

        6. The necessity and proportionality of the data processing with respect to the purpose(s) for which it is being processed;

        7. Risks posed to data subjects;

        8. Risks posed both within and to the Company; and

        9. Proposed measures to minimise and handle identified risks.

  1. Keeping Data Subjects Informed

    1. The Company shall provide the information set out in Part 12.2 to every data subject:

        1. Where personal data is collected directly from data subjects, those data subjects will be informed of its purpose at the time of collection; and

        2. Where personal data is obtained from a third party, the relevant data subjects will be informed of its purpose:

          1. if the personal data is used to communicate with the data subject, when the first communication is made; or

          2. if the personal data is to be transferred to another party, before that transfer is made; or

          3. as soon as reasonably possible and in any event not more than one month after the personal data is obtained.

    2. The following information shall be provided:

        1. Details of the Company including, but not limited to, the identity of its Data Protection Officer;

        2. The purpose(s) for which the personal data is being collected and will be processed (as detailed in Part 21 of this Policy) and the legal basis justifying that collection and processing;

        3. Where applicable, the legitimate interests upon which the Company is justifying its collection and processing of the personal data;

        4. Where the personal data is not obtained directly from the data subject, the categories of personal data collected and processed;

        5. Where the personal data is to be transferred to one or more third parties, details of those parties;

        6. Where the personal data is to be transferred to a third party that is located outside of the European Economic Area (the “EEA”), details of that transfer, including but not limited to the safeguards in place (see Part 28 of this Policy for further details);

        7. Details of data retention;

        8. Details of the data subject’s rights under the GDPR;

        9. Details of the data subject’s right to withdraw their consent to the Company’s processing of their personal data at any time;

        10. Details of the data subject’s right to complain to the Information Commissioner’s Office (the “supervisory authority” under the GDPR);

        11. Where applicable, details of any legal or contractual requirement or obligation necessitating the collection and processing of the personal data and details of any consequences of failing to provide it; and

        12. Details of any automated decision-making or profiling that will take place using the personal data, including information on how decisions will be made, the significance of those decisions, and any consequences.

  1. Data Subject Access

    1. Data subjects may make subject access requests (“SARs”) at any time to find out more about the personal data which the Company holds about them, what it is doing with that personal data, and why.

    2. Data subjects wishing to make a SAR may do so in writing, using the Company’s Subject Access Request Form, or other written communication. SARs should be addressed to the Company’s Data Protection Officer

    3. Responses to SARs shall normally be made within one month of receipt, however this may be extended by up to two months if the SAR is complex and/or numerous requests are made. If such additional time is required, the data subject shall be informed.

    4. All SARs received shall be handled by the Company’s Data Protection Officer.

    5. The Company does not charge a fee for the handling of normal SARs. The Company reserves the right to charge reasonable fees for additional copies of information that has already been supplied to a data subject, and for requests that are manifestly unfounded or excessive, particularly where such requests are repetitive.

  1. Rectification of Personal Data

    1. Data subjects have the right to require the Company to rectify any of their personal data that is inaccurate or incomplete.

    2. The Company shall rectify the personal data in question, and inform the data subject of that rectification, within one month of the data subject informing the Company of the issue. The period can be extended by up to two months in the case of complex requests. If such additional time is required, the data subject shall be informed.

    3. In the event that any affected personal data has been disclosed to third parties, those parties shall be informed of any rectification that must be made to that personal data.

  1. Erasure of Personal Data

    1. Data subjects have the right to request that the Company erases the personal data it holds about them in the following circumstances:

        1. It is no longer necessary for the Company to hold that personal data with respect to the purpose(s) for which it was originally collected or processed;

        2. The data subject wishes to withdraw their consent to the Company holding and processing their personal data;

        3. The data subject objects to the Company holding and processing their personal data (and there is no overriding legitimate interest to allow the Company to continue doing so) (see Part 18 of this Policy for further details concerning the right to object);

        4. The personal data has been processed unlawfully;

        5. The personal data needs to be erased in order for the Company to comply with a particular legal obligation

    2. Unless the Company has reasonable grounds to refuse to erase personal data, all requests for erasure shall be complied with, and the data subject informed of the erasure, within one month of receipt of the data subject’s request. The period can be extended by up to two months in the case of complex requests. If such additional time is required, the data subject shall be informed.

    3. In the event that any personal data that is to be erased in response to a data subject’s request has been disclosed to third parties, those parties shall be informed of the erasure (unless it is impossible or would require disproportionate effort to do so).

  1. Restriction of Personal Data Processing

    1. Data subjects may request that the Company ceases processing the personal data it holds about them. If a data subject makes such a request, the Company shall retain only the amount of personal data concerning that data subject (if any) that is necessary to ensure that the personal data in question is not processed further.

    2. In the event that any affected personal data has been disclosed to third parties, those parties shall be informed of the applicable restrictions on processing it (unless it is impossible or would require disproportionate effort to do so).

