Bower is committed to protecting the privacy of both our clients and our candidates. We understand that your privacy is important to you and that you care about how your information is used and shared online. We respect and value the privacy of everyone who visits Our Site and will only collect and use information in ways that are useful to you and in a manner consistent with your rights and Our obligations under the law.
We take privacy very seriously and it is central to everything that we do. Our integrity is key to our success and adhering to the strictest codes of confidentiality and treatment of personal data is of critical importance to us.
We never disclose the specific details of who our clients are, over and above the essential information provided to us for the purpose of briefing candidates. Likewise, we keep all candidate information confidential and only send out CVs to clients with the express permission of the candidate. We do not send information, CVs, profiles or job information out en masse or at random.
1. Definitions and Interpretation
In this Policy the following terms shall have the following meanings:
“Account” means an account required to access and/or use certain areas and features of Our Site;
“Cookie” means a small text file placed on your computer or device by Our Site when you visit certain parts of Our Site and/or when you use certain features of Our Site. Details of the Cookies used by Our Site are set out in section 12, below;
“Our Site” means this website, www.bower-talent.com
“UK and EU Cookie Law” means the relevant parts of the Privacy and Electronic Communications (EC Directive) Regulations 2003 as amended in 2004, 2011 and 2015; and
“We/Us/Our” means Bower Group (also known as Bower Talent), a limited company registered in England under 9260927 whose registered address is 11 Bressenden Place, London, SW1E 5BY and whose main trading address is 11 Bressenden Place, London, SW1E 5BY.
2. Information About Us
2.1 Our Site, www.bower-talent is owned and operated by Bower Group a limited company registered in England under 9260927, whose registered address is 11 Bressenden Place, London, SW1E 5BY. and whose main trading address is 11 Bressenden Place, London, SW1E 5BY. Our VAT number is 1994839 32.
2.2 Our data protection officer is Georgina Bale who can be contacted at email@example.com.
2.3 We are a member of The Recruitment & Employment Confederation.
3. Scope – What Does This Policy Cover?
4. What Data Do We Collect?
4.2 business/company name
4.3 job title;
4.5 contact information such as email addresses and telephone numbers;
4.6 demographic information such as post code, preferences and interests;
4.7 IP address (automatically collected);
4.8 web browser type and version (automatically collected);
4.9 operating system (automatically collected);
4.10 a list of URLs starting with a referring site, your activity on Our Site, and the site you exit to (automatically collected).
5. How Do We Use Your Data?
5.1 All personal data is stored securely in accordance with the EU General Data Protection Regulation (Regulation (EU) 2016/679) (GDPR). For more details on security see section 6, below.
5.2 We use your data to provide the best possible products and services to you. This includes:
5.2.1 Providing and managing your access to Our Site;
5.2.2 Personalising and tailoring your experience on Our Site;
5.2.3 Supplying Our products and services to you;
5.2.4 Personalising and tailoring Our products and services for you;
5.2.5 Responding to communications from you;
5.2.6 Supplying you with emails from firstname.lastname@example.org e.g. quarterly newsletters, job alerts or marketing campaigns. (you may unsubscribe or opt-out at any time by clicking the link in our emails).
5.2.7 Market research;
5.2.8 Analysing your use of Our Site and gathering feedback to enable Us to continually improve Our Site and your user experience;
5.3 In some cases, the collection of data may be a statutory or contractual requirement, and We will be limited in the products and services We can provide you without your consent for Us to be able to use such data.
5.4 With your permission and/or where permitted by law, We may also use your data for marketing purposes which may include contacting you by email AND/OR telephone AND/OR text message AND/OR post with information, news and offers on Our products and services. We will not, however, send you any unsolicited marketing or spam and will take all reasonable steps to ensure that We fully protect your rights and comply with Our obligations under the GDPR and the Privacy and Electronic Communications (EC Directive) Regulations 2003, as amended in 2004, 2011 and 2015.
5.5 Under GDPR we will ensure that your personal data is processed lawfully, fairly, and transparently, without adversely affecting your rights. We will only process your personal data if at least one of the following basis applies:
a) you have given consent to the processing of your personal data for one or more specific purposes;
b) processing is necessary for the performance of a contract to which you are a party or in order to take steps at the request of you prior to entering into a contract;
c) processing is necessary for compliance with a legal obligation to which we are subject;
d) processing is necessary to protect the vital interests of you or of another natural person;
e) processing is necessary for the performance of a task carried out in the public interest or in the exercise of official authority vested in the controller; and/or
f) processing is necessary for the purposes of the legitimate interests pursued by us or by a third party, except where such interests are overridden by the fundamental rights and freedoms of the data subject which require protection of personal data, in particular where the data subject is a child.
6. How and Where Do We Store Your Data?
6.1 We only keep your data for as long as We need to in order to use it as described above in section 5, and/or for as long as We have your permission to keep it. In any event, We will conduct an annual review to ascertain whether we need to keep your data. Your data will be deleted if we no longer need it in accordance with the terms of our Data Retention Policy. Our Data Retention Policies are:
6.2 Your data will only be stored within the European Economic Area (“the EEA”) (The EEA consists of all EU member states, plus Norway, Iceland and Liechtenstein).
