Data Protection Policy (“DPP”)

Data Protection Policy (“DPP”)

  • Introduction
  • Data Retention
  • Data Collection
  • Your Rights
  • Data Transfer
  • Data Security
  • Changes to DPP
  • Contact

 

  • Introduction

 

Senovo IT Ltd (“We” or “Us” or “Our”) is strongly committed to protecting the privacy and integrity of personal data.

 

Senovo IT Group is a leading IT consulting service provider. It was founded in 2013 and is currently present in 15 countries bringing talent, drive and innovation to national and international projects. We provide business solutions and assistance to IT professionals in finding suitable assignments based on their skills and their level of expertise.

 

Our Group means our subsidiaries, our holding company and its subsidiaries, our associated companies as defined in section 1159 of the UK Companies Act 2006 such as Senovo IT UK Ltd and Senovo IT SL.

 

We are registered as a fee payer for the purposes of the Data Protection Act 2018. We ensure that all data you make available to Us is processed with due skill, care and diligence in accordance with the applicable procedures, laws and regulations.

 

The present DPP describes how We collect personal data from you and how it will be processed by Us. You hereby provide explicit consent to Us holding and processing any such personal data (including, without limitation, sensitive personal data) for the purposes of Our business.

 

  • Data Retention

 

We will only retain personal data for as long as there is an administrative and/or contractual need to keep in order to conduct Our business effectively, including for the purposes of satisfying any legal, regulatory, tax, accounting or reporting requirement.

 

To comply with the requirements set above, We will keep personal data for a period of 7 years from the date of creation of the document and/or file unless otherwise mandated differently by the applicable law.

 

  • Data Collection

 

  • Purposes and legal basis of the processing

 

We use information held about you in the following ways:

 

  • To carry out Our obligations arising from any contracts We intend to enter into or have entered into between you and Us and to provide you with the information, products and services that you request from;
  • To provide you with information about other goods and services We offer that are similar to those that you have already purchased, been provided with or enquired about.
  • In certain circumstances we will process your data to in connection with establishing, exercising or defending legal claims.

 

Our legal basis for the processing of personal data is Our legitimate business interests, described in more detail below, although We will also rely on contract, legal obligation and consent for specific uses of data:

 

  • We will rely on contract if We are negotiating or have entered into a placement agreement with you or your organisation or any other contract to provide services to you or receive services from you or your organisation.

 

  • We will rely on legal obligation if We are legally required to hold information on to you to fulfil Our legal obligations (such as to comply with Our obligations to verify your identity).

 

  • We will in some circumstances rely on consent for particular uses of your data and you will be asked for your express consent, if legally required.

 

Our Legitimate Business Interests

 

Our legitimate interests in collecting and retaining your personal data is described below:

  • To operate Our website and provide Our services;
  • In order to select qualified suppliers and partners;
  • To run internal administrative and auditing purposes; and
  • To maintain, expand and develop Our business

 

Consent

Should We want or need to rely on consent to lawfully process your data We will request your consent orally, by email or by an online process for the specific activity We require consent for and record your response on Our system.

 

Where consent is the lawful basis for Our processing you have the right to withdraw your consent to this particular processing at any time.

 

  • What information do We collect

 

We will collect and process personal data for Our business purposes, either directly from yourself or from other sources.

 

We collect the following types of personal data to provide Our services

 

  • A client

 

Name, address, corporate email address, phone number, bank details

 

  • A vendor

 

Name, address, corporate email address, phone number, bank details

 

  • A customer

 

Name, username, password, date of birth, address, email address, phone number, bank details, credit/debit card information, billing address, details about products and services you purchased from Us, internet protocol (IP) address, login data, browser type and version, time zone setting and location, information about how you use our website, products and services, information provided to Us by you, educational content data such as assignments, essays or quizzes, information about your learning process such as your progress, results and ratings, your communication preferences, your preferences in receiving marketing from Us

 

We will also collect, use and process aggregated data such as demographic or statistical data for any purpose. Aggregated data could be derived from your personal data but is not considered personal data in law as this will not directly or indirectly reveal your identity. For example, We may aggregate your usage data to calculate the percentage of users accessing a specific website feature. However, f We combine or connect aggregated date with your personal data so hat it can directly or indirectly identify you, We treat the combined data as personal data which will be used in accordance with this DPP.

 

Sensitive data

 

Regardless of the basis for your dealings with Us, We request that you do not provide Us with any sensitive personal data unless absolutely necessary. However, to the extent that you do provide Us with any sensitive personal data, such as data which you choose to share with Us in conversation, We shall only use that personal data for the purposes of Our relationship with you or for the provision of our services. This will be for one or more of the following reasons:

 

  • You have explicitly consented to the processing;
  • Where processing is necessary for complying with legal requirements imposed to Us;
  • To maintain records of Our dealings to address any later dispute, including but not limited to the establishment, exercise or defence of any legal claims.

