ABN Resource Ltd Privacy & Cookie Policy

How we use cookies

A cookie is a small file which, with your permission, is placed on your computer’s hard drive. One you give permission, the file is then added and the cookie helps analyse web traffic or lets you know when you visit a particular site.

Cookies allow web applications to respond to you as an individual. The web application can tailor its operations to your needs, likes and dislikes by gathering and remembering information about your preferences.

We use traffic log cookies to identify which pages are used. This helps us analyse data about web page traffic and improve our website in order to tailor it to your needs. We only use this information for statistical analysis purposes and then the data is removed from the system.

Cookies help us provide you with a better website through monitoring which pages you find useful. A cookie in no way gives us access to your computer or any information about you, other than the data you choose to share with us.

You can choose to accept or decline cookies. Most web browsers automatically accept cookies, but you can usually modify your browser setting to decline them if you prefer. But this may prevent you from taking full advantage of the website.

Privacy Policies

PRIVACY NOTICE

“REST OF THE WORLD”

FOR INDIVIDUALS NOT COVERED BY A SPECIFIC PRIVACY NOTICE

This notice applies to you if we process your personal information and you are not an employee or worker of ours, a prospective candidate employee or worker, a candidate we are looking to place into a job or an individual to whom we have provided a specific privacy notice. You may be, for example, an individual that works at a supplier or client or another organisation that we deal with, an attendee at one of our marketing or industry events, a user of our website or someone else who is affected by our activities.

References to you, your and yourself in this privacy notice are to either you as an individual or any organisation that you work for.

References to we, our or us in this privacy notice are to ABN Resource Limited

ABN Resource Limited is a limited company incorporated in England and Wales. Registered Number: 07959593. Registered Office: Floor 8, Pinnacle Building, Albion Street, Leeds, England, LS1 5AA. Telephone Number: +44 0 113 487 7420. VAT Number: 132817523.

We have not appointed a Data Protection Officer to oversee our compliance with data protection laws as we are not required to do so, but our Data Protection Compliance Manager has overall responsibility for data protection compliance in our organisation. Contact details are set out in the “Contacting us” section at the end of this privacy notice.

We are committed to respecting your privacy. This notice is to explain how we may use personal information we collect before, during and after your relationship with us. This notice explains how we comply with the law on data protection and what your rights are.

1. Personal information we collect

We may collect the following types of personal information about you:

Contact details: information that allows us to identify and contact you directly such as your name, addresses, email address, and telephone number.
Identification information: passport and other official identification details, information from a third party money laundering check provider, Companies House information, national insurance number, membership of relevant schemes.
Details of your work history: this may include positions, roles, responsibilities and professional qualifications.
Personal history and information: this includes hobbies, interests, marital status, family details and dietary requirements.
Advisors appointed by you: including, lawyers, financial advisors, surveyors.
Business information: including property owned by you, transactions, amounts paid or owed and tenants.
Responses to surveys, competitions and promotions: we keep records of any surveys you respond to or your entry into any competition or promotion we run.
Creditworthiness: we may undertake investigations into your creditworthiness in order to establish whether to enter into or continue a business relationship with you or the organisation you work for.
Details of your performance: when working with or for us or in relation to any project or work we are engaged in.
How you use our website: we collect information about the pages you look at and how you use them, usernames and passwords.
Videos, photographs and audio recordings: which you or other people take and provide to us or we take ourselves.
Details of the correspondence (including e-mail correspondence) you send and receive from us and details of any claims: this includes letters and emails, SMS, MMS and other electronic communication and may in some cases include audio recording of telephone conversations.
Subscription information: for example when you subscribe to one of our, newsletters or other materials.
IP address information: your computer’s IP address allows us to track your usage of our website.

2. SPECIAL CATEGORIES OF PERSONAL INFORMATION

We do not collect, store and use the following “special categories” of more sensitive personal information regarding you:

information about your race or ethnicity, religious beliefs, sexual orientation and political opinions;
information about your trade union memberships;
information about your health, including any medical condition, health and sickness records, medical records and health professional information; and
biometric information about you, for example fingerprints, retina scans.

If we do collect any special category personal information, we do not currently rely on consent as a basis for processing special category personal information.

We will also not collect, store and use any criminal records information in relation to you. If we do collect any criminal records information, we do not currently rely on consent as a basis for processing criminal records information.

