In this Policy ‘GamaLife’, ‘We’, ‘Us’, or ‘Our’ means Gomes Serviceco Ltd. (trading as ‘GamaLife’) incorporated in England and Wales as a private company limited by guarantee, company number 12003288. Our registered office is at C/O Apax Partners, 33 Jermyn Street, London, United Kingdom, SW1Y 6DN. GamaLife also includes any Affiliated business entity which is under common ownership or control with GamaLife (‘Affiliate’).
2. Lawful Compliance
The law applicable to Our processing Personal Data is the UK Data Protection Act 2018 (‘DPA 18’). Under the DPA 18, We process Personal Data lawfully, fairly, and in a transparent manner. Your Personal Data is processed for the specific and legitimate purposes found in this Policy.
3. All Site Visitors
Legal Basis for Processing Personal Data
We may process Personal Data for our legitimate business interest that include marketing our goods and services, managing and running Our Site and sourcing and acquiring talent for Our workforce. Our processing of Personal Data collected from the Site is based primarily on this justification. However, some processing of Personal Data is also necessary to comply with certain applicable legal or regulatory requirements. We also process Personal Data for these purposes.
In addition, We can provide a wide range of additional services and information for our clients and our professional and business contacts, such as news updates and events. We will process Personal Data collected from the Site in order to inform you of these and the various services that we provide, on the basis that it is necessary for our legitimate interests in promoting and marketing our services. If you do not wish us to process your Personal Data in this way, you will be given an opportunity to object to such processing via any future marketing communications we send to you. You may also object to such processing of Personal Data as specified in this Policy.
Information We Collect From or About You
We will collect Personal Data from or about you in connection with your use of the Site such as the following data:
- Information that you provide by filling in forms on Our Site. This includes information provided when subscribing to Our services (for example to receive information from us), posting material (for example applying for a position) or requesting further information. We may also ask you for information when you enter a competition or promotion online and when you report a problem with Our site;
- Correspondence Records. If you contact us, We may keep a record of that correspondence and may ask you to supply essential contact details (your name, e-mail address, phone number and, where applicable, the company or other person you represent and your job title), which we need in order to identify you and deal with your enquiry;
- Research surveys. We may also ask you to complete surveys that We use for research purposes, although you do not have to respond to them;
- Technical details of your visits to Our Site including, traffic data, location data, weblogs and other communication data, and the resources that you access. This may or may not include Personal Data; and
- Further details, depending on the nature of the enquiry or services we are providing or to keep in touch with you as we believe is, or may become, relevant to Us or you.
Automatic Data Collection: IP Addresses and Cookies
The system may also use web beacons which are similar but not identical to cookies in the way they operate. As with cookies, more information may be obtained about web beacons through your Internet browser.
If you are only browsing Our website, We will not ask you to directly submit in any Personal Data. However, certain information (which may be considered Personal Data) – including computer and connection information, browser type and version, operating system and platform details and the time of accessing the website – will be used to help Us to improve Our Site and to deliver a better and more personalized service. This information is generally processed to:
- To estimate Our audience size and usage pattern;
- To store information about your preferences, and so allow Us to customize Our Site according to your individual interests;
- To speed up your searches; and
- To recognize you when you return to Our Site.
We occasionally carry out market research and business development. A third party might help Us to do this and they may send a cookie or web beacon.
Third Party Data Collection
We may obtain Your Personal Data from third parties, such as data from another website which is linked to ours. Any Personal Data received from such third parties as a result of your navigation to this Site will be processed in accordance with this Policy.
Personal Data Usage
We use Personal Data held about you in the following ways:
- To ensure that content from Our Site is presented in the most effective manner for you and for your computer;
- To provide you with the information, products and services that you request from Us or which We feel may interest you;
- To allow you to participate in interactive features of Our sites;
- To notify you about changes to what We do;
- To protect the integrity of Our website, Our services, and Our reputation;
- To prosecute or defend legal claims; and
- To protect other users of Our websites, and to ensure no unlawful or unethical activity occurs through Our systems.
