1. We recognise and value the importance of protecting the privacy of Users of our Website.
We are committed to ensuring that we manage your personal data professionally and in compliance with all applicable data protection laws. Part of this commitment is to ensure that there is transparency about how we process personal data in connection with the services that we provide and with the operation of our website, which is located at [ https://andfriends.world/ ] (the ‘Website’).. This policy includes an explanation of:
1.1. what data we are processing;
1.2. why we are processing it and what we do with it;
1.3. whether we will share it with anyone else;
1.4. whether we will transfer it outside of the United Kingdom;
1.5. how we keep your data safe; and
1.6. your rights.
3.Our company name is Mr White & Friends Ltd and our registered company number is 10595248. We are located at One Mark Square Shoreditch, London EC2A 4EG and our registered office is at Monometer House, Rectory Grove, Leigh-On-Sea, SS9 2HL In this policy we have referred to Mr White & Friends Ltd as ‘& Friends’, ‘us’ or ‘we’.
4.For any queries concerning your data, please contact us at the above address or by email at [email@example.com].
Your personal data
5.Subject to the & Friends Website Terms, any person may be able to access or use certain sections of this Website via the internet without registering with or disclosing any personally identifying information to & Friends (an ‘Unregistered User’).
6.To make full use of the functionality of this Website, you will need to register with & Friends. There are two different types of registration (collectively referred to as ‘Registered Users’);
6.1 freelancers who are seeking to be engaged by third parties to perform freelancing services (‘Freelancers’); and
6.2 companies who are seeking to engage Freelancers to perform services for them (‘Clients’).
In limited circumstances a Freelancer may also be a Client (and vice versa).
Why do we need to collect your personal data?
7. The Website is more complicated than a traditional market place, because we offer a talent management system that streamlines the way Clients and Freelancers find each other and work together. Our system is designed to handle freelance engagements from end-to-end, including allowing Clients to undertake searches for freelancing talent, to view and organise rosters, facilitate interaction between Freelancers and Clients and to allow for the booking and invoicing of freelancing services. As such, we need to collect, store, use and disclose personal data as part of the normal operation and functioning of our Website.
How will we collect your personal information?
8. We will always interact with you in an open and transparent manner, including by informing you:
• when we collect your personal information; and
• how we will manage your personal information.
When do we collect personal information?
9. Visitors to our Website choose to interact with us in ways that require us to gather personal data. The amount and type of information that we gather depends on the nature of the interaction.
10.We collect personal data in a number of ways, including:
• when you visit and interact with our Website and related software (including any mobile applications);
• when you sign up for a client account, submit form on our Website or sign up for our newsletter;
• when you engage in transactions with us;
• when you submit your application to join as a Freelancer;
• through cookies and other technologies that allow us to give you a better experience on our Website; and
• when you contact us independently of the Website, such as by email, phone or in person.
What personal information will we collect?
11. In order to operate the Website, we need to collect a sufficient amount of your personal data to allow us to undertake our functions, and to allow any transactions between us to take place efficiently and securely.
12. You may be able to browse certain pages of our Website anonymously. However, in order to engage in the freelance process using our Website, you will need to create an account with us and it is not practical for you to transact with us anonymously or using a pseudonym. When creating an account, we will request that you provide us with personal information. This may include, but is not necessarily limited to:
• your full name and prefix (e.g. Mr or Mrs), so that we can identify you;
• your photograph/s;
• your primary telephone number, so that we can contact you if there is a problem;
• your postal address (business and/or home);
• your email address, so that we can correspond with you electronically and administer your account (e.g. password resets);
• credit card and account details; and
• details of the company you represent (eg company name, address and contact details) and the title of your position at that company.
13. If your personal details change, it is your responsibility to update your account with those changes, so that we can keep our records complete, accurate and up to date.
14. We will never collect ‘sensitive’ information about you and you must not disclose sensitive information to us. Sensitive information includes certain kinds of information about you, such as your political opinions or your racial or ethnic origin.
How we use your personal data and our applicable lawful basis.
16. We will use your personal information for a number of purposes associated with the operation of the Website or as otherwise required or authorised by law.