3. Sources we collect your personal information from

We will collect personal information from a number of sources. These may include the following:

Directly from you: when you indicate that you may wish to attend an event, complete forms we provide to you, use our website, enter our competitions and promotions, make a claim, make a complaint, provide money laundering information to us contact us by phone, email or communicate with us directly in some other way.
From referrals and recommendations: usually given by other people who know you or have a working relationship with you.
Our website: provides us with information about how you use it and the devices that you use to connect to our website.
Providers of information: which may include professional bodies or trade associations, credit reference agencies, money laundering check provider, Companies House, the Land Registry, LinkedIn and other web platforms.
Your employer or the organisation you work for: they may provide us with your name, position contact details and background information about you.
Our professional advisors: such as lawyers, accountants, financial advisors, consultants and other advisors.
Your professional advisors: such as lawyers, accountants, financial advisors, consultants and other advisors.
The Government, local authorities or relevant regulators: to assist with investigations, for example the Information Commissioner’s Office or HMRC.
We will also collect additional personal information throughout the period of our relationship with you.
If you are providing information regarding other individuals to us, it is your responsibility to ensure that you have the right to provide the information to us.

If you are providing us with details about other individuals they have a right to know and to be aware of what personal information we hold about them, how we collect it and how we use and may share that information. Please share this privacy notice with those of them whom you feel are sufficiently mature to understand it. They also have the same rights as set out in the “Your rights in relation to personal information” section below.

4. What we use your personal information for

The table below describes the main purposes for which we process your personal information, the categories of your information involved and our lawful basis for being able to do this. Which will apply will depend upon the nature of your relationship and interactions with us.

Purpose	Personal information used	Lawful basis
Carrying out identity and credit checks	Contact details and payment information	We may have a legal obligation to undertake identification We also have a legitimate interest in knowing your identity and carrying out money laundering checks and ensuring that we are likely to be paid
Anti-money laundering checks		We may have a legal obligation to undertake anti-money laundering checks
Enter into and perform contracts, where we may be supplying services to you and/or you may be supplying products/services to us or we may be involved in similar arrangements with third parties	All the personal information we collect	To enter into and perform contracts with either yourself or the organisation that you represent We have a legitimate interest to properly perform contracts with third parties
Deal with your queries or complaints, claims, legal disputes or raise queries, claims, legal disputes or complaints with you or the organisation you work for	All the personal information we collect	This may be necessary to perform a contract with you or the organisation that you represent We have a legitimate interest to improve the services and/or products we provide To defend, bring or establish legal claims
Maintain and improve our services	All the personal information we collect	We have a legitimate interest to improve the services and/or products we provide
Data analytics, statistical analysis and other research to help us improve our online services	How you use our website	We have a legitimate interest to improve the online services we provide and user experience
Security of our IT systems	All the personal information we collect	We have a legitimate interest in ensuring the security of our IT systems
Staff training	All the personal information we collect	We have a legitimate interest to improve the products and services we provide
Direct marketing	Contact details and services and products that we have determined may be of interest to you or your organisation and/or which you or your organisation has purchased in the past	We may ask for your consent to process your data for this purpose, you may revoke your consent at any point. Alternatively if you or your organisation have purchased similar services from us previously we may market similar products or services as a legitimate interest in developing our business. You have the right to opt out from such marketing at any time
Holding events	Your contact details, details of attendance, your comments in response forms and dietary requirements	We have a legitimate interest in holding events and tracking attendance and providing appropriate food and drinks at events We may also have a legal obligation to comply with health and safety requirements
To comply with our legal obligations	All the personal information we collect	To comply with any legal obligations or requirements
To manage our relationship with you or the organisation you work for and to operate and manage our business and internal reporting	All the personal information we collect	We have a legitimate interest to operate our business in an efficient way and to expand our business To enter into and perform contracts with either yourself or the organisation that you represent
Storage of records relating to you and also records relating to our business	All the personal information we collect	To be able to manage and fulfil any contract with you, we may have a legal obligation to do so and we also have a legitimate interest to keep proper records

For some of your personal information you may have a legal, contractual or other requirement or obligation for you to provide us with your personal information. If you do not provide us with the requested personal information we may not be able to properly perform our contract with you or the organisation you represent or comply with legal obligations and we may have to terminate our relationship. For other personal information you may not be under an obligation to provide it to us, but if you do not provide it then we may not be able to properly perform our arrangements with you or the organisation you represent.

