This is an important notice regarding your privacy and the way in which éclat (referred to as “we”, “our” or “us” in this policy) collects and makes use of your personal data. We want to be open and transparent with you, and therefore encourage you to contact us if you have any questions about this policy or the ways in which we use your personal data.

This policy applies to our applicants, customers, and visitors to our offices generally. We take our privacy responsibilities seriously and are committed to protecting and respecting your privacy.

This policy sets out the basis on which any personal data we collect from you, or that you provide to us, will be processed by us. Please read the following carefully to understand our views and practices regarding your personal data and how we will treat it.

For the purpose of applicable privacy legislation, the data controller is éclat of The Old Stables Rectory Farm, Broadway Road, Lightwater, Surrey, GU18 5SH. Our company registration number is 03615098.

Questions regarding this policy should be directed to our Data Protection Compliance Manager. The Data Protection Compliance Manager is responsible for ensuring compliance with the General Data Protection Regulations and this policy. That post is held by Lindsey Barr, who can be contacted at lindsey@eclat.co.uk. Any questions about the operation of this policy or any concerns that the policy has not been followed should be referred in the first instance to the Data Protection Compliance Manager.

Data protection principles

We will comply with data protection law and the GDPR. This says that the personal information we hold about you must be:

  1. Used lawfully, fairly and in a transparent way.
  2. Collected only for valid purposes that we have clearly explained to you and not used in any way that is incompatible with those purposes.
  3. Relevant to the purposes we have told you about and limited only to those purposes.
  4. Accurate and kept up to date.
  5. Kept only as long as necessary for the purposes we have told you about.
  6. Kept securely.

What information do we hold about you?

We may collect, store and use personal data about you (referred to throughout this privacy policy as personal information):

Applicants

Personal contact details such as your name, title, address, telephone number, date of birth and e-mail address.

Recruitment information (including personal information such as copies your right to work documents, your CV or cover letter which is sent to us as part of the application process).

Information provided to us by recruitment agencies in relation to your application for employment with us.

Customers

Information you provide to us via our website, for example, by using the ‘Contact us’ form on our website or by corresponding with our technical team.

Personal information provided to us by the third party service providers we work with, for example, analytics providers.

Business contacts

Contact details such as your name, title, business telephone number and business e-mail address.

Information that you provide or we collect during our interactions with you or your employer, such as how long we have done business with you or how long you have worked at your company.

Generally

Information gathered when you visit our offices via our visitor sign-in process, including your name.

Any personal information you provide to us during your interactions with us.

Information gathered by cookies used on our website. Our website uses cookies to distinguish you from other users of our website. This helps us to provide you with a good experience when you browse and also allows us to improve the way our website works. For detailed information on the cookies we use and the purposes for which we use them, please refer to our Cookie Policy.

Personal information provided to us by third party service providers we work with, for example, payment service or analytics providers.

How will we use your personal information and what is the legal ground we rely on for doing so?

We will only use your personal information when the law allows us to. When we use your personal information, we must have a legal ground for doing so. The following are (amongst others) the legal grounds by which we can use your personal information:

Where you have provided us with your consent for us to do so.

Where we need to perform the contract we have entered into with you or to take steps to enter into a contract with you.

Where we need to comply with a legal obligation to which we are subject.

Where it is in pursuit of our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests.

More specifically, we will use your personal information in the following circumstances:

Applicants:

To evaluate and progress your application for employment with us – to perform the contract with you or to take steps to enter into a contract with you, and in pursuit of our legitimate interests to verify your suitability for our vacancies.

To carry out right to work checks – to comply with a legal obligation.

Using a third party document and signature service to send you a contract of employment if you are successful in a job application with us. We are pursing our legitimate interest as sending documents out using this service is quicker and more reliable.

Customers:

Dealing with your enquiry made via the ‘Contact us’ page on our website – in pursuit of our legitimate interests to ensure your enquiry is dealt with promptly and efficiently.

Your contact details to provide you with information on our products and services. This may include technical information and/or marketing information – where we have your consent to do so.

To provide you with invoices for our products and services – to perform the contract with you or to take steps to enter into a contract with you.

Generally:

Storing your personal data on Sharepoint (a cloud storage service). As our storage is hosted, your information is protected by the security measures put in place by Microsoft. We are pursing out legitimate interest in storing all of our documentation and data in one place cheaply and keeping your information secure using the security measures provided by Microsoft.

To ensure our premises are kept secure – in pursuit of our legitimate interests (site security and evidence).

Health and safety purposes – to comply with a legal obligation.

To administer our website and for internal operations, including troubleshooting, data analysis, testing, research, statistical and survey purposes – in pursuit of our legitimate interests (to better understand how people interact with our website and solve any issues it may have).

To improve our website to ensure that content is presented in the most effective manner for you and your computer – in pursuit of our legitimate interests (to improve our content and your or other third parties’ experience of our products and services).

To improve our services – in pursuit of our legitimate interest (to improve our content and your or other third parties’ experience of our products and services).

To contact you if we wish to use your personal information for a purpose not set out in this policy – to comply with a legal obligation.

What happens if there is a change of purpose?

We will only use your personal information 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 we need to use your personal information for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so.

