BONHILL PARTNERS LTD – PRIVACY POLICY

Bonhill Partners Ltd, a company registered in England and Wales with company number 14359154 (“we,” “us,” or “our”), understands that protecting your personal data is important. This Privacy Policy sets out our commitment to protecting the privacy of personal data provided to us or otherwise collected by us when providing our website and recruitment services (“Services”) or when otherwise interacting with you.

It is important that you read this Privacy Policy together with any other detailed privacy notices we may provide when we are collecting or processing personal data about you so that you understand our privacy practices in relation to your data.

The Information We Collect

Personal data: is information that relates to an identified or identifiable individual. We may collect, use, store, and disclose different kinds of personal data about you which we have listed below.

Where you are applying for a role with one of our customers (Candidate):

Identity Data: including first name, middle name, last name, date of birth, job title, and photographic identification.
Contact Data: including address, email address, and telephone numbers.
Professional Data: including your professional history such as your previous positions and professional experience.

Where you are applying for a role with us (Internal Candidate):

Identity Data: including first name, middle name, last name, date of birth, job title, and photographic identification.
Contact Data: including address, email address, and telephone numbers.
Financial Data: including bank account.
Background Verification Data: including your passport number, photographic identification, or other details requested as part of our onboarding process to comply with our due diligence obligations and related ongoing monitoring commitments.
Transaction Data: including details about payments to you from us and from you to us and other details of products and services you have purchased from us or we have purchased from you.
Professional Data: including your professional history such as your previous positions and professional experience.
Special Categories of Personal Data: is a special category of personal data that includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health, and genetic and biometric data. In the course of providing our Services, we may collect or come across such special categories of personal data in different situations including during the course of conducting a background verification check on you and when reviewing your CV. The types of special categories of data we may collect include information about any criminal convictions and offences.

Where you are a business contact for a customer of ours (Business Contact):

Identity Data: including first name, last name, and job title.
Contact Data: including billing address, email address, and telephone numbers.
Financial Data: including bank account and payment card details (through our third-party payment processor Xero).
Transaction Data: including details about payments to you from us and from you to us and other details of services you have purchased from us or we have purchased from you.

Where you are a Candidate, Internal Candidate, Business Contact, or any user of our website:

Technical and Usage Data: including internet protocol (IP) address, your browser session and geo-location data, device and network information, statistics on page views and sessions, acquisition sources, search queries, and/or browsing behavior, information about your access and use of our website including through the use of Internet cookies, your communications with our website, the type of browser you are using, the type of operating system you are using, and the domain name of your Internet service provider.
Marketing and Communications Data: including your preferences in receiving marketing from us and our third parties and your communication preferences.

How We Collect Personal Data

We collect personal data in a variety of ways including:

Directly: We collect personal data which you directly provide to us including when you register your details with us for the purpose of applying for a role we are recruiting for, through the ‘contact us’ form on our website, or when you request our assistance via email or over the telephone.
Indirectly: We may collect personal data which you indirectly provide to us while interacting with us such as when you use our website, in emails, over the telephone, and in your online enquiries.
From third parties: We collect personal data from third parties such as details of your use of our website from our analytics and cookie providers and marketing providers. See the “Cookies” section below for more detail on the use of cookies.
From publicly available sources: We collect personal data from publicly available resources such as networking sites like LinkedIn.

Purposes and Legal Bases for Processing

We collect and process personal data about you only where we have legal bases for doing so under applicable laws. We have set out below in a table format a description of all the ways we plan to use your personal data and which of the legal bases we rely on to do so. We have also identified what our legitimate interests are where appropriate. Note that we may process your personal data for more than one lawful ground depending on the specific purpose for which we are using your data. Please reach out to us if you need further details about the specific legal ground we are relying on to process your personal data where more than one ground has been set out in the table below.

<tdstyle=”border: 1px solid white;”>To consider whether you would be a suitable Candidate or Internal Candidate including to assess your application for employment with us or one of our clients.

