PRIVACY POLICY
This privacy policy explains what we do with your personal data. Please read it carefully because, by using our service, you are consenting to the processing of your personal data described in this policy.
For the purposes of the Data Protection Act 1998, the Data Controller is EMSG Holdings Ltd acting as Hunted Ltd, a company registered in England with company number 15159696. Our registered office is at Treviot House, 186-192 High Road, Ilford, Essex, United Kingdom, IG1 1LR.
This privacy policy was last updated on 31 May 2024. Updated versions will be posted on this page from time to time. If appropriate, we will notify you by email of any significant changes.
We take your privacy very seriously. Please read this privacy policy carefully as it contains important information on who we are and how and why we collect, store, use and share any information relating to you (your personal data) in connection with your use of our website. It also explains your rights in relation to your personal data and how to contact us or a relevant regulator in the event you have a complaint.
We collect, use and are responsible for certain personal data about you. When we do so we are subject to the UK General Data Protection Regulation (UK GDPR).
This privacy policy is divided into the following sections:
•What this policy applies to
•Personal data we collect about you
•How your personal data is collected
•How and why we use your personal data
•Marketing
•Who we share your personal data with
•How long your personal data will be kept
•Transferring your personal data out of the UK
•Cookies
•Your rights
•Keeping your personal data secure
•How to complain
•Changes to this privacy policy
How to contact us
Do you need extra help?
What this policy applies to
This privacy policy relates to your use of our website only.
Throughout our website we may link to other websites owned and operated by certain trusted third parties to [insert details (eg make additional products and services available to you)]. Those third party websites may also gather information about you in accordance with their own separate privacy policies. For privacy information relating to those third party websites, please consult their privacy policies as appropriate.
Personal data we collect about you
The personal data we collect about you depends on the particular activities carried out through our website. We will collect and use the following personal data about you:
•contact information such as name, address, telephone number, email address
•information to check and verify your identity, eg date of birth
•your gender, if you choose to give this to us
•location data, if you choose to give this to us
•your public profile data on other social platforms such as LinkedIn and your earnings;
•financial information such as your credit card details (Employers Only)
•information about your skills, background and experience (if you are a recruiter)
•information about your job requirements (if you are an employer on our service).
Some of that personal data may be classified as sensitive personal data under the Data Protection Act. For example, if you upload a photograph of yourself to your profile, that will reveal to us information about your ethnicity. We will treat sensitive personal data in accordance with our obligations under the Data Protection Act. Sometimes you can choose if you want to give us your personal data and let us use it. Where that is the case we will tell you and give you the choice before you give the personal data to us. We will also tell you whether declining to share that personal data will have any effect on [insert as appropriate, eg your use of our website or any services on it].
We collect and use this personal data for the purposes described in the section ‘How and why we use your personal data’ below.
How your personal data is collected
We collect personal data from you:
•directly, when you enter or send us information, such as when you [insert, eg register with us, contact us (including via email), send us feedback, post material to our website and complete customer surveys or participate in competitions via our website], and
•indirectly, such as your browsing activity while on our website; we will usually collect information indirectly using the technologies explained in the section on ‘Cookies’ below
How and why we use your personal data
Under data protection law, we can only use your personal data if we have a proper reason, eg:
•where you have given consent
•to comply with our legal and regulatory obligations
•for the performance of a contract with you or to take steps at your request before entering into a contract, or
•for our legitimate interests or those of a third party
A legitimate interest is when we have a business or commercial reason to use your personal data, so long as this is not overridden by your own rights and interests. We will carry out an assessment when relying on legitimate interests, to balance our interests against your own. You can obtain details of this assessment by contacting us (see ‘How to contact us’ below).
The table below explains what we use your personal data for and why.
What we use your personal data for
Our reasons
Creating and managing your account with us
For our legitimate interests, ie to be as efficient as we can so we can deliver the best service to you.
To perform our contract with you or to take steps at your request before entering into a contract.
Providing services to you
To perform our contract with you or to take steps at your request before entering into a contract
Conducting checks to identify you and verify your identity or to help prevent and detect fraud against you or us
To comply with our legal and regulatory obligations.
