myGwork ("We") are committed to protecting and respecting your privacy.
This policy together with our Terms of Use 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 the following carefully to understand our views and practices regarding your personal data and how we will treat it. By visiting www.mygwork.com you are accepting and consenting to the practices described in this policy.
For the purpose of the Data Protection Act 1998 (the Act), the data controller is Gaubert’s Brothers Limited (Company registration number 08967439) with its registered office being myGwork, 86-90 Paul Street, London EC2A 4NE, UK.
Information we collect from you
Welcome
to the myGwork's
privacy policy.
myGwork
respects your privacy and is committed to protecting your personal data. This
privacy policy will inform you as to how we look after your personal data when
you visit our website (regardless of where you visit it from) and tell you
about your privacy rights and how the law protects you.
Please
also use the Glossary to understand the meaning of some of the terms used in
this privacy policy.
Purpose
of this privacy policy
This
privacy policy aims to give you information on how myGwork collects and
processes your personal data through your use of this website, including any
data you may provide through this website when you sign up to our newsletter or
register as a member.
This
website is not intended for children and we do not knowingly collect data
relating to children.
It
is important that you read this privacy policy together with any other privacy
policy or fair processing policy we may provide on specific occasions when we
are collecting or processing personal data about you so that you are fully
aware of how and why we are using your data. This privacy policy supplements
other notices and privacy policies and is not intended to override them.
Controller
Gaubert’s
Brothers Limited is the controller and responsible for your personal data
collectively referred to as “Company”, “myGwork”, "we",
"us", or "our" in this privacy policy.
Changes to the privacy policy and your
duty to inform us of changes
We
keep our privacy policy under regular review.
It
is important that the personal data we hold about you is accurate and current.
Please keep us informed if your personal data changes during your relationship
with us.
Third-party links
This
website may include links to third-party websites, plug-ins and applications.
Clicking on those links or enabling those connections may allow third parties
to collect or share data about you. We do not control these third-party
websites and are not responsible for their privacy statements. When you leave
our website, we encourage you to read the privacy policy of every website you
visit.
Information we collect about you
Personal
data, or personal information, means any information about an individual from
which that person can be identified. It does not include data where the
identity has been removed (anonymous data).
We
may collect, use, store and transfer different kinds of personal data about you
which we have grouped together as follows:
Identity Data includes first name, last name,
username or similar identifier, title, date of birth, gender, job title, and
profession.
Contact Data includes email address and telephone
numbers.
Technical Data includes internet protocol (IP)
address, your login data, browser type and version, time zone setting and
location, browser plug-in types and versions, operating system and platform,
and other technology on the devices you use to access this website.
Profile Data includes your username and password, your
interests, preferences, feedback and survey responses.
Usage Data includes information about how you use
our website.
Marketing and Communications Data includes your preferences in receiving marketing from us
and our third parties and your communication preferences.
We also
collect, use and share Aggregated Data
such as statistical or demographic data for any purpose. Aggregated Data could
be derived from your personal data but is not considered personal data in law
as this data 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, 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 policy.
We do not
collect any Special Categories of
Personal Data about you (this 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). Nor do we collect any information about criminal
convictions and offences.
How is your personal data collected?
We
use different methods to collect data from and about you including through:
Direct
interactions. You may give us your Identity and Contact by filling in
forms or by corresponding with us by post, phone, email or otherwise. This
includes personal data you provide when you:
create an
account on our website;
subscribe to
our publications;
request
marketing to be sent to you;
enter a
competition, promotion or survey; or
give us
feedback or contact us.
Automated
technologies or interactions.
As you interact with our website, we will automatically collect Technical Data
about your equipment, browsing actions and patterns. We collect this personal
data by using cookies, server logs, and other similar technologies. We may also
receive Technical Data about you if you visit other websites employing our
cookies. Please see our cookie policy below for further details.
Third
parties or publicly available sources.
We will receive personal data about you from various third parties and public
sources as set out below:
·
Identity
and Contact Data from publicly available sources such as Companies House.
·
When
your employer or school buys an organisational membership for you to use, they
give us data about you; others buying our Services for your use, such as your
employer or your school, provide us with personal data about you and your
eligibility to use the Services that they purchase for use by their workers,
students or alumni
How we use your personal data
·
We
will only use your personal data when the law allows us to. Most commonly, we
will use your personal data in the following circumstances:
·
Where
it is necessary for our legitimate interests (or those of a third party) and
your interests and fundamental rights do not override those interests.
