Privacy Policy

PRIVACY NOTICE – Version 3, 9 April 2020

Smart HR Solutions Limited is a company incorporated and validly existing under the laws of the Isle of Man with company number 124794C.  We are committed to protecting your privacy when visiting our website or using our services.

This Privacy Notice (the ‘Notice’) explains how we use any personal information we collect about you when you use this website or when you contact us directly. The Notice sets out how we, from time to time, process the personal data of individuals who contact us or who use our website, services, applications, content and related features (collectively, the ‘Website’).

This Notice sets out our views and practices in respect of your personal data and how we will treat it.  Please read this carefully. By visiting our Website, you acknowledge the processing described in this Notice.

From time to time we may make changes to this Notice by posting on our Website or otherwise. Your continued use of the Website, our services or your continued dealing with us after notification of such changes will amount to your acknowledgement of the amended Notice.

Please note that our website uses cookies.  Please refer to the Cookie Statement detailed below.

HOW TO CONTACT US

Please contact us if you have any questions about this Privacy Notice or information we hold about you by writing to us at the following registered office address:

FAO: Data Protection Officer, Smart HR Solutions Limited, 16 Manor Lane, Farmhill, Douglas, Isle of Man, IM2 2NX.

Alternatively, you can email us at contact@SmartHR.co.im

WHAT IS PERSONAL DATA?

‘Personal data’ means any information relating to an identified or identifiable natural person, known as a ‘data subject’, who can be identified directly or indirectly; it may include name, address, email address, phone number, IP address, location data, cookies, a recording of your call with us and similar information. It may also include ‘special categories of personal data’ such as racial or ethnic origin, political opinions, religious or philosophical beliefs, or trade union membership, and the processing of genetic data, biometric data for the purpose of uniquely identifying a data subject, data concerning health or data concerning a natural person’s sex life or sexual orientation.

WHAT PERSONAL DATA TO WE PROCESS?

We may process the following personal data:

Information provided by you. You may give us information about you by, for example, filling in forms such as the contact form on our Website, subscribing to services such as email updates, making applications in respect of job postings, corresponding with us by email, phone or otherwise. This information may include your name, email address, phone number, information about your query and similar information. We may also receive a copy of your CV or a similar document in respect of a job vacancy or a speculative job enquiry.  When you purchase materials/documents and/or services from our website (or if you purchase materials/documents and/or services directly from Smart HR Solutions Limited using a card payment), the payment will be processed using a third-party payment processor, acting on behalf of Smart HR Solutions Limited, on a secure website and they will obtain and verify the payment card details that you supply.  Smart HR Solutions Limited will endeavour to ensure any third party acting on behalf of Smart HR Solutions Limited uses encryption to ensure payment data is protected.

Information about others. You may also provide to us personal data relating to third parties, such as people who you work with, or your referees. Information about third parties should only be provided if you have demonstrable permission to do so or if the information is available in the public domain.

Information about your device. With regard to each visit to our website we may collect technical information about your device such as IP address, operating system, browser, time zone setting, the Internet address of the website from which you linked directly to our website, URL clickstream data, page interaction information (such as scrolling, clicks, and mouse-overs), and methods used to browse away from the page.  Generally, you are under no obligation to provide this information, but without it, we may be unable to provide you with some of our Website content and services.

We will rely on the information provided by you as being accurate, complete and up-to-date and you agree to ensure that this will be the case.

HOW DO WE USE YOUR PERSONAL DATA?

We will only process personal data, in accordance with applicable law, for the following purposes:

• responding to your queries, requests and other communications, for example, if you apply for a job or you send us a query about our Website;
• providing the Website and related services including our Website, content and features;
• enabling suppliers and service providers to carry out certain functions on our behalf in order to provide the Website and related services, including webhosting, data storage, identity verification, technical, logistical and other functions, as applicable;
• allowing you to use features on our Website and related services, when you choose to do so;
• sending you personalised marketing communications as permitted by law or as requested by you. If you would like to unsubscribe please contact us by email at contact@SmartHR.co.im;
• serving personalised advertising to your devices, based on your interests in accordance with our Cookie Statement below.  You have the right to disable cookies, please refer to our Cookie Statement;
• ensuring the security of our business and preventing and detecting fraud;
• administering our business, troubleshooting of our Website, data analysis, quality control, testing of new features, research, statistical and survey purposes;
• developing and improving our Website and related services;
• complying with applicable law, including in response to a lawful request from a court or regulatory body.

