PRIVACY NOTICE – COOKIES AND ATS 

(APPLICANT TRACKING SYSTEM)

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Wavex Technology understands that your privacy is important to you and that you care about how your personal data is used. We respect and value the privacy of everyone who visits this website, www.wavex.co.uk (“Our Site”) and will only collect and use personal data in ways that are described here, and in a way that is consistent with our obligations and your rights under the law.

 
Please read this Privacy Notice carefully and ensure that you understand it. Your acceptance of this Privacy Notice is deemed to occur upon your first use of Our Site. If you do not accept and agree with this Privacy Notice, you must stop using Our Site immediately.

1. Cookies
1.1. Definitions and Interpretation
In this Policy the following terms shall have the following meanings:

“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 My Site are set out in Part 14, below; and

“Cookie Law” means the relevant parts of the Privacy and Electronic Communications (EC Directive) Regulations 2003;

1.2. Information About Us
Our Site is owned and operated by Wavex Technology Limited, a limited company registered in England and Wales under company number 4258498.

Registered address: 66 Prescot Street, London, E1 8HG

VAT number: GB 123 3592 33

Data Protection Officer: Andrea Haywood


Postal Address: as registered address

1.3. What Does This Policy Cover?
This Privacy Policy applies only to your use of Our Site. Our Site may contain links to other websites. Please note that we have no control over how your data is collected, stored, or used by other websites and we advise you to check the privacy policies of any such websites before providing any data to them.

1.4. What is Personal Data?
Personal data is defined by the General Data Protection Regulation (EU Regulation 2016/679) (the “GDPR”) as ‘any information relating to an identifiable person who can be directly or indirectly identified in particular by reference to an identifier’.

Personal data is, in simpler terms, any information about you that enables you to be identified. Personal data covers obvious information such as your name and contact details, but it also covers less obvious information such as identification numbers, electronic location data, and other online identifiers.

1.5. What Are My Rights?
Under the GDPR, you have the following rights, which we will always work to uphold:

a) The right to be informed about our collection and use of your personal data. This Privacy Policy should tell you everything you need to know, but you can always contact us to find out more or to ask any questions using the details in Part 15.

b) The right to access the personal data we hold about you. Part 13 will tell you how to do this.

c) The right to have your personal data rectified if any of your personal data held by us is inaccurate or incomplete. Please contact us using the details in Part 15 to find out more.

d) The right to be forgotten, i.e. the right to ask us to delete or otherwise dispose of any of your personal data that we have. Please contact us using the details in Part 15 to find out more.

e) The right to restrict (i.e. prevent) the processing of your personal data.

f) The right to object to us using your personal data for a particular purpose or purposes.

g) The right to data portability. This means that, if you have provided personal data to us directly, we am using it with your consent or for the performance of a contract, and that data is processed using automated means, you can ask us for a copy of that personal data to re-use with another service or business in many cases.

h) Rights relating to automated decision-making and profiling. We do not use your personal data in this way.

For more information about our use of your personal data or exercising your rights as outlined above, please contact us using the details provided in Part 15.

Further information about your rights can also be obtained from the Information Commissioner’s Office or your local Citizens Advice Bureau.

If you have any cause for complaint about our use of your personal data, you have the right to lodge a complaint with the Information Commissioner’s Office.

1.6. What Data Do We Collect?
Depending upon your use of Our Site, we may collect some or all of the following personal and non-personal data

IP address;
Web browser type and version; 
Operating system; 
A list of URLs starting with a referring site, and your activity on Our Site. 

1.7. How Do You Use My Personal Data?
Under the GDPR, we must always have a lawful basis for using personal data. This may be because the data is necessary for our performance of a contract with you, because you have consented to our use of your personal data, or because it is in our legitimate business interests to use it. Your personal data may be used for the following purposes:

Analysing your use of Our Site to enable us to continually improve Our Site and your user experience.

Third Parties (including Microsoft) may use third-party Cookies, as detailed below in Part 14. Please refer to Part 14 for more information on controlling cookies. Please note that we do not control the activities of such third parties, nor the data that they collect and use themselves, and we advise you to check the privacy policies of any such third parties.

1.8. How Long Will You Keep My Personal Data? 
Out Site/Wavex does not keep personal data. Third Parties will retain your personal data in line with their individual privacy policies.

