Privacy Policy

Last updated: 1st Mar 2016  (Version 1.1)

We collect and use information from individual users and organisations who subscribe for the services we offer. This policy is here to help you understand what information we collect, how we use it, and what choices you have.

Some items contained in this policy may be relevant to planned or proposed application or website functionality that is not yet available. Depending on future decisions by the Company such functionality may never become available.

We are registered as a data controller in the UK with the Information Commissioner's Office (ICO). Our data protection registration number is ZA161273.

Definitions

Throughout this policy

"Candidate" refers to any worker using the Services in order to seek temporary or permanent employment within an Organisation

"Circular Wave Application" refers to the downloadable mobile application provided by the Company

"Company", "us", "we" and "our" refer to Circular Wave Limited, a company registered in England and Wales with Company Number 09854962 and registered address at James House, c/o Moorcrofts LLP, Mere Park, Dedmere Road, Marlow, Buckinghamshire, SL7 1FJ

"Organisation" refers to any organisation that subscribes for the services that the Company offers

"organisational information" refers to any information about an organisation

"personal information" refers to any information about you as an individual user

"information" is used to refer to both personal information and organisational information

"notification" may refer to push notifications, SMS messaging, or email messaging generated and sent by the Services

"Website" refers to the Company’s website at https://circularwave.co.uk

"you" and "user" refers to yourself as an individual user

Our principles

1We will collect and use information only with permission and where there are clear reasons for doing so, for example collecting enough information about you to use our services.

2We will be clear with you about what information about you we will collect and how we will use it.

3We will use information only for the purposes for which it was originally collected, and we will make sure we delete it securely.

4We do our very best to protect your privacy by ensuring that we and any third parties we use have appropriate security measures to protect your information.

5We will respect your privacy. However, we may occasionally send you notifications with important information about us or our services, requests for product feedback, questions about your registration or your account.

Information we collect and receive

We may collect, store and use the following kinds of information

Information about your computer or mobile device and about usage. This may include

  • your IP address
  • your geographical location
  • your computer or device type, and its operating system
  • your browser type and version
  • details of any referring website or email
  • length of your Website visit or app usage
  • page views and any interactions with the Services that you may make

Personal information that you provide to us when registering with the Services as an individual user, or when subscribing to notifications and updates. This may include, but is not limited to

  • your name
  • your email address
  • other contact details such as your telephone number
  • your date of birth
  • profile images
  • professional registration details (where applicable)
  • details of your current employer and job role
  • previous job history
  • information and documentation pertaining to various employment checks

Organisational information. This may include

  • organisation name
  • organisation address
  • relevant registration numbers (e.g. VAT) for your organisation
  • workforce data, e.g. total numbers of staff and breakdown by staff group
  • financial data, e.g. current and historical spend on agency staff

Billing information required to make payment for any of our services

Information that you provide to us in order to use our services. This includes information generated in the course of using those services, and includes but is not limited to

  • details of jobs you apply for, or your organisation creates
  • timing, frequency and pattern of service use

Information contained in or relating to any communication that you send to us. This includes any information sent to us via the Services and via email and applies to both content and metadata associated with the communication.

Security of information

We will take all reasonable technical and organisational precautions to prevent the loss, misuse or alteration of your information. We store information you provide on our secure, password- and firewall-protected servers. We ensure that all electronic financial transactions entered into through our Website are through an appropriate payment provider and protected by encryption technology.

Despite these measures, it is important to acknowledge that the transmission of information over the internet is inherently insecure and that we cannot absolutely guarantee the security of data sent over the internet. Users must also acknowledge the importance of keeping passwords safe.

Use of information

Information submitted to us may be used for any of the purposes specified in this policy; where used for other purposes it will be explicitly mentioned during use of the Services or Website.

We may use your information to:

  • personalise the Services, Website or notifications sent to you or your organisation
  • supply or activate services and functionality available via the Services or Website
  • send statements, invoices and payment reminders to you or your organisation
  • collect payment from your organisation
  • send you or your organisation notifications
  • send you or your organisation non-marketing communications, such as details of important product updates
  • send you or your organisation requests for product feedback or invitations to participate other research
  • send you or your organisation product or marketing communications relating to our business and products which we think may be of interest to you
  • publish results from any deployments of the Services, such as transactional volume, and total savings run rate via our application or website
  • publish non-identifiable, aggregated statistical information about our user base
  • inform our payment services providers as necessary. Personal information will only be shared to the extent necessary for the purposes of processing payments, refunding such payments and dealing with complaints and queries relating to such payments and refunds
  • administer and improve our application, website and business
  • deal with enquiries and complaints made by or about you relating to our website keep our website secure and prevent fraud
  • verify compliance with the Terms Of Service governing the use of our services

Disclosure of information

We may disclose information in the circumstances outlined below:

