What personal information and when and why we use it

Information You Provide

We collect personal information from you if you:

• apply for a job with us
• visit our Site
• purchase one of our Services or require a demo of our Services
• work with us as a business partner or service provider

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

• full name
• email address
• postal address
• phone number
• answers to questions that will contain personal information, such as your proudest achievements, whether you are qualified to work in the UK etc.

We will use this personal information to:

• review your job application
• assess and determine whether we consider that a certain role is suitable for you
• (as applicable) contact you to arrange an interview and any subsequent interviews
• (as applicable) contact you about the progress of your application
• (as applicable) obtain references

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

• your name, email address and your query if you send us a "Hello" email
• your name, email address and contact number if you would like a demo of our Services
• your name email address if you would like to receive our newsletters
• via the cookies we use on our Site. Furthermore, information about our cookie usage, please click here for our Cookie Policy.

POWSTER uses this personal information to:

• personalize your experience of our Site. We may use information in the aggregate to understand how users of our Site, as a group, use the Services and resources provided on our Site
• improve our Site. We may use feedback from you to improve our Services
• send periodic emails and newsletters. For example, we may use your email address to respond to your inquiries, questions, and/or other requests, arrange a demo of our Services or send you newsletters (as applicable)

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

• full name
• job title
• email address
• company name and address
• company telephone
• (as applicable) transaction information

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:

• full name
• job title
• email address
• company address
• company telephone
• transaction information

POWSTER uses this personal information to:

• review/assess your suitability as a business partner or service provider
• provide/use services as required

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

• send you technical notices, updates, security alerts, information regarding changes to our policies, and support and administrative messages
• prevent and address fraud, breach of policies or terms, and threats or harm
• conduct research, including focus groups and surveys
• fulfil any other business or commercial purposes at your direction or with your notice and/or consent.

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:

• Service Use Data, including data about features you use, pages you visit, emails and view, products and services you view and purchase, the time of day you browse, and your referring and exiting pages.
• Device Data, including data about the type of device or browser you use, your device’s operating software, your internet service provider, your device’s regional and language settings, and device identifiers such as IP address.
• Location Data, including imprecise location data (such as location derived from an IP address or data that indicates a city or postal code level)

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:

• Pixels (also known as web beacons), which are code embedded in a website, video, email, or advertisement that sends information about your use to a server. There are various types of pixels, including image pixels (which are small graphic images) and JavaScript pixels (which contains JavaScript code). When you access a website, video, email, or advertisement that contains a pixel, the pixel may permit us or a separate entity to drop or read cookies on your browser. Pixels are used in combination with cookies to track activity by a particular browser on a particular device. We incorporate pixels from separate entities that allow us to provide you with additional functionality, such as the ability to connect our Services with your social media account.
• Device Fingerprinting, which is the process of analyzing and combining sets of data elements from your device’s browser, such as JavaScript objects and installed fonts, to create a “fingerprint” of your device and uniquely identify your browser and device.

Information Collected From Other Sources

We also collect information from other sources, which include:

• Service providers, who collect information from you on our behalf.
• Other companies within our group, for example where we integrate their technology into our Services.
• Cinando, an online network for film professionals.

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:

• placing confidentiality requirements on our staff members and service providers;
• destroying or permanently anonymising personal information if it is no longer needed for the purposes for which it was collected;
• following security procedures in the storage and disclosure of your personal information to prevent unauthorised access to it; and
• using secure communication channels such as SSL ("secure sockets layer") for transmitting data that is sent to us. SSL is an industry standard encryption protocol used to protect online transaction channels.

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:

• with other companies within our group where such disclosure is necessary to provide you with our Services or to manage our business. Click here for a list of our group companies;
• with service providers who help manage our business and deliver services. These service providers have agreed to confidentiality restrictions and use any information we share with them or which they collect on our behalf solely for the purpose of providing the contracted service to us. These include Amazon Web Services, Atlassian, Adobe, Google Cloud Platform, Cloudflare, Ubiquiti, Synology, Apple, Jazz HR, Hired.com, Asana, Github, SalesForce, Slack, Sentry, Strettons, Verisure and banks and payment providers to authorize and complete payments;
• with government organisations and agencies, law enforcement, regulators, to comply with all applicable laws, regulations and rules, and requests of law enforcement, regulatory and other governmental agencies;
• with credit reference agencies and organisations working to prevent fraud in financial services;
• with vendors and other parties for business and commercial purposes, including analytics companies. Vendors may act as our service providers, or in certain contexts, independently decide how to process your information.
• with our customers in connection with us processing information on their behalf. For example, we share information with our customers in order to facilitate your orders, maintain and administer your online accounts, respond to your questions and comments, comply with your requests, and otherwise comply with applicable law.
• for facilitating requests made at your direction;
• with your consent or for any other lawful purpose;
• we may share in aggregate, statistical form, information that does not identify you, regarding the visitors to our Site, traffic patterns, and Site usage with our partners, affiliates or advertisers.

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.

