Introduction

At Thomond we are committed to protecting and respecting your privacy. We work hard to keep your information safe and secure. We follow strict procedures on how personal information is stored and used and we also limit who sees it to help stop any unauthorised person getting hold of it.

This Privacy Policy (and any other documents referred to in it) sets out the basis on which we will process any personal information collected through our activities as a “Data Controller” – most commonly when dealing with enquiries or information that is gathered or sent through to us via our website.

Please read this Privacy Policy carefully to understand our practices regarding your personal information and how we will treat it.

Two quick things we hope you will find useful:

• We will not spam you.
• We will not sell, distribute or otherwise make your personal information public.

Please note that our responsibilities and activities as a “Data processor” on behalf of our customers are covered under our standard terms and conditions and therefore are not specifically addressed as part of this privacy policy.

2. Identity and Contact Details

We have a legal duty to protect personal information that we collect under the Data Protection Act 1998, (the “DPA”) and the General Data Protection Regulation (EU) 2016/679, (the “GDPR”).

For the purposes of the DPA and GDPR, we are the ‘Data controller’ and are located at Thomond Ltd., 17 Heathman’s Rd, London, SW4 7JL.

Any questions, concerns, comments, requests or complaints regarding this Privacy Policy, our Website and/or our use of your personal information should be addressed to info@thomond.com.

3. Personal Information We Collect from You

We may collect and use various types of personal information about visitors to our Website.

Details of this information are set out below:

• When you make an enquiry of us we will collect your name, contact information and details about the service you are interested in so that we can provide you with information that is of interest to you.
• We will collect and use certain technical information about your visit when you view our Website (covered in our Cookie Policy)
• If you submit your CV to us, we will use the information provided only to assess whether you may be a suitable candidate for any posts we are seeking to fill at the time. If there are no suitable vacancies when you submit your CV, we will inform you and will delete your CV details within 6 months.
• If you are selected for interview, but are unsuccessful, we may wish to retain your CV for a period of 3 years in the event, for example, that you wish to re-apply when you have increased your experience or skills or we have a new vacancy that we think may interest you. We will only do this with your consent, which you will be asked to give at the interview.
• We may collect certain other information that you give us, for example, if you report a problem with our website to us.

4. How We Use Personal Information

We use your information to provide services or updates you have asked for, to process employment applications, to enter into contracts with you (if applicable) and to provide you with a good experience on our website.

We collect and use personal information about our website visitors for the following purposes:

• Responding to any enquiries or requests that come through via our website, corresponding with you and recording any communications.
• Providing the products, services and information that you ask us for and carrying out our obligations under any contracts that we enter into with you.
• We do not share website visitors’ personal information with any third parties for marketing purposes.
• Cookies are also used on this website – see section 9 and our separate cookies policy for additional information in this regard.

Sensitive Personal Information

We do not knowingly collect sensitive personal information.

5. Where We Transfer and Store Personal Information

Depending on the nature of your enquiry or visit, we may choose to store your data using software provided by a small number of trusted third party software companies as follows:

Atlassian – https://www.atlassian.com

Google – https://policies.google.com/privacy?hl=en&gl=uk

Prosperworks – https://www.prosperworks.com/privacy

All of the above providers are headquartered in the USA and may store data both in EU and/or US data centres. All have signed up to Privacy Shield or have an alternative GDPR compliant Model Clause arrangement in place.

6. Bases for Processing Your Data

We collect and use website visitors’ personal information on several bases. Your rights as a data subject are balanced against Thomond’s legitimate interests in promoting its services and carrying out any contractual obligations we enter into with you. The bases for processing your data are:

Your consent – you as a customer, potential customer or potential employee (data subject) have consented to the processing of your personal data. This consent will have been provided via a choice of communication preferences at the outset of your relationship with Thomond, through our website or through contracting us to provide our services. You can of course change or opt out of these preference choices at any time should you wish to do so. This can be done via email at info@thomond.com.

Our legitimate Interests – Thomond may also process your personal data to provide you with information about our products, services and any aspects of our service or offers that you may be interested in. This does not affect your rights in any way and you are free to withdraw your consent to us at any time by sending an email request to info@thomond.com.

Our contract with you – if you have made an enquiry about our services, then the processing of the personal data, provided when you enquired through our website, is necessary for the performance of our contract with you.

Our legal obligation – in certain circumstances when Thomond have been requested and to comply with a legal obligation to the relevant UK authorities, then we will process data to fulfil this obligation. For example, this could be with the Police or other governmental or judicial authorities as requested.

7. Retention of Personal Information

We will keep your personal information for limited and appropriate periods of time only.

If you are a potential employee, we will retain any information you may provide only for as long as is necessary for our recruitment process, unless otherwise agreed by you.

If you are a potential client of our business, we will retain any information you may provide through the website only for as long as is necessary to fulfil our contractual commitments to you, unless otherwise agreed by you.

8. Your Rights Regarding your Personal Information

You have certain rights in respect of the personal information that we hold about you. Details of these rights are set out below. To exercise any of these rights, please contact us by emailing info@thomond.com.

We will process all personal data in line with your rights, in each case to the extent required by and in accordance with applicable law only (including in accordance with any applicable time limits and any requirements regarding fees and charges). We will respect your personal information rights in respect of:

Access. At your request we will confirm to you whether or not we are processing and using personal information about you. If we are we will provide you with a record, and a copy, of such personal information and/or other details to which you are entitled.

Rectification. We will correct any inaccurate personal data and complete any incomplete personal data (including by providing a supplementary statement) that we hold about you.

Prevention of processing likely to cause damage or distress. We will respect your rights under the DPA and GDPR to require us to cease or not to begin processing your personal information for a specific purpose, or in a specific way, that is likely to cause you or any third parties unwarranted damage or distress.

Erasure. We will erase your personal information at your request without undue delay.

Restriction. We will restrict the processing of your personal information in certain circumstances, if you ask us to do so.

Data portability. We will provide you or third parties on your behalf and at your request with a copy of any personal information that we hold about you which you have provided to us, in a structured, commonly used and machine readable format.

Objection (including objection to direct marketing). We will respect your general rights to object to the processing of your personal information in certain circumstances, including for direct marketing purposes. We will inform you (before collecting your information) if we intend to use your information for such purposes or if we intend to disclose your information to any third party for such purposes.

9. Cookies

Our website, like many others, uses small files called cookies to help us customise and improve your experience of it.

What are ‘cookies’?

‘Cookies’ are small text files that are stored by the web browser software (for example, Internet Explorer, Chrome or Safari) on your computer, tablet or mobile phone. They allow websites to store things like user preferences.

You can think of cookies as providing a ‘memory’ for the website, so that it can recognise you when you come back and provide the best experience for you. Cookies can also enable tracking of site visits and can help companies understand how their site is being used and how it can be further improved.

You can find out what cookies we use and how to switch them off in our Cookies Notice, which you will find on our website by clicking the link below.

https://thomond.com/cookie-policy.

10. Changes to Our Privacy Policy

We reserve the right to modify this Privacy Policy from time to time. Any changes we make in the future will be reflected in the privacy policy displayed on this website: https://thomond.com. You should check back frequently to see any updates or changes to our Privacy Policy which will be summarised in the versioning section at the end.

11. Complaints

If you have any complaints or concerns regarding this privacy policy, please send an email to info@thomond.com or contact us on 0203 7286 100.

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You may also contact the UK Information Commissioner at telephone number 0303 123 1113 or https://ico.org.uk/

12. Versioning

Thomond June 2019 version 1.0.