CONTENTS

1.     Information about Darogan and our Privacy Policy                              

2.     What data do we collect?                                                                                                                      

3.     How do we collect your data?                                                                                                    

4.     How will we use your data?                                                                                                        

5.     How do we share your personal data?                                                                         

6.     Transferring personal data outside the EEA                                                                                         

7.     Data security                                                                                                                                                      

8.     Data retention                                                                                                                                                    

9.     Your legal rights                                                                                                                                    

10.   Glossary                                                                                                                                                                          

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Welcome to the Privacy Policy for Darogan Ltd.  

We are committed to protecting your personal information and your right to privacy. If you have any questions or concerns about our policy, or our practices with regards to your personal information, please contact us immediately.

This privacy policy will inform you as to how we look after your personal data when you visit our website (regardless of where you visit it from) and tell you about your privacy rights and how the law protects you.

Please read this privacy policy carefully as it will help you make informed decisions about sharing your personal information with us.  

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Please also use the Glossary to understand the meaning of some of the terms used.

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1. Information about Darogan and our Privacy Policy

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Purpose of this privacy policy

This privacy policy aims to give you information on how Darogan Ltd collects and processes your  personal data  through  your use  of  this website,  including  any data  you  may provide  through  this website when you register as a member, provide information for your profile, request to receive information from us or register to attend any of our events.

It is  important  that you  read  this privacy  policy  together with  any  other  policy or policies we may provide on specific occasions when we are collecting or processing personal data about you, so that you are  fully aware of how and  why we  are using  your data. This privacy policy supplements the other policies and is not intended to override them.

Controller

Darogan Ltd (as referred to above) is the controller and responsible for your personal data (collectively referred to as "we", "us" or "our" in this privacy policy).

We have appointed a data privacy manager who is responsible for overseeing questions in relation to this privacy policy. If you have any questions about this policy, including any requests to exercise your legal rights, please contact the data privacy manager using the details set out below.

Contact details

Full name of legal entity:  Darogan Ltd

Name or title of Data Privacy Manager: Owain James – Co-founder of Darogan Ltd

Email Address: owain.james@darogantalent.cymru

Postal address: Darogan Ltd, Ty Cefn, Rectory Road, Cardiff, United Kingdom, CF5 1QL

You have the right to make a complaint at any time to the Information Commissioner's Office (ICO), the UK supervisory authority for data protection issues (www.ico.org.uk). We would, however, always appreciate the opportunity to deal with your concerns before you approach the ICO, so please, where possible, do contact us in the first instance where we will do our best to resolve any matter.

Changes to the privacy policy and your duty to inform us of changes

It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during your relationship with us.

Third-party links

This website may include links to third-party websites, plug-ins and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites and are not responsible for their privacy statements.  When you leave our website, we encourage you to read the privacy policy of every website you visit.

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2. What data do we collect?  

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Personal data, or personal information, means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymous data).

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We may collect, use, store and transfer different kinds of personal data about you which we have grouped together follows:

• ‍Identity Data  includes  first name,  maiden  name, last  name,  username or  similar  identifier, marital status, title, date of birth and gender, job title, university attended, your personal description and your photograph or image on film footage taken at our events.‍
• Contact Data includes email address and telephone numbers.‍
• Technical Data includes internet protocol (IP) address, your login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform and other technology on the devices you use to access this website ‍
• Profile Data  includes  your username  and  password for your membership  of the  network,  your interests, preferences, feedback and survey responses.‍
• Usage Data includes information about how you use our website and services.‍
• Marketing and Communications Data includes your preferences in receiving marketing from us and our third parties and your communication preferences.

We also collect,  use  and share Aggregated  Data  such as statistical or demographic  data for any  purpose. Aggregated Data may be derived from your personal data but is not considered personal data in law as this data does not directly or indirectly reveal your identity. For example, we may aggregate your Usage Data to calculate the percentage of users accessing a specific website feature. However, if we combine or connect Aggregated Data with  your  personal data  so  that it  can  directly or  indirectly  identify you,  we  treat the combined data as personal data, which will be used in accordance with this privacy policy.

We do not collect any Special Categories of Personal Data about you (this includes details about your race or  ethnicity,  religious or  philosophical beliefs, sex  life,  sexual orientation,  political  opinions, trade  union membership,  information about  your  health and  genetic  and biometric  data). Nor do  we collect  any information about criminal convictions and offences.

