Version 3.0, Last update August 2022.
2. Who is the Data Controller of your personal data?
Sturgeon Capital Limited processes personal data as a Data Controller for the purposes included in this policy.
Our registered address is at 1a Britannia Street, London, WC1X9JT. You can contact us via post at this address. Alternatively, you can contact us via email at email@example.com.
Getro Inc. also acts as a Data Controller of your personal data for the purposes outlined in section 3 of this policy, and in order to seek professional opportunities for Job Seekers outside of the Sturgeon Capital Ltd network. Getro Inc may contact you to offer professional opportunities outside of this talent network and in that case, you may consent to the sharing of your details with external employers.
3. Personal data collected by us
When you subscribe to this Network, we will ask you to provide certain personal data, including:
- a valid e-mail address
- your job preferences
Generally, we may collect your personal data as follows:
(a) Registration or subscription – we will collect personal data that you voluntarily submit to us, such as your name and contact details when you register with us as a job seeker, subscribe to job alerts, use our Site and our services, or otherwise interact with us;
(b) Information request or chat – When you request information or interact with us through any communication channels (chat, email, etc) we may collect your contact details (email address, name, your role, name of your company, company sector and number of companies) and you may provide additional information.
(c) Statistical processing – We may process your data for statistical purposes that allow us to prepare reports, determine how many people visit our website and to improve our services. The reports that we generate will only contain aggregated data in a way that does not allow the identification of individuals.
(d) Automatized processing – When you visit our Site, we may also automatically collect standard logging information and device fingerprint data such as the IP address of your device based on our legitimate interest to keep our website secure and prevent fraudulent attacks and to infer the uniqueness of users. Some providers may also collect IP addresses in order to provide their services and for security reasons.
4. For what purposes are we going to process Job Seekers' data?
We process your personal data to help you to find a job that matches your preferences and to connect you with companies within our network for this purpose, using an automated board system that permits us to work efficiently.
If you choose to subscribe to Job Alerts, we will send you by email details of jobs that we think you might be interested in with us or companies in our network. Your subscription data will only be shared with administrators of this network. We cannot subscribe you to job alerts without the minimum mandatory information indicated on the subscription form.
We might contact you in order to offer new professional job opportunities in the future.
5. How long will we keep your data for?
We will continue to process your data until (a) you unsubscribe from job alerts by following the Unsubscribe link in any email correspondence we send to you or (b) until this job board is no longer active.
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, as well as the applicable legal, regulatory, tax, accounting or other requirements.
6. With whom will we share your data?
We will share your personal data with such organisations within our network who may be able to offer employment opportunities that are of interest to you.
Additionally, we may share your personal data with the following categories of recipients to fulfil the purposes for which we collected the personal data.
- Professional advisors: we may share your personal data with our lawyers, accountants, insurers and other professional advisors to the extent we need to (for example, to defend ourselves against legal claims).
- Purchasers and third parties in connection with a business transaction: your personal data may be disclosed to third parties in connection with a transaction, such as a merger, sale of assets or shares, reorganisation, financing, change of control or acquisition of all or a portion of our business.
- Law enforcement, regulators and other parties for legal reasons: we may share your personal data with third parties as required by law or if we reasonably believe that such action is necessary to (i) comply with the law and the reasonable requests of law enforcement; (ii) detect and investigate illegal activities and breaches of agreements; and/or (iii) exercise or protect the rights, property, or personal safety of the Company, Getro, their respective users or others.
7. Marketing from us
From time to time we may contact you with information about our services, including for the purposes of sending you marketing messages and asking for your feedback.
8. Storing and transferring your personal data
Security. We implement appropriate technical and organisational measures to protect your personal data against accidental or unlawful destruction, loss, change or damage. All personal data we collect will be stored on our secure servers. We will never send you unsolicited emails or contact you by phone requesting your account ID, password, bank account details or national identification numbers.
9. Quality of the data
As a subscriber to job alerts, if you change your email address, you should unsubscribe and resubscribe with your new email address. You can update your job preferences by following a link from the daily alert email we send you.
We will diligently try to verify the authenticity of said data, reserving, if necessary and without prejudice to taking the corresponding actions, the right not to register/subscribe or eliminate those users who have provided false or incomplete information. This verification does not imply in any case that we assume responsibility for any loss or damage that may arise from the misinterpretation or inaccuracy of the data provided. The user who provides the information is solely responsible for its accuracy.
10. Children under 14 years old
We do not process the personal data of children under 14 years of age nor do we direct our contents or information to them. If you are under 14 years of age, please do not give us personal data.
Therefore, prior to providing us with your personal data, you guarantee that you are over 14 years of age and that you are entirely responsible for this declaration and for the access and correct use of the website subject to the conditions of use and current legislation, both national and international, as well as the principles of good faith, morals and public order, and with the commitment to diligently observe any additional instruction that, in relation to such use and access, could be given by us.
