Privacy Policy

1. PURPOSE OF THIS POLICY

1. REAL LINKS LIMITED (Company number 10570135) of PO Box 105, The Pill Box, 115 Coventry Road, London, England, E2 6GG  (weus or our) provides the products and services offered on our website (Services) www.reallinks.io (Real Links) to our clients with white-labelled company branding.

2. For the purposes of the Data Protection Act 2018 (the Act), we are a data controller (registered with the Information Commissioner’s Office for data protection: #ZA362196), for the personal data processed by us detailed in this Privacy Policy.

4. We have adopted this Privacy Policy to ensure that we have standards in place to protect the personal data that we collect and receive about individuals in the course of: i) providing the Services that we offer to our clients; ii) communicating with individuals; and iii) the normal operations of our business.

5. By publishing this Privacy Policy we aim to make it easy for our users, clients and the public to understand what data we collect, receive and store, why we do so, how we receive and/or obtain that information, and the rights an individual has with respect to their data in our possession.

2. WHO AND WHAT THIS POLICY APPLIES TO

1. Our Privacy Policy does not apply to information we collect about businesses or companies, however it does apply to information about the people in those businesses or companies, referred to in this Privacy Policy as ‘personal data’ or simply ‘data’.

2. The Privacy Policy applies to all forms of information, physical and digital, whether collected or stored electronically or in hardcopy that relate to an identifiable person.

3. We do not provide Services to, or collect data from, children (persons under the age of 18 years).

4. We will publicise any changes to this Privacy Policy on our website.

3. VISITING OUR WEBSITE

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.

2. 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).

3. Refer to our Cookies Policy (below) for further information about the cookies we use to collect information from visitors to our website.

4. CONSENT – OPT IN, OPT OUT AND OBJECTING TO PROCESSING

1. Where we rely on their consent as a legal basis for processing, an individual may withdraw consent to that processing at any time. Where we rely on the necessity of our legitimate interests as a legal basis for processing, an individual can object to that processing at any time. Unlike your right to withdraw consent, the right to object is a qualified right, which means that it only applies in certain circumstances. However we will always take such an objection under consideration and will generally comply where possible. We will only refuse such a request with strong and legitimate reasons, which will be communicated to you in writing. There is more information about your rights contained below at paragraph 14.

Withdrawing consent or objecting to the processing of some types of personal data may prevent us from offering some or all of our Services and may terminate access to some or all of the Services we provide. Where it is not impracticable or impossible to do so, we will give individuals an opportunity to either:

1.    Opt In. Where relevant, the individual will have the right to choose whether or not to have information collected and/or receive information from us; or

2.    Opt Out. Where relevant, the individual will have the right to choose to exclude himself or herself from some or all collection of information and/or receiving information from us. An individual may also revoke their consent or object to processing at any time, and this decision will be made through the same media which allowed the individual to opt in (and potentially other media).

2. If an individual believes that they have received information from us that they did not opt in or objected to receiving, they should contact us on the details below.

5. THE INFORMATION WE COLLECT AND RECEIVE

Without limitation, the type of information we may collect or receive is:

1.    Personal Information. We may collect or receive personal details such as an individual’s name, job title and other information that allows us to identify who the individual is;

2.    Social media profile information. We may receive information about a person’s professional profile such as work history and professional skills from employees or alumni of our clients;

3.    Internal mobility information. We may receive information about our clients’ employees skills, experience and interests from our clients’ employees;

4.    Contact Information. We may collect or receive information such as an individual’s email address, telephone number, mailing address and other information that allows us to contact the individual;

5.    Statistical Information. We may collect or receive information about an individual’s online and offline preferences, habits, movements, trends, decisions, associations, memberships, finances, purchases and other information for statistical purposes;

6.    Digital Information. We may collect or receive your IP address and device-specific information, such as the hardware model, operating system version, advertising identifier, unique application identifiers, unique device identifiers, browser type, language, wireless network and mobile network information (including mobile phone number); and

7.    Information provided to us. We may collect or receive any personal correspondence that an individual sends us, or that is sent to us by others about the individual’s activities, including activities with our clients and partners.

 

We do not collect special categories personal data and have implemented tools to filter out any such personal data during our collection process, however, if we do inadvertently process special categories personal data we will do so in accordance with this Privacy Policy and delete it as soon as practicable after becoming aware of it.

 

If we collect or receive other personal data about an individual not mentioned above, it will be processed in accordance with this Privacy Policy and the relevant individuals will be notified where it is not impossible or impracticable to do so.

 

6. HOW INFORMATION IS COLLECTED

1. Most information will be collected or received in association with:

1.    an individual’s use of our website(s) and/or Services, an enquiry about Real Links or generally dealing with us; or

2.    our engagement to provide our Services to clients who provide us with information relating to individuals that are employees, staff or contacts of those individuals. We may receive directly from individuals that are employees or alumni of our clients a) Internal Mobility information that relates to themselves and b) Social media profile information that relates to potential candidates from those employees’ or alumni’s business or social networks.