If you fail to provide personal data

Where we need to collect personal data by law, or under the terms of a contract we have with you and you fail to provide that data when requested, we may not be able to perform the contract we have or are trying to enter into with you (for example, to provide you with goods or services). In this case, we may have to cancel a service you have with us but we will notify you if this is the case at the time.

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3. How do we collect your data?

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We use different methods to collect data from and about you including through:

- Direct interactions. You may give us your Identity and Contact by filling in forms or by corresponding with us by post, phone, email or otherwise. This includes personal data you provide when you:

• ‍create an account on our website to become a member;
• contact us to attend one of our events;
• request marketing to be sent to you;
• enter a competition, promotion or survey; or
• provide feedback.

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PLEASE  NOTE  that  where this  data  is provided  to  us by  someone  on your  behalf,  such as a university peer, partner or parent, we shall assume that they do so with the necessary authority from you and we shall therefore continue to collect and process your data in accordance with this privacy policy until you contact us and expressly tell us otherwise.

- Automated   technologies  or   interactions.   As   you  interact   with   our  website,   we   may automatically collect Technical Data about your equipment, browsing actions and patterns. We collect this personal data by using cookies, server logs and other similar technologies. Please see our cookie policy for further details.

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- Third parties. We may receive Technical Data from analytics providers such as Google based outside the EU.

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4. How do we use your personal data

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To be as clear as possible, we have set out a description of all the ways we plan to use your personal data in the table below, and which of the legal bases we rely on to do so. We have also identified what our legitimate interests are where appropriate.

Note that we may process your personal data for more than one lawful ground depending on the specific purpose for which we are using your data. Please contact us if you need details about the specific legal ground we are relying on to process your personal data where more than one ground has been set out in the table below.

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Marketing

We strive to provide you with choices regarding certain personal data uses, particularly around marketing and advertising.

Promotional offers from us

We may use your Identity, Contact, Technical, Usage and Profile Data to form a view on what we think you may want or need, or what may be of interest to you. This is how we decide which services and offers maybe relevant to you, including those offered by our partners (we call this marketing).

You will receive marketing communications from us when you become a member or have attended one of our events and you have not opted out of receiving that marketing.  

Third-party marketing

We will get your express opt-in consent before we share your personal data with any third party for marketing purposes.

Opting out

You can ask us to stop sending you marketing messages by contacting us at any time.

Where you opt out of receiving these marketing messages, this will not apply to personal data provided to us as a result of becoming a member, subscribing to further information or other activity.

Cookies

You can set your browser to refuse all or some browser cookies, or to alert you when websites set or access cookies. If  you  disable or  refuse  cookies, please  note  that some  parts  of this  website  may become inaccessible   or  not  function   properly.  For more  information about   the   cookies  we   use,  please read through our Cookies Policy.  

Change of purpose

We  will  only use  your  personal data  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 you wish to get an explanation as to how the processing for the new purpose is compatible with the original purpose, please contact us.

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

Please note that we may process your personal data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.

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5. How do we share your personal data?

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Profile

When you create a profile, all information and content you provide in your profile (including your email address) are fully visible to all of our registered members.

Third parties

We may have to share your personal data with the third parties set out below for the purposes set out in the table above:

• Service providers acting as processors based in the United Kingdom who provide IT and system administration services.

• Professional advisers acting as processors or joint controllers including lawyers, bankers, auditors and insurers who provide consultancy, banking, legal, insurance and accounting services.

• HM Revenue & Customs, regulators and other authorities acting as processors or joint controllers based in the United Kingdom who require reporting of processing activities in certain circumstances.
• Social media platforms that we use in order to market the platform and our events, such as YouTube, Facebook and Twitter.
• Service providers acting as processors who provide services in connection with our networking  events such as restaurants, hotels, conference centres, caterers, photographers and videographers.
• Mailchimp  who are  based  outside of  the  EEA who  we  use  to  provide marketing  support  services (https://mailchimp.com).
• Our partner organisations and other recruiters in connection with a service we are providing you or where you have asked us to refer you.
• Third  parties to whom  we  may choose  to  sell, transfer,  or merge  parts of our business  or our assets. Alternatively, we may seek to acquire other businesses or merge with them. If a change happens to our business, then the new owners may use your personal data in the same way as set out in this privacy policy.

We require all third parties to respect the security of your personal data and to treat it in accordance with the law. We do not allow our third-party service providers to use your personal data for their own purposes and  only  permit them  to  process your  personal  data for  specified  purposes and  in  accordance with  our instructions.