Which type of third parties might we share your personal information with?

We require third parties to respect the security of your personal information and to treat it in accordance with the law. For example, where we instruct third party service providers, we carry out due diligence on those providers to ensure they treat your personal information as seriously as we do.

We may share your personal information with the following types of third parties:

Third party cloud storage providers, such as Microsoft.

Technical and analytical support providers, for example, assisting with improving and developing our website.

Recruitment partners assisting us with filling our vacancies.

Professional advisers such as lawyers, accountants, and business analysts.

Providers which help us collate and organise information effectively and securely.

Suppliers and sub-contractors for the performance of any contract we enter into with you or who assist us with marketing or information distribution, such as MailChimp.

Data retention

How long will we use your personal information for?

We will only retain your personal information for as long as necessary to fulfill the purposes we collected it for.

We assess the appropriate retention period for different information based on the size, volume, nature and sensitivity of that information, the potential risk of harm to you from unauthorised use or disclosure of that information, the purposes for which we are using that information, applicable legal requirements for holding that information, and whether we can achieve those purpose(s) through other means.

Applicants

Where your application for employment with us is successful, we will provide you with further information as to how we use your personal information during the course of your employment.

Where your application for employment with us is unsuccessful, we will keep your personal information for 12 months.

Customers

The period we keep your personal information depends on a number of circumstances. For example:

Where we have collected your personal information during the course of you or your organisation and us doing business, we will keep your personal information for as long as this business continues, or for as long as we have a commercial interest in holding your personal information, for example, with a view to doing business in the future.

Where you use our website and one of our cookies are activated, that cookie will operate for the duration set out in our Cookie Policy.

Where we have collected your personal information for marketing distribution, we will keep this information for as long as you wish to receive the marketing information. You can unsubscribe by following the simple process in paragraph 9 below.

Business contacts

Where we have collected your personal information during the course of you or your organisation and us doing business, we will keep your personal information for as long as this business continues, or for as long as we have a commercial interest in holding your personal information, for example, with a view to doing business in the future.

Where we store your personal data

Electronic versions of the information you provide to us or we collect about you is stored on servers provided by our cloud hosting solution provider. The company which provides this service is Sharepoint.

Although Sharepoint’s servers are based outside of the EEA, we have taken steps to ensure your personal information is adequately protected. Microsoft adheres to the Privacy Shield regime and we have a processing agreement in place governing the transfer of personal information between us and Microsoft.

Rights of access, correction, erasure, and restriction

Your rights in connection with your personal information

Under certain circumstances, by law, you have the right to:

Request access to your personal information (known as a “data subject access request”). This enables you to receive a copy of the personal information we hold about you and to check that we are lawfully processing it.

Request correction of the personal information that we hold about you. This enables you to have any incomplete or inaccurate information we hold about you corrected.

Request the erasure of your personal information. This enables you to ask us to delete or remove personal information where there is no good reason for us continuing to process it. You also have the right to ask us to stop processing personal information where we are relying on a legitimate interest and there is something about your particular situation which makes you want to object to processing on this ground.

Request the restriction of processing of your personal information. This enables you to ask us to suspend the processing of personal information about you, for example, if you want us to establish its accuracy or the reason for processing it.

Request the transfer of your personal information to another party.

If you want to review, verify, correct or request erasure of your personal information, object to the processing of your personal information, or request that we transfer a copy of your personal information to another party, please contact our Data Protection Compliance Manager in writing using the contact details set out at the beginning of this privacy policy.

No fee usually required

You will not have to pay a fee to access your personal information (or to exercise any of the other rights). However, we may charge a reasonable fee if your request for access is clearly unfounded or excessive. Alternatively, we may refuse to comply with the request in such 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 the information (or to exercise any of your other rights). This is a security measure to ensure that personal information is not disclosed to another person who has no right to receive it

Right to withdraw consent

In the limited circumstances where you may have provided your consent to the collection, processing, and transfer of your personal information for a specific purpose, you have the right to withdraw your consent for that specific processing at any time. To withdraw your consent, please contact our Data Protection Compliance Manager in writing using the contact details set out at the beginning of this privacy policy.

Where we are providing you with marketing information, you can also change your marketing preferences by using the unsubscribe button at the bottom of our marketing e-mails sent to you.

Once we have received notification that you have withdrawn your consent, we will no longer process your personal information for the purpose or purposes you originally agreed to, unless we have another legitimate basis for doing so.

What happens if you fail to provide personal information?

If you fail to provide certain information when requested, we may not be able to perform the contract we have entered into with you (such as providing you with our products or services), or we may be prevented from complying with our legal obligations (such as to ensure the health and safety of visitors to our offices).

Right to complain

You have a right to make a complaint if you wish to do so. The organisation with oversight of our processing is the Information Commissioner’s Office which can be contacted in writing at Information Commissioner’s Office, Wycliffe House, Water Lane, Wilmslow, Cheshire, United Kingdom SK9 5AF, by telephone (0303 123 1113) or by e-mail (casework@ico.org.uk).

Changes to this privacy policy

We may change, modify, add or remove portions of this privacy policy at any time, and any changes will become effective immediately.

Any changes we make to our privacy policy will be posted on this page and, where appropriate, notified to you.