> App privacy notice

App privacy notice

Updated 4 July 2019

1. PURPOSE OF THIS APP PRIVACY NOTICE

1.1 This application privacy notice (‘App Privacy Notice’) is issued by Withers LLP (with ‘we’, ‘us’ or ‘our’ being construed accordingly). It provides you with information on how we collect and process your personal data through your use of the application (the ‘App’), regardless of where you visit it from.

1.2 We reserve the right to revise this App Privacy Notice at any time so please check that you have seen the latest version by visiting this page regularly.

1.3 It is important that you read this App 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 information about you so that you are fully aware of how and why we are using your data. This App Privacy Notice supplements those other notices and is not intended to override them. You should also check the App Terms of Use and any additional terms and conditions as notified to you from time to time that may regulate your use of the App.

2. CONTROLLER

Under the EU General Data Protection Regulation and UK Data Protection Act 2018, Withers LLP is acting as ‘controller’ and has primary legal responsibility for any personal data you submit through the App.

3. THIRD-PARTY LINKS

The App may include links to third-party websites, plug-ins and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites and are not responsible for their privacy statements. When you leave the App, we encourage you to read the privacy notice of every website and application you visit.

4. THE DATA WE COLLECT ABOUT YOU

4.1 We may collect personal data from you if you use the App. For example, when you supply your contact details to register an account, biographical details, including details of your education and employment history and other similar information relevant to the recruitment decision-making process, or request other information from us.

4.2 Provision of your personal data is voluntary but failure to provide certain personal information requested may render you unable to use or access certain services or parts of the App.

4.3 The type of personal data we require will be set out on the relevant page of the App at the time you register with us and may include your name, email address, postal address and other personal details about you. This personal data relating to you is referred to in this App Privacy Notice as ‘Your Information’.

4.4 We may also collect information about your use of our App (for example, how long you use the App). For more information on how we do this, please see our Cookie Policy in section 14 below.

5. HOW WE USE YOUR INFORMATION

5.1 We will only use Your Information when the law allows us to and in the following circumstances:

  • providing you with access to the App and personalising your use of the App;
  • dealing with your enquiries, instructions or issues you raise with us;
  • providing you with information by email, phone or the App which you have requested;
  • seeking your participation in surveys or research by email, phone or the App;
  • modifying and improving our App; and
  • otherwise facilitating the lateral hire process.

5.2 We have a legitimate business interest in processing Your Information for the reasons set out in 5.1.

5.3 We may also contact you for other purposes that you consent to from time to time.

5.4 You have a right at any time to stop us from contacting you for direct marketing purposes.

5.5 If you wish to unsubscribe from receiving marketing communications from us please email us at unsubscribe@withersworldwide.com.

6. WHO WE SHARE YOUR PERSONAL INFORMATION WITH

Your Information may be shared with other entities in the Withers Group (which includes Withers LLP, Withers Bergman LLP, Withers KhattarWong LLP, Withers Australia, Withers BVI, Withers 衛達仕, Studio Legale Associato con Withers LLP, Withers Bengoshi Houjin, Withers Gaikokuho Jimoshu Bengoshi Houjin and Withers Japan Zeirishi Houjin authorised to practice under the name ‘Withers’ or ‘Withersworldwide’) and the App hosting provider for the purposes described in this App Privacy Notice.

6.1 Personal data we hold including Your Information will usually only be shared with third parties, such as our service providers, if the following apply:

  • they require the personal data for the purposes of providing specific contracted services;
  • you have been made aware of such sharing of Your Information and, if needed, your consent has been obtained, or an alternative lawful basis for such processing has been satisfied;
  • where acting as a ‘controller’, the third party has agreed to comply with appropriate data security standards, policies or procedures; or where acting as data ‘processor’ under our instructions, that third party is subject to a written contract that contains relevant security requirements and other obligations to protect Your Information in accordance with applicable law; and
  • where required, the transfer complies with any applicable cross-border transfer restrictions.

6.2 However, we may occasionally need to disclose Your Information to third parties where we are legally required to do so and cannot tell you, for example, in order to comply with a court order or regulatory obligation.

7. INTERNATIONAL TRANSFERS

Please note that because of the international scope of our business, to enable us to provide legal services, it may be necessary to transfer Your Information provided or collected from within the European Union (‘EU’) to a jurisdiction outside of the EU. The level of protection for personal information available in jurisdictions outside of the EU may be lower than the standards applied within the EU or the jurisdiction where you live. Whenever we transfer Your Information outside of the EU, to a territory that does not meet EU approved standards, unless a legal exemption applies, we will ensure appropriate measures are in place to protect Your Information in accordance with applicable EU data protection law.