For our legitimate interests, ie to minimise fraud that could be damaging for you and/or us.
Enforcing legal rights or defend or undertake legal proceedings
Depending on the circumstances:
—to comply with our legal and regulatory obligations
—in other cases, for our legitimate interests, ie to protect our business, interests and rights
Customising our website and its content to your particular preferences based on a record of your selected preferences or on your use of our
Depending on the circumstances:
—your consent as gathered by the separate
What we use your personal data for
Our reasons
website
cookies tool on our website - see ‘Cookies’ below
—where we are not required to obtain your consent and do not do so, for our legitimate interests, ie to be as efficient as we can so we can deliver the best service to you at the best price
If you have provided such a consent you may withdraw it at any time by [insert details, eg explain by changing the setting on the cookies tool and add appropriate links] (this will not affect the lawfulness of our use of your personal data in reliance on that consent before it was withdrawn)
Retaining and evaluating information on your recent visits to our website and how you move around different sections of our website for analytics purposes to understand how people use our website so that we can make it more intuitive or to check our website is working as intended
Depending on the circumstances:
—your consent as gathered [insert, eg by the separate cookies tool on our website]—see ‘Cookies’ below
—where we are not required to obtain your consent and do not do so, for our legitimate interests, ie to be as efficient as we can so we can deliver the best service to you at the best price
If you have provided such a consent you may withdraw it at any time by [insert details as appropriate] (this will not affect the lawfulness of our use of your personal data in reliance on that consent before it was withdrawn)
Communications with you not related to marketing, including about changes to our terms or policies or changes to other important notices
Depending on the circumstances:
—to comply with our legal and regulatory obligations
—in other cases, for our legitimate interests, ie to be as efficient as we can so we can deliver the best service to you at the best price
Protecting the security of systems and data used to provide the services
To comply with our legal and regulatory obligations
We may also use your personal data to ensure the security of systems and data to a standard that goes beyond our legal obligations, and in those cases our reasons are for our legitimate
What we use your personal data for
Our reasons
interests, ie to protect systems and data and to prevent and detect criminal activity that could be damaging for you and/or us
Disclosures and other activities necessary to comply with legal and regulatory obligations that apply to our business, eg to record and demonstrate evidence of your consents where relevant.
To comply with our legal and regulatory obligations
Marketing our services
For our legitimate interests, ie to promote our business
See ‘Marketing’ below for further information
To share your personal data with members of our group and third parties that will or may take control or ownership of some or all of our business (and professional advisors acting on our or their behalf) in connection with a significant corporate transaction or restructuring, including a merger, acquisition, asset sale, initial public offering or in the event of our insolvency
In such cases information will be anonymised where possible and only shared where necessary
Depending on the circumstances:
—to comply with our legal and regulatory obligations
—in other cases, for our legitimate interests, ie to protect, realise or grow the value in our business and assets
How and why we use your personal data—Special category personal data
Certain personal data we collect is treated as a special category to which additional protections apply under data protection law:
•personal data revealing racial or ethnic origin, political opinions, religious beliefs, philosophical beliefs or trade union membership
•genetic data
•biometric data (when used to uniquely identify an individual)
•data concerning health, sex life or sexual orientation
Where we process such special category personal data, we will also ensure we are permitted to do so under data protection laws.
How and why we use your personal data—sharing
See ‘Who we share your personal data with’ for further information on the steps we will take to protect your personal data where we need to share it with others.
Marketing
We will use your personal data to send you updates (by email, text message, telephone or post) about our services.
We have a legitimate interest in using your personal data for marketing purposes. This means we do not need your consent to send you marketing information. If we change our marketing approach in the future so that consent is needed, we will ask for this separately and clearly.
You have the right to opt out of receiving marketing communications at any time by:
•contacting us.
•using the ‘unsubscribe’ link in emails or ‘STOP’ number in texts.
•updating your marketing preferences.
We will always treat your personal data with the utmost respect and never sell or share it with other organisations [outside the [insert organisation’s group name] group ]for marketing purposes.