We may also use your Personal Data or permit selected third parties to use your Personal Data, to provide you with information about goods and services which may be of interest to you, and We or they may contact you about these by email, post, or telephone.
Disclosure of Personal Data
We will not process your Personal Data for any purpose unrelated to the purposes specified in this Policy unless we are required to do so by law, or as mentioned in this section.
Other professionals and other bodies
In order to provide some of our services, we may use the input of third parties such as lawyers, accountants and financial advisers, or we may refer you to such third parties, with your consent or where this is necessary for the performance of a contract with you (or the company or other person you represent). This will require the disclosure to such third parties of your contact details, as well as further Personal Data about you which is relevant to the services they provide. We may also be required to disclose your Personal Data to regulators, or where required to do so by order of the court, or to Government departments and local authorities and similar bodies in order to comply with legal obligations or to perform a contract with you (or the company or other person you represent).
Data processing and other services
Some of our data processing or other services are supplied by third party providers, who will need to have access to your data for that purpose. Such third-party suppliers will be appointed on the basis that they provide sufficient guarantees to implement appropriate technical and organisational measures so that the processing will meet the requirements of the applicable DPA 18, ensure the protection of the rights of the data subjects and will carry out processing only on our written instructions, or where we have a legitimate interest in doing so, as indicated above.
We may disclose your Personal Data if we are required to do so in order to comply with any legal or regulatory obligation or request, or where we have a legitimate interest in doing so, such as in order to enforce or apply a contract with you, to investigate potential breaches, or to protect our property and rights or those of others. This may include exchanging Personal Data with other companies and agencies for the purposes of credit risk reduction and to comply with legislation concerning money laundering, tax evasion, crime prevention and fraud protection.
Professional or business contacts
If you are not a client (or a representative of a client), but have provided us with your professional or business contact details or other relevant Personal Data, we may share your Personal Data with our other professional or business contacts or those of our other Affiliated companies, on the basis that it is necessary for our legitimate interests in promoting and marketing our services, unless you indicate otherwise.
If you contact us with an enquiry about our services but you do not subsequently become an employee or a client (or the company or other person you represent does not do so), it is our Policy to delete Personal Data in accordance with our records retention policy. Generally, this is after twelve months but may be longer if our legitimate interest in processing the data is still present. If you are or become an employee or a client (or the company or other person you represent is or becomes a client), we will process your Personal Data subject to the privacy disclosures you receive upon initiating your commercial relationship with Us. This Policy does not apply to any commercial relationship We may develop with you.
We may agree with you to retain Personal Data for a longer period. In certain cases it may be necessary for us to retain such Personal Data for a period after our commercial relationship with you has ended. For example, we retain data where it is necessary for us to comply with regulatory obligations or for the establishment, exercise or defence of legal claims.
Personal Data relating to our professional contacts will be retained for so long as is necessary, or until you indicate otherwise to us, but we will aim to update our contacts’ preferences on a periodic basis.
Personal Data Storage
We are a global business. As a result, the data that We collect from you may be transferred to, and stored at, any of Our locations; which may be inside or outside the European Union (“EU”). Our primary servers are in the United Kingdom. Data may also be processed by staff around the world working for Us, or for one of Our suppliers. These staff maybe engaged in, among other things, the fulfillment of your information requests, or the provision of support services. If you submit your Personal Data, We will request that you agree to this transfer, storing, or processing. If We do not request your consent to such processing outside the EU, We will implement suitable safeguards as developed and approved by the European Commission. We will store Personal Data we collect about you as long as it is necessary to fulfill the purposes for which we collected it or where there is a legal obligation – laws or regulation that may set a minimum period for which we have to keep your Personal Data.