Purpose of Use / Disclosure	Type of Data	Legal Basis for Processing
If you are a Candidate or Internal Candidate your: Identity Data, Contact Data, Professional Data. If you are an Internal Candidate your: Background Verification Data, Special Categories of Personal Data	Legitimate interests: to provide our Services and ensure we are a good fit for working together
To provide your details to your prospective workplace if we assess you to be a suitable Candidate.	If you are a Candidate your: Identity Data, Contact Data, Professional Data	Legitimate interests: to provide our Services
To provide our Services including to recruit for the roles available in your business.	If you are a Business Contact your: Identity Data, Contact Data, Financial Data, Transaction Data	Performance of a contract with you
To contact and communicate with you about our Services including in response to any support requests you lodge with us or other enquiries you make with us.	If you are a Candidate, Internal Candidate, or a Business Contact: Identity Data, Contact Data	Performance of a contract with you
To contact and communicate with you about any enquiries you make with us via our website.	If you are a Candidate, Internal Candidate, or a Business Contact: Identity Data, Contact Data	Legitimate interests: to ensure we provide the best client experience we can offer by answering all of your questions.
For internal record keeping, administrative, invoicing and billing purposes.	If you are a Candidate or Internal Candidate: Identity Data, Contact Data. If you are a Business Contact: Identity Data, Contact Data, Financial Data, Transaction Data	Performance of a contract with you, To comply with a legal obligation, Legitimate interests: to recover debts due to us and ensure we can notify you about changes to our terms of business and any other administrative points
For analytics, market research, and business development including to operate and improve our Services, associated applications, and associated social media platforms.	If you are a Candidate, Internal Candidate, or a Business Contact: Technical and usage Data	Legitimate interests: to keep our website updated and relevant, to develop our business, improve our Services, and to inform our marketing strategy
For advertising and marketing Here is the continuation and completion of the formatted privacy policy text in HTML: “`html purposes and grow our business	If you are a Candidate, Internal Candidate, or a Business Contact: Identity Data, Contact Data, Technical and usage Data, Marketing and communications Data	Legitimate interests: to develop our Services and grow our business
To run promotions, competitions, and/or offer additional benefits to you.	If you are a Candidate, Internal Candidate, or a Business Contact: Identity Data, Contact Data, Marketing and communications Data	Legitimate interests: to facilitate engagement with our business and grow our business
To comply with our legal obligations or if otherwise required or authorised by law.	All applicable personal data	To comply with a legal obligation

If you have consented to our use of data about you for a specific purpose, you have the right to change your mind at any time, but this will not affect any processing that has already taken place. Where we are using your data because we or a third party have a legitimate interest to do so, you have the right to object to that use, though in some cases this may mean no longer using our services. Further information about your rights is available below.

Our Disclosures of Personal Data to Third Parties

We may disclose personal data to:

Our employees, contractors, and/or related entities;
IT service providers, data storage, web-hosting, and server providers such as Microsoft or Vincere;
Marketing or advertising providers;
Professional advisors, bankers, auditors, our insurers and insurance brokers;
Payment systems operators such as Xero;
Our existing or potential agents or business partners;
Anyone to whom our business or assets (or any part of them) are or may (in good faith) be transferred;
Courts, tribunals, and regulatory authorities in the event you fail to pay for goods or services we have provided to you;
Courts, tribunals, regulatory authorities, and law enforcement officers as required or authorised by law in connection with any actual or prospective legal proceedings or in order to establish, exercise, or defend our legal rights;
Third parties to collect and process data such as Google Analytics (To find out how Google uses data when you use third-party websites or applications please see www.google.com/policies/privacy/partners/ or any other URL Google may use from time to time), Facebook Pixel or other relevant analytics businesses; and
Any other third parties as required or permitted by law, such as where we receive a summons.

