Privacy Policy

Purpose of this privacy notice

This privacy notice aims to give you information on how hiralph.com collects and processes your personal data through your use of this website, telephone and email including any data you may provide through this website.

This website is not intended for children and we do not knowingly collect data relating to children.

It is important that you read this privacy notice together with any other privacy notice or fair processing notice 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 notice supplements the other notices and is not intended to override them.

Controller

Hi Ralph Limited is the controller and responsible for your personal data (referred to as "Hi Ralph", "we", "us" or "our" in this privacy notice).
We have appointed a data privacy manager who is responsible for overseeing questions in relation to this privacy notice. If you have any questions about this privacy notice, including any requests to exercise your legal rights, please contact the data privacy manager using the details set out below.

Contact details

Our full details are:
Full name of legal entity: Hi Ralph Limited
Contact: The Data Privacy Manager
Email address: info@hiralph.com
Postal address: Office 7 35-37 Ludgate Hill, London, England, EC4M 7JN

Changes to the privacy notice and your duty to inform us of changes

This version was last updated on 24/05/2018

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.

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 notice of every website you visit.

Personal data, or personal information, means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymous data).

We may collect, use, store and transfer different kinds of personal data about you which we have grouped together follows:

• Identity Data includes first name, maiden name, last name, marital status, title, date of birth, gender and proof of right to work for example visa or passport details.

• Contact Data includes address, email address and telephone numbers.

• Financial Data includes bank account, hourly rate, number of hours to be worked and national insurance number.

• Transaction Data includes details of product applications you have made through us, the start and end date and address of any assignment associated with that product and surveys you have participated in.

• Technical Data includes internet protocol (IP) address, your login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform and other technology on the devices you use to access this website.

• Profile Data includes your username and password, product applications made by you, your interests, preferences, feedback and survey responses.

• Usage Data includes information about how you use our website.

• Marketing and Communications Data includes your preferences in receiving marketing from us and third parties and your communication preferences.

• Special Categories Data includes health and criminal convictions and offences.

We may also contact you to obtain further personal data if this is required for product or job applications and we will process it in accordance with this privacy policy.

If you provide additional personal data in your product or job application we will also process this in accordance with this privacy policy.

We may also collect, use and share Aggregated Data such as statistical or demographic data for any purpose. Aggregated Data may be derived from your personal data but is not considered personal data in law as this data does not directly or indirectly reveal your identity. For example, we may aggregate your Usage Data to calculate the percentage of users accessing a specific website feature. However, if we combine or connect Aggregated Data with your personal data so that it can directly or indirectly identify you, we treat the combined data as personal data which will be used in accordance with this privacy notice.

If you fail to provide personal data

Where we need to collect personal data by law or to provide our services and you fail to provide that data when requested, we may not be able to provide you with these services. In this case, we may have to suspend or stop the provision of our services but we will notify you if this is the case at the time.

We use different methods to collect data from and about you including through:

• Direct interactions. You may give us your Identity, Contact, Financial, Profile and Special Categories data by filling in forms or by corresponding with us by post, phone, email or otherwise. This includes personal data you provide when you:

  • apply for a product;

  • apply for a job;

  • ask us to contact you through our website;

  • subscribe to our service or publications;

  • request marketing to be sent to you;

  • give us some feedback.

• Automated technologies or interactions. As you interact with our website, we may automatically collect Technical and Usage Data about your equipment, browsing actions and patterns. We collect this personal data by using cookies, server logs and other similar technologies. We may also receive Technical and Usage Data about you if you visit other websites employing our cookies. Please see our cookie information below for further details.

• Third parties or publicly available sources. We may receive personal data about you from various third parties as set out below:
  Technical and Usage Data from providers such as Google based outside the EU;

  • Identity, Contact Special Categories and Marketing and Communications Data from affiliate companies such as payroll service providers, recruitment agencies and employment businesses; and

  • Identity and Contact Data from publicly available sources such as recruitment websites.

We will only use your personal data when the law allows us to. Most commonly, we will use your personal data in the following circumstances:

• Where we provide you with the services offered on our website.

• Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests.

• Where we need to comply with a legal or regulatory obligation.

Generally we do not rely on consent as a legal basis for processing your personal data other than in relation to sending third party direct marketing communications to you via email or text message. You have the right to withdraw consent to marketing at any time by contacting us or the third party where appropriate.

Purposes for which we will use your personal data

We have set out below, in a table format, a description of all the ways we plan to use your personal data, and which of the legal bases we rely on to do so. We have also identified what our legitimate interests are where appropriate.

Note that we may process your personal data for more than one lawful ground depending on the specific purpose for which we are using your data. Please contact us if you need details about the specific legal ground we are relying on to process your personal data where more than one ground has been set out in the table below.