6.3 Data security is of great importance to Us, and to protect your data We have put in place suitable physical, electronic and managerial procedures to safeguard and secure data collected through Our Site.
6.4 Notwithstanding the security measures that We take, it is important to remember that the transmission of data via the internet may not be completely secure and that you are advised to take suitable precautions when transmitting to Us data via the internet.
7. Do We Share Your Data?
7.1 We may share your data with other companies in Our group. This includes Our subsidiaries and Our holding company.
7.2 We may contract with third parties to supply products and services to you on Our behalf. These may include payment processing, delivery of goods, search engine facilities, advertising and marketing. In some cases, the third parties may require access to some or all of your data. Where any of your data is required for such a purpose, We will take all reasonable steps to ensure that your data will be handled safely, securely, and in accordance with your rights, Our obligations, and the obligations of the third party under the law.
7.3 We may compile statistics about the use of Our Site including data on traffic, usage patterns, user numbers, sales and other information. All such data will be anonymised and will not include any personally identifying information. We may from time to time share such data with third parties such as prospective investors, affiliates, partners and advertisers. Data will only be shared and used within the bounds of the law.
7.4 In certain circumstances We may be legally required to share certain data held by Us, which may include your personal information, for example, where We are involved in legal proceedings, where We are complying with the requirements of legislation, a court order, or a governmental authority. We do not require any further consent from you in order to share your data in such circumstances and will comply as required with any legally binding request that is made of Us.
7.5 We may share your data with our sister business, Tech Warriors HQ LTD, for the purpose of supporting you in your employment and job search, as an educational platform. Tech Warriors HQ LTD (also known as Tech Warriors) is a limited company registered in England under 13476453.
8. What Happens If Our Business Changes Hands?
8.2 In the event that any of your data is to be transferred in such a manner, you will be contacted in advance and informed of the changes. When contacted you will be given the choice to have your data deleted or withheld from the new owner or controller.
9. How Can You Control Your Data?
9.1 When you submit information via Our Site, you may be given options to restrict Our use of your data. We aim to give you strong controls on Our use of your data (including the ability to opt-out of receiving emails from Us which you may do by unsubscribing using the links provided in Our emails and at the point of providing your details.
9.2 You may also wish to sign up to one or more of the preference services operating in the UK: The Telephone Preference Service (“the TPS”), the Corporate Telephone Preference Service (“the CTPS”), and the Mailing Preference Service (“the MPS”). These may help to prevent you receiving unsolicited marketing. Please note, however, that these services will not prevent you from receiving marketing communications that you have consented to receiving.
10. Your Right to Withhold Information and Your Right to Withdraw Information After You Have Given it
10.1 You may access Our Site without providing any data at all. However, to use all features and functions available on Our Site you may be required to submit or allow for the collection of certain data.
10.3 You may withdraw your consent for Us to use your personal data as set out in section in 5 at any time by contacting Us using the details set out in section 15, and We will delete Your data from Our systems. However, you acknowledge this may limit Our ability to provide the best possible products and services to you.
11. How Can You Access Your Data?
You have the legal right to ask for a copy of any of your personal data held by Us (where such data is held). Please contact Us for more details at email@example.com, or using the contact details below in section 14.
12. What Cookies Do We Use and What For?
12.2 By using Our Site you may also receive certain third party Cookies on your computer or device. Third party Cookies are those placed by websites, services, and/or parties other than Us. For more details, please refer to section 5, above, and to section 12.6 below. These Cookies are not integral to the functioning of Our Site.
12.3 All Cookies used by and on Our Site are used in accordance with current English and EU Cookie Law.
12.4 Before any Cookies are placed on your computer or device subject to section 12.5 and section 12.8, you will be shown a prompt requesting your consent to set those Cookies. By giving your consent to the placing of Cookies you are enabling Us to provide the best possible experience and service to you. You may, if you wish, deny consent to the placing of Cookies; however certain features of Our Site may not function fully or as intended.
12.5 Certain features of Our Site depend on Cookies to function. UK and EU Cookie Law deems these Cookies to be “strictly necessary”. These Cookies are shown below in section 12.6. Your consent will not be sought to place these Cookies. You may still block these Cookies by changing your internet browser’s settings as detailed below in section 12.10, but please be aware that Our Site may not work as intended if you do so. We have taken great care to ensure that your privacy is not at risk by allowing them.
