1. REAL LINKS LIMITED (Company number 10570135) of 5 Dagmar Road, London, United Kingdom SE5 8NZ (we, us or our) provides the products and services offered on our website www.reallinks.io (Real Links) to our clients with white-labelled company branding.
2. For the purposes of the Data Protection Act 1998 (Act), we are (i) a data controller (registered with the Information Commissioner’s Office for data protection: #ZA362196), and (i) a data processor, in relation to data provided by clients who are the data controller.
3. This policy takes into account application in the European Union of the General Data Protection Regulation (GDPR) with effect from 25 May 2018.
1. We handle data in our own right and also for and on behalf of our clients.
4. If, at any time, an individual or client provides data or other information about someone other than himself or herself, the individual warrants that they have that person’s consent to provide such information for the purpose specified.
5. We do not provide services to or collect data from children (persons under the age of 18 years).
1. You can visit our website without telling us who you are or revealing any information about yourself, including your email address. In this case, our server may collect the name, address, the IP address and domain you used to access the website, the type and version of browser and operating system you are using, and the website you came from and visit next. This information is used by us to measure the number of visits, average time spent, page views, and other statistics about visitors to our website in general. We may also use this data to monitor site performance for systems administration purposes, to make our website easier and more convenient to use and to report information in aggregate form to our advisers (e.g. how many visitors log in to our website).
2. Refer to our Cookies Policy (below) for further information about the cookies we use to collect information from visitors to our website.
1. In respect of information that we collect directly, an individual An individual may withdraw consent or opt to not have us collect their data and communicate with them at certain times by not providing express consent. This may prevent us from offering some or all of our services and may terminate access to some or all of the services we provide. They will be aware of this when:
2. If an individual believes that they have received information from us that they did not opt in or out to receive, they should contact us on the details below.
1. In the course of our business it is necessary for us to collect and receive data where we have a legitimate interest, pursuant to contract or with your consent. This information allows us to identify who an individual is for the purposes of our business, to provide services to our clients, share data when asked of us, contact the individual in the ordinary course of business and transact with the individual.
2. Where information has been received from a client in accordance with our services, we are not responsible for the collection and monitoring of consent in that information. The burden of obtaining consent rests with the client.
3. Without limitation, the type of information we may collect or receive is:
5. We may also collect or receive non-data about an individual such as information regarding their computer, network and browser.
1. Most information will be collected or received in association with:
2. We may receive information from individuals that are employees or alumni of our clients that relates to potential candidates extracted from those employees’ or alumni’s business or social networks.
3. We may also receive data from other sources such as advertising, promotions, public records, mailing lists, contractors, staff, recruitment agencies and our business partners (such as Facebook or Twitter). In particular, information is likely to be collected as follows:
4. If, at any time, a third party provides data or other information about any individual, we require that party warrants that they have that person’s consent to provide such information to us for the purpose specified.
5. Real Links will publish changes to the way that information is collected at the point of collection and within this policy.
1. The data that we collect from you and data which we receive from clients will be stored in the European Economic Area (EEA), but may be transferred to, and stored at, a destination outside the EEA, with and by third parties.
2. Data may also be processed by third parties and/or staff operating outside the EEA who work for us or for one of our third party partners. Such staff may be engaged in, among other things, the fulfilment of your order, the processing of your payment details and the provision of support services. By submitting your personal data, you agree to this transfer, storing or processing.
3. We will retain data for the period necessary to fulfil the purposes outlined in this policy unless a longer retention period is required or permitted by law.
1. Except as necessary and we have a legitimate interest:
2. In particular, we provide CV information to our account managers who seek to find you employment with third party employers. Whereas Real Links takes steps to only engage with reputable organisations, we cannot guarantee that all third parties and employers will adhere to the limitations we impose on them. If at any time you would like your CV or details removed from our website, please email firstname.lastname@example.org and it shall be removed.
3. Job postings which are posted on our website allow an individual to follow links to apply (and provide a CV) in response to a specific job posting. Although we use reasonable means to protect your personal information, Real Links is not responsible for any improper use of your personal information that is beyond our reasonable control.
