1. In this Policy, the following terms shall have the following meanings:
1.1. "Cookie" means a small text file placed on your computer or device by the Website when you visit certain parts of the Website and/or when you use certain features of the Website. Details of the Cookies used by the Website are set out in section 14 below;
1.2. “Personal data” means any and all data that relates to an identifiable person who can be directly or indirectly identified from that data. In this case, it means personal data that you give to Us via the Website. This definition shall, where applicable, incorporate the definitions provided in the EU Regulation 2016/679 – the General Data Protection Regulation (“GDPR”);
1.3. “We/Us/Our” means Brightgrove, a company focused on software development and consulting.
2. What Does This Policy Cover
3. YOUR RIGHTS
4. What type of personal data do We collect?
Depending upon your use of the Website, We may collect some or all of the following personal data:
4.2. [contact information such as email addresses, telephone numbers, and links to social media accounts];
4.3. [web browser type and version];
4.4. [operating system];
4.5 [a list of devices and their screen resolutions].
5. For what purposes do We collect and/or process your personal data?
5.1. All personal data is processed and stored securely for no longer than is necessary in light of the reason(s) for which it was first collected. We will always comply with Our obligations and safeguard your rights under GDPR at all times.
5.2. Our use of your personal data will always have a lawful basis, either because it is necessary for Our performance of a contract with you, because you have consented to Our use of your personal data (e.g., by subscribing to emails), or because it is in Our legitimate interests. Specifically, We may use your data for the following purposes:
5.2.1. Supplying Our services to you (please note that We require your personal data in order to enter into a contract with you);
5.2.2. Replying to emails from you;
5.2.3. Supplying you with emails that you have opted into (you may unsubscribe at any time);
5.2.4. Analysing your use of the Website and gathering feedback to enable Us to continually improve the Website and your user experience;
5.3. With your permission and/or where permitted by law, We may also use your data for marketing purposes which may include contacting you by email and telephone with information, news, and offers on Our services. We will not, however, send you any unsolicited marketing or spam and will take all reasonable steps to ensure that We fully protect your rights and comply with Our obligations under the GDPR and the Privacy and Electronic Communications (EC Directive) Regulations 2003.
5.4. Third parties (Google analytics, Facebook analytics, Linkedin analytics, Twitter analytics, Google Tag Manager) whose analytical tools are implemented on the Website may use third-party Cookies, as detailed below in section 14. Please refer to section 14 for more information on controlling Cookies. Please note that We do not control the activities of such third parties nor the data they collect and use. We advise you to check the privacy policies of any such third parties.
5.5. You have the right to withdraw your consent to Us using your personal data at any time, and to request that We delete it.
6. How and How Long do we store your data?
6.1. We only keep your personal data for as long as We need to in order to use it as described above in section 5 and/or for as long as We have your permission to keep it.
6.2. Brightgrove only keeps Personal Data for the time strictly necessary in order to enable the use of our services and/or to fulfill the purposes identified above and/or to comply with any legal or regulatory obligations. This may imply retaining Personal Data after the recruitment process for a specific position has ended with Brightgrove for the period of time needed for Brightgrove to, for instance, demonstrate compliance with its legal or regulatory obligation, resolve dispute and/or enforce our agreements. If you have questions regarding the specific storage period of your Personal Data, please contact our DPO by email at email@example.com.
7. How do we share your data? Who are the recipients?
7.1. Unless otherwise provided in this Policy, We will not share any of your data with any third parties for any purposes.
7.2. In certain circumstances, We may be legally required to share certain data held by Us, which may include your personal data, for example, where We are involved in legal proceedings, where We are complying with legal obligations, a court order, or a governmental authority.
7.3. We may compile statistics about the use of the Website, including data on traffic, usage patterns, user numbers, sales, and other information. All such data will be anonymized and will not include any personally identifying data or any anonymized data that can be combined with other data and used to identify you.
7.4. We may sometimes use third-party data processors that are located outside of the European Economic Area ("the EEA") (The EEA consists of all EU member states, plus Norway, Iceland, and Liechtenstein). Where We transfer any personal data outside the EEA, We will take all reasonable steps to ensure that your data is treated as safely and securely as it would be within the EEA and under the GDPR.
8. Who is responsible for Your Personal Data?
8.1. Brightgrove is the controller of personal data collected through the Website.
9. What Happens If Our Business Changes Hands?
9.2. In the event that any of your data is to be transferred in such a manner, you will be contacted in advance and informed of the changes. When contacted, you will be given the choice to have your data deleted or withheld from the new owner or controller.