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

• we will take steps to limit direct marketing to a reasonable and proportionate level and only send you communications which we believe may be of interest or relevance to you;
• you can ask us to stop direct marketing at any time - you can ask us to stop sending email marketing, by following the "unsubscribe" link you will find on all the email marketing messages we send you. Alternatively, you can contact us via our Contact Us page. Please specify whether you would like us to stop all forms of marketing or just a particular type (e.g. email); and
• you can change the way your browser manages cookies, which may be used to deliver online advertising, by following the settings on your browser as explained in Our Cookie Policy. 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

• Cookies and Pixels. Most browsers accept cookies by default. Please refer to our Cookie Policy, above, for instruction on disabling cookies.
• Do Not Track. Your browser settings may allow you to automatically transmit a “Do Not Track” signal to online services you visit. Note, however, there is no industry consensus as to what site and app operators should do with regard to these signals. Accordingly, unless and until the law is interpreted to require us to do so, we do not monitor or take action with respect to “Do Not Track” signals. For more information on “Do Not Track,” visit http://www.allaboutdnt.com. Analytics. Google provides tools to allow you to opt out of the use of certain information collected by Google Analytics found here and by Google Analytics for Display Advertising or the Google Display Network here.

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:

• we ensure transfers within our group of companies will be covered by an agreement entered into by members of our group of companies (an intra-group agreement) which contractually obliges each member to ensure that personal information receives an adequate and consistent level of protection wherever it is transferred within our group of companies;
• where we transfer your personal information outside our group of companies or to third parties who help provide our Services, we obtain contractual commitments from them to protect your personal information. Some of these assurances are well recognized certification schemes like the EU - US Privacy Shield for the protection of personal information transferred from within the EU to the United States; or
• where we receive requests for information from law enforcement or regulators, we carefully validate these requests before any personal information are disclosed.

You have a right to Contact Us for more information about the safeguards we have put in place (including a copy of relevant contractual commitments) to ensure the adequate protection of your personal information when this is transferred as mentioned above.

Your Legal Rights and Choices

Legal basis for using your information

European data protection laws require a “lawful basis” for processing personal data. We will only collect, use and share your information where we are satisfied that we have an appropriate legal basis to do so, including:

• we need to use your information to perform a contract or take steps to enter into a contract with you. For example, to take payment for the Service you ordered, and to provide you with, and to inform you of any technical issues concerning, the Service you ordered;
• we need to use your information for our legitimate interest as a commercial organisation. For example, for good governance, accounting, and managing and auditing our business operations. In all such cases, we will look after your information at all times in a way that is proportionate and respects your privacy rights and you have a right to object to processing as explained in Your Legal Rights and Choices;
• we need to use your information to comply with a relevant legal or regulatory obligation that we have. For example, for activities relating to the prevention, detection and investigation of crime and for compliance with legal and regulatory requirements and related disclosures;
• we have your consent to using your information for a particular activity. For example, where relevant, to send certain direct marketing to you.

If you would like to find out more about the legal basis for which we process information, please Contact Us.

Subject to certain exemptions, and in some cases dependent upon the processing activity we are undertaking, you have certain rights in relation to your information.

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):

• To access personal information
• To rectify / erase personal information
• To restrict the processing of your personal information
• To transfer your personal information
• To object to the processing of personal information
• To object to how we use your personal information for direct marketing purposes
• To obtain a copy of personal information safeguards used for transfers outside your jurisdiction
• To lodge a complaint with your local supervisory authority

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:

• it is no longer needed for the purposes for which it was collected; or
• you have withdrawn your consent (where the data processing was based on consent); or
• following a successful right to object (see Right to object); or
• it has been processed unlawfully; or
• to comply with a legal obligation to which POWSTER is subject.

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

• for compliance with a legal obligation; or
• for the establishment, exercise or defence of legal claims.

Right to restrict the processing of your personal information

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

• its accuracy is contested, to allow us to verify its accuracy; or
• the processing is unlawful, but you do not want it erased; or
• it is no longer needed for the purposes for which it was collected, but we still need it to establish, exercise or defend legal claims; or
• you have exercised the right to object, and verification of overriding grounds is pending.

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

• we have your consent; or
• to establish, exercise or defend legal claims; or
• to protect the rights of another natural or legal person.

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:

• the processing is based on your consent or on the performance of a contract with you; and
• the processing is carried out by automated means.

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

• You can request that we change the manner in which we contact you for marketing purposes.
• You can request that we not transfer your personal information to unaffiliated third parties for the purposes of direct marketing or any other 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

• You have a right to lodge a complaint with your local supervisory authority if you have concerns about how we are processing your personal information.
• We ask that you please attempt to resolve any issues with us first, although you have a right to contact your supervisory authority at any time.

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:

• Identifiers, including name, email address, phone number account name, IP address, and an ID or number assigned to your account.
• Customer records, billing and shipping address, and credit or debit card information.
• Commercial information, including purchases and engagement with the Services.
• Internet activity, including your interactions with our Services.
• Employment and education data, including information you provide when you apply for a job with us.
• Inferences, including information about your interests, preferences and favorites.

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.