4. Information is used to enable us to operate our business, especially as it relates to an individual or the provision of services to a client – this may include (subject to necessary consent or pursuant to a relevant contract):
5. If you publicly post about Real Links, or communicate directly with us, on a social media website, we may collect and process the data contained in such posts or in your public profile for the purpose of addressing any customers services requests you may have and to monitor and influence public opinion of Real Links.
1. It may be necessary for us to disclose an individual’s data to third parties in a manner compliant with the Act in the course of our business, such as for processing activities like website hosting.
2. We will not sell an individual’s data to unrelated third parties, unless applicable consent has been obtained for us to partner with those companies to offer you related services, or employ other companies to perform tasks on our behalf and we need to share your information with them to provide products and services to you.
3. There are some circumstances in which we must disclose an individual’s information:
4. We will not disclose an individual’s data to any entity outside of the EEA, unless that entity operates in an environment governed by requirements that are at least equivalent to the GDPR. We will take reasonable steps to ensure that any disclosure to an entity outside of the EEA will not be made until that entity has agreed in writing with us to safeguard data as we do.
5. We may partner with or utilise third-party service providers (such as Gmail from Google, Inc) to communicate with an individual or client and to store contact details about an individual or client. These service providers may be located outside the United Kingdom, including the United States of America.
6. If Real Links gets involved in a merger, asset sale, financing, liquidation or bankruptcy, or acquisition of all or some portion of the business to another company, you consent to us sharing with that company before and after the transaction closes information: (i) that we hold in our capacity as data controller relating to an individual; and (ii) that we hold in our capacity as data processor subject to any confidentiality provisions between us and our clients.
1. We may share an individual’s information and information received from our clients, client employees or client alumni with third parties for the processing and storage of that information. For example:
2. We are not responsible for the privacy practices of third parties. We recommend that you read the privacy policies of third party service providers so you can understand the manner in which your personal information will be handled by these providers.
3. In particular, remember that certain service providers may be located in or have facilities that are located in a different jurisdiction (including outside the EEA). So if you elect to proceed with a transaction that involves the services of a third-party service provider, then your information may become subject to the laws of the jurisdiction(s) in which that service provider or its facilities are located.
4. As an example, if you are located in United Kingdom and your transaction is processed by a payment gateway located in the United States, then your personal information used in completing that transaction may be subject to disclosure under United States legislation (including the USA Patriot Act).
5. The information we may obtain from those services often depends on your settings or their privacy policies. We recommend that you read any third party privacy policies before entering any personal information.
6. When you click on links on our platform, they may direct you to third party websites. We are not responsible for the privacy practices of other sites and encourage you to read their privacy statements.
1. We will take all reasonable precautions to protect an individual’s and our client’s data from unauthorised access. This includes appropriately securing our physical facilities and digital networks.
2. The security of online transactions and the security of communications sent by electronic means or by post cannot be guaranteed. Each client and individual that provides information to us via the internet or by post does so at their own risk. We cannot accept responsibility for misuse or loss of, or unauthorised access to, data where the absolute security of information is not always within our control.
3. We are not responsible for the privacy or security practices of any third party (including third parties that we are permitted to disclose an individual’s data to in accordance with this policy or any applicable laws). The collection and use of an individual’s or a client’s information by such third parties may be subject to separate privacy and security policies.
4. If an individual or client suspects any misuse or loss of, or unauthorised access to, their data, they should let us know immediately.
5. To the extent permitted by law, we are not liable for any loss, damage or claim arising out of another person’s use of the data where we were authorised to provide that person with the data.
13. HOW TO ACCESS AND/OR UPDATE INFORMATION
1. The Act gives you the right to request from us the data that we have about you.
2. If an individual cannot update his or her own information, we will correct any errors in the data we hold about an individual within one month of receiving written notice from them about those errors.
3. It is an individual’s responsibility to provide us with accurate and truthful data. We cannot be liable for any information that is provided to us that is incorrect.
4. We may charge an individual a reasonable fee for based on our administrative costs incurred in meeting any of their requests to disclose the data we hold about them if such a request is manifestly unfounded or excessive. We reserve the right to clarify the specific information your request relates to.
5. Information will be provided within one month of receipt of the request.
unless we hold legitimate grounds for processing or the processing is for the establishment, exercise or defence of legal claims.
All correspondence with regards to privacy should be addressed to:
Real Links Limited
5a Dagmar Road
We ask that you contact us by email in the first instance.