17. We may also process your information to allow us to pursue our legitimate interests including:
- provide you with functional access to the Website, including the ability to participate in various stages of the freelance search process with a view to engaging a Freelancer if you are a Client or propose to provide freelancing services to a Client if you are a Freelancer;
- to put Freelancers in communication with Clients (and vice versa);
- identify you and authenticate your identity;
- contact you in respect of the Website, and the freelance process;
- ensure that Cavalry Freelancing receives payment of any fees due to it;
- facilitate payment by Clients to Freelancers;
- send you service or promotional communications, including surveys and information about security updates;
- create or distribute marketing material that is relevant to you;
- permit content on the Website (such as postings or third party advertisements) to be targeted, on an aggregate basis, to the users for whom it is most likely to be relevant;
- undertake quality assurance and training;
- conduct research;
- develop new Website features;
- customise the content on the Website and any advertising on the Website;
- develop relationships with affiliate service providers;
- for statistical reporting purposes, on an anonymised and aggregated basis;
- act in a way that is required or authorised by or under law
- undertake any other uses identified at the time of collection of your personal data.
18. If you are a Freelancer, certain of your personal data included in your professional profile to may be visible to Clients, depending on the extent to which you have opted in to share your personal data via your account settings.
19. We may also offer a profile feature that allows portions of a Freelancer’s profile to be published to the Internet. If you are a Freelancer, certain portions of your public profile may be indexed and displayed through public search engines such as Google when someone searches for your name, and allow them to click through to your & Friends profile. You may opt out of this feature entirely in your account settings. [However, you should be aware that third-party search engines may not automatically update their caches, which may contain old public profile information.]
20. Our lawful basis for keeping you updated about our products and services is usually our legitimate interests (namely, to grow our business).
The secondary purpose for which we will use your personal information is to allow us to send you direct marketing in relation to our respective goods and services [or the respective goods and services of trusted third parties]. If you do not agree to us using your personal information for this secondary purpose, you should just notify us of this at the time you create a user account. You can also change your mind at a later date by notifying us. You can opt-out of receiving direct marketing materials or ‘unsubscribe’ at any time in a number of ways. Firstly, you can log on to your user account at the Website and change your preferences and settings. Secondly, you can in many cases unsubscribe via the marketing materials themselves. For example, any direct marketing emails we send to you will contain a functional ‘unsubscribe’ feature which will always be valid for at least 30 days from the date of the communication. Finally, you can always change your marketing preferences by contacting us using the contact details provided.
21. Where relevant you consent to & Friends posting and using any photographs, content and/or personal information you might upload on our website or have otherwise provided consent to publish on our website, blog, in our marketing collateral or social media channels, which we may use in order to provide our services, the marketing of our services or for the purpose of our functions and/or activities.
Who will we disclose your personal information to?
22. We may disclose your personal data:
- for the purposes for which it is collected and for any related purposes, including 1) to any person where necessary or desirable in connection with the provision of the Website, and the services to you; and 2) to any person where necessary or desirable in connection with the management of our relationship with you; and
- to our external advisors, service providers, subcontractors and suppliers, so that they can provide professional, financial, technical, administrative or other advice and services in connection with the operation of our business;
- if you are a Freelancer, to Clients or, if you are a Client, to Freelancers;
- to our affiliated entities for the purpose of such affiliated entities contacting you about their products and services [or the products and services of trusted third parties];
- to any person who acquires or expresses an interest in acquiring all or any part of our business;
- to facilitate payments in relation to the freelancing process;
- to any person where necessary or desirable in connection with us investigating, preventing or taking action regarding any breach or suspected breach by you of the Website Terms or any law; and
- to any person as required or authorised by or under law, and to any other person to which you subsequently consent from time to time.
23. When you use the Website to participate in the freelance search process or otherwise communicate in a public forum on the Website, your user ID and all or some of the material you post may be visible to other users on the Website and may be publicly available to other internet users. We therefore suggest that you use discretion and caution when posting information to the Website. We do not in any way control, and do not accept any responsibility or liability whatsoever for, the disclosure or use of personal information which is voluntarily posted by you in any publicly accessible area of the Website.
24. We will never sell your personal information.
25. We will never use or disclose your personal data for the purpose of sending you spam, that is, unsolicited commercial messages which offer or advertise goods or services.
Transferring your data outside of the United Kingdom (‘UK’)
26. The information that you send to us may be transferred to countries outside the UK. By way of example, this may happen if any of our servers or those of our third-party service providers are located in a country outside of the UK. These countries may not have similar data protection laws to the UK.