Purpose/Activity	Type of data	Lawful basis for processing including basis of legitimate interest	Data retention
To register you as a new user	Identity Contact Profile Special Categories	Necessary for our legitimate interests (providing services to enable users to compare payroll providers)	7 years after you last apply for a product through our website
To put enable you to apply for products	Identity Contact Financial Profile Special Categories	Performance of a contract with you Necessary for our legitimate interests (providing services to enable users to compare payroll providers)	7 years after you last apply for a product through our website
To manage our relationship with you which will include: Notifying you about changes to our terms or privacy policy Asking you to leave a review or take a survey	Identity Contact Transaction Profile Marketing and Communications	Necessary to comply with a legal obligation Necessary for our legitimate interests (to keep our records updated and to study how customers use our services)	7 years after you last apply for a product through our website
To administer and protect our business and this website (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data)	Identity Contact Technical Profile Usage	Necessary for our legitimate interests (for running our business, provision of administration and IT services, network security, to prevent fraud and in the context of a business reorganisation or group restructuring exercise) Necessary to comply with a legal obligation	3 years after the data is collected for this purpose
To deliver relevant website content and advertisements to you and measure or understand the effectiveness of the advertising we serve to you	Identity Contact Technical Usage Marketing and Communications Transaction	Necessary for our legitimate interests (to study how customers use our services, to develop them, to grow our business and to inform our marketing strategy)	3 years after the data is collected for this purpose
To use data analytics to improve our website, products/services, marketing, customer relationships and experiences	Technical Profile Usage	Necessary for our legitimate interests (to define types of customers for our services, to keep our website updated and relevant, to develop our business and to inform our marketing strategy)	3 years after the data is collected for this purpose
To make suggestions and recommendations to you about jobs or services that may be of interest to you	Identity Contact Technical Usage	Necessary for our legitimate interests (to develop our services and grow our business) Consent	3 years after the data is collected for this purpose

Marketing

We strive to provide you with choices regarding certain personal data uses, particularly around marketing and advertising. You can opt out of marketing communications from us by contacting us at any time.

Promotional offers from us

We may use your Identity, Contact, Transaction, Profile, Technical, and Usage data to form a view on what we think you may want or need, or what may be of interest to you. This is how we decide which communications may be relevant for you (we call this marketing).

You will receive marketing communications from us if you have requested information from us or applied for a role through us and, in each case, you have not opted out of receiving that marketing.

Third-party marketing

We will get your express opt-in consent before we share your personal data with any other company for marketing purposes.

Opting out

You can ask us or third parties to stop sending you marketing messages at any time by following the opt-out links on any marketing message sent to you or by contacting us, or the third party where appropriate, at any time.

Where you opt out of receiving these marketing messages, this will not apply to personal data provided to us as a result of a product or job application.

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.

A cookie is a small file of letters and numbers that we store on your browser or the hard drive of your computer if you agree. Cookies contain information that is transferred to your computer's hard drive.

You can set your browser to refuse all or some browser cookies, or to alert you when websites set or access cookies. Please note that if you disable or refuse cookies some parts of this website may become inaccessible or not function properly. For more information about the cookies we use, please see below:

We use the following cookies:

Strictly necessary cookies. These are cookies that are required for the operation of our website. They include, for example, cookies that enable you to log into secure areas of our website and upload documentation. or make use of e-billing services.

Analytical/performance cookies. They allow us to recognise and count the number of visitors and to see how visitors move around our website when they are using it. This helps us to improve the way our website works, for example, by ensuring that users are finding what they are looking for easily.

Functionality cookies. These are used to recognise you when you return to our website. This enables us to personalise our content for you, greet you by name and remember your preferences (for example, your choice of language or region).

Targeting cookies. These cookies record your visit to our website, the pages you have visited and the links you have followed. We will use this information to make our website and the advertising displayed on it more relevant to your interests. We may also share this information with third parties for this purpose.

Cookie	Name	Purpose	More information
_ga, _gid, _gat, DSID, IDE, _gads,	Google Analytics	These are Google Analytics cookies which we use to distinguish users and sessions, follow your journey through our webpages, for demographic and interest reports, to see where visitors came from (e.g. search engine or link), to store the amount of visits and details for each and to find out how long visitors are on the website and bounce rates	Further information can be found at Google privacy policy.
Guest_id, ads_pref, ct0, kdt, eu_cn personalization_id, Remember_checked_on, Tfw_exp, External_referer	Twitter	These are Twitter cookies which are used to to collect information about your browsing behaviour (so that adverts are more relevant and targeted), to give our content the ability to be directly shared on Twitter	Further information can be found at Twitter Cookies Policy
Atuvc, atuvs	AdThis	These cookies are associated with the AddThis social sharing widget. They enable users to share content with a range of networking and sharing platforms. It stores an updated page share count.	Further information can be found at AdThis Privacy Policy
CONSENT
NID

Please note that third parties (including, for example, advertising networks and providers of external services like web traffic analysis services) may also use cookies, over which we have no control. These cookies are likely to be analytical/performance cookies or targeting cookies Except for essential cookies, all cookies will expire after two years.

