Privacy Policy

Richwell Partners Ltd - April 2024

1. INTRODUCTION

Welcome to the privacy policy of Richwell Partners Limited (“the firm” / “we” / “us” / “our”).

We take your privacy seriously and we are committed to protecting personal data (information) that we receive from you. This privacy policy explains our policies and practices regarding its processing of your personal data and explains your privacy rights under applicable privacy and security laws. We notify you of this as required under the General Data Protection Regulation.

This privacy policy has been effective since 14th May 2018. We review our privacy practices on an ongoing basis, so may change this privacy policy from time to time. If such change includes any significant, material changes, we will provide clear notice of the update on our website, www.richwellpartners.com.

Please check this policy frequently to ensure that you are familiar with its current content.

For the purposes of the Data Protection Act 1998 and the EU General Data Protection Regulations, the Company is a Data Controller in respect of any personal data that the firm, its affiliates and subcontractors collect. The firm also acts as a Data Processor in respect of any personal data it receives from, or collects directly, on behalf of each of our Partners. Further information on how your data is processed and for what purposes is set out below.

Contacting us

If you would like additional information on anything in or related to this privacy policy, or you would like to exercise any rights that you may have in relation to your personal data, please contact us at info@richwellpartners.com.

2. WHAT PERSONAL DATA MAY WE PROCESS?

The types of personal data relating to you that we may “process” (such as collect, use, store and share) depends on your interaction with us. The key types of personal data that we may process are set out below.

Personal data that you give us

Activity

Your Information supplied via our website

Types of personal data that we may process

Name, title, gender

Contact details (email address, business address)

Company

Any other personal data that you provide to us in your contact with us through our website, such as your home and business addresses, phone numbers, description of yourself, your position, and your requirements or comments

Please note that “Cookies” used on our website do not collect any personal data

Our legal bases for processing

Legitimate interests:

Getting to know clients or potential clients / colleagues / recruiters / employees / workers / consultants / service providers

Managing business communications with our clients and industry contacts

Responding to your communication(s) with us

Personal data that you give us

Activity

Your use of our services/ Our use of your services

Types of personal data that we may process

Name, title, gender

Contact details (personal or business email address, telephone numbers, address)

Company

Position

Information relating to any matter that you want to discuss with us that relates to you as an individual

Information from identification documents

Financial information, such as bank account details and requests relating to invoices

Any other personal data that you may disclose to us during your relationship with us, such as in calls or email correspondence

Information required by us for processing in relation to our mutual dealings with the Financial Conduct Authority.

Our legal bases for processing

Legitimate interests:

Getting to know clients / potential clients / service providers

Growing our business

Responding to your communication(s) with us

Contract

Fulfilling our obligations under our retainer or other agreement with you

Personal data that you give us

Activity

Your interest in our services

Types of personal data that we may process

Name, title, gender

Contact details (personal or business email address, telephone numbers, address)

Company

Position

Information relating to any matter that you want to discuss with us that relates to you as an individual

Any other personal data that you may disclose to us during your relationship with us, such as in calls or email correspondence

Our legal bases for processing

Legitimate interests:

Getting to know clients / potential clients / industry contacts

Growing our business

Responding to your communication(s) with us

Personal data that you give us

Activity

Your interest employment with us or our Clients or third- party consulting arrangement

Types of personal data that we may process

Name, title, gender, date of birth

Results of background checks including references, qualifications, and to the extent permitted by law, criminal background checks (unspent convictions)

Passport, work permit, visa, or other immigration documentation

Contact details (personal, business or educational institution email address, telephone numbers, address)

Curriculum Vitae, including relevant skills and experience

Application reasons

Language capabilities

Special requirements (such as, or relating to, a disability / health issue)

Any other personal data that you may provide to us through the application process, such as views and preferences that you disclose to us in interviews, your responses to questions, and demonstrations of your skills

Our legal bases for processing

Legitimate interests:

Getting to know employees or potential employees / workers / consultants

Fulfilling our staffing requirements

Ensuring potential recruits of any kind are appropriately qualified for positions at the firm

Consent

On the basis of the consent that you have provided to us to process your personal data in the context of your application which would include in relation to our conducting criminal background and other checks

Legal obligation

We have a legal obligation to verify your right to work lawfully in the UK


Personal data that we may collect through cookies

“Cookies” are small pieces of information that are stored by your browser on your computer’s hard-drive for record-keeping purposes. Cookies are used on our website www.richwellpartners.com . Cookies are not used to collect or to be linked to any personal data.