Some parts of this Site may link across to the websites of third parties who work with Us. For example, if you use Our website to order goods or apply for a job, it is likely your Personal Data will be collected and processed by third parties. You should always check their privacy statement as well since it will govern how your Personal Data is processed by them.
We take reasonable administrative, procedural, and technical steps to safeguard your Personal Data. Where We have given you (or where you have chosen) a password which enables you to access certain parts of Our site, you are responsible for keeping this password confidential. We ask you not to share a password with anyone. Unfortunately, the transmission of information via the internet cannot be completely secure. Although We will do Our best to protect your Personal Data, We cannot guarantee the security of your Personal Data transmitted to Our site; any transmission is at your own risk. Once We have received your information, We will use Our own procedures and security measures to mitigate the risks of unauthorized access.
Your rights as a data subject
As a data subject, you have certain legal rights (subject to certain exceptions under the DPA 18) including the right:
- to access the Personal Data held about you and request a copy of it;
- to ask us not to process your Personal Data for marketing purposes;
- to withdraw at any time any consent you have given to receive marketing material from us, or in any other case where we process your Personal Data on the basis of a consent that you have given (and not on some other legal basis);
- to ask us to rectify inaccurate Personal Data about you;
- to ask for the restriction of Personal Data about you that is inaccurate, unlawfully processed, or no longer required;
- to ask for the transfer of your Personal Data in a structured, commonly used and machine-readable format where appropriate;
- to ask for the erasure of Personal Data about you where processing is no longer necessary, or the legitimate interests we have in processing your Personal Data are overridden by your interests, rights and freedoms as the data subject; and
- to make a complaint to the Information Commissioner’s Office, which can be contacted by post via: Information Commissioner’s Office, Wycliffe House, Water Lane, Wilmslow, Cheshire, SK9 5AF or by telephone via 0303 123 1113 (local rate) or 01625 545 745 if you prefer to use a national rate number.
4. Candidates for employment
Outside the general Personal Data collected as described elsewhere in this Policy, in order for you to apply for employment or to receive information from GamaLife or its Affiliates about job openings, you may be asked to provide Personal Data. The Personal Data that you may be requested to provide may include:
- Contact information, including home address, home telephone, mobile telephone and email address;
- Date of birth;
- Tax Identification or other government identification number;
- Work history;
- Education history and results;
- Eligibility or right to work;
- Interest in employment opportunities;
- Job specific questions that relate to your fitness for a particular position;
- Employment history;
- Information regarding potential conflict of interest issues;
- Information you provide to create security questions and answers used to validate your identity when you return to the Site.
As a result of certain governmental mandates, GamaLife or its Affiliates may ask individuals to self-identify certain Personal Data such as their ethnicity, gender, veteran status, and disability information. That information is voluntary and your decision to provide or withhold any of that information will not negatively impact whether or how the GamaLife or its Affiliates will consider you for employment.
GamaLife or its Affiliates will treat any Personal Data considered sensitive under the DPA 18 in accordance with that law. The collection and use of sensitive Personal Data will be limited to that which is strictly necessary for the purposes for which it was collected. Your explicit consent will be obtained to the processing of your sensitive Personal Data, unless otherwise permitted by applicable law.
Use of Personal Data
As part of or seeking consideration for employment with GamaLife or its Affiliates, any Personal Data collected will be used to:
- enable you to express interest in and/or allow you to apply for employment with GamaLife or its Affiliates;
- consider your candidacy for employment with GamaLife or its Affiliates;
- comply with any applicable legal and regulatory requirements involving job applicants, which may include providing reports to government agencies;
- verify your identity to ensure security for one of the other purposes listed in this policy;
- populate your employee records in the event you are hired by GamaLife or its Affiliates;
- ensure or enhance the security and functionality of GamaLife or its Aaffiliates’ electronic systems;
- protect against fraud; and
- conduct internal investigations and comply with legal obligations.
Note that all other representations in this Policy also apply to Our handling of any Personal Data collected as part of your consideration for employment with GamaLife or its Affiliates.
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