Privacy and Cookies Policy for www.gradtouch.com

1. Who are we?

1.1. We are GradTouch Limited ("we", "us" or "our"), a company registered in England and Wales under company number 07718853 and with registered office at Laurel House, 173 Chorley New Road, Bolton, England, BL1 4QZ.

1.2. We own and operate www.gradtouch.com ("the Website").

1.3. For the purpose of the Data Protection Act 1998 and the General Data Protection Regulation (or any other subsequent enactment of it in the United Kingdom) (together, “Data Protection Laws ”), we are:

1.3.1. a data controller in respect of any personal data that you share with us, or that we collect, through the Website (including personal data you provide to us, or that we collect, during your registration for, and subscription to, the services we provide); and

1.3.2. a data processor in respect of personal data that you share with us when you enquire about, or apply for, a role made available by an employer through the Website, and in respect of which the relevant employer is the data controller; our obligations in relation to that personal data are set out in our contract with the relevant employer.

You can contact us at the above address, or at info@gradtouch.com.

2. What does this Privacy and Cookies Policy apply to?

This Privacy and Cookies Policy applies to all use of the Website, whether as a registered user or non-registered viewer of the Website.

3. What does this Privacy and Cookies Policy do?

This Privacy and Cookies Policy (together with our Terms and Conditions and any other documents referred to in it) sets out the basis on which any personal data we collect from you, or that you provide to us, will be processed by us. Please read this Privacy and Cookies Policy carefully to understand our views and practices regarding your personal data and how we will treat it.

4. Fair processing

4.1. We will only use your personal data in the manner set out in this Privacy and Cookies Policy. We will only use your personal data in a way that is fair to you. We will only collect personal data where it is necessary for us to do so and where it is relevant to our dealings with you. We will only keep your personal data for as long as it is relevant to the purpose for which it was collected or for as long as we are required to keep it by law.

4.2. Other than as set out in this Privacy and Cookies Policy, we shall NOT sell or disclose your personal data to third parties without obtaining your prior consent unless this is necessary for the purposes set out in this Privacy and Cookies Policy or unless we are required to do so by law.

4.3. We will only use your personal data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If you wish to get an explanation as to how the processing for the new purpose is compatible with the original purpose, please contact us.

4.4. If we need to use your personal data for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so.

4.5. Please note that we may process your personal data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.

5. Collection and processing of your personal data

What personal data do we collect?

How do we collect the personal data?

Why do we use the personal data?

How long do we hold the personal data for?

Your title and name

- By you filling in a registration form at the time you subscribe to receive the services we provide through the Website.

- When you fill in forms available on the Website to get in touch with us, for example to inform us of a particular issue, to make a complaint, or to request access to additional services.

- By you applying to employers for job opportunities that such employers make available through the Website.

- When you contact us in any other way for any reason.

We use the personal data you provide to us for the following purposes:

- To manage the Website, detect fraud or Website abuses, send you information relevant to the Website and in case we have any queries. This is in our legitimate interest.

- To carry out our obligations arising from any contracts entered into between you and us. This is necessary for the performance of the contract we have in place with you.

- To notify you about changes to our services. This is necessary for the performance of the contract we have in place with you.

- To allow you to register for an account on the Website, which may include sending an email to you to confirm your details. This is necessary for the performance of the contract we have in place with you.

- To allow you to apply to employers for job opportunities that such employers make available through the Website. This is necessary for the performance of the contract we have in place with you.

- To give you a new password if you have forgotten it. This is necessary for the performance of the contract we have in place with you.

- To provide customer support. This is necessary for the performance of the contract we have in place with you.

- To prevent or investigate prohibited activity. This is in our legitimate interest.

- To enforce the Terms and Conditions . This is in our legitimate interest.

- To verify information. This is in our legitimate interest.

We may use your name, email address and telephone number to provide you with information about products or services we feel may interest you. It is in our legitimate interest to market products and services to you in this way. If we contact you in this way, we will tell you how you can opt-out of such communications.

For as long as we have a contract with you to provide services to you through the Website. We will delete your personal data when we or you close your account on the Website, or you delete it from your account. If you do not have your account, we will keep your data for as is necessary for the purposes of facilitating any application you make for a role through the Website.

We will keep personal data after we stop providing services to you through the Website, to see if you would like to start using those services again.

After that, we will delete your personal data, except where we need to keep it for legal, regulatory or audit reasons. More information about our data retention periods is available on request – please contact us at info@gradtouch.com.

Please note that we cannot control the storage and/or use of your personal data by employers.

Your date of birth

- By you filling in a registration form at the time you subscribe to receive the services we provide through the Website.

- By you applying to employers for job opportunities that such employers make available through the Website.

Your address

- By you supplying information to include in your profile on the Website.

- By you applying to employers for job opportunities that such employers make available through the Website.

Your email address

- By you filling in a registration form at the time you subscribe to receive the services we provide through the Website.

- When you fill in forms available on the Website to get in touch with us, for example to inform us of a particular issue, to make a complaint, or to request access to additional services.