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6. Transferring personal data outside the EEA

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Many of our third party service providers are based outside the European Economic Area (EEA) so their processing of your personal data will involve a transfer of data outside the EEA. Please note that some countries outside the EEA may not have similar safeguards in place regarding protection and use of your data as those inside the EEA.

Whenever we  transfer  your personal  data  out  of  the EEA,  we  ensure a  similar  degree of  protection  is afforded to it by ensuring at least one of the following safeguards is implemented:

•   Where  we use  certain  service providers,  we  may use  specific  contracts approved  by  the European Commission which give personal data the same protection it has in Europe.

•  Where we use providers based in the US, we may transfer data to them if they are part of the Privacy Shield which requires them to provide similar protection to personal data shared between Europe and the US.

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7. Data Security

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We have put in place appropriate security measures to prevent your personal data from being accidentally lost,  used or  accessed  in an  unauthorised  way, altered  or  disclosed. In addition, we limit access to  your personal data to those employees, agents, contractors and other third parties who have a business need to know.  They  will only  process  your personal  data  on our  instructions  and they  are  subject to  a  duty of confidentiality.

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We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.

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8. Data Retention

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We  will  only  retain your  personal  data for  as  long as  necessary  to fulfil  the  purposes we  collected  it for, including for the purposes of satisfying any legal, accounting, or reporting requirements.

To determine  the  appropriate retention  period  for personal  data,  we consider  the  amount, nature,  and sensitivity  of  the  personal data,  the  potential risk  of  harm from  unauthorised  use or  disclosure  of your personal data, the  purposes  for which we  process your personal data and whether we  can achieve those purposes through other means, and the applicable legal requirements.

By law we have to keep basic information about our customers (including Contact, Identity Data) for six years after you cease being our customer for tax purposes.

In some circumstances  you  can ask  us  to delete  your  data: see   Request  erasure below  for  further information.

In other circumstances we may anonymise your personal data (so that it can no longer be associated with you)  for research  or statistical purposes  in  which case  we  may use  this  information indefinitely  without further policy to you.

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9. Your legal rights

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Under certain circumstances, you have rights under data protection laws in relation to your personal data.

You have the right to:

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

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• Request correction of the personal data that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.

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•  Request erasure of your personal data. This enables you to ask us to delete or remove personal data where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your  personal  data where  you  have successfully  exercised  your right  to  object to  processing  (see below), where we may have processed your information unlawfully or where we are required to erase your personal data to comply with local law. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.‍

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• Object to processing of your personal data where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms. You also have the right to object where we are processing your personal data for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms.

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•  Request restriction of processing of your personal data.  This  enables you  to  ask us  to  suspend the processing  of  your personal  data  in the  following  scenarios: (a)  if  you want  us  to establish  the  data's accuracy; (b) where our use of the data is unlawful but you do not want us to erase it; (c) where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims; or (d) you have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.

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•  Request the transfer of your personal data to you or to a third party. We will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.‍

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• Withdraw consent at any time where we are relying on consent to process your personal data. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain products or services to you. We will advise you if this is the case at the time you withdraw your consent.

If you wish to exercise any of the rights set out above, please contact us.

No fee usually required

You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we may refuse to comply with your request in these 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  your  personal data  (or  to exercise  any  of your  other  rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.

Time limit to respond

We try to respond to all legitimate requests within one month. Occasionally it may take us longer than a month if your request is particularly complex, or you have made a number of requests. In this case, we will notify you and keep you updated.

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10. Glossary

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LAWFUL BASIS

Legitimate Interest means the interest of our business in conducting and managing our business to enable us to give you the best service / product and the best and most secure experience. We make sure we consider and balance any potential impact on you(both positive and negative) and your rights before we process your personal data for our legitimate interests.  We do  not use  your  personal data  for  activities where our interests are overridden by the impact on you (unless we have your consent or are otherwise required or permitted to by law).  You can  obtain  further information  about  how we  assess  our legitimate  interests against any potential impact on you in respect of specific activities by contacting us

Performance of  Contract  means  processing your  data  where it  is  necessary for  the  performance of  a contract to which you are a party or to take steps at your request before entering into such a contract.

Comply with a legal or regulatory obligation means processing your personal data where it is necessary for compliance with a legal or regulatory obligation that we are subject to.

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