The legal basis for our processing of personal data for the purposes described above will typically include:

• processing necessary to fulfil a legitimate interest;
• your consent which will be expressly obtained when necessary;
• processing necessary to fulfil a contract;
• any processing necessary for compliance with a legal obligation;
• any other applicable legal ground from time to time.

CONTACTING US VIA SOCIAL MEDIA

In addition to this website, we also have various social media platforms. We include them in this Notice for completeness.  You may choose to provide us with personal information on our social media platforms. If you do so, we ask that you also check the platform’s privacy policy / notice and terms of service prior to sending us any personal data.

Smart HR Solutions Limited’s social media message boxes are accessed by restricted personnel who have responsibility for maintaining our social media platforms; this may include a third-party service provider.

COOKIE STATEMENT

In order to collect the information including personal data as described in this Notice, we may use cookies and similar technology on our Website. A cookie is a small piece of information which is sent to your browser and stored on your computer’s hard drive, mobile phone or other device. Cookies can be first party, i.e. cookies that the website you are visiting places on your device, or third-party cookies, i.e. cookies placed on your device through the Website but by third parties, such as, Google. For more information please visit www.allaboutcookies.org.

We use the following cookies on our Website:

• Strictly necessary cookies. These cookies are essential in order to enable you to move around our Website and use its features. Without these cookies, the Website and related services you have asked for cannot be provided. They are deleted when you close the browser. These are first party cookies.
• Performance cookies. These cookies collect information in an anonymous form about how visitors use our Website. They allow us to recognise and count the number of visitors and to see how visitors move around the Website when they are using it and the approximate regions that they are visiting from. These are first party cookies.
• Functionality cookies. These cookies allow our Website to remember choices you make (such as your user name, language or the region you are in, if applicable) and provide enhanced, more personal features. The information these cookies collect may be anonymised and they cannot track your browsing activity on other websites. These are first party cookies.
• Targeting or advertising cookies. These cookies allow us and our advertisers to deliver information more relevant to you and your interests. They are also used to limit the number of times you see an advertisement as well as to help measure the effectiveness of advertising campaigns. They remember that you have visited our Website and may help us in compiling your profile. These are persistent cookies which will be kept on your device until their expiration or earlier manual deletion.
• Social Media cookies. These cookies allow you to connect with social media networks such as Facebook, Twitter, LinkedIn and Google+. These are persistent cookies which will be kept on your device until their expiration or earlier manual deletion.

We may combine information from these types of cookies and technologies with information about you from other sources.

Cookie consent and opting out. By using our Website, we assume that you are happy for us to place cookies on your device. Most Internet browsers automatically accept cookies; however, if you, or another user of your device, wish to withdraw your consent at any time, you have the ability to accept or decline cookies by modifying your browser setting. If you choose to decline cookies, you may not be able to fully experience the interactive features of our Website and related services.

If you are based in Europe, when you arrive on our website a pop-up message will appear asking for your consent to place advertising cookies on your device. In order to provide your consent, please click ‘I understand’. Once your consent has been provided, this message will not appear again when you revisit.  If you, or another user of your device, wish to withdraw your consent at any time, you can do so by altering your browser settings.

DISCLOSURE OF PERSONAL DATA

There are circumstances where we may wish to disclose or are compelled to disclose your personal data to third parties. These scenarios include disclosure to:

• our suppliers and service providers to facilitate the provision of the Website, related services and our client services, including IT consultants, web-hosting providers, recruitment services providers, consultants and similar third parties;
• subject to appropriate legal basis such as consent, our advertising and marketing partners who enable us, for example, to deliver personalised ads to your devices or who may contact you by post, email, telephone, SMS or by other means;
• successor or partner legal entities, on a temporary or permanent basis, for the purposes of a joint venture, collaboration, financing, sale, merger, reorganisation, change of legal form, dissolution or similar event relating to our business. In the case of a merger or sale, your personal data will be permanently transferred to a successor company;
• public authorities, such as law enforcement agencies, courts and other public bodies where we are required by law to do so; and
• other third parties where you have provided your consent.