·
Where
we need to comply with a legal obligation.
·
Our
Services allow you to stay in touch and up to date with colleagues, partners,
clients, and other professional contacts. To do so, you will “connect” with the
professionals who you choose, and who also wish to “connect” with you. Subject
to your settings, when you connect with other Members, you will be
able to search each other’s’ connections in order to exchange professional
opportunities.
·
We
will use data about you (such as your profile, profiles you have viewed or data
provided through address book uploads or partner integrations) to help others
find your profile, and enable you to invite others to become a Member and
connect with you.
·
When
you invite someone to connect with you, your invitation will include your name,
photo, network and contact information. We will send invitation reminders to
the person you invited.
·
Our
Services allow you to explore careers with our inclusive partners, evaluate
educational opportunities, and seek out, and be found for, career
opportunities. Your profile can be found by those looking to hire (for a job or
a specific task e.g. Speaking, networking and mentoring) or be hired
by you. We will use your data to recommend jobs or mentees, show you and others
who work at a company, in an industry, function or location or have certain
skills and connections. You can signal that you are interested in
changing jobs and share information with job recruiters by messaging them
directly or signalling that in your bio. We will use your data to recommend
jobs to you and you to recruiters. We may use automated systems to profile and
provide recommendations to help make our Services more relevant to our Members,
Visitors and customers. Keeping your profile accurate and up-to-date may help
you better connect to others and to opportunities through our Services.
·
Our
Services allow you to collaborate with colleagues, search for potential
clients, customers, partners and others to do business with. Our Services allow
you to communicate with other Members and schedule and prepare meetings with
them.
·
Generally,
we do not rely on consent as a legal basis for processing your personal data
although we will get your consent before sending third party direct marketing
communications to you via email or text message. You have the right to withdraw
consent to marketing at any time by contacting us.
·
Your employer may offer you access to our enterprise Services such as
Recruiter, Sales Navigator, mygwork Learning or our advertising Campaign
Manager. Your employer can review and manage your use of such enterprise
Services.
·
Depending on the enterprise Service, before you use such Service, we
will ask for permission to share relevant data from your profile or use of our
non-enterprise Services. We understand that certain activities such as job
hunting and personal messages are sensitive, and so we do not share those with
your employer unless you choose to share it with them through our Services (for
example, by applying for a new position in the same company or mentioning your
job hunting in a message to a co-worker through our Services).
Purposes for which we will use your
personal data
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
contact us if you need 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.
Purpose/Activity |
Type of data |
Lawful basis for processing including
basis of legitimate interest |
To manage our
relationship with you which will include: (a) Notifying
you about changes to our terms or privacy policy
|
(a) Identity (b) Contact (c) Profile (d) Marketing
and Communications |
(a)
Performance of a contract with you (b) Necessary
to comply with a legal obligation (c) Necessary
for our legitimate interests (to keep our records updated and to study how
customers use our products/services) |
To enable you
to partake in a prize draw, competition or complete a survey |
(a) Identity (b) Contact (c) Profile (d) Usage (e) Marketing
and Communications |
(a)
Performance of a contract with you (b) Necessary
for our legitimate interests (to study how customers use our
products/services, to develop them and grow our business) |
To administer
and protect our business and this website (including troubleshooting, data
analysis, testing, system maintenance, support, reporting and hosting of
data) |
(a) Identity (b) Contact (c) Technical |
(a) Necessary
for our legitimate interests (for running our business, provision of
administration and IT services, network security, to prevent fraud and in the
context of a business reorganisation or group restructuring exercise) (b) Necessary
to comply with a legal obligation |
To deliver
relevant website content and advertisements to you and measure or understand
the effectiveness of the advertising we serve to you |
(a) Identity (b) Contact (c) Profile (d) Usage (e) Marketing
and Communications (f) Technical
|
Necessary for
our legitimate interests (to study how customers use our products/services,
to develop them, to grow our business and to inform our marketing strategy) |
To use data
analytics to improve our website, products/services, marketing, customer
relationships and experiences |
(a) Technical
(b) Usage |
Necessary for
our legitimate interests (to define types of customers for our products and
services, to keep our website updated and relevant, to develop our business
and to inform our marketing strategy) |
To make
suggestions and recommendations to you about goods or services that may be of
interest to you |
(a) Identity (b) Contact (c) Technical
(d) Usage (e) Profile (f) Marketing and Communications |
Necessary for
our legitimate interests (to develop our products/services and grow our
business) |
We
strive to provide you with choices regarding certain personal data uses,
particularly around marketing and advertising. We have established the
following personal data control mechanisms:
Promotional offers from us
We
may use your Identity, Contact, Technical, Usage and Profile Data to form a
view on what we think you may want or need, or what may be of interest to you.