Google Analytics: We have enabled Google Analytics Advertising Features including Remarketing Features, Advertising Reporting Features, Demographics and Interest Reports, Store Visits, Google Display Network Impression reporting, etc. We and third-party vendors use first-party cookies (such as the Google Analytics cookie) or other first-party identifiers and third-party cookies (such as Google advertising cookies) or other third-party identifiers together. You can opt-out of Google Analytics Advertising Features including using a Google Analytics Opt-out Browser add-on found here. To opt-out of personalised ad delivery on the Google content network, please visit Google’s Ads Preferences Manager here, or if you wish to opt-out permanently even when all cookies are deleted from your browser, you can install their plugin here. To opt out of interest-based ads on mobile devices, please follow these instructions for your mobile device: On android, open the Google Settings app on your device and select “ads” to control the settings. On iOS devices with iOS 6 and above, use Apple’s advertising identifier. To learn more about limiting ad tracking using this identifier, visit the settings menu on your device.

Overseas Transfers

Where we disclose personal data to the third parties listed above, these third parties may store, transfer, or access personal data outside of the United Kingdom. The level of data protection in countries outside of the United Kingdom may be less comprehensive than what is offered in the United Kingdom. Where we transfer your personal data outside of the United Kingdom, we will perform those transfers using appropriate safeguards in accordance with the requirements of applicable data protection laws and we will protect the transferred personal data in accordance with this Privacy Policy. This includes:

Only transferring your personal data to countries that have been deemed by applicable data protection laws to provide an adequate level of protection for personal data; or
Including standard contractual clauses in our agreements with third parties that are overseas.

Data Retention

We will only retain your personal data for as long as reasonably necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, regulatory, tax, accounting, or reporting requirements. We may retain your personal data for a longer period in the event of a complaint or if we reasonably believe there is a prospect of litigation in respect to our relationship with you.

To determine the appropriate retention period for personal data, we consider the amount, nature, and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data, and whether we can achieve those purposes through other means, and the applicable legal, regulatory, tax, accounting, or other requirements.

Your Rights and Controlling Your Personal Data

Your Choice: Please read this Privacy Policy carefully. If you provide personal data to us, you understand we will collect, hold, use, and disclose your personal data in accordance with this Privacy Policy. You do not have to provide personal data to us; however, if you do not, it may affect our ability to provide our Services to you and your use of our Services.

Information from Third Parties: If we receive personal data about you from a third party, we will protect it as set out in this Privacy Policy. If you are a third party providing personal data about somebody else, you represent and warrant that you have such person’s consent to provide the personal data to us.

Access, Correction, Processing, and Portability: You may request details of the personal data that we hold about you and how we process it (commonly known as a “data subject request”). You may also have a right in accordance with applicable data protection law to have your personal data rectified or deleted, to restrict our processing of that information, to object to decisions being made based on automated processing where the decision will produce a legal effect or a similarly significant effect on you, to stop unauthorised transfers of your personal data to a third party, and in some circumstances to have personal data relating to you transferred to you or another organisation.

Unsubscribe: To unsubscribe from our e-mail database or opt-out of communications (including marketing communications), please contact us using the details below or opt-out using the opt-out facilities provided in the communication.

Withdraw Consent: Where we are relying on consent to process your personal data, you have the right to withdraw your consent at any time. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain products or services to you. We will advise you if this is the case at the time you withdraw your consent.

Complaints: If you wish to make a complaint, please contact us using the details below and provide us with full details of the complaint. We will promptly investigate your complaint and respond to you in writing setting out the outcome of our investigation and the steps we will take to deal with your complaint. You have the right to make a complaint at any time to the Information Commissioner’s Office (ICO), the UK regulator for data protection issues (www.ico.org.uk). We would however appreciate the chance to deal with your concerns before you approach the ICO, so please contact us in the first instance.

Storage and Security

We are committed to ensuring that the personal data we collect is secure. In order to prevent unauthorised access or disclosure, we have put in place suitable physical, electronic, and managerial procedures to safeguard and secure personal data and protect it from misuse, interference, loss, and unauthorised access, modification, and disclosure.

While we are committed to security, we cannot guarantee the security of any information that is transmitted to or by us over the Internet. The transmission and exchange of information is carried out at your own risk.

Cookies

We may use cookies on our website from time to time. Cookies are text files placed in your computer’s browser to store your preferences