PP Recruitment Holdings Ltd
Global Privacy Policy
- SCOPE OF THIS PRIVACY POLICY
- The privacy of your personal data is extremely important to us and this privacy policy sets out important information about how PP Recruitment Holdings Ltd and its affiliates (“Levin“, “Levin Group“, “we” or “us“) collects, handles and uses your personal data; personal data is any information from which you can be identified. PP Recruitment Holdings Ltd (UK)’s affiliate is Levin Group Inc. (USA). We’re committed to protecting the privacy and security of your personal data.
- In this privacy policy, “processing” means the collection, recording, storage, use, disclosure and generally any other uses, form of operations or dealings with your personal data.
- ABOUT US
- Levin is a specialist recruitment company in the technology sector and is comprised of four tech recruitment brands operating under the trading names of Storm2, Storm3, Storm4, and Storm6. All brands are specialist recruitment companies in the respective sectors: financial, health, green and education technology and shall each or collectively be referred to throughout this Privacy Policy as “Levin“, “Levin Group“, “we” or “us“.
- In order for us to operate as a recruitment consultancy, Levin must process personal data and when doing so, the relevant Levin Group entity communicating with you; providing you with services or with which you have a contract or engage with will be a “controller” of your personal data; this means we are responsible for the processing of your personal data. We are committed to protecting your privacy and processing your personal data fairly and lawfully in compliance with all data protection laws, including in the United Kingdom the UK GDPR and the Data Protection Act 2018, and in the USA the California Consumer Privacy Act (CCPA) OF 2018 (“Data Protection Laws“).
- WHOSE PERSONAL DATA DO WE USE?
- The personal data that we collect, use and process and the purposes for doing so will depend on your relationship with us. We obtain and process personal data relating to: (i) candidates who we provide recruitment and/or related career intermediary services to (ii) clients; and (iii) individuals applying to work at Levin.
- Please click on the relevant heading below (which correlates to your relationship with Levin) to learn more about how we use your personal data.
- Candidates who we provide recruitment and/or related career intermediary services to
This section will apply to those candidates who we provide recruitment and/or related intermediary services to.
- What personal data do we collect and use?
- general information such as your name and contact details including phone number and email address;
- professional details such as your job title, information about your job role, industry, current employer and employment history;
- your CV or cover letter and information contained in applications;
- any other information which you have shared with us through general correspondence such as emails or messages on LinkedIn;
- marketing preferences; and
- information obtained through our use of cookies such as IP address data; [please see our cookie notice on our website for more information].
The communication system we use for our external telephone calls and SMS messages can record video and audio calls and produce artificial intelligence (AI) generated summaries that will capture highlights and action items from calls so that we can remain focused throughout, without the need for manual notetaking. We will only use these features with your permission, and you will be notified before the summary transcript function is enabled or the call is recorded so you can decide whether you wish to proceed. RingCentral’s Trust Center states it does not use customer data to train either its AI models or their third-party vendor AI models.
We do not collect any of your special category data; this is any information relating to your health or medical records, criminal records or convictions, sexual orientation, racial or ethnic origin, political or philosophical opinions or affiliations, religious or philosophical beliefs or affiliations or trade union membership or genetic or biometric data.
- How do we obtain your personal data?
We obtain your personal data in a number of different ways:
- directly from you; such as via our website where you submit an application or sign up for marketing emails or during any form of communication such as face to face, written and phone correspondence or correspondence on LinkedIn;
- through search platforms;
- from third parties who we use to find your most recent contact details;
- through friend referrals;
- from our corporate clients; or
- via our website, collected via cookies.
- For what purpose do we use your personal data and with whom is it shared?
We only process personal data for the purposes described in this Notice. Data Protection Laws require companies to have a “lawful basis” to collect and use personal data. For Levin these will be:
- it is necessary for legitimate business interests pursued by us or a third party and your interests and fundamental rights do not override those interests. In each case we will always consider your interests and undertake a balancing exercise to ensure that our business interest does not cause you harm or override your own interest.
- in limited circumstances, where you have given consent.