Change of purpose

We will only use your personal data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If you wish to get an explanation as to how the processing for the new purpose is compatible with the original purpose, please contact us.

If we need to use your personal data for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so.

Please note that we may process your personal data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.

We will only retain your personal data for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements.

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, and the applicable legal requirements.

Details of retention periods for different aspects of your personal data are set out in the table in paragraph 4 above.

In some circumstances you can ask us to delete your data: see Request erasure below for further information.

You should be aware that we will retain some of your data should you ask us to remove you from our mailing list in order to ensure that we do not contact you again.

In some circumstances we may anonymise your personal data (so that it can no longer be associated with you) for research or statistical purposes in which case we may use this information indefinitely without further notice to you.

• We may have to share your personal data with the parties set out below for the purposes set out in the table in paragraph 4 above.

• Service providers acting as processors based in the UK, Ireland and USA who provide IT, cloud storage, mailing and system administration services.

• Companies and organisations advertising vacancies.

• Affiliate companies such as payroll service providers, employment businesses and recruitment agencies who may advertise their products on our site or refer you to our site.

• Professional advisers acting as processors or joint controllers including lawyers, bankers, auditors and insurers based in the UK who provide consultancy, banking, legal, insurance and accounting services.

• HM Revenue & Customs, regulators and other authorities acting as processors or joint controllers based in the United Kingdom who require reporting of processing activities in certain circumstances.

• Third parties to whom we may choose to sell, transfer, or merge parts of our business or our assets. Alternatively, we may seek to acquire other businesses or merge with them. If a change happens to our business, then the new owners may use your personal data in the same way as set out in this privacy notice.

We require all third parties to respect the security of your personal data and to treat it in accordance with the law. We do not allow our third-party service providers to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our instructions.

Many of our external third parties are based outside the European Economic Area (EEA) so their processing of your personal data will involve a transfer of data outside the EEA.

Where we use providers based in the US, we may transfer data to them if they are part of the Privacy Shield which requires them to provide similar protection to personal data shared between the Europe and the US.

Please contact us if you want further information on the specific mechanism used by us when transferring your personal data out of the EEA.

We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal data on our instructions and they are subject to a duty of confidentiality.

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

You have the right to make a complaint at any time to the Information Commissioner's Office (ICO), the UK supervisory authority for data protection issues (www.ico.org.uk). We would, however, appreciate the chance to deal with your concerns before you approach the ICO so please contact us in the first instance.

Under certain circumstances, you have rights under data protection laws in relation to your personal data. You have the right to:

Request correction of the personal data that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.

Request erasure of your personal data. This enables you to ask us to delete or remove personal data where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal data where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your personal data to comply with local law. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.

Object to processing of your personal data where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms. You also have the right to object where we are processing your personal data for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms.

Request restriction of processing of your personal data. This enables you to ask us to suspend the processing of your personal data in the following scenarios: (a) if you want us to establish the data's accuracy; (b) where our use of the data is unlawful but you do not want us to erase it; (c) where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims; or (d) you have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.

Request the transfer of your personal data to you or to a third party. We will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.

Withdraw consent at any time where we are relying on consent to process your personal data. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain products or services to you. We will advise you if this is the case at the time you withdraw your consent.

If you wish to exercise any of the rights set out above, please contact us.

No fee usually required

You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we may refuse to comply with your request in these circumstances.

What we may need from you

We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.

Time limit to respond

We try to respond to all legitimate requests within one month. Occasionally it may take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.

LAWFUL BASIS

Legitimate Interest means the interest of our business in conducting and managing our business to enable us to give you the best service/product and the best and most secure experience. We make sure we consider and balance any potential impact on you (both positive and negative) and your rights before we process your personal data for our legitimate interests. We do not use your personal data for activities where our interests are overridden by the impact on you (unless we have your consent or are otherwise required or permitted to by law). You can obtain further information about how we assess our legitimate interests against any potential impact on you in respect of specific activities by contacting us

Performance of Contract means processing your data where it is necessary for the performance of a contract to which you are a party or to take steps at your request before entering into such a contract.

Comply with a legal or regulatory obligation means processing your personal data where it is necessary for compliance with a legal or regulatory obligation that we are subject to.