Where you have given us your consent to use your personal information in a particular manner, you have the right to withdraw this consent at any time, which you may do by contacting us as described in the “Contacting us” section below. We will generally only ask for your consent for direct marketing.

Please note however that the withdrawal of your consent will not affect any use of the data made before you withdrew your consent and we may still be entitled to hold and process the relevant personal information to the extent that we are entitled to do so on bases other than your consent. Withdrawing consent may also have the same effects as not providing the information in the first place, for example we may no longer be able to provide marketing information to you.

We may anonymise and aggregate any of the personal information we hold (so that it does not directly identify you). We may use anonymised and aggregated information for purposes that include testing our IT systems, research, data analysis, improving our site and services.

5. Who we share your personal information with

We may share personal information with the following parties:

Other companies in our supply chain: so that they can contact you about any issues in the supply chain or where your personal information is relevant to a subcontractor or party above us in the supply chain.
Credit reference and other identification agencies: so that we can assess your creditworthiness and to verify your identity. These agencies may retain a footprint that a search has been undertaken.
Third parties who ask for or want referrals: we may provide your details to a third party who is seeking services/products which are the same or similar to those that you provide.
Marketing and public relations companies: to help us to develop, carry out and assess marketing and PR campaigns
Other service providers and advisors to us: such as companies that support our IT, help us analyse the data we hold, process payments, send communications to our customers, provide us with legal, property or financial advice and generally help us deliver our services to you or the organisation that you represent or for us to purchase them from you or the organisation you represent.
Information providers: which may include credit reference agencies, money laundering check provider, Companies House, the Land Registry.
Purchasers of our business: buyers or perspective buyers to whom we sell or negotiate to sell our business.
The Government, local authorities, planning authorities or relevant regulators: where we are required to do so by law or to assist with their investigations, for example the Information Commissioner’s Office.
Police, law enforcement agencies and security services: to assist with the investigation and prevention of crime and the protection of national security.

We also use Google Analytics which sets cookies to collect information about how visitors use our website. We use the information to compile reports and to help us improve the website. The cookies collect information in an anonymous form, including the number of visitors to the website and blog, where visitors have come to the website from and the pages they visited. To opt out of being tracked by Google Analytics across all websites visit http://tools.google.com/dlpage/gaoptout.

We may provide third parties with aggregate statistical information and analytics about users of our products and services but we will make sure no one can be identified from this information before we disclose it.

We do not disclose personal information to anyone else except as set out above unless we have your consent or we are legally obliged to do so. We do not sell, rent or trade your data.

6. Direct Marketing

Email, post and SMS marketing: from time to time, we may contact you by email, post or SMS with information about products or services we believe you may be interested in.

We will only send marketing messages to you in accordance with the marketing preferences you set when you create your account or that you tell us afterwards you are happy to receive or where you or the organisation you represent have purchased similar services or goods from us previously.

You can then let us know at any time that you do not wish to receive marketing messages by sending an email to us at enquiries@abnresource.com or by using the by using the details set out in the “Contacting us” section below. You can also unsubscribe from our marketing by clicking on the unsubscribe link in any marketing messages we send to you.

7. Transferring your personal information internationally

The personal information we collect may be transferred to and stored in countries outside of the UK and the European Union. Some of these jurisdictions require different levels of protection in respect of personal information and, in certain instances, the laws in those countries may be less protective than the jurisdiction you are typically resident in. We will take all reasonable steps to ensure that your personal information is only used in accordance with this privacy notice and applicable data protection laws and is respected and kept secure and where a third part processes your data on our behalf we will put in place appropriate safeguards as required under data protection laws. For further details please contact us by using the details set out in the “Contacting us” section below.

Our directors and other individuals working for us may in limited circumstances access personal information outside of the UK and European Union if they are on holiday abroad outside of the UK or European Union. If they do so they will be using our security measures and will be subject to their arrangements with us which are subject to English Law and the same legal protections that would apply to accessing personal data within the UK.

In limited circumstances the people to whom we may disclose personal information as mentioned in the “Who we share your personal information with” section above may be located outside of the UK and European Union. In these cases we will impose any legally required protections to the personal information as required by law before it is disclosed.

If you require more details on the arrangements for any of the above then please contact us using the details in the “Contacting us” section below.