We may transfer your personal data to a third-party in countries outside the country in which it was originally collected for further processing in accordance with the purposes set out above. In particular, your personal data may be transferred outside of the EU/EEA. Where this is the case, we will ensure that appropriate transfer mechanisms as set in the General Data Protection Regulations (‘GDPR’) are in place to ensure an adequate level of data protection.

If we transfer personal data to private organisations outside of the EU/EEA, such as our suppliers and service providers, we will, as required by applicable law, ensure that your privacy rights are adequately protected by appropriate technical, organisation, contractual or other lawful means. Where this is necessary you may contact us for a copy of such safeguards at contact@SmartHR.co.im.

RETENTION OF PERSONAL DATA

We retain personal data for as long as is necessary for the purposes listed above or longer as may be required by the law. Further details of applicable retention periods can be provided by contacting us at contact@SmartHR.co.im.

We may keep an anonymised form of your personal data, which will no longer refer to you, for statistical purposes without time limits, to the extent that we have a legitimate and lawful interest in doing so.

SECURITY OF PERSONAL DATA

We will use appropriate technical and organisational information security measures to try to ensure prevention of any unauthorised access to your personal data; however, transmission of information via the internet is never completely secure. Whilst we will do our best to keep our own systems secure, we cannot control the entirety of the internet and cannot therefore guarantee the security of your information as it is transmitted to and from our Website.

Smart HR Solutions Limited recommends that you install your own security measures, firewalls, software spyware and other appropriate security procedures.  We are unable to provide any guarantee that information and data provided to users will be free of viruses or other conditions which may damage or interfere with data, hardware or software with which it might be used.  All information sent by Smart HR Solutions Limited is done so on the strict condition that the user carries out and relies upon its own procedures for ensuring that its use will not interfere with the recipient’s systems and the recipient assumes all risk of use and absolves Smart HR Solutions Limited of all responsibility for any consequences of its use.

DATA SUBJECT RIGHTS

Depending on your country’s laws and the legal basis for collection of your data, you may have certain rights in relation to your personal data. Further information about your data privacy rights may be obtained by visiting the website of your local data privacy authority. In summary GDPR provides, as follows:

• Right to access. Data subjects may request in writing copies of their personal data. However, compliance with such requests is subject to certain limitations and exemptions and the rights of other individuals. You may also be required to submit proof of your identity when making such a request.
• Right to rectification. You may request that we rectify any inaccurate or incomplete personal data that we hold about you.
• Right to withdraw consent. You may at any time withdraw your consent to the processing of your personal data carried out by us on the basis of your previous consent. Such withdrawal will not affect the lawfulness of processing based on such previous consent.
• Right to object to processing including profiling. We will comply with valid objection requests unless we have a compelling overriding legitimate ground for the continuation of our processing or we have another lawful reason to refuse such a request. We will comply with each valid opt-out request in relation to marketing communications.
• Rights in relation to automated decisions about you. Where we make a decision about you based solely on automated processing which significantly affects you, you will have the right to contest the decision, express your point of view and obtain human intervention.
• Right to erasure. You may request that we erase your personal data. We will comply, unless there is a lawful reason for not doing so.
• Restriction of processing. You may request that we restrict our processing of your personal data in various circumstances. We will comply, unless there is a lawful reason for not doing so, such as, a legal obligation to continue processing your personal data in a certain way.
• Right to data portability. In certain circumstances, you may request that we, as a data controller, provide a copy of your personal data in a structured, commonly used and machine-readable format and have it transferred to another provider of the same or similar services. We do not consider that this right applies to our Website. However, to the extent it does, we will comply with such transfer request. Please note that a transfer to another provider does not imply erasure of the data subject’s personal data which may in some circumstances still be retained for legitimate and lawful purposes.
• Right to lodge a complaint with the supervisory authority. We suggest that you contact us about any questions or complaints in relation to how we process your personal data. However, you have the right to contact the relevant supervisory authority directly and in the Isle of Man this is the Information Commissioner on 01624 693260 or by emailing ask@inforights.im.

THIRD PARTY LINKS

You may find links to third party websites on our Website.  These websites should have their own privacy policy / notice for you to review.  Smart HR Solutions Limited has no control over any third-party websites and we do not accept responsibility or liability for any third-party policies or practices on third-party websites whatsoever.