Privacy Policy

Welcome to the Contracting Wise Limited privacy notice. Contracting Wise Limited respects your privacy and is committed to protecting your personal data. This privacy notice will inform you as to how we look after your personal data when you visit our website (regardless of where you visit it from) and tell you about your privacy rights and how the law protects you.

Purpose of this privacy notice This privacy notice aims to give you information on how Contracting Wise Limited collects and processes your personal data through your use of this website, including any data you may provide through this website when you [sign up to our newsletter, use our services or take part in a competition]. This website is not intended for children and we do not knowingly collect data relating to children. It is important that you read this privacy notice together with any other privacy notice or fair processing notice we may provide on specific occasions when we are collecting or processing personal data about you so that you are fully aware of how and why we are using your data. This privacy notice supplements the other notices and is not intended to override them. Controller Contracting Wise Limited is the controller and responsible for your personal data (referred to as “Contracting Wise Limited “, “we”, “us” or “our” in this privacy notice). We have appointed a data protection officer (DPO) who is responsible for overseeing questions in relation to this privacy notice. If you have any questions about this privacy notice, including any requests to exercise your legal rights, please contact the DPO using the details set out below. Contact details Full name of legal entity: Contracting Wise Limited Email address of DPO: dpo@contractingwise.co.uk You have the right to make a complaint at any time to the Isle of Man Information Commissioner’s Office https://www.inforights.im/contact-us (ICO), the IOM supervisory authority for data protection issues. We would, however, appreciate the chance to deal with your concerns before you approach the ICO so please contact us in the first instance. Changes to the privacy notice and your duty to inform us of changes This version was last updated on 2nd May 2018 The data protection law in the IOM will change on 25 May 2018. Although this privacy notice sets out most of your rights under the new laws, we may not yet be able to respond to some of your requests (for example, a request for the transfer of your personal data) until May 2018 as we are still working towards getting our systems ready for some of these changes. It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during your relationship with us.

Personal data, or personal information, means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymous data). We may collect, use, store and transfer different kinds of personal data about you which we have grouped together follows: • Identity Data includes first name, maiden name, last name, username or similar identifier, marital status, title, date of birth and gender. • Contact Data includes address, email address and telephone numbers. • Technical Data includes internet protocol (IP) address, your login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform and other technology on the devices you use to access this website. • Profile Data includes your feedback and survey responses. • Usage Data includes information about how you use our website, products and services. • Marketing and Communications Data includes your preferences in receiving marketing from us and our third parties and your communication preferences. We also collect, use and share Aggregated Data such as statistical or demographic data for any purpose. Aggregated Data may be derived from your personal data but is not considered personal data in law as this data does not directly or indirectly reveal your identity. For example, we may aggregate your Usage Data to calculate the percentage of users accessing a specific website feature. However, if we combine or connect Aggregated Data with your personal data so that it can directly or indirectly identify you, we treat the combined data as personal data which will be used in accordance with this privacy notice. We do not collect any Special Categories of Personal Data about you (this includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health and genetic and biometric data). If you fail to provide personal data Where we need to collect personal data by law, or under the terms of a contract we have with you and you fail to provide that data when requested, we may not be able to perform the contract we have or are trying to enter into with you. In this case, we may have to cancel the service you have with us but we will notify you if this is the case at the time.

We use different methods to collect data from and about you including through: • Direct interactions. You may give us your [Identity, Contact and Financial Data] by filling in forms or by corresponding with us by post, phone, email or otherwise. This includes personal data you provide when you: • apply for services; • subscribe to our service or publications; • request marketing to be sent to you; • enter a competition, promotion or survey; or • give us some feedback. • Automated technologies or interactions. As you interact with our website, we may automatically collect Technical Data about your equipment, browsing actions and patterns. We collect this personal data by using cookies, [server logs] and other similar technologies. We may also receive Technical Data about you if you visit other websites employing our cookies.] Please see our cookie policy for further details. • Third parties or publicly available sources. We may receive personal data about you from various third parties [and public sources] as set out below: • Technical Data from the following parties: ○ analytics providers [such as Google based outside the EU]; and ○ search information providers based inside or outside the EU].

