INTRODUCTION

Rivenmoor Limited (Rivenmoor), is a registered company in England and Wales under registration number 13737761 with registered address at 4-7 Great Pulteney Street, London, United Kingdom, W1F 9NA. This Privacy and Cookies Policy (Policy) sets out how Rivenmoor collects and processes your personal data when you use our website. Pursuant to the Data Protection Act 2018 (DPA), we have a legal duty to respect and protect any personal data we collect from you.

We take all safeguards necessary to prevent unauthorised access and except as stated under this Policy, we do not pass on your details collected from you to any third party unless you give us your consent to do so or as authorised by law. We are introducing this Policy to make it easier for you to find out how we collect, use, protect, and disclose your personal data and which rights and options you have in relation to the personal data we hold.

This website is not intended for children, and we do not knowingly collect data relating to children.

Should you have any concerns with the way we have dealt with your personal data, you have the right to make a complaint at any time to the Information Commissioner's Office (ICO) (www.ico.org.uk). We would, however, appreciate the chance to deal with your concerns before you approach the ICO so please contact us in the first instance.

WHAT PERSONAL DATA MIGHT WE COLLECT?

Personal data means any information about an individual from which that person can be identified.

We may collect, use and store different kinds of personal data about you including:

• Identity and Contact Data such as your photo, name, date of birth, gender, occupation, country of residence, residence status, nationality, address, telephone number, email address and any other personal data you may provide us when you contact us.
• Employment Data relating to your employment history, education, family or personal circumstances and interests, and any other personal data you may provide when you send us your CV.
• Financial Data such as your bank account, payment card details, details about payments to and from you and details of products or services you have purchased from us.
• Marketing and Communications Data such as your preferences in receiving marketing from us and your communication preferences.
• Technical and Usage Data such as how you interact with and use our website, your IP address, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform, website usage data and other technology on the devices you use to access this website. We may also collect, use and share aggregated data such as statistical or demographic data which is not personal data as it does not directly (or indirectly) reveal your identity. For example, we may aggregate individuals' usage data to calculate the percentage of users accessing a specific website feature in order to analyse general trends in how users are interacting with our website to help improve the website and our product and service offering. You can find more information on this under the section entitled Cookies.

HOW WE COLLECT PERSONAL DATA

We use different methods to collect data from and about you including through direct interactions where you may provide us with your name and email address or by corresponding with us by post, phone or otherwise.

As you interact with our website, we will automatically collect Technical and Usage Data about your equipment, browsing actions and patterns. We collect this personal data by using cookies, server logs and other similar technologies. Technical Data is collected by analytics providers such as Google who have operations based outside of the UK. Please see the 'Cookies' section for more information.

HOW WE USE YOUR PERSONAL DATA

We will only use your personal data as allowed by law i.e. carrying out an instruction or agreement, fulfilling a legal obligation because we or a third-party recipient have a legitimate interest or as agreed by you. A legitimate business interest to use your personal data may include:

• To comply with our legal obligations, including reporting and,or being audited by regulatory bodies.
• To analyse and improve our services and communication with you.
• To recognise and count the number of visitors and to see how visitors move around our website when they are using it to improve the way our website works.
• For marketing to you, but we do not share personal data with third parties for marketing purposes.
• For the management and administration of our business.
• For insurance purposes.
• Seeking advice on our rights and obligations.
• Protecting the security of our Information Technology and communication systems, website and other systems, preventing and detecting security threats, fraud and other criminal or malicious activities.
• To comply with court orders and or defend our legal rights.
• To detect, prevent or reduce the incidence of crime and create a safer environment.
• To assist with health and safety of employees, service providers and visitors and to assist with serious occurrences, for example, disciplinary investigations.
• Where you have provided us with a CV, for vetting or verification purposes prior to or during the course of an employment assessment.

