Privacy Policy, Terms & Conditions
Polygon Ventures Limited (”We”) are committed to protecting and respecting your privacy.
Our Group means our subsidiaries, our ultimate holding company and its subsidiaries, our associated companies as defined in section 1159 of the UK Companies Act 2006 (our Group).
This notice sets out the basis on which any personal data we collect from you, or that you provide to us, will be processed by us.
The General Data Protection Regulation (GDPR) (Regulation (EU) 2016/679) is a new regulation which replaces the Data Protection Regulation (Directive 95/46/EC). The Regulation aims to harmonise data protection legislation across EU member states, enhancing privacy rights for individuals and providing a strict framework within which commercial organisations can legally operate.
Even though the UK has expressed its intention to leave the EU in March 2019, the GDPR will be applicable in the UK from 25th May 2018. The Government intends for the GDPR to continue in UK law post Brexit and has also introduced a Data Protection Bill to replace the current Data Protection Act in due course.
Your new rights under the GDPR are set out in this notice and will be applicable from the 25th May 2018.
Please read the following carefully to understand our views and practices regarding your personal data and how we will treat it.
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.
Important information and who we are
This privacy policy aims to give you information on how Polygon Ventures Limited collects and processes your personal data through your use of this website, including any data you may provide through this website when you purchase a product or service.
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.
Polygon Ventures Limited is the controller and responsible for your personal data. If you have any questions about this privacy policy, including any requests to exercise your legal rights, please contact us using the details set out at the end of this notice.
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.
What personal data we collect
We collect the personal data of the following types of people to allow us to undertake our business;
Name, contact information, such as address, email, mobile phone number, company and designation;
Country of residence;
IP address, browser type and language, your access times;
Information in any complaints you make ;
Details of how you use our products and services;
Details of how you like to interact with us, and other similar information relevant to our relationship.
Prospective and placed candidates for permanent or temporary roles;
Prospective and live client contacts;
Supplier contacts to support our services;
Employees, consultants, temporary workers;
We collect information about you to carry out our core business and ancillary activities.
Information you give to us or we collect about you.
This is information about you that you give us by filling in forms on our site www.polygontech.com (our site) or by corresponding with us by phone, e-mail or otherwise. It includes information you provide when you register to use our site, to enter our database, subscribe to our services, attend our events, participate in discussion boards or other social media functions on our site, enter a competition, promotion or survey, and when you report a problem with our site.
The information you give us or we collect about you through our careers page may include your name, address, private and corporate e-mail address and phone number, financial information, compliance documentation and references verifying your qualifications and experience and your right to work in the United Kingdom, curriculum vitae and photograph, links to your professional profiles available in the public domain e.g. LinkedIn, Twitter, business Facebook or corporate website.
Information we collect about you when you visit our website.
With regard to each of your visits to our site we will automatically collect the following information:
technical information, including the Internet protocol (IP) address used to connect your computer to the Internet, your login information if applicable, browser type and version, browser plug-in types and versions, operating system and platform.
information about your visit, including the full Uniform Resource Locators (URL), clickstream to, through and from our site (including date and time), products you viewed or searched for’, page response times, download errors, length of visits to certain pages, page interaction information (such as scrolling, clicks, and mouse-overs), methods used to browse away from the page.
Information we obtain from other sources.
This is information we obtain about you from other sources such as LinkedIn, corporate websites, job board websites, online CV libraries, your business card, personal recommendations. In this case we will inform you, by sending you this privacy notice, within a maximum of 30 days of collecting the data of the fact we hold personal data about you, the source the personal data originates from and whether it came from publicly accessible sources, and for what purpose we intend to retain and process your personal data.
We are working closely with third parties including companies within our Group, business partners, sub-contractors in technical, professional, payment and other services, advertising networks, analytics providers, search information providers, credit reference agencies, professional advisors. We may receive information about you from them for the purposes of our recruitment services and ancillary support services.
Cookies.
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.
How we use your personal data
We process information about you and/or your business to enable us and other members of the Polygon Ventures Limited Network to provide our services to you or our clients, and to meet our legal or regulatory obligations. Some of your personal data may be used for other business purposes. Below are some examples.