You may be required by us at any time, so that we can verify your age, to provide a photocopy of your identity document that legally and unambiguously confirms your age. Failure to supply us with this information in the term indicated will entitle us to suspend or cancel your profile or any processing of your data. Any abuse or violation of these conditions and, in particular, those that affect minors, must be reported immediately to us.
11. What rights do you have?
In order to control your data, at all times, you have the right to:
- know if your personal data is being processed and, where appropriate, access it
- rectify your personal data if it was inaccurate or incomplete
- require us to delete your data if it is not necessary for the indicated purposes
- require us to limit the processing of your personal data
- transfer your personal data to another provider of your choice (portability)
- oppose the processing of your personal data or withdraw your consent at any time
- file a claim with the relevant Data Protection Authority (if you are based in the EEA), or with the Information Commissioner (https://ico.org.uk/) (if you are based in the UK) if you believe your rights have been infringed.
To do this, you only have to contact us by written communication via email: firstname.lastname@example.org
Please note that the above rights are not absolute, and we may be entitled to refuse requests, wholly or partly, where exceptions under the applicable law apply.
If you want to cancel your subscription, you can do so in a simple way by following the Unsubscribe link in the daily alert email we send to you.
12. Links to Third Party Websites
We do not assume any responsibility derived from other privacy policies or practices performed by websites that have been accessed through hyperlinks located on this website and that are not managed directly by Sturgeon Capital Limited. Therefore, we assume no responsibility in relation to the information contained in the websites of third parties or the consequences that may arise derived from such information. If any user observes that such links are contrary to law, morality and public order, you must inform us by sending an email to: email@example.com.
Annex 1 – Purpose and legal basis for processing of personal data of UK and EEA based individuals.
If you are based in the UK or the EEA, the table below provides further detail on how we use your personal data and the legal basis of such processing.
Category of Personal Data
How we use it
Legal basis for processing
Contact details (including name, email address, phone number etc.); professional details (including your educational and professional history and achievements, job preferences, and information contained in your resume); account details (including username, password, communication preferences)
To register you for our services.
Performance of a contract.
Administration of your account or subscription (including matching you with and sending you information regarding professional opportunities that may be of interest to you, your use of the job boards, changes to our policies, other terms and other administrative information).
Performance of a contract.
Contact details (including name, email address, phone number etc.); professional details (including your educational and professional history and achievements, job preferences, and information contained in your resume); account details (including username, password, communication preferences);
To provide you with the services we make available through the Site.
Performance of a contract.
Correspondence and communications data (including details contained in your emails, messages and other communications with us); contact details (including name, email address, phone number etc.)
To respond to queries and complaints and provide you with information and materials that you request from us.
It is in our legitimate interests to respond to your queries and provide any information and materials requested in order to maintain good customer relations.
Contact details (including email address, phone number etc.); professional details (including your educational and professional history and achievements, job preferences, and information contained in your resume); marketing preferences (including marketing consents)
Marketing and advertising (including sending you newsletters and measuring the effectiveness of our marketing).
Consent (if required under applicable law).
Where consent is not required under applicable law (for example, where you are an existing customer and have not opted out of receiving our marketing communications), such processing is necessary in our legitimate interests, namely, to develop and grow our business.
Account details (including username, password, communication preferences); technical data (including IP address, browser type, internet service provider, device identifier, your login information, time zone setting, browser plug-in types and versions, preferred language, activities, operating system and platform, and geographical location)
To correct errors and problems with the Site.
It is in our legitimate interests to monitor the Site to ensure that it functions properly and is secure.
To protect the security of systems and data.
To comply with our legal and regulatory obligations.
It is also in our legitimate interests to protect systems and data and to prevent and detect criminal activity that could be damaging for you and/or us.
Technical data (including IP address, browser type, internet service provider, device identifier, your login information, time zone setting, browser plug-in types and versions, preferred language, activities, operating system and platform, and geographical location); usage data (including URL, clickstream to, through and from the website, pages you viewed and searched for, page response times, length of visits to certain pages, referral source/exit pages, page interaction information (such as scrolling, clicks and mouse-overs), date and time pages are accessed, website navigation and search terms used)
To analyse your usage of the Site, including for the purposes of improving your experience and the Site and to ensure that content is presented in the most effective manner for you.
It is in our legitimate interests to monitor your usage to better understand how our users use the Site for analytics and development purposes
Contact details (including name, email address, phone number etc.)
To enforce legal rights or defend or undertake legal proceedings.
It is in our legitimate interests or those of a third party, i.e., to protect our business, interests and rights or those of others.
A legitimate interest is when we have a business or commercial reason to use your personal data, so long as this is not overridden by your own rights and interests.