WHO CAN WE SHARE YOUR PERSONAL DATA WITH

We may share your personal data with:

• Your agents, intermediaries and advisors with your permission.
• Our group companies. A group company is any direct or indirect subsidiary or any direct or indirect holding company or any such subsidiary of any such holding company or any such holding company of such subsidiary, "subsidiary" and "holding company" having the meanings defined in section 1159 of the Companies Act 2006.
• Third parties we engage to provide services to you such as agents, advisors, banks, brokers, insurers, or any third party to whom we assign or novate any of our rights or obligations.
• Professional advisors such as lawyers, auditors, accountants, IT software and hardware providers.
• Our data processors.
• Courts, regulators, and law enforcement agencies, where required.
• Where you have provided us with a C.V., background checking agencies for the purposes of verifying the information contained within your C.V.

HOW LONG WE KEEP YOUR PERSONAL DATA

We will keep your personal data for as long as you have a relationship with us. After that relationship ends, we will keep your data as long as we may have a legitimate purpose or you withdraw your consent (where applicable) and we are not legally required or otherwise permitted to continue storing your data. In particular, we will retain your personal data:

• Where we have collected your personal information as required for anti-money laundering legislation.
• To help us respond to queries or complaints.
• To help us respond to requests from authorities.
• For other reasons such as fighting fraud and financial crime.

DATA SECURITY

We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal data on our instructions and they are subject to a duty of confidentiality.

Please be aware that where data is transmitted via the internet, such transmission is not completely secure. Although we take appropriate and proportionate steps to manage the risk posed we cannot guarantee the security of your data transmitted to our online services.

TRANSFERRING YOUR DATA OVERSEAS

Your personal data may be transferred and stored as set out in this Policy to countries outside European Economic Area or to countries not approved as providing an adequate level of protection for personal data. This may include countries which do not provide the same level of protection for personal data. When this happens, we will ensure any such transfers are made subject to appropriate or suitable safeguards. Such transfers will occur where you have given explicit consent, or where the recipient has entered into standard contractual clauses.

LINKS TO THIRD-PARTY WEBSITES

Our website may provide links to third party sites, including social networking sites. If you click on a third-party link, you will be directed to that third party's site. We strongly advise you to review the privacy policy of every site you visit. We have no control over and assume no responsibility for the content, privacy policy of any third-party sites or services.

YOUR LEGAL RIGHTS

You have rights in relation to your personal data including the right to:

• Request a copy of the personal data we hold about you.
• Request us to share your personal date with another party.
• Request us to update incorrect or incomplete details.
• Request us to erase your personal data.
• Object to or restrict our processing activities of your data.
• Make a complaint.
• Withdraw your consent to our processing of your personal data.

COOKIES

What are Cookies?

Our website uses cookies which are small text files that are placed on your device when you visit a website. Our use of cookies aims to provide you with an optimum user experience when you browse our website and allows us to monitor the performance of the website on an ongoing basis.

What type of cookies do we use?

We may use third-party cookies by Google Analytics in order to monitor and analyse the use of our website. Google Analytics is a web analytics service offered by Google that tracks and reports website traffic. Google uses the data collected to track and monitor the use of our website. You can learn more about data collected by Google and what this data is used for in Google's Privacy Policy. Additional information on Google services and products is available in Google's Terms of Service.

What data is collected by the cookies?

If you consent to the use of cookies, we may collect from you the following data: your browser type, language, operating system, device ID, geolocation data, the state or country from which you accessed the website's services, the webpages you visited, and the date and the time of a visit. Please note that this data is aggregated and therefore the data is anonymous and will not be traced back to you.

How to manage cookies?

You can opt-out of having your activity made available to Google Analytics across all websites by installing the Google Analytics opt-out browser add on, which you can access here Google Analytics Opt-out Browser Add-on Download Page. You may also opt-out of tracking by Google Analytics on our website by pressing the 'Reject' button on our cookies banner. For more information on the privacy practices of Google, please visit the Google Privacy Terms web page: https://policies.google.com/privacy.

UPDATES TO THIS POLICY

We reserve the right to update and change this Policy from time to time in order to reflect regulatory changes or changes to the way we process your personal data. In case of such changes, we post the amended Policy on our website. The changes will come into effect upon publication.

Last updated 01 October 2024.