2. 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:

  • Services/engagements. When a client or individual engages our Services and/or provides list, account, connection or other process whereby they enter data details or grant access to information in order to receive or access something, including a transaction or Services. In particular, we will be provided with information relating to individuals within a client organisation;
  • When an individual grants us access to their accounts with our business partners (such as Facebook or Twitter);
  • Supply/Contact. When an individual supplies us with goods or Servicesor contacts us in any way;
  • Pixel Tags. Pixel tags enable us to send email messages in a format customers can read and they tell us whether mail has been opened.

 

3. If, at any time, a third party provides data or other information about any individual, we require that party warrants that they have a valid legal basis to provide such information to us for the purpose specified.

4. Real Links will publish changes to the way that information is collected at the point of collection and within this policy.

7. HOW DATA IS STORED

1. The data that we collect from you and data which we receive from clients will be stored by us in the European Economic Area (EEA), but may be transferred to, and stored at, a destination outside the EEA, with and by third parties (please see paragraph 9 below for more details).

 

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.

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.

8. WHEN DATA IS USED

1. We use personal data in a variety of different ways depending on who you are and how you are interacting with us. We have prepared a table (found at the end of this Privacy Policy) which provides an overview of the personal data that we collect where it applies to specific categories of data subjects, the purposes for which we use that data, the legal basis which permits us to use it and the rights that you have in relation to your personal data. Please refer to this for a more detailed explanation of how we use your personal data.

2. In general, we use personal data to:

enable us to operate our business, especially as it relates to an individual or the provision of Services to a client;

answer enquiries and questions from individuals and communicating with future opportunities and/or registration;

 

give developers information that is useful in determining appropriate new features, content and Services;

 

provide advertisers with non-personally identifiable aggregate, not individual, information about our customers;

 

investigate any complaints about or made by an individual or client, or if we have reason to suspect that an individual or client is in breach of any of our terms and conditions or that an individual or client is or has been otherwise engaged in any unlawful activity;

 

carry out regulatory checks and meeting our obligations to our regulators; and/or

 

as required or permitted by any law (including the Act).

 

3. 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 customer’s Services requests you may have and to monitor and influence public opinion of Real Links.

9. WHEN DATA IS DISCLOSED

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:

1.    Where we reasonably believe that an individual may be engaged in fraudulent, deceptive or unlawful activity that a governmental authority should be made aware of;

2.    As required by any law (including the Act) including court orders; and/or

3.    In order to sell our business (as we may transfer data to a new owner).

 

4. We will not disclose an individual’s data to any entity outside of the UK, unless that entity operates in an environment governed by requirements that are at least equivalent to the Act or the UK General Data Protection Regulation, which includes any jurisdiction within the European Economic Area and any jurisdictions that found adequate by the European Commission or the UK Government (Adequate Jurisdictions). We will take reasonable steps to ensure that any disclosure to an entity or body based outside of an Adequate Jurisdiction 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. Where possible, these service providers store our data in servers based in Adequate Jurisdictions. However, your data may be stored outside of an Adequate Jurisdiction, including the United States of America. As detailed above, where this is the case, we have put in place contractual, technical and organizational measures to ensure your data is protected to same level as it would be in an Adequate Jurisdiction.

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.

10. THIRD PARTY SERVICES, WEBSITES AND ACCOUNTS

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:

1.    all information may be processed and stored with cloud service providers (such as Amazon Web Services);

2.    all payment information may be provided to and processed by a payment gateway (such as www.Stripe.com or paypal.com); and

3.    information may be processed but not stored our by data partners (such as People Data Labs).

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.

11. COOKIE POLICY

1. Our website may use cookies to distinguish you from other users of our platform. This helps us to provide you with a good experience when you browse our platform and also allows us to improve our website. Your consent will be obtained prior to our use of cookies on our platform and you are able to revoke that consent by following the method below.

2. A cookie is a small file of letters and numbers that we store on your browser or the hard drive of your device if you agree. Cookies contain information that is transferred to your device’s hard drive. You block cookies by activating the setting on your browser that allows you to refuse the setting of all or some cookies. However, if you use your browser settings to block all cookies (including essential cookies) you may not be able to access all or parts of our website for which we require the use of cookies.

12. THE SAFETY & SECURITY OF DATA

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.

6. Real Links sources applicants from employees’ social and/or business networks and displays applicant profiles which include key details about applicants’ work histories but exclude any personal identifiers (name, sex, nationality, age etc.) and as such does not give access to personal data about applicants. Real Links uses publicly available information alongside information taken from social and/or business networks provided by employees and alumni to enrich applicant profiles with useful work related information about applicants. Real Links does not display any applicant personal data until an applicant makes the decision to apply for a position and confirms they have read and understood this privacy policy.

