Technicorns - Privacy Policy

twentyAI (”We”) are committed to protecting and respecting your privacy. Any mention of “Our Group” means our subsidiaries, our ultimate holding company and its subsidiaries, and our associated companies.

This notice sets out the basis on which any personal data we collect from you, or that you provide to us, will be processed by us. Please read the following carefully to understand our views and practices regarding your personal data and how we will treat it.

This Privacy Policy applies globally, but we have included additional information below for residents of the European Economic Area, the United Kingdom and California.

This Privacy Policy does not apply to pseudonymised, anonymous, or business contact information.

Who we are and what we do

We are a talent solutions business that provides recruitment and employment services. We collect the personal data of the following types of people to allow us to undertake our business;

Prospective and placed candidates for permanent or temporary roles;
Prospective and live client contacts;
Supplier contacts to support our services
Employees, consultants, temporary workers;

We collect information about you to carry out our core business and ancillary activities.

Information you give to us or we collect about you.

This is information about you that you give us by filling in forms on our site www.technicorns.com (our site) or by corresponding with us by phone, e-mail or otherwise. It includes information you provide when you register to use our site, to enter our database, subscribe to our services, attend our events, participate in discussion boards or other social media functions on our site, enter a competition, promotion or survey, and when you report a problem with our site.

The information you give us or we collect about you may include your name, address, private and corporate e-mail address and phone number, financial information, employment information, compliance documentation and references verifying your qualifications and experience and your right to work, photograph, links to your professional profiles available in the public domain e.g. LinkedIn, Twitter, business Facebook or corporate website.

Information we collect about you when you visit our website.

With regard to each of your visits to our site we will automatically collect the following information:

Technical information, including the Internet protocol (IP) address used to connect your computer to the Internet, your login information if applicable, browser type and version, information about your visit, including the full Uniform Resource Locators (URL), clickstream to, through and from our site (including date and time), jobs you viewed or searched for, page response times, download errors, length of visits to certain pages, page interaction, and any phone number used to call our customer service number.

Information we obtain from other sources.

This is information we obtain about you from other sources such as LinkedIn, corporate websites, job board websites, online resume libraries, your business card, personal recommendations.

We are working closely with third parties including business partners, sub-contractors in technical, professional, payment and other services, advertising networks, analytics providers, search information providers, credit reference agencies and professional advisors. We may receive information about you from them for the purposes of our recruitment and employment services and ancillary support services.

Purposes of the processing and the legal basis for the processing

We use information held about you in the following ways:

To carry out our obligations arising from any contracts we intend to enter into or have entered into between you and us and to provide you with the information and services that you request from us or we think will be of interest to you because it is relevant to your career or to your organisation.

To provide you with information about other services we offer that are similar to those that you have already purchased, been provided with or enquired about.

The core service we offer to our candidates and clients is the introduction of candidates to our clients for the purpose of temporary or permanent engagement. However, our service expands to supporting individuals throughout their career and to supporting businesses’ resourcing needs and strategies.

Our legal basis for the processing of personal data is our legitimate interests, described in more detail below, although we will also rely on contractual obligations to which you are subject, legal obligations and consent for specific uses of data.

We will rely on contractual obligations if we are negotiating or have entered into a placement agreement with you or your organisation or any other contract to provide services to you or receive services from you or your organisation.

We will rely on legal obligation in some cases, where we are required by law or regulation to process your data.

We will in some circumstances rely on consent for particular uses of your data. Where we rely on consent, you will be asked for your express consent. An example of when we will rely on consent as the legal basis for processing your data is when we process your data for marketing purposes.

Our Legitimate Interests

Our legitimate interests in collecting and retaining your personal data is described below:

As a talent solutions business which provides recruitment and employment services, we introduce candidates to clients for permanent employment, temporary worker placements or independent professional contracts. The exchange of personal data of our candidates and our client contact details is a fundamental part of this process.

In order to support our candidates’ career aspirations and our clients’ resourcing needs, we require a database of candidate and client personal data. The database will contain historical information as well as current resourcing requirements.

To maintain, expand and develop our business we need to record the personal data of prospective candidates and client contacts.

Consent

Should we want or need to rely on consent to lawfully process your data we will request your consent orally, by email or by an online process for the specific activity we require consent for and record your response on our system. Where consent is the lawful basis for our processing you have the right to withdraw your consent to this particular processing at any time.

