Liberata UK Limited (“LUKL”, “We”, “Us”) is committed to protecting and respecting your privacy.
[LUKL is registered with the Information Commissioner’s Office (ICO) and our registration number is [Z7035984]. Please note that all data captured by Liberata UK Limited will be used and held in accordance with the requirements of the EU General Data Protection Regulation (GDPR). The data controller is Liberata UK Limited,5th Floor, Knollys House, 17, Addiscombe Road, Croydon, Surrey CR0 6SR.]
INFORMATION WE COLLECT FROM YOU
We will collect and process the following data about you:
Information you give us:
This is information about you that you give us by filling in forms on liberata.com (our Website) or by corresponding with us by phone, e-mail, or otherwise. The information you give us may include your name, address, e-mail address and phone number, CV information, financial details, and information relating to a limited company through which you supply your services.
Information we collect about you:
We will automatically collect the following information each time you visit our Website:
- technical information, including the Internet protocol (IP) address used to connect your computer to the Internet, screen resolution and colour depth, browser type and version, time zone setting, browser plug-in types and versions and operating system and platform
- information about your visit, including the full Uniform Resource Locators (URL), clickstream to, through and from our Website (including date and time), length of visits to certain pages and methods used to browse away from the page.
Information we receive from other sources:
This is information we receive about you from third parties, business partners, suppliers and credit reference and vetting agencies.
In order to improve our Website, we may use small files commonly known as “cookies”. A cookie is a small amount of data which often includes a unique identifier that is sent to your computer or mobile phone (referred to in this policy as a ‘device’) from our Website and is stored on your device’s hard drive. A cookie records on your device information relating to your internet activity (such as whether you have visited our website before).
We currently set the following Google Analytics cookies and User Input cookies.
We use Google Analytics which is a web analytics service provided by Google Inc. to understand how visitors to our Website use our Website. The Google Analytics cookies collect information about how people are using our Website, for example which pages are visited the most often, how people are moving from one link to another and if they get error messages from certain pages. The cookies do not gather any information that identifies you. The information these cookies collect is grouped together with information from other people’s use of our Website on an anonymous basis. Overall, these cookies provide us with analytical information about how our Website is performing and how we can improve our Website. You can opt out of Google Analytics without affecting your use of our Website – for more information on opting out of being tracked by Google Analytics across all websites you use, visit https://tools.google.com/dlpage/gaoptout.
We use user-input cookies to keep track of your input when filling online forms.
HOW WE USE YOUR INFORMATION
We rely upon different legal bases for the processing of personal information according to the relationship and purpose for which it is collected as explained below:
Consent: This is where the individual has given clear consent for us to process their personal data for a specific purpose. We will seek consent from individuals who we want to stay in touch with where another legal basis does not apply. For example, where individuals have previously worked or engaged with us as an organisation and we would like to keep in touch about future opportunities or to send invitations we think are of relevance to them.
Legal obligation: Where processing is necessary for us to comply with the law. For example, processing personal data to comply with our legal obligations to disclose employee salary details to HMRC.
Legitimate interests: Where processing of your personal data is necessary and used in ways you would reasonably expect us to. For example: for current Associates or Employees, we will need to process personal data to maintain contact, facilitate payments, and share appropriate and relevant information with you.
We use information held about you in the following ways:
Information you give to us:
We will use this to carry out our obligations arising from any contracts entered into between you and us and to notify you about opportunities, events and information which may be relevant to you.
Information we collect about you:
We will use this information:
- to administer our Website and for internal operations;
- to improve our Website to ensure that content is presented in the most effective manner for you and for your computer;
- as part of our efforts to keep our Website safe and secure.
Information we receive from other sources:
We will combine this information with information you give to us and information we collect about you. We will use this information and the combined information for the purposes set out above.
RETENTION OF YOUR INFORMATION
We will not retain your information for any longer than is necessary.
Information that we collect will be retained for as long as needed to fulfil the purposes outlined in ‘How we use your Information’ section above, or for a period specifically required by applicable regulations or laws, or contractual arrangements with our clients.
Where information is retained through ‘Consent’, it will be marked as inactive after 24 months unless you re-consent.
If you have given your consent for us to use your information, you have the right to withdraw that consent. Withdrawing consent will not however make unlawful our use of your information while consent had been apparent.
You can withdraw consent at any time by contacting us as set out in the ‘Contact’ section below.
DISCLOSURE OF YOUR INFORMATION
We will share your personal information with:
- Any member of our group, which means our subsidiaries, our parent company, our ultimate parent company, and any subsidiaries of these organisations as defined in section 1159 of the UK Companies Act 2006.
- Selected third parties including associates and representatives of the person whose personal data we are processing, financial organisations, current or prospective employers, educators and examining bodies, suppliers and services providers, credit reference agencies, central government, debt collection and tracing agencies;
- Clients, business partners, suppliers and sub-contractors for the performance of any contract or prospective contract we enter into with them or you;
- Analytics and search engine providers that assist us in the improvement and optimisation of our Website;
- Credit reference and vetting agencies as part of our onboarding processes.
We will disclose your personal information to third parties:
- If we sell or buy any business or assets, in which case we will disclose your personal data to the prospective seller or buyer of such business or assets.
- If our company or substantially all its assets are acquired by a third party, in which case personal data held by it about its customers will be one of the transferred assets.
WHERE WE STORE YOUR PERSONAL DATA
We protect your personal data from unauthorised access and disclosure by ensuring security measures are in place and access to personal data is restricted to only those who have a legitimate business purpose and reason for accessing it. We store most data about you in computer systems and databases operated by either us or our external service providers. However, where necessary, security measures apply to personal data in both electronic and hard copy form.
Data held by us is stored on cloud storage with the physical location of the datacentre within the United Kingdom.
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 our 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.
TRANSFER OF PERSONAL DATA
It may sometimes be necessary to transfer personal data overseas. This will always be in line with the ‘Disclosure of your Information’ section above and any transfers made will be in full compliance with the requirements of GDPR.
Under data protection law, you have a number of rights concerning the data we hold about you. If you wish to discuss or exercise any of these rights, please contact us as set out in the ‘Contact’ section below.
There is also more detailed explanations of each of your rights on the ICO website which can be accessed here.
The right to be informed. You have the right to be provided with clear, transparent and easily understandable information about how we use your information and your rights. Therefore, we are providing you with the information in this policy.
The right of access. You have the right to obtain access to your information. This will enable you, for example, to check that we are using your information in accordance with data protection law.
The right to rectification. You are entitled to have your information corrected if it is inaccurate or incomplete.
The right to erasure. This is also known as ‘the right to be forgotten’ and enables you to request the deletion or removal of certain information that we hold about you.
The right to restrict processing. You have right to ‘block’ or ‘suppress’ further use of your information. When processing is restricted, we can still store your information, but will not use it further.
The right to data portability. You have the right to obtain your personal information in an accessible and transferrable format so that you can re-use it for your own purposes.
The right to withdraw consent. If you have given us consent to process your information, you have the right to withdraw that consent at any time. Withdrawing consent will not however make unlawful our use of your information while consent had been apparent.
The right to object to processing. You have the right to object to us processing your personal data in certain circumstances. Applicability of this depends on the purpose and lawful basis for which we are processing it.
If you have any concerns about the way we use your information please contact us to discuss. You do also have the right to raise your concerns with the ICO. Their details can be found here.