This privacy policy ("Policy") governs the manner in which POWSTER LTD of Unit G, Bagel Factory, 24 White Post Lane, London, E9 5SZ ("POWSTER", "we", "us." or "our") collects, uses, maintains, discloses and processes the information collected from visitors of the www.powster.com website ("Site"), job applicants, business contacts, suppliers, prospective customers and customers who use any of our services or products (collectively, the "Services") (together referred to as "you" or "your").

Our Site and Services are targeted to adults. We never knowingly collect personal information via our Site from those we know are under 16, and no part of our Site is structured to attract anyone under 16. If you are a parent or guardian and you believe we have collected information from your child in a manner not permitted by law, contact us via the contact details set out below. We will remove the data to the extent required by applicable laws.

This Policy does not apply to information collection activities outside of the Services, such as POWSTER's products and services that our customer may use to collect information on their own behalf (“Customer Data”). For example, POWSTER provides interactive online platforms for its customers, and may process information on their behalf to provide those services. This Policy does not describe the processing of Customer Data, and we invite you to visit the applicable customer’s privacy policy for information about their privacy practices. Any questions you have relating to such information and your rights under data protection law should be directed to the customer, as the controller of that information, and not to POWSTER.

At POWSTER, we're committed to keeping your information safe and secure, and handling it in accordance with applicable data protection laws. This Policy contains important information and we ask that you read it carefully. In this Policy, you can find more about:

Our Cookie Policy

What is a cookie?

A cookie is a small text file containing small amounts of information which is downloaded to/stored on your computer (or other internet enabled devices, such as a smartphone or tablet) when you visit a website. Cookies help us remember information about your visit to our Site, like your country, language and other settings. They can also help us to operate our Site more efficiently and make your next visit easier. Cookies can also allow us to do various other things, as we further explain below.

What cookies do we use?

When you visit our Site, the following cookies may be downloaded to your device:

Analytical/performance cookies

These cookies allow us to recognise and count the number of visitors/users of our Site and to see how such visitors/users move around our Site when they are using it. This helps us to improve the way our Site works, for example, by ensuring that users are finding what they are looking for easily.

Functionality cookies

These cookies are used to recognise you when you return to our Site. This enables us to personalise our content for you, greet you by name and remember your preferences.

While we do not use targeting cookies for advertising purposes, we use Google Analytics on our Site for analytical/performance purposes. Google Analytics allows us to track anonymous user movement and interaction on our Site, as well as monitoring how our Site works under high volume or stressed conditions. The types of aggregated events we track using Google Analytics include:

To enrich our content, we sometimes embed social options, photos and video content from websites such as Facebook, Twitter and YouTube. As a result, when you visit a page with content embedded from, for example, YouTube, YouTube may set a cookie. Please note that we do not control the dissemination of these cookies and you should check the relevant third party website, such as Facebook, Twitter or YouTube, for more information about their cookies.

How can you turn off cookies?

If you do not want us to install cookies or you don’t agree to how we use them in any way, you can change the settings on your internet browser or reject cookies. The "Help" section of the toolbar on most browsers will tell you how to prevent your device from accepting new cookies, how to have the browser notify you when you receive a new cookie, or how to disable cookies altogether. However, if you use your browser settings to block all cookies (including those cookies that are strictly necessary for the administration and operation of our Site) you may experience reduced functionality or not be able to access all or parts of our Site. Further information may be found at www.allaboutcookies.org.

What personal information we collect and when and why we use it

Information You Provide

We collect personal information from you if you:

If you apply for a job with us via our Site, we collect the following information from you:

We will use this personal information to:

If you visit our Site, we collect the following personal information from you:

POWSTER uses this personal information to:

If you purchase one of our Services, we collect the following personal information from you:

POWSTER uses this personal information to facilitate the delivery of the requested Services, and (where applicable) provide Powster updates and/or newsletters.

If you work with us as a business partner or service provider, we collect the following personal information from you:

POWSTER uses this personal information to:

In addition to the above, we use the information we collect from the above sources for the following purposes, to:

Notwithstanding the above, we may use information that does not identify you (including information that has been aggregated or de-identified) for any purpose except as prohibited by applicable law. For information on your rights and choices regarding how we use information about you, please see the “Your Legal Rights and Choices” section below.

Information Collected Automatically

In addition, we automatically collect the following information when you use the Services:

Please see our Cookie Policy (above) for information about how we use cookies and similar tracking technologies to collect this information. In addition to the technologies listed in our Cookie Policy, we use the following:

Information Collected From Other Sources

We also collect information from other sources, which include:

How we protect and store your personal information

We have adopted appropriate data collection, storage and processing practices, technical, organisational and security measures designed to protect against unauthorized access, alteration, disclosure or destruction of the personal information that you share with us. For example, such measures include:

As the security of information depends in part on the security of the computer you use to communicate with us and the security you use to protect user IDs and passwords, please take appropriate measures to protect this information.