  1. Data Portability

    1. The Company processes personal data using automated means.

    2. Where data subjects have given their consent to the Company to process their personal data in such a manner, or the processing is otherwise required for the performance of a contract between the Company and the data subject, data subjects have the right, under the GDPR, to receive a copy of their personal data and to use it for other purposes (namely transmitting it to other data controllers).

    3. To facilitate the right of data portability, the Company shall make available all applicable personal data to data subjects in the following format:

        1. A full download of data held on internal system;

    4. Where technically feasible, if requested by a data subject, personal data shall be sent directly to the required data controller.

    5. All requests for copies of personal data shall be complied with within one month of the data subject’s request. The period can be extended by up to two months in the case of complex or numerous requests. If such additional time is required, the data subject shall be informed.

  1. Objections to Personal Data Processing

    1. Data subjects have the right to object to the Company processing their personal data based on legitimate interests, direct marketing (including profiling)

    2. Where a data subject objects to the Company processing their personal data based on its legitimate interests, the Company shall cease such processing immediately, unless it can be demonstrated that the Company’s legitimate grounds for such processing override the data subject’s interests, rights, and freedoms, or that the processing is necessary for the conduct of legal claims.

    3. Where a data subject objects to the Company processing their personal data for direct marketing purposes, the Company shall cease such processing immediately.

  1. Data Security - Transferring Personal Data and Communications

  2. The Company shall ensure that the following measures are taken with respect to all communications and other transfers involving personal data:

      1. All emails containing personal data must be encrypted

      2. Personal data may be transmitted over secure networks only; transmission over unsecured networks is not permitted in any circumstances;

      3. Personal data may not be transmitted over a wireless network if there is a wired alternative that is reasonably practicable;

      4. Personal data contained in the body of an email, whether sent or received, should be copied from the body of that email and stored securely. The email itself should be deleted. All temporary files associated therewith should also be deleted

      5. Where personal data is to be sent by facsimile transmission the recipient should be informed in advance of the transmission and should be waiting by the fax machine to receive the data;

      6. Where personal data is to be transferred in hardcopy form it should be passed directly to the recipient

    1. Data Security - Storage

    2. The Company shall ensure that the following measures are taken with respect to the storage of personal data:

      1. All electronic copies of personal data should be stored securely using passwords and data encryption;

      2. All hardcopies of personal data, along with any electronic copies stored on physical, removable media should be stored securely in a locked box, drawer, cabinet, or similar;

      3. All personal data stored electronically should be backed up

      4. No personal data should be stored on any mobile device (including, but not limited to, laptops, tablets, and smartphones), whether such device belongs to the Company or otherwise

      5. No personal data should be transferred to any device personally belonging to an employee and personal data may only be transferred to devices belonging to agents, contractors, or other parties working on behalf of the Company where the party in question has agreed to comply fully with the letter and spirit of this Policy and of the GDPR (which may include demonstrating to the Company that all suitable technical and organisational measures have been taken).

  1. Data Security - Disposal

  2. When any personal data is to be erased or otherwise disposed of for any reason (including where copies have been made and are no longer needed), it should be securely deleted and disposed of. For further information on the deletion and disposal of personal data, please refer to the Company’s Data Retention Policy.

  1. Data Security - Use of Personal Data

  2. The Company shall ensure that the following measures are taken with respect to the use of personal data:

    1. No personal data may be shared informally and if an employee, agent, sub-contractor, or other party working on behalf of the Company requires access to any personal data that they do not already have access to, such access should be formally requested from Mark Lennard;

    2. No personal data may be transferred to any employees, agents, contractors, or other parties, whether such parties are working on behalf of the Company or not, without the authorisation of Mark Lennard

    3. Personal data must be handled with care at all times and should not be left unattended or on view to unauthorised employees, agents, sub-contractors, or other parties at any time;

    4. If personal data is being viewed on a computer screen and the computer in question is to be left unattended for any period of time, the user must lock the computer and screen before leaving it; and

    5. Where personal data held by the Company is used for marketing purposes, it shall be the responsibility of Mark Lennard to ensure that the appropriate consent is obtained and that no data subjects have opted out, whether directly or via a third-party service such as the TPS.

  1. Data Security - IT Security

  2. The Company shall ensure that the following measures are taken with respect to IT and information security:

    1. All passwords used to protect personal data should be changed regularly and should not use words or phrases that can be easily guessed or otherwise compromised. All passwords must contain a combination of uppercase and lowercase letters, numbers, and symbols.