8. PROTECTING YOUR INFORMATION

8.1 We employ appropriate technical and organisational security measures to protect Your Information from being accessed by unauthorised persons and against unlawful processing, accidental loss, destruction and damage.

8.2 We also endeavour to take all reasonable steps to protect Your Information from external threats. However, please be aware that there are inherent security risks of sending information by public networks or on public computers and we cannot therefore 100% guarantee the security of any data disclosed or transmitted over the internet.

9. HOW LONG YOUR INFORMATION WILL BE KEPT AND YOUR RIGHTS

9.1 Our document and records retention schedules (and criteria for determining how long we hold personal data, including without limit, Your Information) are based on our statutory obligations and our business purposes, activities or needs. Destruction of records may be suspended if it becomes apparent that there is possibility of a claim, anticipated litigation or regulatory investigation that means such data may have to be retained.

9.2 You may have the following legal rights under data protection law (subject to certain legal exemptions and restrictions) in respect of Your Information that we hold:

  • request that we give you access to a copy of it;
  • request that we rectify or update it, if inaccurate;
  • request that we erase it, in certain circumstances where it is no longer needed;
  • request that we restrict our use of it, in certain circumstances
  • object to our using it, in certain circumstances;
  • withdraw your consent to our using it (where our processing is based on your consent);
  • a right to data portability, in certain circumstances;
  • request us not to use it for direct marketing; and
  • lodge a complaint with the data protection regulator or supervisory authority in your country (if there is one). In the UK, the relevant authority is the Information Commissioner’s Office (‘ICO’).

9.3 For more information about the ICO, the above data rights and how to lodge a complaint, please visit the ICO website.

10. CHANGES TO THIS APP PRIVACY NOTICE

This App Privacy Notice was last updated on 4 July 2019. It may be amended or updated from time to time, so please check that you have seen the latest version.

11. HOW TO CONTACT US

11.1 Please contact us and/or our Data Protection Office by post or email if you have any questions about this App Privacy Notice or the information we hold about you.

11.2 Our contact details are shown below:

  • Post: Data Protection Office, 20 Old Bailey, London EC4M 7AN
  • Email: gdproffice@withersworldwide.com
  • We may need further information to verify your identity before we can fully respond.

12. COOKIES

12.1 Cookies are small pieces of information sent by the web server that hosts our Website to the web browser on the computer or device you use to access this Website (e.g. Internet Explorer, Safari, Google Chrome or Firefox). Cookies enable our computer server to collect information from the browser on your device about your browsing activity when using your device to access our Website.

12.2 We use Cookies to help us better understand how our Website is used and provide a more user-friendly experience. For example, using knowledge of your previous Website visits, we can tailor content to match your particular needs and interests when you revisit our Website. Please note that Cookies are not used by us to collect special category personal information or financial information such as credit card details.

12.3 The following describes the Cookies that we may use and what they are used for:

Strictly necessary Cookies: Some Cookies are essential in order to enable you to navigate our Website and use special features you require. Where such Cookies are strictly necessary to receive a particular service you have asked for (e.g. secure extranet access) or to enable you to view or use our Website, we do not need to ask your permission to use them.

Performance Cookies: These Cookies collect information about user visits to our Website, for instance which pages visitors go to most often. Some of these Performance Cookies are ‘analytics’ cookies, using third party software tools, which help us understand more about how our Website is used. For example, we use Google Analytics to help us monitor visitor traffic to our Website. Performance Cookies do not collect information that personally identifies a visitor by name so our use of them should not impact on your privacy.

Functionality Cookies: This describes Cookies that allow our Website to remember information from your previous visit, such as details you previously submitted or your previously stated preferences. For example, when you complete a registration form and you tick the ‘Remember Me’ checkbox, we will use a Cookie to remember your details if you complete another form without you having to re-enter them. These Cookies may also be used to provide services you request such as newsletters or publications. Such a cookie may also be used to set the background image across the Website. This will remember which image was displayed to you the last time you visited our Website and will display the next image (in a set order) on your next visit.

Third party Cookies: Our Website may also allow third parties to download cookies to your device. For example if you choose to ‘share’ a page or article from our Website with friends through a third party site such as a LinkedIn and Twitter, you may be sent cookies from these third party websites which we have no control over. You should check the third party website’s privacy policy or terms of use for more information about their use of cookies.

12.4 You can disable cookies using the settings on your web browser although this may affect your ability to get full use of all the features on our Website.