- By you applying to employers for job opportunities that such employers make available through the Website.

- When you contact us in any other way for any reason.

Your contact telephone number(s)

- By you filling in a registration form at the time you subscribe to receive the services we provide through the Website.

- When you fill in forms available on the Website to get in touch with us, for example to inform us of a particular issue, to make a complaint, or to request access to additional services.

- By you applying to employers for job opportunities that such employers make available through the Website.

Your username and password for accessing the restricted areas of the Website

By you filling in a registration form at the time you subscribe to receive the services we provide through the Website.

Your career and role preferences, based on the services we provide.

By you creating your account and agreeing to receive information about particular roles made available on the Website by employers.

Your career history, experience and other work-related personal information.

By you creating your profile and adding information to it in order to access the services we provide and applying to employers for job opportunities that such employers make available through the Website.

We provide this data to employers, in respect of whom you wish to make an application for a job opportunity through the Website.

Job application details in respect of roles you apply for with third-party employers listed on the Website.

By you applying to employers for job opportunities that such employers make available through the Website.

We provide this data to employers, in respect of whom you wish to make an application for a job opportunity through the Website, and facilitate the application process on behalf of the employer.

5.1. We 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. For example, we may aggregate your data to calculate the percentage of users accessing a specific website feature. 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.

5.2. Where we need to collect personal data by law, or under the terms of a contract we have with you and you fail to provide that data when requested, we may not be able to perform the contract we have or are trying to enter into with you (for example, to provide you with access to the services). In this case, we may have to cancel your access to services but we will notify you if this is the case at the time.

6. Making sure the personal data we hold is accurate and up-to-date

6.1. You should only submit to us or the Website information which is accurate and not misleading.

6.2. By submitting your or anyone else's data to us or the Website, you must ensure that you have full authority and consent to supply us with that data on their behalf and you warrant to us that you have that authority.

7. IP addresses

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

7.2. We use this data to ensure that content from the Website is presented in the most effective manner for you and for your computer. We hold this data for 5 years; more information about our data retention periods is available on request – please contact us at info@gradtouch.com.

8. Cookies

8.1. The Website uses cookies. Cookies are tiny text files which identify your computer to our server as a unique user when you visit certain pages on the Website and they are stored by your Internet browser on your computer's hard drive. Cookies can be used to recognise your Internet Protocol address, saving you time while you are on the Website.

8.2. We only use cookies for your convenience in using the Website and not for obtaining or using any other information about you (for example targeted advertising). Your browser can be set to not accept cookies, but this would restrict your use of the Website.

8.3. If you want to find out more information about cookies, go to http://www.allaboutcookies.org or to find out about removing them from your browser, go to http://www.allaboutcookies.org/manage-cookies/index.html .

8.4. Please note that we collect data from the Website about use of the Website using a web analysis tool which uses cookies that are (able to be) used to generate pseudonyms for a user's profile. This means that use cookies (which may be stored on your computer after you leave the Website) can store information about your visit.

8.5. Please also note that our suppliers and partners may also use cookies, over which we have no control.

8.6. The Website uses the following cookies:

Name

Expiration Date

Purpose

gradtouch.com

gradtouch_sess

Session

This is a general purpose identifier used to maintain your user session variables. A random generated unique number, is used to identify you to maintain your logged in status throughout our website.

_webCSRF

Session

This is a security token that prevents Cross-Site Request Forgery (CSRF) attacks. It is a secure random unique alphanumeric identifier that prevents attackers tricking users into executing actions of the attacker's choosing.

gradtouch_guest_id

3 Years

This is a general purpose identifier used to track visitor behaviour and performance.

gradtouch_signupprompt

14 Days

This is used to prevent a reminder for a user to sign up to be displayed in certain situations when a user has already dismissed it.

_webIdentity

3 Years

This is a general purpose identifier used to automatically sign you into your user account allowing you access and to automatically update your job preferences.

platform.gradtouch.com

gtplat_sess

Session

This is a general purpose identifier used to maintain your user session variables. A random generated unique number, is used to identify you to maintain your logged in status throughout our website.

_appCSRF

Session

This is a security token that prevents Cross-Site Request Forgery (CSRF) attacks. It is a secure random unique alphanumeric identifier that prevents attackers tricking users into executing actions of the attacker's choosing.

_appIdentity

14 Days

This is a general purpose identifier used to automatically sign you into your user account allowing you access and to automatically update your job preferences.

Google Analytics

_ga

2 Years

This is used by Google Analytics which enables GradTouch to track visitor behaviour and measure website performance.

_gat

10 Minutes

This is used by Google Analytics which to throttle the request rate between our website and their service. This cookie does not store any user information, it's just used to limit the number of requests that have to be made to doubleclick.net.

_gid

1 day

This is used by Google Analytics which enables GradTouch to track visitor behaviour on individual pages and measure website performance.

_gat_aggTracker

10 Minutes

This is used by Google Analytics which to throttle the request rate between our website and their service. This cookie does not store any user information, it's just used to limit the number of requests that have to be made to doubleclick.net.