 

Information We collect about you when you visit Our website

 

Regarding each of your visits to Our site We will automatically collect the following information:

 

We collect information that your browser sends whenever you visit our Service (“Log Data”). This Log Data may include information such as your computer’s Internet Protocol (“IP”) address, browser type, browser version, the pages of our Service that you visit, the time and date of your visit, the time spent on those pages and other statistics.

 

This site uses Google Analytics (GA) to track user interaction with Log Data. We use this data to determine the number of people using our site, to better understand how they find and use our web pages and to see their journey through the website. None of this information personally identifies you to Us. GA also records your computer’s IP address which could be used to personally identify you but Google do not grant Us access to this. GA makes use of cookies (see below for more about cookies), details of which can be found on Google’s developer guides.

 

Disabling cookies on your internet browser will stop GA from tracking any part of your visit to pages within this website.

 

Our website may, from time to time, contain links to and from the websites of our partner networks, advertisers 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.

 

Information We obtain from other sources

 

We may share your personal data with certain third parties such as business partners, professional advisors, and subcontractors in order to achieve Our business purposes.

 

We require all third parties to respect your privacy and to treat your personal data in accordance with the applicable law. We only permit third-parties to process your personal data for specified purposes in accordance with our instructions.

 

If you fail to provide personal data

 

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 or We may not be able to provide Our services to you (or the effectiveness of those Services may be significantly reduced).

 

  • Your rights

 

The data protection laws provide you with the following rights:

 

  • Right to be informed about the collection and use of their personal data
  • Request access to the personal data held by Us about you. This grants you the right to confirm how your personal data is being collected and processed.
  • Request correction of the personal information that We hold about you. This enables you to have any incomplete or inaccurate information We hold about you corrected.
  • Right to erasure of your personal data, otherwise known as the right to be forgotten. This enables you to request your personal data be deleted.
  • Object to the processing of your personal data where We are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground. You also have the right to object where We are processing your personal data for direct marketing purposes.
  • Request the restriction of processing of your personal information. This enables you to ask Us to suspend the processing of personal data about you, for example if you want Us to establish its accuracy or the purpose of processing it.
  • Right of data portability. This enables you to receive a copy all details you have provided to Us in a machine-readable format.
  • Right to withdraw consent that you have previously given to Us to process your personal data. Please note that if you withdraw your consent to further processing that will not affect any processing done prior to the withdrawal of that consent, or which is done according to another legal basis.
  • Right not to be subject to an automated individual decision-making. You have the right to ask Us to review any decisions made about you based solely on an automated processing, including profiling, which produces legal effects concerning you or similarly affects you.
  • Right to complain to a supervisory body which in the United Kingdom is the Information Commissioner’s Office (“ICO”) and in Spain is the Agencia Española de Protección de Datos (“AEPD”). The ICO and the AEPD can be contacted through these links respectively: https://ico.org.uk/concerns/ and https://aepd.es, although We encourage you to first bring to our attention any issues before contacting the ICO and/or the AEPD so We can properly investigate matters.

 

  • Data transfer

 

We also may transfer the personal data We collect about you to countries outside of the country in which the information originally was collected for the purposes of Our services.

 

Whenever We transfer your personal data to other countries, We will ensure a similar degree of protection is afforded to it by ensuring at least one of the following safeguards is implemented:

 

  • We will only transfer personal data to countries that have been deemed to provide an adequate level of protection for personal data;
  • In absence of an adequacy decision, we will ensure any transfer of your personal data takes place on the basis of other legally permitted grounds: (a) legally binding and enforceable instrument between public authorities or bodies; (b) binding corporate rules; (c) standard data protection clauses (formerly called the Model Clauses) adopted by the Commission; or (d) agreement between the parties.

 

  • Data security

 

We have implemented a variety of appropriate security measures in order to maintain the satefy of your personal data.

 

We will only disclose your personal data to those employees, contractors or third parties who have a business need to know and who are subject to a duty of confidentiality. Personal data will only be processed by them on our instructions.

 

  • Changes to the DPP

 

Any changes We make to the DPP in the future will be posted on this page and, where appropriate, notified to you by email. We encourage you to check back the DPP frequently to see any updates or changes to it.

 

Please keep Us informed if your personal data changes during your relationship with Us.

 

  • Contact

 

Questions, comments and requests regarding this DPP or Our privacy practices are welcomed and should be addressed to dpo@senovo.it or by writing to Us at Our postal address Unit 110 Coppergate House, 10 White’s Row, E1 7NJ London.

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