Use of personal data to provide services to our clients
We will use your personal data to provide you or our clients or other third parties with services, and this includes using your personal data in correspondence relating to those services. That correspondence may be with:
you;
other third parties or other members of the Polygon Ventures Limited Network;
our service providers; or
competent authorities.
We may also use your personal data to conduct due diligence checks relating to the services.
Because we provide a wide range of services to our clients or other third parties, the way we use personal data in relation to our services also varies. For example, we might use personal data about:
Use of personal data for other activities that form part of the operation of our business
legal or regulatory requirements;
requests and communications from competent authorities;
client account opening and other administrative tasks;
financial accounting, invoicing and risk analysis;
relationship management, which may involve:
(a) sending you thought leadership or details of our products and services;
(b) contacting you for feedback on services;
(c) sending you event invitations; and
(d) other marketing or research purposes;
recruitment and business development, which may involve:
(a) the use of testimonials from a client’s employees as part of our recruitment and business development materials (with that employee’s permission); and
(b) the use of third-party data sources to help us verify and improve the information we hold about key business relationships with individuals;
Use of personal data collected via our Website
In addition to the above, we may also use your personal data collected via our Website:
to manage and improve our Website;
to tailor the content of our Website to give you a more personalised experience;
to draw your attention to information about our products and services that may be of interest to you; or
to manage and respond to any request you submit through our Website.
The legal grounds we use for processing personal data
We are required by law to set out in this privacy statement the legal grounds on which we rely in order to process your personal data. We rely on one or more of the following lawful grounds:
you have explicitly agreed to us processing your information for a specific reason;
the processing is necessary to perform the agreement we have with you or to take steps to enter into an agreement with you;
the processing is necessary for compliance with a legal obligation we have such as keeping records for tax purposes or providing information to a public body or law enforcement agency; or
the processing is necessary for the purposes of a legitimate interest pursued by us or a third party, which might be:
(a) to provide our services to you or our clients and other third parties and ensure that our client engagements are well-managed;
(b) to prevent fraud;
(c) to protect our business interests;
(d) to ensure that complaints are investigated;
(e) to evaluate, develop or improve our services or products; or
(f) to keep you or our clients informed about relevant products and services and provide you with information, unless you have indicated at any time that you do not wish us to do so.
Sharing your personal data
In connection with any of the purposes outlined in the “How we use your personal data?” section above, we may disclose details about you to:
other members of the Polygon Ventures Limited Network or third parties that provide services or online platforms to us and/or the Polygon Ventures Limited Network;
competent authorities (including courts and authorities regulating us and other members of the Polygon Ventures Limited Network);
your employer and/or its advisers, or your advisers;
anyone to whom we may transfer our rights and/or obligations under the Terms;
any other person or organisation after a restructure, sale or acquisition of any member of the Polygon Ventures Limited Network, as long as they use your information for the same purposes we did;
credit reference agencies or other organisations that help us make credit decisions and reduce the incidence of fraud; and
other third parties that reasonably require access to personal data relating to you.
Our Website hosts various blogs, forums, wikis and other social media applications or services that allow you to share content with other users (collectively “Social Media Applications”). Any personal data that you contribute to these Social Media Applications can be read, collected and used by other users of the application. We have little or no control over these other users, so any information you contribute to these Social Media Applications might not be handled in line with this privacy statement.
Transferring your personal data outside the UK
Information we hold about you may be transferred to other countries (which may include countries outside the UK or the European Economic Area (“EEA”)) :
where we do business;
which are linked to your engagement with us;
from which you regularly receive or transmit information; or
where our third parties conduct their activities.
These countries may have less stringent privacy laws than we do, so any information they hold can become subject to their laws and disclosure requirements, including disclosure to governmental bodies, regulatory agencies and private persons. In addition, a number of countries have agreements under which information is exchanged with other countries for law enforcement, tax and other purposes.
When we, or our permitted third parties, transfer your personal data outside the UK or the EEA, we will impose contractual obligations on the recipients of that data to protect your personal data to the standard required in the UK and EEA. We or they may also require the recipient to subscribe to international frameworks intended to enable secure data sharing. We may also transfer your personal data when:
the transfer is to a country deemed to provide adequate protection of your personal data by the European Commission; or
where you have consented to the transfer.