14. COMPLAINTS AND DISPUTES

1.    You have the right to object to:

1.    processing based on legitimate interests or the performance of a task in the public interest/exercise of official authority (including profiling);

2.    direct marketing; and

3.    processing for purposes of scientific/historical research and statistics

unless we hold legitimate grounds for processing or the processing is for the establishment, exercise or defence of legal claims.

1.    If an individual has an objection or complaint about our handling of their data, they should address their complaint in writing to the details below.

2.    You have the right to lodge a complaint with a supervisory authority if you consider that the processing of your data infringes the General Data Protection Regulation.

3.    If we have a dispute regarding an individual’s data, we both must first attempt to resolve the issue directly between us.

4.    If we become aware of any unauthorised access to an individual’s data which is likely to result in a high risk for the rights and freedoms of the data subjects we will inform the individual without undue delay after becoming aware of it once we have established what was accessed and how it was accessed.

15. ADDITIONS TO THIS POLICY

1. We reserve the right to modify this privacy policy at any time, so please review it frequently. Changes and clarifications will take effect immediately upon their posting on the website. If we make material changes to this policy, we will notify you here that it has been updated, so that you are aware of what information we collect, how we use it, and under what circumstances, if any, we use and/or disclose it.

2. If we decide to change this Privacy Policy, we will post the changes on our website at www.reallinks.co.uk/privacy. It is your responsibility to refer to this Privacy Policy to review any amendments. We may do things in addition to what is stated in this Privacy Policy to comply with the Act and nothing in this Privacy Policy shall deem us to have not complied with the Act.

16. CONTACTING US

All correspondence with regards to privacy should be addressed to:

Real Links Limited

PO Box 105, The Pill Box, 115 Coventry Road, London, England, E2 6GG

 

info@reallinks.io

 

We ask that you contact us by email in the first instance.


 


Category of data subject

Purpose

Personal data used

Legal basis

Which rights apply?*

Employees and alumni of our clients

For the provision of Services to a client, which includes to:

Manage your personal data and account on our Services;

Help you and your employer match your contacts from your network to job openings and assist you in contacting these candidates;

Help you and your employer match your skills and interests to job openings and assist you applying for these jobs and connecting with appropriate mentors;

Help you understand your role and responsibilities when acting as a mentor;

Send you notifications within the Services about the status of referrals you have made to your employer;

Respond to questions, comments, and other requests; and

Give your account access to key features of our platform such as rewards.

 

Personal Information

Contact information

Internal Mobility information

Digital Information

Statistical Information

Please note that often our clients (who may be your employer or potential employer) are acting as controller of personal data in this category. However, where we are acting as controller, the below legal basis applies.

Legitimate interest. It is necessary for us to process this information to provide our Services to our client (your employer).

It is in your employer’s interests to ensure it recruits the best possible candidates in order to achieve its business goals and objectives.

It is in your interests for us to process this information so that you can benefit from incentives schemes offered by your employer.

It is in our interest to process this information to improve our Services, generate new business and maintain existing relationships.

The generally applicable rights plus the right to object.

 

Potential candidates

For the provision of Services to a client, which includes to:

Build a profile for you on our Services based on your skills and experience using information gathered from our clients’ employees and publically available sources;

Help our clients match your skills and experience to job openings advertised by our clients; and

Allow you to apply for a job with one of our clients if you wish to do so; and

Send notifications to the employee who referred you about the status of your application.

 

Please note that all of your personal data is pseudonymised (temporarily anonymised) on our Services so our clients do not process, or even have sight of your personal data, until you have actively decided to apply for a role with them.

All communications will come via our clients’ employees (your social media contacts) and not from us.

 

Personal Information

Contact information

Social media profile information

 

Legitimate interest. It is necessary for us to process this information to provide our Service to our clients.

It is in our client’s interests to ensure it recruits the best possible candidates in order to achieve its business goals and objectives.

It is in your interests to be considered for new roles that may enhance your career and match your career aspirations.

The generally applicable rights plus the right to object.

Employees and alumni of our clients

For our own administrative, business or legal purposes, which includes to:

analyse the use and trends in our Services;

develop new products and Services;

ensure the quality of our products;

verify your identity;

communicate with you as a user of our services about changes to our Services;

process payment for products or Services purchased;

identify and prevent behavior that breaches our policies or relevant laws; and

enforce our legal rights and the provisions of our terms and conditions.

Personal Information

Contact information

Digital Information

Statistical Information

Legitimate interest.

All of these purposes are necessary to achieve our legitimate interests in ensuring the continued progress and smooth running of our business.

 

The generally applicable rights plus the right to object.

Employees and alumni of our clients

For the purpose of promoting our products and Services, which include to:

provide you with materials about offers for products and Services that may be of interest to you, including new content or Services; and

personalise content, advertisements, and offers.

 

Personal Information

Contact information

Digital Information

Statistical Information

Your explicit consent or our legitimate interest.

If we have a preexisting relationship with you through the Services we may rely on a ‘soft-opt’ and that processing is necessary in our legitimate interest to publicise our Services to clients/ customers and third parties.

The generally applicable rights plus the right to object.

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