Other information that we may collect automatically

We may collect the following information relating to our website visitors automatically: domain name, IP address, and type of browser and type of operating system used. We may use this information for internal statistical analysis, such as to see where our website is being used geographically. However, we do not link this information with any personal data.

Personal data from minors

Our services, including our website, are directed solely at adults. We do not collect information from minors. Minors should not provide personal information to us via the website or in any other way.

3. HOW AND WHY MAY WE PROCESS YOUR PERSONAL DATA?

We may process your personal data in the following ways (depending upon your interaction with us):

Collecting your personal data that you input on our website, or provide to us in conversations, emails, or meetings with us.

Recording your personal data, such as through electronic or handwritten notes that we make.

Organising and storing your personal data on our servers, in our case management system, in our electronic HR filing system, in our employee’s email inbox folders, or in hard copy files.

Using your personal data to provide our services to you, and address any preferences, complaints, or comments that you have.

Disclosing your personal data to third parties, where necessary, appropriate and/or as required by law (see section 5 providing more information on this below).

We may process your personal data for the following purposes:

  1. To process and manage your purchase and use of our services.

  2. To respond to your questions, comments, complaints, or requests.

  3. To follow up with you on a job application or Consulting assignment.

  4. To create and deliver personalised communications that are relevant to services provided and your preferences.

  5. To further our internal business purposes, such as to perform data analysis, audits, fraud monitoring, and prevention; and operate and expand our business activities.

4. HOW WILL WE PROTECT YOUR PERSONAL DATA?

We have implemented security policies and technical measures to protect the personal data that we collect, consistent with applicable privacy and security laws. These security measures are designed to prevent unauthorised access, improper use or disclosure, unauthorised modification, and unlawful destruction or accidental loss of your personal data.

We update our personal data privacy and security measures on an ongoing basis. We also provide training to our employees on privacy laws and how to comply with them. We have disciplinary procedures in place that may be imposed on employees if they do not comply with our standards. Only employees who need to know your personal data to fulfil the purposes of processing that personal data (as described in this privacy policy) have access to it.

5. WITH WHOM MAY WE SHARE YOUR PERSONAL DATA?

We take your privacy seriously and will not share your personal data with others, except in the following circumstances:

Service providers – we may disclose your personal data to third-party service providers to provide us with services such as website hosting and professional services, including information technology services, payroll services, auditing services, consultancy services, regulatory services, and legal services.

Corporate transactions or events – we may disclose your personal data to a third party in connection with a corporate reorganisation, merger, joint venture, sale, transfer, or other disposition of all or any portion of our business or shares.

Legal reasons – we may use or disclose your personal data as we deem necessary or appropriate under applicable laws; to respond to requests from public, governmental; and regulatory authorities; to comply with court orders, litigation procedures, and other legal processes; to obtain legal remedies or limit our damages; to protect the operations of our company; and to protect the rights, safety, or property of our employees, you, or others.

6. WHAT RIGHTS DO YOU HAVE WITH RESPECT TO YOUR PERSONAL DATA?

If you are an EU citizen and reside in the EU, or are non-EU national residing in the EU, you may have the following rights with respect to the personal data you provide to us, to the extent permitted by applicable data protection laws:

  1. To withdraw any consent that you have provided to us to process your personal data.

  2. To access or review your personal data held by us.

  3. To have your personal data erased if it is no longer necessary for the purposes for which it was processed, you have withdrawn your consent to, or object to, its processing and there are no other legitimate grounds for processing it or you consider it has been unlawfully processed.

  4. To have the processing of your personal data restricted if you contest its accuracy, its processing is unlawful, we no longer need it but you need it for a legal claim, or you have objected to its processing and await verification of our legitimate grounds for processing it.

  5. To have your personal data transferred to another company under certain circumstances.

  6. To complain to your national data protection regulator if you feel that your personal data has been unlawfully processed.

7. FOR HOW LONG DO WE RETAIN YOUR PERSONAL DATA?

We retain your personal data only for as long as is necessary to facilitate our relationship with you, in accordance with our retention policies, and in accordance with applicable laws. We do not collect more personal data than we need to fulfil our purposes stated in this privacy policy, and we will not retain it for longer than is necessary.