1.9. How and Where Do You Store or Transfer My Personal Data?
We do not store your personal data.

1.10. Do You Share My Personal Data?
We will not share any of your personal data with any third parties for any purposes, subject to one important exception.
In some limited circumstances, we may be legally required to share certain personal data, which might include yours, if we are involved in legal proceedings or complying with legal obligations, a court order, or the instructions of a government authority.

1.11. How Can I Control My Personal Data?
In addition to your rights under the GDPR, set out in Part 5, when you submit personal data via Our Site, you may be given options to restrict our use of your personal data. In particular, we aim to give you strong controls on our use of your data for direct marketing purposes (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).

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.

1.12. Can I Withhold Information?
You may access certain areas of Our Site without providing any personal 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.

You may restrict our use of Cookies. For more information, see Part 14.

1.13. How Can I Access My Personal Data?
If you want to know what personal data we have about you, you can ask us for details of that personal data and for a copy of it (where any such personal data is held). This is known as a “subject access request”.

All subject access requests should be made in writing and sent to the email or postal addresses shown in Part 15.

There is not normally any charge for a subject access request. If your request is ‘manifestly unfounded or excessive’ (for example, if you make repetitive requests) a fee may be charged to cover our administrative costs in responding.

We will respond to your subject access request within one month of receiving it. Normally, we aim to provide a complete response, including a copy of your personal data within that time. In some cases, however, particularly if your request is more complex, more time may be required up to a maximum of three months from the date we receive your request. You will be kept fully informed of our progress.

1.14. How Do You Use Cookies?
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 the table below. These Cookies are not integral to the functioning of Our Site and your use and experience of Our Site will not be impaired by refusing consent to them.
All Cookies used by and on Our Site are used in accordance with current Cookie Law.

Before Cookies are placed on your computer or device, you will be shown a pop-up 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;

The following third-party Cookies may be placed on your computer or device:
Name of Cookie Provider
Tawk
First / Third Party
Third Party
Purpose
To enable the online chat feature on Our Site
Our Site uses analytics services provided by Google, Linkedin and Lead Forensics. Website analytics refers to a set of tools used to collect and analyse anonymous usage information, enabling us to better understand how Our Site is used. This, in turn, enables us to improve Our Site and the products and services offered through it.

The analytics services used by Our Site use Cookies to gather the required information. You do not have to allow us to use these Cookies, however whilst our use of them does not pose any risk to your privacy or your safe use of Our Site, it does enable us to continually improve Our Site, making it a better and more useful experience for you.

The analytics service(s) used by Our Site use(s) the following Cookies:
Name of Cookie Provider
First / Third Party
Purpose
Google Analytics
Third Party
Website analytics
Google AdWords
Third Party
Advertising services
Lead Forensics
Third Party
Website analytics
LinkedIn Demographics
Third Party
Website analytics
In addition to the controls that we provide, 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.

You can choose to delete Cookies on your computer or device 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.

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.

1.15. How Do I Contact You?
To contact us about anything to do with your personal data and data protection, including to make a subject access request, please use the following details:


1.16. Changes to this Privacy Policy
We may change this Privacy Notice from time to time. This may be necessary, for example, if the law changes, or if we change our business in a way that affects personal data protection.

Any changes will be immediately posted on Our Site and you will be deemed to have accepted the terms of the Privacy Policy on your first use of Our Site following the alterations. We recommend that you check this page regularly to keep up-to-date.

2. ATS
Wavex Technology understands that your privacy is important to you. We respect and value the privacy of everyone who applies for our vacancies, either directly via the https://www.wavex.co.uk/careers/ page (“Our Site”) or Job Portals.
This part of the notice explains how your personal data is used at Wavex with respect to your registering an application for a job vacancy.

2.1. Principles
We will only collect and use personal data in ways that are described here and in a manner that is consistent with Wavex obligations, and your rights under the law.

Please read this Privacy Notice carefully and ensure that you understand it. You must accept this notice before continuing to use Our Site.