12.6 The following first party Cookies may be placed on your computer or device:
|Name of Cookie||Purpose||Strictly Necessary?|
|wordfence_verifiedHuman||This Cookie is set by the Wordfence Security WordPress plugin to protect Our Site against malicious attacks||Yes|
12.9 Google Analytics uses the following first party Cookies on Our Site:
|Name of cookie||Purpose|
|_ga||This cookie is used to distinguish users on Our Site. It is included in each page request in a site and used to calculate visitor, session and campaign data for analytics reports.|
|_gat||This cookie is used to throttle request rate.|
|_gid||This cookie registers a unique ID that is used to generate data on how the visitor uses Our Site.|
|_utma||This cookie is used to collect data on the number of times a user has visited Our Site, including first and most recent visit.|
|_utmb||This cookie is also used to determine new sessions and visits on Our Site.|
|_utmt||This cookie is used to throttle the speed of requests to the server.|
|_utmc||This cookie registers a timestamp with the exact time of when a user leaves the website.|
|_utmz||This cookie records how people arrive at Our Site – for example, from a particular search engine or referral from another site. We use this information to see measure how effective Our online advertising is and by what channels visitors are referred to Our Site.|
12.10 Our site uses functional cookies which enable the website to provide enhanced functionality and personalisation. They may be set by us or by third party providers whose services we have added to our pages. If you do not allow these cookies then some or all of these services may not function properly. The following functional cookies are used on our site:
|Name of cookie||Purpose|
|wordfence_verifiedHuman, wfvt_2264011662||This Cookie is set by the Wordfence Security WordPress plugin to protect Our Site against malicious attacks.|
|giphy||This cookie enables images and media content from giphy.com on our site.|
|Paypalobjects||Used for the Paypal login system.|
|abmr||This cookie is set by the abmr.net domain to enable streaming data such as videos.|
|accounts.google.com||This cookie is used by Google accounts on relevant pages.|
12.11 We may have some third party targeting cookies on our site. These cookies may be set through our site by our advertising partners. They may be used by those companies to build a profile of your interests and show you relevant adverts on other sites. They do not store directly personal information, but are based on uniquely identifying your browser and internet device. If you do not allow these cookies, you will experience less targeted advertising.
|Name of cookie||Purpose|
|quantserve||The Quantcast service is used to reveal unique audience insights. Cookie information.|
|doubleclick||DoubleClick is a subsidiary of Google which develops and provides Internet advertising serving services.|
|This cookie is used by Google for advertising purposes.|
|cdn.syndication.twimg||This cookie is used to remember the user’s selected language for using the website.|
|youtube||We embed videos from our official YouTube channel using YouTube’s privacy-enhanced mode. This mode may set cookies on your computer once you click on the YouTube video player, but YouTube will not store personally-identifiable cookie information for playbacks of embedded videos using the privacy-enhanced mode.|
|Allows the user to interact with our site through their Facebook account.|
|Allows the user to interact with our site through their Pinterest account.|
|Allows the user to interact with our site through their Twitter account.|
12.12 You can choose to enable or disable Cookies in your internet browser. Most internet browsers also enable you to choose whether you wish to disable all cookies or only third party cookies. By default, most internet browsers accept Cookies but this can be changed. For further details, please consult the help menu in your internet browser or the documentation that came with your device.
12.13 You can choose to delete Cookies at any time however you may lose any information that enables you to access Our Site more quickly and efficiently including, but not limited to, login and personalisation settings.
12.14 It is recommended that you keep your internet browser and operating system up-to-date and that you consult the help and guidance provided by the developer of your internet browser and manufacturer of your computer or device if you are unsure about adjusting your privacy settings.
12.10 You can choose to enable or disable Cookies in your internet browser. Most internet browsers also enable you to choose whether you wish to disable all cookies or only third party cookies. By default, most internet browsers accept Cookies but this can be changed. For further details, please consult the help menu in your internet browser or the documentation that came with your device.
12.11 You can choose to delete Cookies at any time however you may lose any information that enables you to access Our Site more quickly and efficiently including, but not limited to, login and personalisation settings.
12.12 It is recommended that you keep your internet browser and operating system up-to-date and that you consult the help and guidance provided by the developer of your internet browser and manufacturer of your computer or device if you are unsure about adjusting your privacy settings.
13. Summary of Your Rights under GDPR
Under the GDPR, you have:
13.1 the right to request access to, deletion of or correction of, your personal data held by Us;
13.2 the right to complain to a supervisory authority;
13.3 be informed of what data processing is taking place;
13.4 the right to restrict processing;
13.5 the right to data portability;
13.6 object to processing of your personal data;
13.7 rights with respect to automated decision-making and profiling (see section 14 below).
14. Automated Decision-Making and Profiling
14.1 In the event that We use personal data for the purposes of automated decision-making and those decisions have a legal (or similarly significant) effect on You, You have the right to challenge to such decisions under GDPR, requesting human intervention, expressing their own point of view, and obtaining an explanation of the decision from Us.
14.2 The right described in section 14.1 does not apply in the following circumstances:
a) The decision is necessary for the entry into, or performance of, a contract between the You and Us;
b) The decision is authorised by law; or
c) You have given you explicit consent.
14.3 Where We use your personal data for profiling purposes, the following shall apply:
a) Clear information explaining the profiling will be provided, including its significance and the likely consequences;
b) Appropriate mathematical or statistical procedures will be used;
c) Technical and organisational measures necessary to minimise the risk of errors and to enable such errors to be easily corrected shall be implemented; and
d) All personal data processed for profiling purposes shall be secured in order to prevent discriminatory effects arising out of profiling.
15. Contacting Us