8. How long do we keep personal information for

We will keep your personal information for as long as is necessary for the purpose for which it has been obtained and then for as long as there is any risk of a potential claim, which will be dependent upon the limitation period for the particular type of claim. We have set out below the main retention periods which will apply:

For individual contacts at customers and suppliers this will be for as long as we continue to have a relationship with that customer or supplier and then for a period of 6 years afterwards.
For marketing contacts it will generally be a period of 6 years after we were last in contact with you.
For website users it will generally be a period of 6 years after you used our website.
For individuals seeking information, making complaints or otherwise corresponding with us it will generally be 6 years.
For individuals attending an event it will generally be a period of 6 years after the event.

It is important to ensure that the personal information we hold about you is accurate and up-to-date, and you should let us know if anything changes, for example if you move position or work for a different organisation or change your phone number or email address. you can contact us by using the details set out in the “Contacting us” section below.

9. Security

We have numerous security measures in place to protect the loss, misuse and alteration of information under our control, such as passwords and firewalls. We cannot, however, guarantee that these measures are, or will remain, adequate. We do, however, take data security very seriously and will use all reasonable endeavours to protect the integrity and security of the personal information we collect about you.

10. Your rights in relation to your personal information

You have the following rights in relation to your personal information:

the right to be informed about how your personal information is being used;
the right to access the personal information we hold about you;
the right to request the correction of inaccurate personal information we hold about you;
the right to request the erasure of your personal information in certain limited circumstances;
the right to restrict processing of your personal information where certain requirements are met;
the right to object to the processing of your personal information;
the right to request that we transfer elements of your data either to you or another service provider; and
the right to object to certain automated decision making processes using your personal information.

You should note that some of these rights, for example the right to require us to transfer your data to another service provider or the right to object to automated decision making, may not apply as they have specific requirements and exemptions which apply to them and they may not apply to personal information recorded and stored by us. For example we do not use automated decision making in relation to your personal data. However some have no conditions attached, so your right to withdraw consent or object to processing for direct marketing are absolute rights.

We may need to request specific information from you to help us confirm your identity and ensure your right to access the information (or to exercise any of your other rights). This is another appropriate security measure to ensure that personal information is not disclosed to any person who has no right to receive it.

Whilst this privacy notice sets out a general summary of your legal rights in respect of personal information, this is a very complex area of law. More information about your legal rights can be found on the Information Commissioner’s website at https://ico.org.uk/for-the-public/.

To exercise any of the above rights, or if you have any questions relating to your rights, please contact us by using the details set out in the “Contacting us” section below.

If you are unhappy with the way we are using your personal information you can also complain to the UK Information Commissioner’s Office or your local data protection regulator. We are here to help and encourage you to contact us to resolve your complaint first.

11. CHANGES TO THIS NOTICE

We may update this privacy notice from time to time. When we change this notice in a material way, we will update the version date at the bottom of this notice. For significant changes to this notice we will try to give you reasonable notice unless we are prevented from doing so. Where required by law we will seek your consent to changes in the way we use your personal information.

12. CONTACTING US

In the event of any query or complaint in connection with the information we hold about you, please email enquiries@abnresource.com or write to us at Floor 8, Pinnacle Building, Albion Street, Leeds, England, LS1 5AA.

Version July 2018

PRIVACY NOTICE FOR CANDIDATES

We are committed to respecting your privacy. This notice is to explain how we may use personal information we collect before, during and after your working relationship with us.

This notice applies to current and former candidates, who we have either placed into a permanent role or who have contacted us/we have contacted about a prospective job role. This notice does not form part of any contract to provide services.

References to we, our or us in this privacy notice are to ABN Resource Limited.

1. Personal Information

In order to support your career aspirations and source new job opportunities for you, you may provide us with or we may obtain personal information about you, such as information regarding your:

- personal contact details such as name, title, addresses, telephone numbers and personal email addresses;
- date of birth;
- gender;
- passport/driving licence details (including copies where we are required to hold such information for identification purposes);
- employment history and location of current employment or workplace, salary, annual leave, pensions and benefits entitlement;
- attendance at any events we host, organise or attend;
- records of your interactions with us such as telephone conversations, emails and other correspondence and your instructions to us;
- recruitment records including references and other information included in a CV, cover letter or as part of the application process) and activities (including information about interviews, jobs applications and offers);
- details about how you use our website e.g. the pages you look at and how you use them; and images in photographic or video format (where we record any footage of a video-conference between you and a client).

