Who are we?

SpinUp Search Ltd, a limited company registered in England and Wales (under company number 13844519, with Registered address at: 20-22 Wenlock Road, N1 7GU London, United Kingdom), is committed to protecting and respecting your privacy. This Privacy Notice (together with any other documents referred to herein) sets out the basis on which the personal data collected from you, or that you provide to Us, will be processed by Us in connection with Our processes. Please read the following carefully to understand Our views and practices regarding your personal data and how We will treat it.

For the purpose of the General Data Protection Regulation (“GDPR”) and the version of the GDPR retained in UK law (the “UK GDPR”) the Data Controller is SpinUp Search Ltd.

We apply this Privacy Policy to the personal data of our Website Users, Candidates, Clients and people whom we will contact during the recruitment process.

What type of information do we collect?

We receive, collect and store any information you enter on our website or provide us in any other way. In addition, we collect the Internet protocol (IP) address used to connect your computer to the Internet; e-mail address; computer and connection information. We may use software tools to measure and collect session information, including page response times, length of visits to certain pages, page interaction information, and methods used to browse away from the page. We also collect personally identifiable information.

Clients:

We collect information such as Company Name, Company Address, Contact name, work address, email address, phone number, position at company.

Candidates:

In particular, We process personal details such as name, email address, address, telephone number, date of birth, qualifications, experience, information relating to your employment history, skills experience that you provide to Us, as well as your video in case you conduct your interview using the Video Interview feature.

If you contact Us, We may keep a record of that correspondence, a record of your progress through any hiring process that we may conduct.

Details of your visits to our Carrier Portal including, but not limited to, traffic data, location data, weblogs and other communication data, the site that referred you the Carrier Portal and the resources that you access.

Third parties

We may collect also further information about you from third parties,
including information about your previous work performance from the referees
named in your CV, information about your work experience or professional profile from social media.

Website visitors:

We receive, collect and store any information you enter on our website or provide us in any other way. In addition, we collect the Internet protocol (IP) address used to connect your computer to the Internet; login; e-mail address; password; computer and connection information. We may use software tools to measure and collect session information, including page response times, length of visits to certain pages, page interaction information, and methods used to browse away from the page.

How do we collect information?

Clients:

When you complete a form on our website, such as contact us, subscribe, as part of the process, we collect personal information you give us such as your name, address and email address. Your personal information will be used for the specific reasons stated above only.

Candidates:

We use Manatal, a cloud-based recruitment software by Manatal Company Limited, to assist with Our recruitment process. We use Manatal to process personal information as a data processor on Our behalf. Manatal is only entitled to process your personal data in accordance with Our instructions.

Where you apply for a job opening through our career page powered by Manatal at https://www.careers-page.com/spinup-search-ltd, and submit our application by clicking on the Apply now button, or submit your CV to us by email, these Privacy Notice provisions will apply to Our processing of your personal information in addition to our Website Terms of Use (where applicable) which has been provided to you separately or is available on Our Website.

Where you apply for a job opening via the application function on a job site or similar online service provider (“Partner”), including our career page, or opt-in for a reference and background checks, you should note that the relevant Partner may retain your personal data and may also collect data from Us in respect of the progress of your application. Any use by the Partner of your data will be in accordance with the Partner’s Privacy Notice.

Manatal’s privacy policy: https://www.manatal.com/privacy-policy/

Why do we collect such information?

Lawful basis for processing:

We rely on legitimate interest as the lawful basis on which We collect and use your personal data. Our legitimate interests are the recruitment of staff for Our business.

Clients:

We collect such information for the purpose of building adequate talent pool during the recruitment process.

Candidates:

Purposes of processing:

We use information held about you in the following ways:

• To consider your application in respect of a role for which you have applied.
• To consider your application in respect of other roles.
• To communicate with you in respect of the recruitment process.
• To enhance any information that we receive from you with information obtained from third party data providers.
• To find appropriate candidates to fill Our job openings.
• To help our service providers (such as Manatal and its processors and data providers) and Partners (such as the job sites through which you may have applied) improve their services.

• Where you apply for a job opening through the Indeed Apply functionality, we rely on your consent, which is freely given by you during the application process, to disclose your personal data to Indeed on the basis described below.

Automated decision making/profiling

We may use Manatal’s technology to select appropriate candidates for Us to consider based on criteria expressly identified by us, or typical in relation to the role for which you have applied. The process of finding suitable candidates is automatic, however, any decision as to who We will engage to fill the job opening will be made by Our staff.

Whom do we share your information with?

Clients:

We share your data primarily with Candidates and Prospective Candidates to ensure that we provide you with a suitable pool of Candidates.

Candidates:

As set out above, we pass your information to our third party service providers, including Manatal, who use it only in accordance with our instructions and as otherwise required by law.