We will store your information for as long as is reasonably necessary for the purposes for which it was collected, as explained in this Policy. Where your information is no longer needed, we will ensure that it is disposed of in a secure manner. In some circumstances we may store your personal information for longer periods of time, for instance where we are required to do so in accordance with legal, regulatory, tax and accounting requirements. In specific circumstances we may store your personal information for longer periods of time so that we have an accurate record of your dealings with us in the event of any complaints or challenges, or if we reasonably believe there is a prospect of litigation relating to your personal information or dealings.

Nevertheless, transmission of information via the internet is not completely secure and we cannot guarantee the security of information. If you have any questions about how we store your personal information, please contact us via the contact details set out below.

How we share your personal information

We share your personal information in the manner and for the purposes described below:

If, in the future, we sell or transfer some or all of our business or assets to a third party, we may disclose information to a potential or actual third party purchaser of our business or assets.

For more information on your rights and choices regarding how we share information about you, please see the “Your Legal Rights and Choices” section.

Social Media and Technology Integrations

We offer parts of our Services through websites, platforms, and services operated or controlled by separate entities. In addition, we integrate technologies operated or controlled by separate entities into parts of our Services. Some examples include:

Links

You may find there is advertising or other content on our Site that link to the sites and services of our partners, suppliers, advertisers, sponsors, licensors and others.

Liking and Sharing

We may embed a pixel or SDK on our Services that allows you to “like” or “share” content on, or log-in to your account through social media. If you choose to engage with such integration, we may receive information from the social network that you have authorized to share with us. Please note that the social network may independently collect information about you through the integration.

Brand Pages

We may offer content through social media. Any information you provide to us when you engage with our content (such as through our brand page) is treated in accordance with this Policy. Also, if you publicly reference our Services on social media (e.g., by using a hashtag associated with POWSTER in a tweet or post), we may use your reference on or in connection with our Services.

We do not control the content or links that appear when you interact with other entities, including when you leave our Services, and are not responsible for the practices employed by websites linked to, or from our Site. In addition, these sites or services, including their content and links, may be constantly changing. These sites and services may have their own privacy policies and customer service policies. Browsing and interaction on any other website, including websites which have a link to our Site, is subject to that website's own terms and policies. This Policy does not apply to your use of any other entity’s websites.

Explaining more about direct marketing

How we use personal information to keep you up to date with our Services

We may use personal information to let you know about Services that we believe will be of interest to you and/or provide you with our newsletter. We may contact you by email, post, or telephone or through other communication channels that we think you may find helpful. In all cases, we will respect your preferences for how you would like us to manage marketing activity with you.

ow you can manage your marketing preferences

To protect privacy rights and to ensure you have control over how we manage marketing with you:

Please note that you cannot opt-out of non-promotional emails, such as those about your transactions, servicing, or POWSTER’s ongoing business relations. Your opt out is limited to the email address, device, and phone number used and will not affect subsequent subscriptions.

We recommend you routinely review the privacy notices and preference settings that are available to you on any social media platforms as well as your preferences within your account with us. For more information about how you can exercise control over your information please see “Your Legal Rights and Choices” below.

Explaining more about tracking technology choices

Please be aware that if you disable or remove tracking technologies some parts of the Services may not function correctly.

Transferring personal information globally

We operate on a global basis. Accordingly, as part of our business activities, your personal information may be transferred and stored in countries outside of the country that you are located in, including Europe, the United States and New Zealand, that are subject to different standards of data protection.

We will take appropriate steps to ensure that transfers of personal information are in accordance with applicable law and carefully managed to protect your privacy rights and interests and transfers are limited to countries which are recognized as providing an adequate level of legal protection or where we can be satisfied that alternative arrangement are in place to protect your privacy rights. To this end:

Legal Rights for Residents of the European Economic Area

If you are a resident of the European Economic Area, under Euorpean law you have the following rights in relation to your personal information (click on the links below to learn more about each right you may have):

If you wish to access any of the above-mentioned rights, we may ask you for additional information to confirm your identity and for security purposes, in particular before disclosing personal information to you. We reserve the right to charge a fee where permitted by law, for instance, if your request is manifestly unfounded or excessive.

You can exercise your rights by Contacting Us. Subject to legal and other permissible considerations, we will make every reasonable effort to honour your request promptly or inform you if we require further information in order to fulfil your request.

We may not always be able to fully address your request, for example, if it would impact the duty of confidentiality we owe to others, or if we are legally entitled to deal with the request in a different way.

Right to access personal information

You have a right to request that we provide you with a copy of your personal information that we hold and you have the right to be informed of: (a) the source of your personal information; (b) the purposes, legal basis and methods of processing; (c) the data controller’s identity; and (d) the entities or categories of entities to whom your personal information may be transferred.

Right to rectify or erase personal information

You have a right to request that we rectify inaccurate personal information. We may seek to verify the accuracy of the personal information before rectifying it.