You
will receive marketing communications from us if you have requested information
from us and you have not opted out of receiving that marketing.
Third-party marketing
We will get
your express opt-in consent before we share your personal data with any third
party for marketing purposes.
Opting out
You can ask us or third parties to stop sending you marketing messages at any time by logging into the website and checking or unchecking relevant boxes to adjust your marketing preferences OR by following the opt-out links on any marketing message sent to you OR by contacting us at any time.
Glossary
LAWFUL BASIS
Legitimate Interest
means the interest of our business in conducting and managing our business to
enable us to give you the best service/product and the best and most secure
experience. We make sure we consider and balance any potential impact on you
(both positive and negative) and your rights before we process your personal
data for our legitimate interests. We do not use your personal data for
activities where our interests are overridden by the impact on you (unless we
have your consent or are otherwise required or permitted to by law). You can
obtain further information about how we assess our legitimate interests against
any potential impact on you in respect of specific activities by contacting us.
Performance of Contract
means processing your data where it is necessary for the performance of a
contract to which you are a party or to take steps at your request before
entering into such a contract.
Comply with a legal obligation
means processing your personal data where it is necessary for compliance with a
legal obligation that we are subject to.
THIRD PARTIES
Service
providers who provide IT and system administration services.
Professional
advisers including lawyers, bankers, auditors and insurers based in who provide
consultancy, banking, legal, insurance and accounting services.
HM Revenue
& Customs, regulators and other authorities based in the United Kingdom who
require reporting of processing activities in certain circumstances.
Cookies
You
can set your browser to refuse all or some browser cookies, or to alert you
when websites set or access cookies. If you disable or refuse cookies, please
note that some parts of this website may become inaccessible or not function
properly.
Our website uses cookies to distinguish you from other
users of our website. This helps us to provide you with a good experience when
you browse our website and also allows us to improve our site.
A
cookie is a small file of letters and numbers that we store on your browser or
the hard drive of your computer if you agree. Cookies contain information that
is transferred to your computer's hard drive.
We
use the following cookies:
- Strictly necessary cookies. These are cookies that are
required for the operation of our website. They include, for example,
cookies that enable you to log into secure areas of our website.
- Analytical or performance cookies. These allow us to recognise and
count the number of visitors and to see how visitors move around our
website when they are using it. This helps us to improve the way our
website works, for example, by ensuring that users are finding what they
are looking for easily.
- Functionality cookies. These are used to recognise you
when you return to our website. This enables us to personalise our content
for you, greet you by name and remember your preferences (for example,
your choice of language or region).
- Targeting cookies. These cookies record your visit to our website, the
pages you have visited and the links you have followed. We will use this
information to make our website and the advertising displayed on it more
relevant to your interests.
You
can block cookies by activating the setting on your browser that allows you to
refuse the setting of all or some cookies. However, if you use your browser
settings to block all cookies (including essential cookies) you may not be able
to access all or parts of our website.
Except
for essential cookies, all cookies will expire after the session.
Change of purpose
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.
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.
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.
Disclosures of your personal data
Third parties
to whom we may choose to sell, transfer or merge parts of our business or our
assets. Alternatively, we may seek to acquire other businesses or merge with
them. If a change happens to our business, then the new owners may use your
personal data in the same way as set out in this privacy policy. We require all third parties to respect the security of your
personal data and to treat it in accordance with the law. We do not allow our
third-party service providers to use your personal data for their own purposes
and only permit them to process your personal data for specified purposes and
in accordance with our instructions.
