PRIVACY POLICY PRIVACY NOTICE This Privacy Notice sets out the personal that Espire collects from you, how and when it may be collected and what happens to it. It is drafted in compliance with Data Protection Law. In this Privacy Notice, the following terms have defined meanings: Data Controller means the organisation that determines the purposes for which and the manner in which Personal Data are processed; Data Processor means the organisation that processes Personal Data on behalf of the Data Controller; Data Protection Law means any laws and regulations in the UK relating to privacy or the use or processing of data relating to natural persons, including: EU Directives 95/46/EC and 2002/58/EC (as amended by 2009/136/EC) and any legislation implementing or made pursuant to such directives, including (in the UK) the Data Protection Act 1998 (the DPA) and the Privacy and Electronic Communications (EC Directive) Regulations 2003; and from 25 May 2018, EU Regulation 2016/679 (GDPR); and any laws or regulations ratifying, implementing, adopting, supplementing or replacing GDPR or DPA; in each case, to the extent in force, and as such are updated, amended or replaced from time to time; Data Subject means a living, identifiable individual about whom Personal Data is processed; Espire Contact means an individual whose Personal Data an Espire Entity would like to Process for the purpose of Marketing and Sales Activities; Marketing and Sales Activities means the following activities and any combination of these activities: inviting you (using e-mail, telephone or other media) to: (i) marketing events organised by an Espire Entity or by a third party on behalf of an Espire Entity; and/or (ii) webinars organised by an Espire Entity or by a third party on behalf of an Espire Entity; sending you marketing newsletters; sending you information in relation to our products and services generally as well as current news and special offers; arranging personal/progress review meetings with you to discuss our products/services and check progress performance; connecting with you for business purposes on social media (such as LinkedIn); and any other reasonable marketing and sales activity which is carried out by similar businesses Personal Data means data which relate to a living individual who can be identified from those data or from those data and other information which is in the possession of or is likely to come into our possession as Data Controller or Data Processor, as the case may be. Personal Data include opinions and any indications of our intentions towards an individual; Processing includes obtaining, recording, holding, altering, retrieving, consulting, using, disclosing, blocking, erasing or destroying Personal Data; Espire Entities means: Espire Infolabs Limited, a private limited company incorporated in England and Wales with registration number 04313295, whose registered office is at Portland House| Bressenden Place, London SW1E 5RS, United Kingdom (Espire UK); and Espire Infolabs Private Limited, a private limited company incorporated in India with registration number, whose registered office is at A-41, Mohan Co-operative Industrail estate, New Dehli - 110044, India Espire India); Espire, we, our, us means Espire UK; Espire India and Espire group company You, your means each Espire Contact in receipt of this Privacy Notice whether by notice, URL link or other form of communication. The person responsible for overseeing data protection compliance issues at Espire is the Data Protection Officer who can be contacted via sapna.sharma@espire.com For the purpose of this Privacy Notice, we are a Data Controller and we Process Personal Data about you. This Privacy Notice concerns your Personal Data and describes how we collect and use Personal Data about you in respect of Marketing and Sales Activities. It is important that you read this Privacy Notice, together with any other privacy notice we may provide on specific occasions when we are collecting or processing Personal Data about you, so that you are aware of how and why we are using such Personal Data. This Privacy Notice should also be read in conjunction with our Privacy Policy. What personal data do we collect When you interact with us in the different ways described below, we may ask you for the following Personal Data: Personal and contact details (for example your name, email address, gender and your choice of language with which you wish to interact with us) Personal and contact details you give us when subscribing to receive emails, newsletters or marketing information from us during pre-assignment vetting we will request details from you including, your name, contact details (such as email, work and mobile telephone number), choices and requirements specific to particular requests or services details like bank details , references, right to work and other information will only be asked when you engage with us for taking services. Espire's cookies policy states that we do not store personal data via cookies. Please visit our websites for finding out more information about Espire services. How, when and why do we collect your Personal Data? We may collect your Personal Data in the following circumstances: as a result of and/or in the course of physical marketing events (for example, we may collect your business card at a marketing event); through Linked-In's Sales Navigator; from third parties, such as marketing agents, content syndicators and telemarketing services providers; from information you submit online (for example when using the "Contact Us" tool on our website); and from information you provide to register for webinars (whether organised by Espire Entity or by a third party). Lawful Basis of Processing? Under Data Protection Law, Data Controllers must justify the use of Personal Data by establishing a "Lawful Basis" of Processing. In Espire's case, this lawful basis is the pursuance of our legitimate interests (see below) as long as your interests and fundamental rights do not override those interests. Our Legitimate Interests Our 'legitimate interests' include, but are not limited to: the furtherance of our Marketing and Sales Activities; the pursuit or defence of any claims, rights or litigation or detection of a crime; our accounting or auditing functions and reporting duties; the furtherance of our commercial development, strategy, planning or growth including any business