2. SPECIAL CATEGORIES OF PERSONAL INFORMATION

We may also collect, store and use the following “special categories” of more sensitive personal information regarding you where it is included in any CV:

- information about your race or ethnicity, religious beliefs, sexual orientation and political opinions;
- information about your trade union memberships; and
- information about your health, including any medical condition, health and sickness records, medical records and health professional information and disability information.

We may not collect all of the above types of special category information about you. In relation to the special category personal data that we do process we do so on the basis that:

- the processing is necessary for reasons of substantial public interest, on a lawful basis;
- it is necessary for the establishment, exercise or defence of legal claims;
- it is necessary for the purposes of carrying out the obligations and exercising our or your rights in the field of employment and social security and social protection law; or
- based on your explicit consent.

In the table below we refer to these as the “special category reasons for processing of your personal data”.

3. WHERE WE COLLECT YOUR INFORMATION

We typically collect personal information about candidates when you fill in forms on or upload a CV onto our site at http://abnresource.com or when you correspond with us by phone, e-mail or otherwise.

We also may collect personal information about candidates through other sources such as LinkedIn, job board websites, online CV libraries, personnel recommendations and referrals, hiring platforms and through the use of business development tools.

If you are providing us with details of referees, they have a right to know and to be aware of how what personal information we hold about them, how we collect it and how we use and may share that information. Please share this privacy notice with those of them whom you feel are sufficiently mature to understand it. They also have the same rights as set out in the “Your rights in relation to personal information” section below.

4. Uses made of the information

The table below describes the main purposes for which we process your personal information, the categories of your information involved and our lawful basis for being able to do this

*Purpose*	*Personal information used*	*Lawful basis*
Non- ‘special categories’ of Personal Information
To assess your CV and qualifications *(where you have provided us with/we have collected your personal information directly from you)*	All the personal information we collect for the purposes of the recruitment process.	We need this information to be able to perform and administer the recruitment process for you. We process special category personal data on the basis of the “special category reasons for processing of your personal data” referred to in section 2 above
To provide you with information regarding job opportunities that may be of interest to you based on your CV and qualifications *(where you have provided us with/we have collected your personal information directly from you)*	All the personal information we collect for the purposes of the recruitment process.	As above.
To contact you with information regarding job opportunities that may be of interest to you based on your CV and qualifications *(where we have obtained your information from a third party source)*	All contact details and all information contained in any CV (including employment and education history and location of current workplace).	Where your personal information has been sourced indirectly from either: (i) a hiring platform; (ii) social media platform where you have selected a function to let recruiters know that you are open to job opportunities; or (iii) a job board onto which you have uploaded your CV we have a legitimate business interest to do so. In all other cases, we will only contact you with information about job opportunities where we have your consent to do.
To manage our relationship with you including dealing with any support enquiries made by you	All your personal information excluding ‘special categories’ of personal information and criminal records information	To be able to manage and perform our contract with you and it is also in our legitimate business interest to ensure that all enquiries are managed properly.
To share your CV or details of your qualifications with a client in relation to potential job roles	All the non-‘special categories’ of personal information we collect for the purposes of the recruitment process.	We have a legitimate business interest to do so.
To arrange an interview with/introduction to a prospective employer in relation to a particular job role and managing the introductory process, provided you have indicated that you are happy for an introduction to be arranged	All the non-‘special categories’ of personal information we collect for the purposes of the recruitment process.	We will only do so with your explicit consent.
To check you are legally entitled to work in the UK	Personal contact details and identification documents and right to work documentation	We have a legal obligation to do so and it is also in our legitimate business interest to ensure that you are suitable for a role.
Storage of records relating to you and also records relating to our business such as your recruitment records and records of your interactions with us	All non-‘special categories’ of personal information	To be able to manage and fulfil our contract with you, we may have a legal obligation to do so and we also have a legitimate interest to keep proper records.
Dealing with legal disputes involving you.	All your personal information excluding ‘special categories’ of personal information and criminal records information	We have a legitimate interest to ensure that all legal claims are managed effectively.
To send you information we think you might find useful or which you have requested from us, including information about our services and any events we are running, provided you have indicated that you are happy to be contacted for these purposes	Personal contact details	Where you have given us your explicit consent to do so.
To conduct data analytics studies to review and better understand market trends within the recruitment industry	Records of your attendance at any events hosted or attended by us. All the personal information we collect for the purposes of the recruitment process excluding ‘special categories’ of personal information and criminal records information.	We have a legitimate interest in doing so to ensure that our business is targeted and relevant.
‘Special categories’ of Personal Information
Storage of records relating to you and also records relating to our business	All ‘special categories’ of personal information	We process special category personal data on the basis of the “special category reasons for processing of your personal data” referred to in section 2 above.
We will use information about your physical or mental health to assess your suitability for particular roles based on health grounds	Information about your health, including any medical condition, health and sickness records, medical records and health professional information	We process special category personal data on the basis of the “special category reasons for processing of your personal data” referred to in section 2 above.