Other Uses we will make of your data:

We will also use your data:

To administer our site and for internal operations, including troubleshooting, data analysis, testing, research, statistical and survey purposes;
To improve our site to ensure that content is presented in the most effective manner for you when you are using your computer or other devices;
To notify you about changes to our service;
To allow you to participate in interactive features of our service, when you choose to do so;
As part of our efforts to keep our site safe and secure;
To measure or understand the effectiveness of advertising we serve to you and others, and to deliver relevant advertising to you;
To make suggestions and recommendations to you and other users of our site about goods or services that may interest you or them.

Do you have to provide us with personal data?

You may refuse to give us your personal and sensitive personal data. Furthermore, you have the right to ask us to delete, change or stop processing your data that we have already received or collected. If you do not provide us with personal or sensitive personal data, or if you request a restriction of processing however, we may not be able to provide you with the services that you have requested and that are stated in this policy.

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.

Where we store, process and disclose your personal data

Some information you provide to us is stored on our secure servers. Any payment transactions will be encrypted. Where we have given you (or where you have chosen) a password which enables you to access certain parts of our site, you are responsible for keeping this password confidential. We ask you not to share a password with anyone.

Unfortunately, the transmission of information via the internet is not completely secure. Although we will do our best to protect your personal data, we cannot guarantee the security of your data transmitted to our site; any transmission is at your own risk. Once we have received your information, we will use strict procedures and security features to try to prevent unauthorised access.

We will share your personal information with:

Any member of our group, including staff operating within our group, which is in the UK, the EEA and outside of the EEA. By submitting your personal data, you agree to this processing. We will take all steps reasonably necessary to ensure that your data is treated securely and in accordance with this privacy notice.

Selected third parties for the purpose of providing our recruitment and employment services including:

Clients for the purpose of introducing candidates to them;
Candidates for the purpose of arranging interviews and engagements;
Clients, business partners, suppliers, brokers and sub-contractors for the performance and compliance obligations of any contract we enter into with them or you;
Subcontractors including email marketing specialists, event organisers, payment and other financial service providers;
Credit reference agencies, our insurance broker, compliance partners and other sub-contractors for the purpose of assessing your suitability for a role where this is a condition of us entering into a contract with you.

We will disclose your personal information to third parties:

In the event that we sell or buy any business or assets, in which case we will disclose your personal data to the prospective seller or buyer of such business or assets.
If twentyAI or substantially all of its assets are acquired by a third party, in which case personal data held by it about its customers will be one of the transferred assets.
If we are under a duty to disclose or share your personal data in order to comply with any legal obligation, or in order to enforce or apply our terms of use and other agreements; or to protect the rights, property, or safety of twentyAI, our customers, or others. This includes exchanging information with other companies and organisations for the purposes of fraud protection and credit risk reduction.

The lawful basis for the third-party processing will include:

Their own legitimate interests in processing your personal data, in most cases to fulfil their internal resourcing needs;
Satisfaction of their contractual obligations to us as our data processor;
For the purpose of a contract in place or in contemplation;
To fulfil their legal obligations.

Your rights

You have the right to ask us not to process your personal data for marketing purposes. We will usually inform you (before collecting your data) if we intend to use your data for marketing purposes or if we intend to disclose your information to any third party for marketing purposes. We will collect express consent from you, if legally required, prior to using your personal data for marketing purposes.

You can exercise your right to accept or prevent processing for marketing purposes by checking the boxes on the forms we provide you when we collect your data. You can also exercise the right to not have your data used for marketing purposes at any time by contacting us support@twentyai.com.

Our site may, from time to time, contain links to and from the websites of our partner networks, advertisers and affiliate. If you follow a link to any of these websites, please note that these websites have their own privacy policies and that we do not accept any responsibility or liability for these policies. Please check these policies before you submit any personal data to these websites.

Information you give to us or we collect about you.

Additional Information for European Residents

The UK General Data Protection Regulation (UK GDPR) (Regulation (EU) 2016/679) is a regulation which replaces the Data Protection Regulation (Directive 95/46/EC). The Regulation aims to harmonise data protection legislation across EU member states, enhancing privacy rights for individuals and providing a strict framework within which commercial organisations can legally operate.

The Brexit transition period ended on 31 December 2020 and the UK has now officially left the EU. The UK GDPR has been directly incorporated into UK law sitting alongside the Data Protection Act 2018.