We will only use your personal data when the law allows us to. Most commonly, we will use your personal data in the following circumstances: • Where we need to in order to assist you with your pre-contractual interests. • Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests. • Where we need to comply with a legal or regulatory obligation. Generally we do not rely on consent as a legal basis for processing your personal data other than in relation to sending third party direct marketing communications to you via email or text message. You have the right to withdraw consent to marketing at any time by contacting us. Purposes for which we will use your personal data We have set out below, in a table format, a description of all the ways we plan to use your personal data, and which of the legal bases we rely on to do so. We have also identified what our legitimate interests are where appropriate. Note that we may process your personal data for more than one lawful ground depending on the specific purpose for which we are using your data. Please contact us if you need details about the specific legal ground we are relying on to process your personal data where more than one ground has been set out in the table below. Marketing We strive to provide you with choices regarding certain personal data uses, particularly around marketing and advertising. Promotional offers from us We may use your Identity, Contact, Technical, Usage and Profile Data to form a view on what we think you may want or need, or what may be of interest to you. This is how we decide which products, services and offers may be relevant for you (we call this marketing). You will receive marketing communications from us if you have requested information from us or purchased [goods or services] from us [or if you provided us with your details when you entered a competition or registered for a promotion] and, in each case, you have not opted out of receiving that marketing. Third-party marketing We will get your express opt-in consent before we share your personal data with any company for marketing purposes. Opting out You can ask us or third parties to stop sending you marketing messages by following the opt-out links on any marketing message sent to you or by contacting us at any time. Where you opt out of receiving these marketing messages, this will not apply to personal data provided to us as a result of a service provision. Cookies You can set your browser to refuse all or some browser cookies, or to alert you when websites set or access cookies. If you disable or refuse cookies, please note that some parts of this website may become inaccessible or not function properly. For more information about the cookies we use, please see https://www.contractingwise.co.uk/cookie-policy/ Change of purpose We will only use your personal data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If you wish to get an explanation as to how the processing for the new purpose is compatible with the original purpose, please contact us. If we need to use your personal data for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so. Please note that we may process your personal data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.

We may have to share your personal data with the parties set out below for the purposes set out in the table in paragraph 4 above. • External Third Parties as set out in the Glossary. • Third parties to whom we may choose to sell, transfer, or merge parts of our business or our assets. Alternatively, we may seek to acquire other businesses or merge with them. If a change happens to our business, then the new owners may use your personal data in the same way as set out in this privacy notice. We require all third parties to respect the security of your personal data and to treat it in accordance with the law. We do not allow our third-party service providers to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our instructions.

We may transfer your data outside the European Economic Area (EEA). Whenever we transfer your personal data out of the EEA, we ensure a similar degree of protection is afforded to it by ensuring at least one of the following safeguards is implemented: • We will only transfer your personal data to countries that have been deemed to provide an adequate level of protection for personal data by the European Commission. For further details, see European Commission: Adequacy of the protection of personal data in non-EU countries. • Where we use certain service providers, we may use specific contracts approved by the European Commission which give personal data the same protection it has in Europe. For further details, see European Commission: Model contracts for the transfer of personal data to third countries. Please contact us if you want further information on the specific mechanism used by us when transferring your personal data out of the EEA.

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. We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.

How long will you use my personal data for? We will only retain your personal data for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements. To determine the appropriate retention period for personal data, we consider the amount, nature, and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal requirements. In some circumstances we may anonymise your personal data (so that it can no longer be associated with you) for research or statistical purposes in which case we may use this information indefinitely without further notice to you.

Under certain circumstances, you have rights under data protection laws in relation to your personal data. If you wish to exercise any of the rights set out at the end of this Policy, please contact the DPO at dpo@contractingwise.co.uk No fee usually required You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we may refuse to comply with your request in these circumstances. What we may need from you We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response. Time limit to respond We try to respond to all legitimate requests within one month. Occasionally it may take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.

LAWFUL BASIS Legitimate Interest means the interest of our business in conducting and managing our business to enable us to give you the best service/product and the best and most secure experience. We make sure we consider and balance any potential impact on you (both positive and negative) and your rights before we process your personal data for our legitimate interests. We do not use your personal data for activities where our interests are overridden by the impact on you (unless we have your consent or are otherwise required or permitted to by law). You can obtain further information about how we assess our legitimate interests against any potential impact on you in respect of specific activities by contacting us Performance of Contract means processing your data where it is necessary for the performance of a contract to which you are a party or to take steps at your request before entering into such a contract. Comply with a legal or regulatory obligation means processing your personal data where it is necessary for compliance with a legal or regulatory obligation that we are subject to. THIRD PARTIES External Third Parties • Service providers acting as processor who provide IT and system administration services. • Professional advisers acting as processors who may provide consultancy, banking, legal, insurance and accounting services. • Regulators and other authorities acting as processors who require reporting of processing activities in certain circumstances. YOUR LEGAL RIGHTS You have the right to: Request access to your personal data (commonly known as a “data subject access request”). This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it. Request correction of the personal data that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us. Request erasure of your personal data. This enables you to ask us to delete or remove personal data where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal data where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your personal data to comply with local law. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request. Object to processing of your personal data where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms. You also have the right to object where we are processing your personal data for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms. Request restriction of processing of your personal data. This enables you to ask us to suspend the processing of your personal data in the following scenarios: (a) if you want us to establish the data’s accuracy; (b) where our use of the data is unlawful but you do not want us to erase it; (c) where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims; or (d) you have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it. Request the transfer of your personal data to you or to a third party. We will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you. Withdraw consent at any time where we are relying on consent to process your personal data. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain products or services to you. We will advise you if this is the case at the time you withdraw your consent.