2.2. Definitions and Interpretation
In this Notice, the following terms shall have the following meanings:   
Job Portals
means other job advertising websites (i.e. LinkedIn, Indeed) that Wavex uses to post open vacancies, from which you will always be requested to follow a link to Wavex ATS system, to complete your application. These portals have their own privacy policies. Please check these policies before you decide to submit any Personal Data. 
ATS
means Application Tracking System, which is a third party cloud-based solution, provided by PeopleHR as a sub processor of Wavex. Wavex uses this platform to manage all applications for vacancies, by accepting this privacy notice you are agreeing to your data being stored on PeopleHR. PeopleHR delivers stringent privacy and security protections that are built into the platform. Please check these policies before you decide to submit any Personal Data.
Personal Data
means any and all data that relates to an identifiable person who can be directly or indirectly identified from that data. In this case, it means personal data that you give to Wavex via Our Site. This definition shall, where applicable, incorporate the definitions provided in the Data Protection Act 1998 and/or EU Regulation 2016/679 – the General Data Protection Regulation (GDPR) from 25 May 2018
2.3. What Does This Policy Cover?
This Privacy Notice applies only to your use of Our Site. Our Site may contain links to other pages on Wavex website and/or Wavex ATS.

2.4. What information do we hold about you?
When you apply for a vacancy with Wavex, to support your application we will ask for specific information:

Personal contact details such as name, title, address, telephone numbers and personal email

Employment records
o Salary remuneration, bonus and benefits history
o Work history, including job titles, professional memberships

Evidence of rights to work in the UK

Reference and other information in a CV and/or cover letter or as part of the application process

We may also collect, store and use the following "special categories" of more sensitive personal information, especially if the job you are applying for requires additional security checks: 

Information about criminal convictions and offences

Information about your race or ethnicity, religious beliefs, sexual orientation and political opinions

Information about your health, including any medical condition, health and sickness records

2.5. How we store information about you
All information you provide to Wavex is stored on Wavex servers and ATS system.

The data that we collect about you will not be transferred outside the European Economic Area (“EEA”). Email communication between you and Wavex via the ATS platform is performed by an application called MailGun. MailGun are based in the USA and participates and has certified its compliance with the EU-U.S. Privacy Shield Framework in order to ensure any transfers of personal data to the USA are adequate. For more information about how Mailgun do this please read the following https://www.mailgun.com/privacy-policy.

By submitting Personal Data, you agree to storing or processing your data by Wavex. We will take all reasonable organisational and technical steps necessary to ensure that the information you supply to Wavex is treated securely and in accordance with this privacy policy.

2.6. How long we retain your information
We retain your information in line with our data retention policy

o Unsuccessful applicants – 12 months from the date of application
o Successful applicants – data will be transferred to your staff file

2.7. How we use your information
We will only use your personal information when the law allows Wavex to. Most commonly, we will use your Personal Data in the following circumstances:

Where we need to process your application

Undertake pre-employment checks

To maintain the Wavex recruitment talent pool (we will always ask you for consent to retain your information)

Use and manage the employee data during employment with Wavex (should you be hired by Wavex, at that point our staff privacy policy will apply)

Where we need to comply with a legal obligation

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

We may also use your Personal Data in the following situations:

where we need to protect your interests (or someone else's interests)

where it is needed in the public interest or for official purposes

When processing your Personal Data we will aim to do so fairly, lawfully and in line with the current Data Protection Act 1998 (and the GDPR regulations from 25 May 2018).

2.8. Your rights
As a Data Subject under the Data Protection Legislation you have the following rights:

If you submit an enquiry form on Wavex careers page, you give your consent to Wavex contacting you for recruitment purposes. You can exercise your right to prevent Wavex from further contacting you at any time by emailing Wavex at humanresources@wavex.co.uk

You have the right to ask Wavex to give you a copy to you the information we hold, this is known as a data subject access request. For further details please contact Wavex at humanresources@wavex.co.uk

You have the right to ask Wavex to rectify the data we hold in the event that it contains inaccuracies or is incomplete. To discuss this please contact us at humanresources@wavex.co.uk

You have the right to ask us to erase the Personal Data we hold if:
o it is no longer necessary for Wavex to hold the data
o you wish to withdraw your consent to Wavex holding the data
o you object to Wavex holding or processing the data
o you believe that we have processed the data unlawfully
o the data needs to be erased for Wavex to comply with a particular legal obligation

To make a request please contact Wavex at humanresources@wavex.co.uk

If you have any queries about this notice, please email humanresources@wavex.co.uk

This Policy has been approved and authorised by:
Name:
Gavin Russell
Position:
CEO
Date:
24 May 2018
Due for Review by:
24 May 2019