ENLIGHTEN SUPPLY POOL PRIVACY POLICY

INTRODUCTION

1. We are committed to safeguarding the privacy of our website visitors and service users.

2. This policy applies where we are acting as a data controller with respect to the personal data of our website visitors and service users; in other words, where we determine the purposes and means of the processing of that personal data.

3. We will ask you to consent to our use of cookies in accordance with the terms of this policy when you first visit our website. OR By using our website and agreeing to this policy, you consent to our use of cookies in accordance with the terms of this policy.

4. In this policy, “we”, “us” and “our” refer to Enlighten Supply Pool.

HOW WE USE YOUR PERSONAL DATA

In this Section 2 we have set out:

• the general categories of personal data that we may process;

• in the case of personal data that we did not obtain directly from you, the source and specific categories of that data;

• the purposes for which we may process personal data; and

• the legal bases of the processing.

1. “We may process data about your use of our website and services (“usage data”). The usage data may include your IP address, geographical location, browser type and version, operating system, referral source, length of visit, page views and website navigation paths, as well as information about the timing, frequency and pattern of your service use.” The source of the usage data is our analytics tracking system. This usage data may be processed for the purposes of analysing the use of the website and services. The legal basis for this processing is your explicit consent OR our legitimate interests, namely monitoring and improving our website and services.

2. We may process your account data (“account data”). The account data may include your name and email address. The source of the account data is you or your employer. The account data may be processed for the purposes of operating our website, providing our services, ensuring the security of our website and services, maintaining back-ups of our databases and communicating with you. The legal basis for this processing is your explicit consent OR our legitimate interests, namely the proper administration of our website and business OR the performance of a contract between you and us and/or taking steps, at your request, to enter into such a contract.

3. We may process your information included in your personal profile on our website (“profile data”). The profile data may include your name, address, telephone number, email address, profile pictures, gender, date of birth, relationship status, interests and hobbies, educational details and employment details. The profile data may be processed for the purposes of enabling and monitoring your use of our website and services. The legal basis for this processing is your explicit consent OR our legitimate interests, namely the proper administration of our website and business OR the performance of a contract between you and us and/or taking steps, at you request, to enter into such a contract.

4. We may process your personal data that are provided for the course of the use of our services (“service data”). The source of the service data is you or your employer. The service data may be processed for the purposes of operating our website, providing our services, ensuring the security of our website and services, maintaining back-ups of our databases and communicating with you. The legal basis for this processing is your explicit consent OR our legitimate interests, namely the proper administration of our website and business OR the performance of a contract between you and us and/or taking steps, at your request, to enter into such a contract.

5. We may process information that you post for publication on our website or through our services (“publication data”). The publication data may be processed for the purposes of enabling such publication and administering our website and services. The legal basis for this processing is your explicit consent OR our legitimate interests, namely the proper administration of our website and business OR the performance of a contract between you and us and/or taking steps, at your request, to enter into such a contract.

6. We may process information contained in any enquiry you submit to us regarding goods and/or services (“enquiry data”). The enquiry data may be processed for the purposes of offering, marketing and selling relevant goods and/or services to you. The legal basis for this processing is your explicit consent.

7. We may process information relating to transactions, including purchases of goods and services, that you enter into with us and/or through our website (“transaction data”). The transaction data may include your contact details, your card details and the transaction details. The transaction data may be processed for the purpose of supplying the purchased goods and services and keeping proper records of those transactions. The legal basis for this processing is the performance of a contract between you and us and/or taking steps, at your request, to enter into such a contract and our legitimate interests, namely our interest in the proper administration of our website and business.

8. We may process information that you provide to us for the purpose of subscribing to our email notifications and/or newsletters (“notification data”). The notification data may be processed for the purposes of sending you the relevant notifications and/or newsletters. The legal basis for this processing is your explicit consent OR the performance of a contract between you and us and/or taking steps, at your request, to enter into such a contract.

9. We may process information contained in or relating to any communication that you send to us (“correspondence data”). The correspondence data may include the communication content and metadata associated with the communication. Our website will generate the metadata associated with communications made using the website contact forms. The correspondence data may be processed for the purposes of communicating with you and record-keeping.

10. We may process personal data for the use of job applications. This data may include Your name, address, town/city, postcode, email address, telephone, CV content which may include prior work history and education history, hobbies and interests. The source of this data is your CV/Resume. This data may be processed for job applications. The legal basis for this processing is your consent when you apply for a job or register on this website OR the performance of a contract between you and us and/or taking steps, at your request, to enter into such a contract.

11. We may process any of your personal data identified in this policy where necessary for the establishment, exercise or defence of legal claims, whether in court proceedings or in an administrative or out-of-court procedure. The legal basis for this processing is our legitimate interests, namely the protection and assertion of our legal rights, your legal rights and the legal rights of others.

12. We may process any of your personal data identified in this policy where necessary for the purposes of obtaining or maintaining insurance coverage, managing risks, or obtaining professional advice. The legal basis for this processing is our legitimate interests, namely the proper protection of our business against risks.

13. In addition to the specific purposes for which we may process your personal data set out in this Section 2, we may also process any of your personal data where such processing is necessary for compliance with a legal obligation to which we are subject, or in order to protect your vital interests or the vital interests of another natural person.

14. Please do not supply any other person’s personal data to us, unless we prompt you to do so.

RETAINING AND DELETING PERSONAL DATA

This Section sets out our data retention policies and procedure, which are designed to help ensure that we comply with our legal obligations in relation to the retention and deletion of personal data.

Personal data that we process for any purpose or purposes shall not be kept for longer than is necessary for that purpose or those purposes.

We will retain your personal data as follows:

1. Personal data category or categories will be retained for a minimum period of 1 year following the date of collection, and for a maximum period of 6 years (AS per the OFSTED Rules) following the date the data was collected.

2. In some cases, it is not possible for us to specify in advance the periods for which your personal data will be retained. In such cases, we will determine the period of retention based on the following criteria:

3. The period of retention of your collected data will be determined based on up to date personal information such as CV, email or telephone number.

4. If the candidate has got the DBS certificate issue from ESP, the Data must be retained for 7 year as per the OSFTED guidelines.

5. If the Candidates already have got the DBS Certificate from external sources, his or her Data is subjected to above mentioned retention policies.

Notwithstanding the other provisions of this Section, we may retain your personal data where such retention is necessary for compliance with a legal obligation to which we are subject, or in order to protect your vital interests or the vital interests of another natural person.

SECURITY OF PERSONAL DATA

1. We have appropriate technical and organisational precautions & principles in place to secure your personal data and to prevent the loss, misuse or alteration of your personal data.

2. We will store all your personal data on secure Encrypted server’s hardware, Encrypted Office computers or Laptops and also in secure manual record-keeping systems.

3. The following personal data will be stored by us in encrypted form: your password(s).

4. Data relating to your enquiries and financial transactions that is sent from your web browser to our web server, or from our web server to your web browser, will be protected using encryption technology.

5. You acknowledge that the transmission of unencrypted (or inadequately encrypted) data over the internet is inherently insecure, and we cannot guarantee the security of data sent over the internet.

6. You should ensure that your password is not susceptible to being guessed, whether by a person or a computer program. You are responsible for keeping the password you use for accessing our website confidential and we will not ask you for your password (except when you log in to our website).