  • to any of our company officers, employees, insurers, professional advisers, agents, suppliers or subcontractors insofar as reasonably necessary for the purposes set out in this policy
  • to the extent that we are required to do so by law, in connection with any ongoing or prospective legal proceedings
  • to any person who we reasonably believe may apply to a court or other competent authority for disclosure of that information where, in our reasonable opinion, such an authority would be likely to order disclosure of that information
  • in order to establish, exercise or defend our legal rights (including providing information to others for the purposes of fraud prevention and reducing credit risk)
  • to the purchaser (or prospective purchaser) of any business or asset that we are, or are contemplating selling

We will never disclose information to:

  • any third parties for marketing purposes
  • any third parties for any other purpose without your explicit consent

International data transfers

Information that we collect may be stored, processed in and transferred between any of the countries in which we operate in order to enable us to use the information in accordance with this policy. In using our services, you are explicitly agreeing to such a transfer of information.

If we transfer any information out of the European Economic Area (EEA), it will only be done with adequate assurances of the relevant protection (stated under UK law) for your privacy being in place.

Updating information

It will be possible to amend most of the information that we hold about you in the very near future via the Services. In the meantime please contact us if you wish to amend any details or if you are experiencing issues.

Retention and deletion of information

We do not keep information that we collect and process for any longer than is absolutely necessary. With that said, the Services are used by organisations to source Candidates to fill temporary vacancies in regulated environments such as healthcare. Many of these vacancies require that the Candidates meet various compliance criteria, for instance criminal record checks, previous job history and right to work. Whilst we would love to be able to immediately and completely erase a user’s personal information immediately after a request to do so, for legal purposes this simply is not possible due to the need for us to maintain an “audit trail” for a reasonable period of time.

With the above noted, upon a request to delete an account the associated personal information will be deleted according to the following schedule:

ITEM SCHEDULE
Credentials (email address, password hash etc) Immediate
Other contact details
Profile image
Location data
Usage history
In-app messages
Direct communications with the Company
Full name 10 years
Date of birth
Professional registration details
Uploaded compliance documentation and associated audit trail
History of jobs undertaken via the Services

Deletion of organisational data occurs as follows:

ITEM SCHEDULE
Credentials (email address, password hash etc) Immediate
Billing details
Organisation name 10 years
History of jobs created via the Services

Notwithstanding the other provisions of this section, we may retain information (including electronic documents) for longer than the times specified above in the following circumstances:

  • to the extent that we are required to do so by law
  • if we believe that the documents may be relevant to any ongoing or prospective legal proceedings
  • in order to establish, exercise or defend our legal rights (including providing information to others for the purposes of fraud prevention and reducing credit risk)

Cookies

The Website may use cookies, either currently or in future. Technologies with a similar purpose such as web beacons may also be used. Cookies are small text files sent by us to your computer, and from your computer to us, each time you visit our website. They do not typically contain data that can identify you personally but may be linked (via a unique ID for example) to other information about you or your organisation that we hold.

We may use either session-based or persistent cookies, or a combination of both. Session-based cookies last only while your browser is open and are automatically deleted when you close your browser, whereas persistent cookies last until you or your browser delete them or until they expire.

Some cookies are unique to your unique account and/or your browser, and allow us to customise your experience, such as remembering that you are logged in or your last session state. Other cookies may allow us to analyse how you are using the website, see how it is performing, and detect problems. Disabling or disallowing cookies in your browser may therefore limit or break certain functionality of both the Website and other websites and is therefore not recommended for the best experience, but can still be done if desired.

The Company may set and access cookies on our company-owned domains, and additionally may use third party services (such as Google Analytics). You may opt-out of third party cookies from these providers on their respective websites.

We do not currently recognise or respond to browser-initiated Do Not Track signals due to the lack of an appropriate cross-browser standard for implementation of such functionality.

Third party websites

Our application and website may include hyperlinks to, and details of, third party websites. We are not responsible for, and have no control over, the privacy policies and practices of any third parties.

Your rights

You may instruct us to provide you with a copy of any and all information we hold about you. Provision of such information is subject to:

  • the payment of an administration fee (currently fixed at £10)
  • the supply of appropriate evidence of your identity. For this purpose, we will usually accept a photocopy of your passport certified by a solicitor or bank plus an original copy of a letter or bill from an established organisation that shows your current address

We may withhold some information that you request to the extent permitted by law.

In practice, you will usually either expressly agree in advance to our use of your information for marketing / research purposes, or we will provide you with an opportunity to opt out of the use of your information for such purposes.

Changes to this policy

We may change this policy from time to time, and if we do we’ll post any changes on this page. If you continue to use our services after those changes are in effect, you implicitly agree to the revised policy. If the changes are significant, we may notify you and / or explicitly seek your consent to the new policy.

Contacting us

Please feel free to contact us if you have any questions about this policy or our practices.