    2. Under no circumstances should any passwords be written down or shared between any employees, agents, contractors, or other parties working on behalf of the Company, irrespective of seniority or department. If a password is forgotten, it must be reset using the applicable method. IT staff do not have access to passwords;

    3. All software (including, but not limited to, applications and operating systems) shall be kept up-to-date. The Company’s IT staff shall be responsible for installing any and all security-related updates after the updates are made available by the publisher or manufacturer

    4. No software may be installed on any Company-owned computer or device without the prior approval of the Mark Lennard

  1. Organisational Measures

  2. The Company shall ensure that the following measures are taken with respect to the collection, holding, and processing of personal data:

    1. All employees, agents, contractors, or other parties working on behalf of the Company shall be made fully aware of both their individual responsibilities and the Company’s responsibilities under the GDPR and under this Policy, and shall be provided with a copy of this Policy;

    2. Only employees, agents, sub-contractors, or other parties working on behalf of the Company that need access to, and use of, personal data in order to carry out their assigned duties correctly shall have access to personal data held by the Company;

    3. All employees, agents, contractors, or other parties working on behalf of the Company handling personal data will be appropriately trained to do so;

    4. All employees, agents, contractors, or other parties working on behalf of the Company handling personal data will be appropriately supervised;

    5. All employees, agents, contractors, or other parties working on behalf of the Company handling personal data shall be required and encouraged to exercise care, caution, and discretion when discussing work-related matters that relate to personal data, whether in the workplace or otherwise;

    6. Methods of collecting, holding, and processing personal data shall be regularly evaluated and reviewed;

    7. All personal data held by the Company shall be reviewed periodically, as set out in the Company’s Data Retention Policy;

    8. The performance of those employees, agents, contractors, or other parties working on behalf of the Company handling personal data shall be regularly evaluated and reviewed;

    9. All employees, agents, contractors, or other parties working on behalf of the Company handling personal data will be bound to do so in accordance with the principles of the GDPR and this Policy by contract;

    10. All agents, contractors, or other parties working on behalf of the Company handling personal data must ensure that any and all of their employees who are involved in the processing of personal data are held to the same conditions as those relevant employees of the Company arising out of this Policy and the GDPR; and

    11. Where any agent, contractor or other party working on behalf of the Company handling personal data fails in their obligations under this Policy that party shall indemnify and hold harmless the Company against any costs, liability, damages, loss, claims or proceedings which may arise out of that failure.

  1. Transferring Personal Data to a Country Outside the EEA

    1. The Company may from time to time transfer (‘transfer’ includes making available remotely) personal data to countries outside of the EEA.

    2. The transfer of personal data to a country outside of the EEA shall take place only if one or more of the following applies:

        1. The transfer is to a country, territory, or one or more specific sectors in that country (or an international organisation), that the European Commission has determined ensures an adequate level of protection for personal data;

        2. The transfer is to a country (or international organisation) which provides appropriate safeguards in the form of a legally binding agreement between public authorities or bodies; binding corporate rules; standard data protection clauses adopted by the European Commission; compliance with an approved code of conduct approved by a supervisory authority (e.g. the Information Commissioner’s Office); certification under an approved certification mechanism (as provided for in the GDPR); contractual clauses agreed and authorised by the competent supervisory authority; or provisions inserted into administrative arrangements between public authorities or bodies authorised by the competent supervisory authority;

        3. The transfer is made with the informed consent of the relevant data subject(s);

        4. The transfer is necessary for the performance of a contract between the data subject and the Company (or for pre-contractual steps taken at the request of the data subject);

        5. The transfer is necessary for important public interest reasons;

        6. The transfer is necessary for the conduct of legal claims;

        7. The transfer is necessary to protect the vital interests of the data subject or other individuals where the data subject is physically or legally unable to give their consent; or

        8. The transfer is made from a register that, under UK or EU law, is intended to provide information to the public and which is open for access by the public in general or otherwise to those who are able to show a legitimate interest in accessing the register.

  1. Data Breach Notification

    1. All personal data breaches must be reported immediately to the Company’s Data Protection Officer.

    2. If a personal data breach occurs and that breach is likely to result in a risk to the rights and freedoms of data subjects (e.g. financial loss, breach of confidentiality, discrimination, reputational damage, or other significant social or economic damage), the Data Protection Officer must ensure that the Information Commissioner’s Office is informed of the breach without delay, and in any event, within 72 hours after having become aware of it.

    3. In the event that a personal data breach is likely to result in a high risk (that is, a higher risk than that described under Part 29.2) to the rights and freedoms of data subjects, the Data Protection Officer must ensure that all affected data subjects are informed of the breach directly and without undue delay.

    4. Data breach notifications shall include the following information:

        1. The categories and approximate number of data subjects concerned;

        2. The categories and approximate number of personal data records concerned;

        3. The name and contact details of the Company’s data protection officer (or other contact point where more information can be obtained);

        4. The likely consequences of the breach;

        5. Details of the measures taken, or proposed to be taken, by the Company to address the breach including, where appropriate, measures to mitigate its possible adverse effects.

  1. Implementation of Policy

  2. This Policy shall be deemed effective as of 25th May 2018. No part of this Policy shall have retroactive effect and shall thus apply only to matters occurring on or after this date.