For more information on your right to object at any time to your personal data being used for marketing purposes, see ‘Your rights’ below.
Who we share your personal data with
We routinely share personal data with:
•third parties we use to help deliver our services to you, eg payment service providers
•other third parties we use to help us run our business, eg website hosts and website analytics providers
•our bank
We only allow those organisations to handle your personal data if we are satisfied they take appropriate measures to protect your personal data. We also impose contractual obligations on them to ensure they can only use your personal data to provide services to us and to you.
We or the third parties mentioned above occasionally also share personal data with:
•our and their external auditors, eg in relation to the audit of our or their accounts, in which case the recipient of the information will be bound by confidentiality obligations
•our and their professional advisors (such as lawyers and other advisors), in which case the recipient of the information will be bound by confidentiality obligations
•law enforcement agencies, courts, tribunals and regulatory bodies to comply with our legal and regulatory obligations
•other parties that have or may acquire control or ownership of our business (and our or their professional advisers) in connection with a significant corporate transaction or restructuring, including a merger, acquisition, asset sale, initial public offering or in the event of our insolvency—usually, information will be anonymised but this may not always be possible. The recipient of any of your personal data will be bound by confidentiality obligations
Who we share your personal data with—further information
If you would like more information about who we share our data with and why, please contact us (see ‘How to contact us’ below).
How long your personal data will be kept
We will not keep your personal data for longer than we need it for the purpose for which it is used.
Different retention periods apply for different types of personal data.
If you stop using your account we will delete or anonymise your account data after 7 years.
Following the end of the of the relevant retention period, we will delete or anonymise your personal data.
Your rights
You generally have the following rights, which you can usually exercise free of charge:
Access to a copy of your personal data
The right to be provided with a copy of your personal data
Correction (also known as rectification)
The right to require us to correct any mistakes in your personal data
Erasure (also known as the right to be forgotten)
The right to require us to delete your personal data—in certain situations
Restriction of use
The right to require us to restrict use of your personal data in certain circumstances, eg if you contest the accuracy of the data
Data portability
The right to receive the personal data you provided to us, in a structured, commonly used and machine-readable format and/or transmit that data to a third party—in certain situations.
To object to use
The right to object:
—at any time to your personal data being used for direct marketing (including profiling)
—in certain other situations to our continued use of your personal data, eg where we use your personal data for our legitimate interests unless there are compelling legitimate grounds for the processing to continue or the processing is required for the establishment, exercise or defence of legal claims.
Not to be subject to decisions without human involvement
The right not to be subject to a decision based solely on automated processing (including profiling) that produces legal effects concerning
you or similarly significantly affects you
We do not make any such decisions based on data collected by our website.
The right to withdraw consents
If you have provided us with a consent to use your personal data you have a right to withdraw that consent easily at any time
Withdrawing a consent will not affect the lawfulness of our use of your personal data in reliance on that consent before it was withdrawn
If you would like to exercise any of those rights, please email, call or write to us—see below:
When contacting us please:
•provide enough information to identify yourself (eg your full name and address) and any additional identity information we may reasonably request from you, and
•let us know which right(s) you want to exercise and the information to which your request relates
Keeping your personal data secure
We have appropriate security measures to prevent personal data from being accidentally lost, or used or accessed unlawfully. We limit access to your personal data to those who have a genuine need to access it.
We also have procedures in place to deal with any suspected data security breach. We will notify you and any applicable regulator of a suspected data security breach where we are legally required to do so.
Changes to this privacy policy
We may change this privacy policy from time to time—when we make significant changes we will take steps to inform you.
How to contact us
Individuals in the UK
You can contact us and/or our Data Protection Officer by post, email or telephone if you have any questions about this privacy policy or the information we hold about you, to exercise a right under data protection law or to make a complaint.
Our contact details are shown below:
Our contact details
144a George Lane, London, E18 1AY
Our contact details
help@hunted.com
0203 195 3588
Do you need extra help?
If you would like this policy in another format (for example audio, large print, braille) please contact us (see ‘How to contact us’ above).