We will process your personal data for the following purposes and in reliance of the listed lawful bases:
| Purpose for processing your personal data | Lawful basis |
| To provide recruitment and/or career intermediary services. This shall include:
· assessing your qualifications against relevant vacancies that we feel may be appropriate for you; · speaking to corporate clients who have vacancies for jobs in which you are interested; and · referring you to corporate clients.
|
· Legitimate interests (to provide our services as a recruitment consultant) |
| Applying for jobs on your behalf.
|
· We have your consent |
| For general correspondence purposes | · Legitimate interests (to provide our services as a recruitment consultant and keep you updated about prospective jobs)
|
| To create testimonials of our services | · We have your consent
|
| For marketing purposes
Electronic Marketing |
· We have your consent
· Legitimate interests (to send you information and industry developments you have requested)
· Where we send unsolicited electronic marketing to you, we may also require either an opt-in consent or opt-out consent under the Privacy and Electronic Communications Regulations 2003 (PECR). That means we are permitted to market products or services to you which are related to the recruitment services we provide to you as long as you do not actively opt-out from these communications.
|
| General business management, record keeping, operations and planning, including accounting and auditing. | · Legitimate interests (business administration and operations) |
When we share your personal data, we do so in accordance with Data Protection Laws and our internal security standards. Below are the parties with whom we may share personal data and why:
- Within the Levin group: We may share your personal data with other companies within the Levin group based in the USA where we have satellite offices.
Your personal data may be shared within our trading divisions and satellite offices as part of our day-to-day business activities and regular reporting activities on company performance.
- With our corporate clients: We will share your personal data with our corporate clients for whom we are recruiting, and we need to share your personal data with to put you forward for a job.
- Our third-party service providers: We will share personal data with third party service providers such as providers/vendors and agents (including their subcontractors) such as IT suppliers, document management providers, software providers and information security providers.
No mobile information will be shared with third parties/affiliates for marketing/promotional purposes. All other use cases exclude text messaging originator opt-in data and consent; this information will not be shared with any third parties.
- Clients
This section will apply to individuals with whom we liaise at a corporate client.
- What personal data do we collect and use?
- general information such as your name and contact details including phone number and email address;
- professional details such as your job title and information about your job role and
- information obtained through our use of cookies such as IP address data; [please see our cookie notice on our website for more information].
The communication system we use for our external telephone calls and SMS messages can record video and audio calls and produce artificial intelligence (AI) generated summaries that will capture highlights and action items from calls so that we can remain focused throughout, without the need for manual notetaking. We will only use these features with your permission, and you will be notified before the summary transcript function is enabled or the call is recorded so you can decide whether you wish to proceed. RingCentral’s Trust Center states it does not use customer data to train either its AI models or their third-party vendor AI models.
We do not collect any of your special category data; this is any information relating to your health or medical records, criminal records or convictions, sexual orientation, racial or ethnic origin, political or philosophical opinions or affiliations, religious or philosophical beliefs or affiliations or trade union membership or genetic or biometric data.
- How do we obtain your personal data?
We obtain your personal data in a number of different ways:
- directly from you; such as via our website where you submit an application or sign up for marketing emails or during any form of communication such as face to face, written and phone correspondence or correspondence on LinkedIn;
- through search platforms;
- from third parties who we use to find your most recent contact details;
- from our corporate clients or
- via our website, collected via cookies.
For what purpose do we use your personal data and with whom is it shared?
We only process personal data for the purposes described in this Notice. Data Protection Laws require companies to have a “lawful basis” to collect and use personal data. For Levin this will be:
- it is necessary for legitimate business interests pursued by us or a third party and your interests and fundamental rights do not override those interests. In each case we will always consider your interests and undertake a balancing exercise to ensure that our business interest does not cause you harm or override your own interest.
We will process your personal data for the following purposes and in reliance of the listed lawful bases:
| Purpose for processing your personal data | Lawful basis |
| To liaise with you about placement of a candidate/referral of a candidate for a role in your organisation
|
· Legitimate interests (to provide our services as a recruitment consultant) |
| For general correspondence purposes and to create relationships | · Legitimate interests (to provide our services as a recruitment consultant and keep you updated about prospective candidates)
|
| For marketing purposes | · Legitimate interests (to send you information about our recruitment consultancy services)
|
| To create testimonials of our services | · We have your consent
|
- Who do we share your personal data with
When we share your personal data, we do so in accordance with Data Protection Laws and our internal security standards. Below are the parties with whom we may share personal data and why:
- Within the Levin group: We may share your personal data with other companies within the Levin group based in the USA where we have satellite offices.
Your personal data may be shared within our trading divisions and satellite offices as part of our day to day business activities and regular reporting activities on company performance.