27. If we transfer your information outside of the UK in this way, we will take steps to ensure that appropriate security measures are taken with the aim of ensuring that your privacy rights continue to be protected. These measures include imposing contractual obligations on the recipient of your personal information or ensuring that the recipients are subscribed to ‘international frameworks’ that aim to ensure adequate protection. Please contact us if you would like more information about the protections that we have put in place.
Data Security and How will we hold your personal information?
28.We are committed to storing your personal information as securely as possible.
29.We will take all reasonable to steps to protect your personal data from misuse, loss, interference and unauthorised access, modification or disclosure.
30. We have adopted appropriate technical and organisational measures to protect the personal data we collect and use having regard to the state of the art, the nature of the data stored and the risks to which the data is exposed to human action or the physical or natural environment. However, as effective as our security measures are, no security system is impenetrable. We cannot guarantee the security of our database.
31. The transmission of information via the internet is not completely secure. Although we will do our best to protect your personal data, we cannot guarantee the security of your data transmitted to our website; any transmission is at your own risk. Once we have received your information, we will use procedures and security features to try to prevent unauthorised access.
32. Where we have given you (or where you have chosen) a password which enables you to access certain parts of our website, you are responsible for keeping this password confidential. We ask you not to share a password with anyone.
33. We will only retain your personal data for as long as necessary to fulfil the purposes we have collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements.
34. Cookies are small text files that many websites place on your computer or device. Some cookies are deleted when you close down your browser. These are known as session cookies. Others remain on your device until they expire or you delete them from your cache. These are known as persistent cookies and enable us to remember things about you as a returning visitor.
To find out more about cookies, including how to see what cookies have been set and how to manage and delete them, visit www.allaboutcookies.org.
36. Most browsers are automatically set up to accept cookies. The storage of cookies can be deactivated or the browser can be configured in such a way that it sends a notification when cookies are sent. You are always free to decline our cookies, however doing so may significantly interfere with your use of the Website.
37.We use the following third party cookies on our Website:
- Analytics cookies
- Application performance monitoring and error logging
- Advertising cookies
- Tracking ad spend and attribution
- Analytics cookies
- User flows and monitoring
- Advertising cookies
- Tracking ad spend and attribution
- Analytics cookies
- User and behavioural tracking analytics
- Analytics cookies
- User and behavioural tracking analytics
- Functional cookies
- Support live chat
- Analytics cookies
- User flows and lifecycle event tracking
Your right to access data
38. We always aim to be as open as we can and allow people access to their personal information. Where we hold your personal data, you can make a ‘subject access request’ to us and we will provide you with:
38.1. a description of it;
38.2. an explanation of why we are holding it;
38.3. information about who it could be disclosed to; and
38.4. a copy of the information in an intelligible form – unless an exception to the disclosure requirements is applicable.
39. If you would like to make a ‘subject access request’ please make it in writing to our contact email address noted above and mark it clearly as ‘Subject Access Request’.
40. If you agree, we will try to deal with your request informally, for example by providing you with the specific information you need over the telephone.
41. Unless you agree a different time, we will complete your subject access request within one month.
What if your personal information is wrong?
42.We will take reasonable steps to ensure that the personal information we hold, use and disclose is accurate, up to date and complete. However, we will not take any administrative steps to verify the accuracy or completeness of the information you provide to us at the time of collection (for example, if you make a mistake when typing in your details).
43.If you suspect or believe that the personal information we have is not accurate, complete or up to date, please either (a) log in to the Website and update your personal information as appropriate, or (b) contact us at the details below and we will respond to your request within a reasonable period. When responding, we will take reasonable steps to correct that information and to ensure that it remains accurate, complete and up to date in the future. If for some reason we are unable to correct your personal information, we will provide you with our reasons in writing and your further options for complaint. We will not ordinarily charge you for requesting the correction of your personal information.
Right to be forgotten
44. If we hold personal data about you, but it is no longer necessary for the purposes that it was collected and cannot otherwise be justified – you have the right to request that we delete the data.
Right to complain
45. You always have the right to complain to the personal data regulator, the ICO. You may also be entitled to seek compensation if there has been a breach of data protection laws.
Changes to this Policy
47.This policy was last updated on 14 December 2021