sales or transactions; and monitoring and ensuring compliance with our policies, processes and procedures However, we will only collect, use and handle your Personal Data when it is necessary for our legitimate interests . How long we keep your personal data for It is our policy to retain your Personal Data for: the length of time required for the specific purpose or purposes for which it was collected, which are set out in this Privacy Policy; or where a longer time period is required by applicable laws or a regulatory requirement, in which case we will ensure that your Personal Data will continue to be treated in accordance with this Privacy Policy. How we contact you We may contact you by post, e-mail, SMS text messages, WhatsApp message, telephone or other means including other electronic means such as Facebook and social media applications, and only using such contact details as you provide to us from time to time. You may at any time tell us that you no longer wish to receive such or certain communications, by contacting us using the unsubscribe Security and Confidentiality We employ appropriate technical and operational measures to help protect your Personal Data and guard against unauthorised access. Information storage is on secure computers in a secure environment, or in secure, locked storage in the case of hard copies. The Personal Data is encrypted wherever possible and we undergo periodic reviews of our security policies and procedures to ensure that our systems is secure and protected. We acknowledge that the Personal Data you provide may be confidential. We do not sell, rent, distribute or otherwise make Personal Data commercially available to any third party. We will keep your Personal Data confidential and protect it in accordance with our Privacy Policy and all applicable laws. Your rights It is important to us that you are in control of your own Personal Data. As a result, we offer the following controls, which you can exercise by contacting us via GDPR@espire.com or writing to us at the address below You may request access to or copies of the Personal Data that we hold about you If you believe that any Personal Data we have about you is incorrect or incomplete, we will take steps to seek to correct or update any Personal Data if we are satisfied that the Personal Data we hold is inaccurate You may request that your Personal Data be deleted, where it is no longer necessary for the purposes for which it is being processed and provided there is no other lawful basis for which we may continue to process such Personal Data, we will do so You request the transfer of your Personal Data You may object to our processing as set out above You may request the restriction of processing of your Personal Data. This enables you to ask us to suspend the processing of Personal Data about you, for example if you want us to establish its accuracy or the reason for processing it Where we may undertake automated decision-making we will request your explicit consent if the decision-making is not authorised by law or necessity for the performance of a contract Third Party Recipients of Personal Data From time to time, we may share your Personal Data with Espire Entities as part of our regular reporting activities on company performance, in the context of a business reorganisation or group restructuring exercise, for system maintenance support or hosting of data. We will also share your Personal Data with third parties: where required by law; where it is necessary to administer the working relationship with you; or where we have another legitimate interest in doing so We may share your Personal Data with other third parties in relation to Marketing and Sales Activities and we may also need to share your Personal Data with a regulator or to otherwise comply with applicable law. The third-party recipients or categories of recipients of the Personal Data may include: legal representatives; accountants; auditors; regulators and professional bodies; government or statutory bodies; non-government bodies; marketing or PR agencies; organisers of marketing events; cloud service providers; specialist marketing and CRM services providers, solely in order or provide elements of the Marketing and Sales Activities; data analysis service providers who help us to assess the best services and pricing structure to offer you; industry regulators; and consultants or contractors working on our behalf This list may include an organisation or third-party recipient(s) outside of the UK. This list is non-exhaustive. All our third-party service providers are required to comply with appropriate contractual terms we have in place with them in respect of Data Protection Laws, which are in line with the terms of our Privacy Policy. We do not allow our third-party service providers to use your Personal Data for their own purposes. We only permit them to process your Personal Data for specified purposes and in accordance with our instructions. Transferring Personal Data outside the EU We may transfer the Personal Data we collect about you to the following countries outside the EU in order to fulfil our responsibilities to you: India Australia US Singapore We will only transfer your Personal Data to these countries under the terms of an International Group Data Transfer Agreement which apply the standard of the EU’s Standard Contractual Clauses and we will only transfer it to Espire Entities in India. Any questions about the transmission of Personal Data or requests to receive a copy of the Personal Data being transferred should be addressed in writing to the Data Protection Officer at GDPR@espire.com CONTACT US If you have any questions in relation to this Privacy Policy, or if you would like to contact us to exercise your rights as stated in this Privacy Policy, you may contact us at: GDPR@espire.com for assistance. Changes To This Notice Any changes to this Privacy Notice will be posted on this website so you are always aware of what Personal Data we collect, how we use it, and under what circumstances, if any, we disclose it. If at any time we decide to use Personal Data in a manner significantly different from that stated in this Privacy Notice, or otherwise disclosed to you at the time it was collected, we will notify you by email, and you will have a choice as to whether we use your Personal Data in the new manner. 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