Policy Key Definitions
- “I”, “our”, “us”, or “we” refer to the business, Human Capital Project Ltd.
- “you”, “the user” refer to the person(s) using this website.
- GDPR means General Data Protection Act.
- PECR means Privacy & Electronic Communications Regulation.
- ICO means Information Commissioner’s Office.
- Cookies mean small files stored on a users computer or device.
Processing of your Personal Data
Under the GDPR (General Data Protection Regulation) we control and / or process any personal information about you electronically using the following lawful bases. We are registered with the ICO under the Data Protection Register.
Lawful basis: Consent, Legitimate interests
The reason we use these basis: These have been recommended according to the ICO lawful basis self-assessment tool.
We process your information in the following ways: Communication related to your activity on the site, your account & marketing messages.
Data retention period: We will continue to process your information under this basis until you withdraw consent or it is determined your consent no longer exists.
Sharing your information: We do not share your information with third parties without your permission. Your name, location, photo and public activity on the site will be visible to other members of the site.
If, as determined by us, the lawful basis upon which we process your personal information changes, we will notify you about the change and any new lawful basis to be used if required. We shall stop processing your personal information if the lawful basis used is no longer relevant.
Your Individual Rights
Under the GDPR your rights are as follows. You can read more about your rights in detail here.
- the right to be informed;
- the right of access;
- the right to rectification;
- the right to erasure;
- the right to restrict processing;
- the right to data portability;
- the right to object; and
- the right not to be subject to automated decision-making including profiling.
You also have the right to complain to the ICO if you feel there is a problem with the way we are handling your data. We handle subject access requests in accordance with the GDPR.
By using our service, you agree to us using cookies. Some cookies will be saved for specific time periods, where others may last indefinitely. Your web browser should provide you with the controls to manage and delete cookies from your device, please see your web browser options.
Cookies that we use are:
- Google Tracking
- Facebook Pixel
Data Security and Protection
We ensure the security of any personal information we hold by using secure data storage technologies and precise procedures in how we store, access and manage that information. Our methods meet the GDPR compliance requirement.
Email Marketing Messages, Notifications & Subscription
Under the GDPR we use the consent lawful basis for anyone subscribing to our newsletter or marketing mailing list. We only collect certain data about you, as detailed in the “Processing of your personal data” above. Any email marketing messages we send are done so through an EMS, email marketing service provider. An EMS is a third party service provider of software / applications that allows marketers to send out email marketing campaigns to a list of users.
Email marketing messages that we send may contain tracking beacons / tracked clickable links or similar server technologies in order to track subscriber activity within email marketing messages. Where used, such marketing messages may record a range of data such as; times, dates, I.P addresses, opens, clicks, forwards, geographic and demographic data. Such data, within its limitations will show the activity each subscriber made for that email campaign.
Any email marketing messages we send are in accordance with the GDPR and the PECR. We provide you with an easy method to withdraw your consent (unsubscribe) or manage your preferences / the information we hold about you at any time. See any marketing messages for instructions on how to unsubscribe or manage your preferences.
Our EMS provider is SendinBlue. We hold the following information about you within our EMS system:
- First name
- Last name
- Email address
- Subscription time & date
We also send transactional emails and app notifications related to your activity on the site. You can control these notifications from within your account settings.
Links to Other Sites
We have no control over, and assume no responsibility for the content, privacy policies or practices of any third party sites or services.
Our Service does not address anyone under the age of 18 (“Children”).
We do not knowingly collect personally identifiable information from children under 18. If you are a parent or guardian and you are aware that your Children have provided us with Personal Information, please contact us. If we discover that anyone under the age of 18 has provided us with Personal Information, we will delete such information from our servers immediately.
We reserve the right, at our sole discretion, to modify or replace this Policy at any time. If a revision is material we will try to provide at least 30 days notice prior to any new terms taking effect. What constitutes a material change will be determined at our sole discretion.
By continuing to access or use our Service after those revisions become effective, you agree to be bound by the revised policy. If you do not agree to the new policy, please stop using the Service. You are advised to review this policy periodically for any changes. Changes to this policy are effective when they are posted on this page.