If you are a UK or European Economic Area resident, GDPR provides you with the right to:

Request correction of the personal information that we hold about you. This enables you to have any incomplete or inaccurate information we hold about you corrected.
Request erasure of your personal information. This enables you to ask us to delete or remove personal information 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 information where you have exercised your right to object to processing (see below).
Object to processing of your personal information 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. You also have the right to object where we are processing your personal information for direct marketing purposes.
Request the restriction of processing of your personal information. This enables you to ask us to suspend the processing of personal information about you, for example if you want us to establish its accuracy or the reason for processing it.
Request the transfer of your personal information to another party in certain formats, if practicable.
Make a complaint to a supervisory body which in the United Kingdom is the Information Commissioner’s Office. The ICO can be contacted through this link: https://ico.org.uk/concerns/.

Access to information

The Data Protection Act 2018 and the UK GDPR give you the right to access information held about you. We also encourage you to contact us to ensure your data is accurate and complete. Your right of access can be exercised in accordance with the Act and the UK GDPR.

A subject access request should be submitted to support@twentyai.com. No fee will apply unless the requests from a data subject are manifestly unfounded or excessive, in particular because of their repetitive character. In such circumstances, we may charge a fee or refuse to act on the request.

Additional Information for California Residents

If you are a California resident, you can make certain requests regarding your personal information. We will fulfill each of these requests to the extent required by law.

You can ask us what personal information we have about you, including a list of categories of your personal information that we have sold and a list of categories of your personal information that we have shared with another company for a business purpose.
You can ask us to delete your personal information.
You can ask that we stop selling your personal information (although as noted we do not currently sell personal information to third parties.)

In order to exercise these rights, please contact us at support@twentyai.com. You may also contact us if you have any questions regarding the categories of personal information we have disclosed and to whom we disclose them.

In the preceding twelve (12) months, we have not sold personal information. We do not disclose your personal information to third parties for their direct marketing purposes.

Data Retention

We understand our legal duty to retain accurate data and only retain personal data for as long as we need it for our legitimate interests. We view our relationship with our candidates and clients as one of supporting continued growth and career advancement. As such, twentyAI may retain your data for a period which is greater than the minimum if we reasonably believe we will continue to have an ongoing business relationship with you.

We do the following to try to ensure that the data we hold about you is accurate:

Prior to making an introduction we check that we have accurate information about you.
We keep in touch with you so you can let us know of changes to your personal data.

We may store and handle your data in the following ways:

We may archive part or all of your personal data, retain it on our financial systems only or delete all or part of the data from our main Customer Relationship Manager (CRM) system.
We may pseudonymise parts of your data, particularly following a request for restriction or erasure of your data, to ensure that we do not re-enter your personal data on to our database, unless requested to do so.

For your information, pseudonymised data is created by taking identifying fields within a database and replacing them with artificial identifiers, or pseudonyms.

We will appropriately and securely dispose of your personal data when it is no longer required. Where there is no retention period stated in law, to determine the appropriate retention period we consider factors such as the purposes for which we process your personal data, including any legal, regulatory, payroll, accounting and reporting obligations, the amount and nature of data and its sensitivity, potential risk of harm from unauthorised use or access and the purpose for which we handle it.

Where we engage third parties to process data on our behalf, we will ensure, via a data processing agreement with the third party, that the third party takes such measures to maintain the Company’s commitment to protecting data.

All employees receive training covering basic information about confidentiality, data protection and the actions to take upon identifying a potential data breach. All employees who use our computer systems are trained to protect individuals’ private data, to ensure data security, and to understand the consequences to them as individuals and the Company of any potential lapses and breaches of the Company’s policies and procedures.

Where you have consented to the Company processing your personal data/sensitive personal data you have the right to withdraw that consent at any time by contacting support@twentyai.com.

Changes to our privacy notice

Any changes we make to our privacy notice in the future will be posted on this page and, where appropriate, notified to you by e-mail. Please check back frequently to see any updates or changes to our privacy notice.

Contact

Questions, comments and requests regarding this privacy notice are welcomed and should be addressed to Copthall House, 14-18 Copthall Avenue, London, United Kingdom, EC2R 7DJ.

For the purposes of GDPR the data controller is twentyAI Ltd of Copthall House, 14-18 Copthall Avenue, London, EC2R 7DJ.