10. What are your rights regarding my Personal Data?
10. Your Rights
10.1. As a data subject, you have the following rights under the GDPR, which this Policy and Our use of personal data have been designed to uphold:
10.1.1. The right to be informed about Our collection and use of personal data;
10.1.2. The right of access to the personal data We hold about you;
10.1.3. The right to rectification if any personal data We hold about you is inaccurate or incomplete;
10.1.4. The right to be forgotten – i.e., the right to ask Us to delete any personal data We hold about you (We only hold your personal data for a limited time);
10.1.5. The right to restrict (i.e., prevent) the processing of your personal data;
10.1.6. The right to data portability (obtaining a copy of your personal data to re-use with another service or organization);
10.1.7. The right to object to Us using your personal data for particular purposes;
10.1.8. Rights with respect to automated decision-making and profiling.
10.2. If you have any cause for complaint about Our use of your personal data, please get in touch with Us using the details provided in section 11, and We will do Our best to solve the problem for you. If We are unable to help, you also have the right to lodge a complaint with the supervisory authority, the Information Commissioner's Office.
10.3. For further information about your rights, don't hesitate to get in touch with the Information Commissioner's Office or your local Citizens Advice Bureau.
11. How Can You Control Your Data?
11.1. In addition to your rights under the GDPR, set out in section 10, when you submit personal data via the Website, you may be given options to restrict Our use of your data. In particular, We aim to give you strong controls on Our use of your data for direct marketing purposes (including the ability to opt-out of receiving emails from Us which you may do by unsubscribing using the links provided in Our emails and at the point of providing your details).
12. Your Right to Withhold Information
12.1. You may access the Website without providing any data at all. However, to use all features and functions available on the Website, you may be required to submit or allow for the collection of certain data: consent to process your Personal Data for recruitment or providing service purposes. In such cases, Brightgrove will always ask for your prior consent before you submit your Personal Data to the Website. You will give your consent by taking a positive action (such as ticking a box) and will be free to withdraw your consent.
12.2. You have the right to request that we stop processing your Personal Data while we resolve any issues.
This is only possible in the following four cases: 12.2.1. If you contest the fact that the personal data we hold about you is accurate: in this case, the processing operations in relation to this data will be put on hold for the period during which this is verified.
12.2.3 You consider that the processing is unlawful, but you object to erasure and request restriction instead.
12.2.4 We have no further need for the data, but you require it to establish, exercise, or defend legal claims. Despite your request, we may continue to process your data if we have to establish, exercise, or defend legal claims. We will notify you before lifting a restriction.
13. How Can You Access Your Data?
13.1. You have the right to ask for a copy of any of your personal data held by Us (where such data is held). Under the GDPR, no fee is payable, and We will provide any and all information in response to your request free of charge. Don't hesitate to get in touch with Us for more details at firstname.lastname@example.org.
14. Cookies Policy
14.2. By using the Website, you may also receive certain third-party Cookies on your computer or device. Third-party Cookies are those placed by websites, services, and/or parties other than Us. Third-party Cookies are used on the Website. For more details, please refer to section 14.3 below.
14.3. All Cookies used by and on the Website are used in accordance with the current Cookie Law. We may use some or all of the following types of Cookie:
14.3.1. Strictly Necessary Cookies A Cookie falls into this category if it is essential to the operation of the Website. These cookies are necessary to allow us to operate the Website, so you may access them as requested. These also include cookies, which allow us to remember your previous actions within the same browsing session and to secure the Website.
14.3.2. Analytics Cookies It is important for Us to understand how you use the Website, for example, how efficiently you are able to navigate around it and what features you use. Analytics Cookies enable us to gather this information, helping Us to improve the Website and your experience of it.
14.3.3. Functionality Cookies Functionality Cookies enable Us to provide additional functions to you on Our Site, such as personalization and remembering your saved preferences. Some functionality Cookies may also be strictly necessary Cookies, but not all necessarily fall into that category.
14.3.4. Targeting Cookies It is important for Us to know when and how often you visit the Website and which parts of it you have used (including which pages you have visited and which links you have visited). As with analytics Cookies, this information helps us to better understand you. We never share this information with third parties for any purpose.
14.3.5. Third-Party Cookies Third-party Cookies are not placed by Us; instead, they are placed by third parties that provide services to Us and/or to you. Third-party Cookies may be used by advertising services to serve up tailored advertising to you on the Website or by third parties providing analytics services to Us (these Cookies will work in the same way as analytics Cookies described above).
14.3.6. Persistent Cookies Any of the above types of cookies may be a persistent Cookie. Persistent Cookies are those which remain on your computer or device for a predetermined period and are activated each time you visit the Website.
14.3.7. Session Cookies Any of the above types of cookies may be a session Cookie. Session Cookies are temporary and only remain on your computer or device from the point at which you visit the Website until you close your browser. Session Cookies are deleted when you close your browser.
14.3.8. Cookies on the Website are not permanent and will expire after a year of use. Afterward, their usage is re-launched automatically.
14.3.9. For more specific details of our Cookies, please refer to the table below.
Remarks, Questions & Reporting Violations
To report any violation of this Policy, or if you have any question, suggestion, or other comment you might have in the context of these terms, please email us at email@example.com.