Where you have applied for a job opening through the Indeed Apply functionality, and where you have consented to this disclosure, We will disclose to Indeed certain personal data that We hold, including but not limited to a unique identifier used by Indeed to identify you, and information about your progress through our hiring process for the applicable job opening, as well as tangible, intangible, visual, electronic, present, or future information that we hold about you, such as your name, contact details and other information involving analysis of data relating to you as an applicant for employment (collectively “Disposition Data”). Indeed’s Privacy Notice in respect of Indeed’s use of the Disposition Data is available on Indeed’s website.

Where you have applied to a job opening through another service provider, we may disclose data similar to the Disposition Data defined above to such service provider. The service provider shall be the data controller of this data and shall therefore be responsible for complying with all applicable law in respect of the use of that data following its transfer by Us.

We also disclose your information to our Clients through email and Manatal’s portal. We disclose information that we collected from you during the application process.

Website users:

Unless you specify otherwise, we will share your information with providers of web analytics services such as Visitor Analytics, marketing automation platforms such as Wix Ascend, and social media services such as LinkedIn and Twitter.

How We store your Personal Data

Security

Our company is hosted on the Wix.com platform. Wix.com provides us with the online platform that allows us to sell our products and services to you. Your data may be stored through Wix.com’s data storage, databases and the general Wix.com applications. They store your data on secure servers behind a firewall.

Our career portal is hosted on the https://www.careers-page.com/spinup-search-ltd platform. Manatal provides us with the online platform that allows us to search and introduce candidates to our Clients. Your data may be stored through Manatal’s data storage, databases and the general Manatal applications. They store your data on secure servers behind a firewall.

We take appropriate measures to ensure that all personal data is kept secure including security measures to prevent personal data from being accidentally lost, or used or accessed in an unauthorised way. On our recruitment platform, We limit access to your personal data to those who have a genuine business need to know it. Those processing your information will do so only in an authorised manner and are subject to a duty of confidentiality.

We also have procedures in place to deal with any suspected data security breach. We will notify you and any applicable regulator of a suspected data security breach where We are legally required to do so.

Unfortunately, the transmission of information via the internet is not completely secure. Although We will do Our best to protect your personal data, We cannot guarantee the security of your data transmitted through any online means, therefore any transmission remains at your own risk.

How do we communicate with you?

We may contact you to notify you regarding your application, to send updates about our company, or as otherwise necessary to contact you to enforce our User Agreement, applicable national laws, and any agreement we may have with you. For these purposes we may contact you via email, telephone, text messages, and postal mail.

How do we use Cookies and other tracking tools?

Our website tracks personal information through the use of cookies. You can access our Cookies Policy here.

How long we keep your Personal Data

We will hold all data collected, used and shared for recruitment purposes for 5 years.

We will hold all data collected, used and shared for other purposes such as analytics and marketing for 12 months.

Your personal information will be deleted on one of the following occurrences:

• deletion of your personal information by you (or by another person engaged by the Client); or
• receipt of a written request by you (or another person engaged by the Client) to us.

Your rights

Under the General Data Protection Regulation and the UK GDPR, you have a number of important rights free of charge. In summary, those include rights to:

• access to your personal data and to certain other supplementary information that this Privacy Notice is already designed to address
• require Us to correct any mistakes in your information which We hold
• require the erasure of personal data concerning you in certain situations
• receive the personal data concerning you which you have provided to Us, in a structured, commonly used and machine-readable format and have the right to transmit those data to a third party in certain situations
• object at any time to processing of personal data concerning you for direct marketing
• object to decisions being taken by automated means which produce legal effects concerning you or similarly significantly affect you
• object in certain other situations to our continued processing of your personal data
• otherwise restrict our processing of your personal data in certain circumstances
• claim compensation for damages caused by our breach of any data protection laws.

For further information on each of those rights, including the circumstances in which they apply, see the Guidance from the UK Information Commissioner’s Office (ICO) on individuals rights under the UK GDPR.

If you would like to exercise any of those rights, please:

• contact us using our Contact details below
• let Us have enough information to identify you,
• let Us have proof of your identity and address, and
• let Us know the information to which your request relates.

How to complain

We hope that We can resolve any query or concern you raise about Our use of your information.

The General Data Protection Regulation and the UK GDPR also gives you right to lodge a complaint with a supervisory authority, in particular (under the GDPR) in the European Union (or European Economic Area) state where you work, normally live or where any alleged infringement of data protection laws occurred. The supervisory authority in the UK is the Information Commissioner who may be contacted at https://ico.org.uk/make-a-complaint or telephone: 0303 123 1113.

Changes to our Privacy Policy

We reserve the right to modify this privacy policy at any time, so please review it frequently. Changes and clarifications will take effect immediately upon their posting on the website. If we make material changes to this policy, we will notify you here that it has been updated, so that you are aware of what information we collect, how we use it, and under what circumstances, if any, we use and/or disclose it.

Contact

All questions, comments and requests regarding this Privacy Notice should be addressed to contactus@spinupsearch.com