You can also request that we erase your personal information in limited circumstances where:

We are not required to comply with your request to erase personal information if the processing of your personal information is necessary:

Right to restrict the processing of your personal information

You can ask us to restrict your personal information, but only where:

We can continue to use your personal information following a request for restriction, where:

Right to transfer your personal information

You can ask us to provide your personal information to you in a structured, commonly used, machine-readable format, or you can ask to have it transferred directly to another data controller, but in each case only where:

Right to object to the processing of your personal information

You can object to any processing of your personal information which has our legitimate interests as its legal basis, if you believe your fundamental rights and freedoms outweigh our legitimate interests. If you raise an objection, we have an opportunity to demonstrate that we have compelling legitimate interests which override your rights and freedoms.

Right to object to how we use your personal information for direct marketing purposes

Right to obtain a copy of personal information safeguards used for transfers outside your jurisdiction

You can ask to obtain a copy of, or reference to, the safeguards under which your personal information is transferred outside of the European Union.

We may redact data transfer agreements to protect commercial terms.

Right to lodge a complaint with your local supervisory authority

Additional Disclosures for California Residents

California residents have certain privacy rights under the California Consumer Privacy Act of 2018, also known as the CCPA. The CCPA requires additional disclosures, and provides rights to know, delete, and opt-out, which are detailed below.

Notice of Collection.

In the past 12 months, we have collected the following categories of personal information listed in the CCPA:

For more information on information we collect, including the sources we receive information from, review the What Personal Information We Collect and When and Why We Use It section. We collect and use these categories of personal information for the business purposes described in the same section, including to provide and manage our Services.

POWSTER does not sell (as that term is defined in the CCPA) the personal information we collect (and will not sell it without providing a right to opt out). We use and partner with different types of entities to assist with our daily operations and manage our Services. Please review the Sharing Your Information With Others section for more detail about the parties we have shared information with.

Roles

Our Site and Services are intended to provide information to our customers and job applicants. By using the Site, Services or interacting with POWSTER offline, you represent and warrant that you will only provide information within the context of (i) your role as a job applicant, business contact, supplier, prospective customer or customer or (ii) POWSTER conducting due diligence regarding, or providing or receiving a product or service to or from your employer.

Our processing of Customer Data is governed by the terms of our service agreements with our customers and their privacy policies, and not this Policy. We are not responsible for how our customers treat the information we collect on their behalf, and we recommend you review their own privacy policies.

We acknowledge that you may have rights in connection with Customer Data. If you are a California resident and we as a service provider have processed your information on behalf of a customer and you wish to exercise your CCPA rights, please inquire with our customer directly. If you wish to make your request directly to us, please provide the name of the customer on whose behalf we have processed your information. We will refer your request to that customer, and will support them to the extent required by applicable law in responding to your request.

Right to Non-Discrimination.

You have the right not to receive discriminatory treatment by us for the exercise of any of your rights.

Shine the Light.

California’s “Shine the Light” law permits residents of California to request certain details about how certain types of their information are shared with third parties and, in some cases, affiliates, for those third parties’ and affiliates’ own direct marketing purposes. POWSTER does not share personal information as defined by California’s “Shine the Light” law with third parties and/or affiliates for those third parties’ and affiliates’ own direct marketing purposes.

Additional Disclosures for Nevada Residents

Nevada law (NRS 603A.340) requires each business to establish a designated request address where Nevada consumers may submit requests directing the business not to sell certain kinds of personal information that the business has collected or will collect about the consumer. A sale under Nevada law is the exchange of personal information for monetary consideration by the business to a third party for the third party to license or sell the personal information to other third parties. If you are a Nevada consumer and wish to submit a request relating to our compliance with Nevada law, please contact us as at hello@powster.com.

Legal rights in other jurisdictions

Residents in other jurisdictions may also have similar rights to the above. Please contact us if you would like to exercise one of these rights, and we will comply with any request to the extent required under applicable law.

Changes to this Privacy Policy

POWSTER may update this Policy at any time. When we do, we will revise the updated date at the bottom of this page. We encourage you to frequently check this page for any changes to stay informed about how we may use and protect the personal information we collect. If we make fundamental changes to this Policy, we will seek to inform you by notice on our Site or by email.

Contact us

Our Head of Information Security and Compliance has ultimate responsibility for making sure that POWSTER Policy and any applicable laws are complied with. Our Head of Information Security and Compliance can be contacted by emailing: dataprotection@powster.com.

If you experience any difficulties accessing the information here, please contact us via the details below to obtain this Policy in an alternate format.

If you have any questions, concerns or complaints regarding our compliance with this Policy, the information we hold about you or if you wish to exercise your rights, we encourage you to first contact us. We will investigate and attempt to resolve complaints and disputes and make every reasonable effort to honour your wish to exercise your rights as quickly as possible and in any event, within the timescales provided by data protection laws.

You have a right to lodge a complaint with your local data protection supervisory authority (i.e. your place of habitual residence, place or work or place of alleged infringement), which in the UK is the Information Commissioner's Office at any time. We ask that you please attempt to resolve any issues with us before your local supervisory authority.

POWSTER LTD
www.powster.com
Unit G
Bagel Factory
24 White Post Lane
London, E9 5SZ
United Kingdom
+44 (0)20 8063 2562
hello@powster.com

Issue Date of Privacy Notice: 23/03/2020