We may work with third parties to research certain usage and activities on our website on our behalf. No personal information about you is shared, however in the course of conducting this research these third parties may place a unique “cookie” on your browser. A cookie is a small file which is sent to your browser and stored on your computer’s hard disc and helps us understand and track your use of the site and where it can improve the information and services provided. We use cookies solely to gather information on IP addresses, to analyse trends, administer the site, track user’s movements on the site and gather broad demographic information for aggregate use. IP addresses are not linked to other personally identifiable information and will not be used to deliver targeted marketing messages. For information about blocking the use of cookies, please refer to the instructions/help screen on your Internet browser. Please note that you may not be able to use or access certain parts of the site or online services if you block the use of cookies.

As a result of improvements we make to our services, amendments to laws or regulation or developments in the technology or processes we use, we may change the information we hold about you and/or the way in which or the purposes for which we process such information. Where we require your consent to such change we will notify you of the change. However, unless you inform us otherwise, we will deem your continued use of products and services to which the change relates to constitute your consent to the relevant change.

In no event shall ContractingWISE be liable (whether to you or to any third party) for any cost or damages, including any direct, indirect, special, incidental, or consequential damages, arising out of or in connection with (a) your access or use of, or your inability to access or use, this site or (b) any transaction effected by you or us and arising out of your access (or arising out of access which has been purportedly made by you) to this site. You accept full responsibility for the validity, accuracy and transmission of information you send to us. Without limitation, we do not accept any responsibility for the loss, delay or corruption of any information that you send to us. You should not interpret any information on this site as providing any advice or recommendation that any particular transaction should or should not be effected or service obtained. Any services that are indicated as being available on the site may be withdrawn or modified at any time. We, ContractingWISE Limited reserve the right to alter the content, presentation, performance, user facilities and availability of all or any part of the site at its sole discretion, at any time, and without giving any notice. You must use your own judgement in making any decision based on information supplied on this site. It is your responsibility to evaluate the accuracy, completeness, reliability and usefulness of any opinions, services or other information provided on the site.

We make every effort to check and test material at all stages of production. It is always wise for you to run an anti-virus program on all material downloaded from the Internet. We cannot accept any responsibility for any loss, disruption or damage to your data or your computer system which may occur whilst using material derived from this website.

We are not responsible for the contents or reliability of the linked websites and does not necessarily endorse the views expressed within them. Listing should not be taken as endorsement of any kind. We cannot guarantee that these links will work all of the time and we have no control over the availability of the linked pages.

This statement is made on behalf of Contracting Wise Limited, in respect to the Modern Slavery Act 2015. This act requires us as a Company to be clear both in our business and our wider supply chain about our efforts to eliminate any slavery and human trafficking. As a responsible organisation we have the responsibility to be aware of the risk, and to tackle slavery and human trafficking, reporting any concerns to management. Our organisation have zero tolerance to slavery and human trafficking.

Contracting Wise Limited operates compliantly with UK employment legislation as an employer to contractors who work under a contract assignment, usually through a recruitment agency in the United Kingdom. We expect all those in our supply chain and contractors to comply with our values, in this regard. As part of our due diligence, we liaise with our clients and employees, to ensure that all parties are compliant with up to date employment law legislation and employment rights, this also includes a distribution of an employment rights questionnaire.

To ensure a high level of understanding regarding the risks of modern slavery and human trafficking we provide training to our staff, and have a number of internal policies. These include, but are not limited to; Right To Work training Anti-Money Laundering training Whistleblowing Policy Code of Business Conduct Identity Checks Our staff are encouraged to identify any suspicious behaviour in breach of the Modern Slavery Act 2015. This statement is made pursuant to Section 54(1) of the Modern Slavery Act 215, and constitutes our group’s slavery and human trafficking statement for the current financial year.

This statement was approved by the Board of Directors on 1 February 2019