Privacy Policy

Important Information and Who We Are

Purpose of this Privacy Notice

This privacy notice aims to give you information on how we collect and process your personal data in a variety of circumstances. It is important that you read this privacy notice so that you are fully aware of how and why we are using your data. This version was last updated on 27 August 2019.

Controller

Castleforge Partners Limited (company no. 09103652) (referred to as we, us or our in this privacy notice) is the controller and responsible for your personal data. If you have any questions about this privacy notice (including any requests to exercise any of your legal rights) please contact us by emailing compliance@castleforge.com.

Third-Party Links

Our 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 or practices. When you leave our website, we encourage you to read the privacy notice of every website you visit.

The Data We Hold About You

Personal data means any information about an individual from which that person can be identified. We may (directly or indirectly) collect, use, store and transfer different kinds of personal data about you which we have grouped together follows:

Identity Data includes first name, last name, image, online username or similar identifier, title, date of birth and gender;
Contact Data includes email address, physical address and telephone numbers;
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 our website;
Usage Data includes information about how you use our website and services;
Marketing and Communications Data includes your preferences in receiving marketing from us and our third parties and your communication preferences;
Employment Data includes your education and employment history and other personal data you include on your CV, application form or covering letter or disclosed through a recruiter or during the application process (which may include data disclosing your racial or ethnic origin, religious or philosophical beliefs, trade union membership or health data); and
Diversity Data includes data relating to your ethnicity, disability, socio-economic status, religion, and gender identity. We ask our personnel to provide this information to us voluntarily.

Other than as noted above, we do not normally collect Special Categories of Personal Data about you (such as details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health and genetic and biometric data) through use of the website or when otherwise dealing with or concerning you.

If you fail to provide personal data

Where we need to collect personal data by law, or under the terms of a contract we have with you and you fail to provide that data when requested, we may not be able to perform the contract we have or are trying to enter into with you (for example, to provide you with services or employ you).

Your Duty to Inform us of Changes

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.

How Is Your Personal Data Collected?

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

Process of Collection	Types of data collected
(A) during direct interactions whenever you provide the personal data in person, by post, by phone, via our website, by email, via social media, or otherwise	Identity Data; Contact Data; Financial Data; Marketing and Communications Data
(B) as you interact with our website, we may use cookies, server logs and similar technologies	Technical Data; Usage Data; Marketing and Communications Data
(C) from third parties including your employer, analytics providers, advertising networks, electronic payment providers or data aggregators	Identity Data; Contact Data; Technical Data
(D) from recruitment service providers	Employment Data
(E) provided by personnel via our HR information system	Diversity Data

How We Use Your Personal Data

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

where we need to perform a contract we are about to enter into, or have entered into, with you;
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; or
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 where expressly asked for separately than in this notice, in relation to certain cookies and if necessary for 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.

Purposes for, and legal basis on, which we will use your personal data.

We have set out below a description of all the ways we may use your personal data, and which of the legal bases we rely on to do so (including a description of the legitimate interest pursued). Note that we may process your personal data for more than one basis depending on the specific purpose for which we are using your data.

Purpose/Activity	Legal basis for processing including basis of legitimate interest
To manage our relationship with you which may include notifying you about changes to our terms or privacy policy.	(a) Performance of a contract with you; (b) Necessary to comply with a legal obligation; and (c) Necessary for our legitimate interests (to keep our records updated and to study how customers use our products/services).
To administer a contract with an organisation you are associated with (e.g. your employer).	Necessary for our legitimate interests (to establish and perform a contractual relationship including receiving services) and all ancillary services.
To administer and protect our business and our website (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data).	(a) 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); and (b) Necessary to comply with a legal obligation.
To deliver relevant website content and advertisements to you and measure or understand the effectiveness of the advertising we serve to you.	Necessary for our legitimate interests (to study how customers use our products/services, to develop them, to grow our business and to inform our marketing strategy).
To use data analytics to improve our website, services, marketing, customer relationships and experiences.	Necessary for our legitimate interests (to define types of customers for our products and services, to keep our website updated and relevant, to develop our business and to inform our marketing strategy).
To make suggestions and recommendations to you about services that may be of interest to you or provide you with industry insights.	Necessary for our legitimate interests (to develop our products/services and grow our business).
We use your Diversity Data to generate anonymous data that we will use to promote diversity and inclusion in our recruitment process and workplace.	Necessary for our legitimate interest of identifying and reporting on the steps we wish to take in order to promote diversity and inclusion in the recruitment process and workplace. Where Diversity Data contains special category data, it will be collected in accordance with the substantial public interest condition, specifically equality of opportunity or treatment. Note that any such information is provided voluntarily and there are no consequences for you not providing this data.

Legitimate Interest means the interest of our organisation 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).

Marketing

We may contact you from time to time by call or email to provide some information about our products or services, including by occasional emails, bulletins or letters highlighting work we have been doing recently or are interested in working on in the future. 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, as 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 service experience or other transactions.

We will get your express opt-in consent before we share your personal data with any company outside of our own group for marketing unrelated to our company group.

Disclosures Of Your Personal Data

We may have to share your personal data with the parties (all established in the European Union unless otherwise stated) set out below for the purposes set out in the table in paragraph 4 above:

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;
HM Revenue & Customs, regulators and other authorities who require reporting of processing activities in certain circumstances;
Professional advisers including lawyers, bankers, auditors and insurers based in the European Union or United Kingdom who provide consultancy, banking, legal, insurance and accounting services; and
Service providers acting as processors, including (as at the date noted above and who may be updated from time to time):
- online banking provider based in England;
- phone and IT assistance services provider based in England;
- confidential waste and data destruction service provider based in England; and
- an online coworking management platform service provider based in England.

If you need further information on who your data may be transferred to, contact us at the above email address to discuss this. 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.

International Transfers

We do not transfer your personal data outside the European Economic Area (EEA).

Data Security

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. 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. 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.

Data Retention

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, how long a legal claim may be taken and whether we can achieve those purposes through other means, and the applicable legal requirements.

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.

Your Legal Rights

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

Request access to your personal data (commonly known as a “data subject access request”).
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 (subject to verification).
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, 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.
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.
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.
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.

If you wish to exercise any of the rights set out above, please contact us. Please note that we may not always be able to comply with your request for specific legal reasons which will be notified to you, if applicable.

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 we receive a number of requests. In this case, we will notify you and keep you updated.

Supervisory Authority Contact

You have the right to make a complaint to a relevant supervisory authority responsible for data protection. The Information Commissioner’s Office (ICO) is 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 a supervisory authority so please contact us in the first instance.