- With prospective candidates applying for a job at your organisation.
- Our third-party service providers: We will share personal data with third party service providers such as providers/vendors and agents (including their subcontractors) such as IT suppliers, document management providers, software providers and information security providers.
No mobile information will be shared with third parties/affiliates for marketing/promotional purposes. All other use cases exclude text messaging originator opt-in data and consent; this information will not be shared with any third parties.
- Individuals applying to work at Levin
This section will apply to individuals when they are applying to work at Levin. If you become an employee, you will be provided with a separate employee privacy notice which outlines how we collect and use your personal data during and after your working relationship with us.
- What personal data do we collect and use?
- personal details such as your name, address, date of birth, country of residence and contact details including phone number and email address;
- identity documents such as copies of passports (this information is only collected when we offer you a job);
- information relevant to the recruitment process such as your job title, information about your job role, your CV or cover letter and any other information which you have shared with us as part of the recruitment process and any notes taken from an interview with you; and
- information obtained through our use of cookies such as IP address data; [please see our cookie notice on our website for more information]
The communication system we use for our external telephone calls and SMS messages can record video and audio calls and produce artificial intelligence (AI) generated summaries that will capture highlights and action items from calls so that we can remain focused throughout, without the need for manual notetaking. We will only use these features with your permission, and you will be notified before the summary transcript function is enabled or the call is recorded so you can decide whether you wish to proceed. RingCentral’s Trust Center states it does not use customer data to train either its AI models or their third-party vendor AI models.
We do not collect any of your special category data; this is any information relating to your health or medical records, criminal records or convictions, sexual orientation, racial or ethnic origin, political or philosophical opinions or affiliations, religious or philosophical beliefs or affiliations or trade union membership or genetic or biometric data.
- How do we obtain your personal data?
We obtain your personal data in a number of different ways:
- directly from you when you apply to work at Levin or during any form of communications such as face to face, written and phone correspondence or interviews;
- from third parties who we use to find your most recent contact details;
- from correspondence with you on LinkedIn;
- from recruitment agencies; or
- via our website, collected via cookies
For what purpose do we use your personal data and with whom is it shared?
We only process personal data for the purposes described in this Notice. Data Protection Laws require companies to have a “lawful basis” to collect and use personal data. For Levin these will be:
- it is necessary in order to take steps to enter into a contract with you;
- it is necessary for legitimate business interests pursued by us or a third party and your interests and fundamental rights do not override those interests. In each case we will always consider your interests and undertake a balancing exercise to ensure that our business interest does not cause you harm or override your own interest.
We will process your personal data for the following purposes and in reliance of the listed lawful bases:
| Purpose for processing your personal data | Lawful basis |
| For the purposes of the recruitment process including:
· considering your suitability for the role; · conducting interviews; · determining the terms on which you would work for us; · conducting right to work checks (when we make you an offer); · record-keeping purposes; and · general correspondence with you.
|
· Performance of contract
· Legitimate interests (for recruitment and record-keeping and management)
|
| General business management, record keeping, operations and planning. | Legitimate interests (business administration and operations) |
- Who do we share your personal data with
When we share your personal data, we do so in accordance with Data Protection Laws and our internal security standards.
- Within the Levin group: We may share your personal data with other companies within the Levin group based in the USA where we have satellite offices.
Your personal data may be shared within our trading divisions and satellite offices as part of our day-to-day business activities and regular reporting activities on company performance.
- Our third-party service providers: We will share personal data with third party service providers such as providers/vendors and agents (including their subcontractors) such as IT suppliers, document management providers, software providers and information security providers.
No mobile information will be shared with third parties/affiliates for marketing/promotional purposes. All other use cases exclude text messaging originator opt-in data and consent; this information will not be shared with any third parties.
- HOW DO WE PROTECT YOUR PERSONAL DATA WHEN SENDING IT OUTSIDE THE UK/EEA?
- In some circumstances, we may need to transfer your personal data to a country or territory outside the UK and/or the European Economic Area (which means all the European Union (EU) countries plus Norway, Iceland and Liechtenstein, together “EEA“).
- When we do so, we will ensure that such transfers are appropriately safeguarded and in compliance with Data Protection Laws. This may mean that we enter into the UK’s International Data Transfer Agreement with service providers – this is a set of contractual wording which has been issued by the UK’s data protection regulator.