If we transfer your personal data outside the UK or EEA in other circumstances (for example, because we have to by law), we will make sure it remains adequately protected.
We may share non-personal, anonymised and aggregated information with third parties for several purposes, including data analytics, research, submissions, thought leadership and promotional activity.
Protecting your personal data
We use a range of measures to ensure we keep your personal data secure, accurate and up to date. These include:
education and training to relevant staff to ensure they are aware of our privacy obligations when handling personal data;
administrative and technical controls to restrict access to personal data to a ‘need to know’ basis;
technological security measures, including fire walls, encryption and anti- virus software; and
The transmission of data over the internet (including by e-mail) is never completely secure. So although we use appropriate measures to try to protect personal data, we cannot guarantee the security of data transmitted to us or by us.
How long we keep your personal data for
We seek to ensure that we only keep your personal data for the longest of:
the period necessary for the relevant activity or services;
any retention period that is required by law; or
the period in which litigation or investigations might arise in respect of the services.
Your rights
You have various rights in relation to your personal data. In particular, you have a right to:
obtain confirmation that we are processing your personal data and request a copy of the personal data we hold about you;
be informed about the processing of your personal data (i.e. for what purposes, what types, to what recipients it is disclosed, storage periods, any third party sources from where it was obtained, confirmation of whether we undertake automated decision-making, including profiling, and the logic, significance and envisaged consequences);
ask that we update the personal data we hold about you, or correct such personal data that you think is incorrect or incomplete;
ask that we delete personal data that we hold about you, or restrict the way in which we use such personal data; withdraw consent to our processing of your personal data (to the extent such processing is based on previously obtained consent);
receive a copy of the personal data concerning you, which you have provided to us,
ask us to stop or start sending you marketing messages at any time by using the contact details specified towards the end of this notice below; and
object to our processing of your personal data.
If you would like to access or see a copy of your personal data, you must ask us in writing. We will endeavour to respond within a reasonable period, and in any event within one month in line with Data Protection Legislation. We will comply with our legal obligations as regards your rights as a data subject.
To help us ensure that your information is up to date, let us know if any of your personal details change using the contact details set out in this notice
You may also use the contact details, if you wish to make a complaint relating to your privacy.
Sending you marketing information
We and other members of the Polygon Ventures Limited Network may use your information from time to time to inform you by letter, telephone, email and other electronic methods about products and services (including those of third parties) that may be of interest to you.
You may, at any time, ask us and/or other members of the Polygon Ventures Limited Network not to send marketing information to you by following the unsubscribe instructions in communications from us, or contacting us in the way described in this notice.
Right to complain
If you wish to raise a complaint about how we are using your information, exercise any of the rights set out above, or if you have any questions or comments about privacy issues, you can contact us by:
writing to
Data Protection Office,
Polygon Ventures Limited at
71-75, Shelton Street, Covent Garden, London, United Kingdom, WC2H 9JQ or
sending an email to [email protected].
You can also complain to the Information Commissioner’s Office, which regulates and supervises the use of personal data in the UK, on 0303 123 1113.
Changes to this privacy statement
We may modify or amend this privacy statement from time to time.
When we make changes to this privacy statement, we will amend the revision date at the top of this page. The modified or amended privacy statement will apply from that date. We encourage you to review this statement periodically to remain informed about how we are protecting your information.
Where we store and process your personal data.
The data that we collect from you will be transferred to, and stored at, a destination inside the European Economic Area (” EEA”). It may be transferred to third parties outside of the EEA for the purpose of our recruitment services. It may/will also be processed by staff operating outside the EEA who works for us or for one of our suppliers. This includes staff engaged in, among other things, our recruitment services 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 notice.
All information you provide to us is stored on secure servers. Where we have given you (or where you have chosen) a password which enables you to access certain parts of our site, you are responsible for keeping this password confidential. We ask you not to share a password with anyone.
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 to our site; any transmission is at your own risk. Once we have received your information, we will protect it with adequate security mechanisms to try to prevent unauthorised access.
Retention of your data
We understand our legal duty to retain accurate data and only retain personal data for as long as we need it for our legitimate business interests and that you are happy for us to do so. Accordingly, we will remove your data from our records when we no longer have a legitimate business interest in retaining your data.