For some of your personal information you will have a legal, contractual or other requirement or obligation for you to provide us with your personal information. If you do not provide us with the requested personal information we may not be able to engage you or we may not be able to properly perform our contract with you or comply with legal obligations and we may have to terminate your engagement. For other personal information, whilst you may not be under an obligation to provide it to us, if you do not provide it then we may not be able to properly perform our contract with you.

You should be aware that you are not required under any contract with us to agree to any request for consent. Where you have given us your consent to use your personal information in a particular manner, you have the right to withdraw this consent at any time, which you may do by contacting us as described in the “Contacting us” section below.

5. DIRECT MARKETING

Email, post and SMS marketing: from time to time, we may contact you by email, post or SMS with information about products and services we believe you may be interested in.

We will only send marketing messages to you in accordance with the marketing preferences you set. You can then let us know at any time that you do not wish to receive marketing messages by emailing us at enquiries@abnresource.com. You can also unsubscribe from our marketing by clicking on the unsubscribe link in the marketing messages we send to you.

6. Disclosure of your PERSONAL information

We share personal information with the following parties:

Any party approved by you.
Clients of our business where necessary: for example, the client of ours for whom you are ultimately providing services to.
Other service providers to our business and advisors: for example email marketing specialists, business development tool providers, professional advisors, contractors, and administration and IT services (including CRM, website, video- and teleconference services). All our third-party service providers and other entities in the group are required to take appropriate security measures to protect your personal information.
Purchasers of our business: buyers or perspective buyers to whom we sell or negotiate to sell our business.
Prospective new employers: our clients for the purpose of introducing you as a prospective new candidate;
The Government or our regulators: where we are required to do so by law or to assist with their investigations or initiatives, for example HMRC or the Information Commissioner’s Office; and
Police, law enforcement and security services: to assist with the investigation and prevention of crime and the protection of national security.

We do not disclose personal information to anyone else except as set out above.

7. TRANSFERRING YOUR PERSONAL INFORMATION INTERNATIONALLY

If you require more details on the arrangements for any of the above then please contact us using the details in the “Contacting us” section below.

8. HOW LONG WE KEEP PERSONAL INFORMATION FOR

The duration for which we retain your personal information will differ depending on the type of information and the reason why we collected it from you. However, in some cases personal information may be retained on a long term basis: for example, personal information that we need to retain for legal purposes will normally be retained in accordance with usual commercial practice and regulatory requirements. Generally, where there is no legal requirement we retain all physical and electronic records for a period of 6 years following your last contact with us.

It is important to ensure that the personal information we hold about you is accurate and up-to-date, and you should let us know if anything changes, for example if you move home or change your phone number or email address. You can contact us by using the details set out in the “Contacting us” section below.

9. YOUR RIGHTS IN RELATION TO PERSONAL INFORMATION

You have the following rights in relation to your personal information:

the right to be informed about how your personal information is being used;
the right to access the personal information we hold about you;
the right to request the correction of inaccurate personal information we hold about you;
the right to request the erasure of your personal information in certain limited circumstances;
the right to restrict processing of your personal information where certain requirements are met;
the right to object to the processing of your personal information;
the right to request that we transfer elements of your data either to you or another service provider; and
the right to object to certain automated decision making processes using your personal information.

To exercise any of the above rights, or if you have any questions relating to your rights, please contact us by using the details set out in the “Contacting us” section below.

10. CHANGES TO THIS NOTICE

We may update this privacy notice from time to time. When we change this notice in a material way, we will update the version date at the bottom of this page. For significant changes to this notice we will try to give you reasonable notice unless we are prevented from doing so. Where required by law we will seek your consent to changes in the way we use your personal information.

11. CONTACTING US

Version dated July 2018