Where we store your personal data
Where we store your personal data
The data that
we collect from you is stored in a database in the Netherlands and will not be
transferred European Economic Area ("EEA"). It may also be processed
by staff operating inside the EEA who work for us or for one of our
contractors. Such staff maybe engaged in, among other things, the fulfilment of
your order for the products or services provided by us and the provision of
support services. By submitting your personal data, you agree to this transfer,
storing or processing. We will take all steps reasonably necessary to ensure
that your data is treated securely and in accordance with this Privacy Policy.
International transfers
We
do not transfer your personal data outside the European Economic Area (EEA).
Data security
We
have put in place appropriate security measures to prevent your personal data
from being accidentally lost, used or accessed in an unauthorised way, altered
or disclosed. In addition, we limit access to your personal data to those
employees, agents, contractors and other third parties who have a business need
to know. They will only process your personal data on our instructions, and
they are subject to a duty of confidentiality.
We
have put in place procedures to deal with any suspected personal data breach
and will notify you and any applicable regulator of a breach where we are
legally required to do so.
Data retention
How long will you use my personal data
for?
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.
Account
Closure
We keep some of
your data even after you close your account.If you choose to close your mygwork account, your personal data
will generally stop being visible to others on our Services within 24 hours. We
generally delete closed account information within 30 days of account closure,
except as noted below. We retain your personal data even after you have closed
your account if reasonably necessary to comply with our legal obligations
(including law enforcement requests), meet regulatory requirements, resolve
disputes, maintain security, prevent fraud and abuse, enforce our User
Agreement, or fulfill your request to “unsubscribe” from further messages from
us. We will retain de-personalized information after your account has been
closed. Information you have shared with others (e.g., through MyMessages,
updates or group posts) will remain visible after you closed your account or
deleted the information from your own profile or mailbox, and we do not control
data that other Members copied out of our Services. Groups content and ratings
or review content associated with closed accounts will show an unknown user as
the source. Your profile may continue to be displayed in the services of others
(e.g., search engine results) until they refresh their cache.
Your legal rights
Under
certain circumstances, you have rights under data protection laws in relation
to your personal data.
- Request access to your personal data (commonly
known as a "data subject access request"). This enables you to
receive a copy of the personal data we hold about you and to check that we
are lawfully processing it.
- Request correction of
the personal data that we hold about you. This enables you to have any
incomplete or inaccurate data we hold about you corrected, though we may
need to verify the accuracy of the new data you provide to us.
- Request erasure
of your personal data. This enables
you to ask us to delete or remove personal data where there is no good
reason for us continuing to process it. You also have the right to ask us
to delete or remove your personal data where you have successfully
exercised your right to object to processing (see below), where we may
have processed your information unlawfully or where we are required to
erase your personal data to comply with local law. Note, however, that we
may not always be able to comply with your request of erasure for specific
legal reasons which will be notified to you, if applicable, at the time of
your request.
- Object to 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 as you feel it impacts on your fundamental
rights and freedoms. You also have the right to object where we are
processing your personal data for direct marketing purposes. In some
cases, we may demonstrate that we have compelling legitimate grounds to
process your information which override your rights and freedoms.
- Request restriction of processing of
your personal data. This enables you to ask us to suspend the processing
of your personal data in the following scenarios:
- If you want us to
establish the data's accuracy.
- Where our use of
the data is unlawful but you do not want us to erase it.
- Where you need us
to hold the data even if we no longer require it as you need it to
establish, exercise or defend legal claims.
- You have objected
to our use of your data but we need to verify whether we have overriding
legitimate grounds to use it.
- Request the transfer of your personal data to you or to
a third party. We will provide to you, or a third party you have chosen,
your personal data in a structured, commonly used, machine-readable
format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the
information to perform a contract with you.
- Withdraw consent at any time where we are relying on consent to
process your personal data. 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.
If you wish to exercise any of the rights set out above,
please contact us at [email protected]
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 could refuse to comply with your request in these circumstances.
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.
We try to respond to all legitimate requests within one
month. Occasionally it could 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.
Contact
If
you have any questions about this privacy policy or our privacy practices,
please contact us:
Full
name of legal entity: Gaubert’s
Brothers Limited (myGwork)
Email
address: [email protected]
Postal
address: 86-90 Paul
Street, London, Greater London, EC2A 4NE
You
have the right to make a complaint at any time to the Information
Commissioner's Office (ICO), the UK supervisory authority 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.