Facebook

fr

3 Months

This is used by Facebook which enables GradTouch to analyse and monitor campaign performance.

Twitter

lang

3 Months

This is used by Twitter to store language preferences.

New Relic

JSESSIONID

Session

This is a general purpose identifier used by New Relic which enables GradTouch to monitor website performance and errors. A random generated unique number, is used to identify you throughout your visit.

9. Where we store your personal data

9.1. All information you provide to us is stored on our secure servers. We use industry standard security and firewalls on our servers. Where we have given you (or where you have chosen) a password which enables you to access certain parts of the Website, you are responsible for keeping that password confidential. We ask you not to share a password with anyone.

9.2. We maintain physical, electronic and procedural safeguards in connection with the collection, storage and disclosure of your information. Our security procedures mean that we may occasionally request proof of identity before we disclose personal information to you.

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

10. Sharing personal data with third parties

10.1. We may transfer our databases containing your personal information if we sell our business or part of it to an actual or potential purchaser. This is in our legitimate interest.

10.2. In providing our services, we use third parties which assist us in operating our business, and which process certain personal data on our behalf. We share personal data with those third parties only to the extent it is necessary for us to provide the services, and where it is in our legitimate interest to do so. We have contracts with those third parties in which they are obligated to process personal data in compliance with Data Protection Laws.

10.3. Some of the third parties who provide us with services are based outside of the European Economic Area (the “EEA ”) so their processing of your data will involve a transfer of data outside the EEA. Whenever we transfer your personal data out of the EEA, we ensure a similar degree of protection is afforded to it by ensuring at least one of the following safeguards is implemented:

10.3.1. We will only transfer your personal data to countries that have been deemed to provide an adequate level of protection for personal data by the European Commission. For further details, see European Commission: Adequacy of the protection of personal data in non-EU countries.

10.3.2. Where we use certain service providers, we may use specific contracts approved by the European Commission which give personal data the same protection it has in Europe. For further details, see European Commission: Model contracts for the transfer of personal data to third countries.

10.3.3. 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 the Europe and the US. For further details, see European Commission: EU-US Privacy Shield.

10.4. We share data with employers that have listed roles on the Website, to the extent that you make applications for those roles through the Website.

10.5. We also share data with:

10.5.1. Service providers, acting as processors on our behalf, based both inside and outside the EEA who provide IT and system administration services.

10.5.2. Professional advisers, acting as processors on our behalf or joint controllers, including lawyers, bankers, auditors and insurers based in the United Kingdom who provide consultancy, banking, legal, insurance and accounting services.

10.5.3. HM Revenue & Customs, regulators and other authorities, acting as processors on our behalf or joint controllers, based in the United Kingdom who require reporting of processing activities in certain circumstances.

11. Other websites

The Website may, from time to time, contain links to and from the websites of our partner networks and affiliates. If you follow a link to any of these websites, please note that these websites have their own privacy policies and that we do not accept any responsibility or liability for these policies. Please check these policies before you submit any personal data to these websites.

12. Your rights under Data Protection Laws

12.1. If you would like to:

12.1.1. correct or update the personal data that we hold about you

12.1.2. ask that we delete your personal data;

12.1.3. get a copy of the personal data that we hold about you;

12.1.4. access the personal data we hold about you;

12.1.5. restrict the uses for which we use your personal data;

12.1.6. transfer the personal data we hold about you to a third-party data controller;

12.1.7. object to our processing of your personal data for particular purposes; or

12.1.8. withdraw your consent to our use of your personal data (where relevant);

please email us at info@gradtouch.com. When you email us, please include your name and email address so that we can be sure that it is you that is contacting us and not somebody else.

12.2. 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.

12.3. 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. We may also contact you to ask you for further information in relation to your request to speed up our response.

12.4. 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.

12.5. You can unsubscribe from receiving marketing communications from us by clicking here.

12.6. Your account’s functionality makes it possible for you to de-activate your account. This means that neither us nor employers are able to view your personal data stored within your account. You can request the deletion of your account as well as the personal data from within your account, by emailing us at info@gradtouch.com.

13. Complaints

You can make a complaint to a supervisory authority in respect of our processing of personal data at any time. In the UK, the Information Commissioner’s Office (also known as the ICO) is the supervisory authority; for information on how to contact the ICO, click here. We would, however, appreciate the chance to deal with your concerns before you approach the ICO, so please contact us in the first instance.

14. Changes to our Privacy and Cookies Policy

Any changes we may make to this Privacy and Cookies Policy in the future will be posted on the Website and, where appropriate, notified to you by e-mail. Each time you enter the Website, you agree that the Privacy and Cookies Policy current at that time shall apply to all information held by you.

15. Contact

Questions, comments and requests regarding this Privacy and Cookies Policy are welcomed and should be addressed to GradTouch Limited, Fourways House, 57 Hilton Street, Manchester, M1 2EJ

This Privacy and Cookies Policy was most recently updated on 24th May 2018.