- A summary of our regular data transfers are set out below:
| Country/jurisdiction to where we transfer personal data | Purpose for the transfer | Safeguard used to protect your personal data |
| United States of America | This is an intra-group transfer i.e., a transfer to a company within the Levin group for servicing, account management, administrative purposes and client relationship/marketing purposes. | Levin’s Intra-Group Data Sharing Agreement |
- WHAT MARKETING ACTIVITIES DO WE CARRY OUT?
- We may from time to time provide you with information about our services or information about any relevant industry developments which we think will be of interest to you or which you have asked us to provide you with. This may be sent by email or we may contact you by phone.
- In addition to the DPA 2018 and the GDPR 2018 requirement for a lawful basis, where we send unsolicited electronic marketing to you we may also require either an opt-in consent or opt-out consent under the Privacy and Electronic Communications Regulations 2003 (PECR). That means we are permitted to market products or services to you which are related to the recruitment services we provide to you as long as you do not actively opt-out from these communications.
- Please note that you can opt out of receiving any marketing communications at any time. An “unsubscribe” link appears in all our marketing emails and SMS text messages. To unsubscribe from emails and SMS text messages sent by us, simply click on the link at any time. Alternatively, you can contact us to update your preferences using the contact details in the “Contacting Us” section below (see section 10).
- AUTOMATED PROCESSING
We do not carry out any automated decision-making. If this changes, we will let you know.
- YOUR RIGHTS
- Under some data protection laws, you have the right to make certain requests of us in relation to the personal data that we hold about you. If you wish to exercise these rights at any time please contact us using the details set out in the “Contacting us” section (see section 10).
- Please note that not all of your data subject rights will be absolute; this means that there may be some circumstances where we may not be able to comply with your request (such as where this would conflict with our obligation to comply with legal requirements). However, if we cannot comply with your request, we will tell you the reason, and we will always respond to any request you make. In some locations, not all rights will be available. We have set out a summary of relevant rights available to you under the locations in which we operate.
- There may also be circumstances where exercising some of these rights (such as the right to erasure, the right to restrict processing and the right to withdraw consent) will mean we can no longer provide you with our services. We will inform you of these consequences when you exercise your right.
- Your rights under data protection laws are:
- the right to access your personal data:
- you are entitled to a copy of the personal data we hold about you and certain details of how we use it; and
- we will usually provide you with your personal data in writing, unless you request otherwise, or where you have made the request using electronic means, in which case the information will, where possible, be provided to you by electronic means;
- the right to rectification: we take reasonable steps to ensure that your personal data that we hold is accurate and complete, however, you can ask us to amend or update the personal data if you do not believe that this is so or if your details change;
- the right to erasure: you have the right to ask us to erase your personal data in certain circumstances, for example where you withdraw your consent or where the personal data we obtained is no longer necessary for the original purpose; this right, will, however, need to be balanced against other factors, for example, we may have legal obligations which mean we cannot comply with your request;
- the right to restrict processing: in certain circumstances, you are entitled to ask us to stop using your personal data, for example where you think that we no longer need to use your personal data or where you think that the personal data we hold about you may be inaccurate;
- the right to data portability: you have the right, under certain circumstances, to ask that we transfer personal data that you have provided to us to another third party of your choice;
- the right to object to marketing: you can ask us to stop sending you marketing messages at any time. You can exercise this right by either clicking on the “unsubscribe” link which is contained in any email that we send to you or you can use the details set out in the “Contacting us” section to contact us (see section 10). Please note that exercise of this right does not extend to service-related communications which, where necessary, we will continue to send;
- the right to object to processing: where we process your personal data based on our legitimate business interests (indicated in this privacy policy), you can object to our processing. We will consider your objection and determine whether or not our legitimate business interests prejudice your privacy rights;
- the right to withdraw consent: we may ask for your consent for certain uses of your personal data – we have indicated in this privacy policy where we need your consent. You have the right to withdraw your consent at any time;
- rights relating to automated decision-making: we do not carry out any automated decision making. If this changes in the future, we will let you know; and
- the right to lodge a complaint with the Information Commissioner’s Office: you can find out more information at the Information Commissioner’s Office website: https://ico.org.uk/. Please note that lodging a complaint will not affect any other legal rights or remedies that you have.
- the right to access your personal data:
- HOW WE PROTECT YOUR PERSONAL DATA
- We have put in place:
- appropriate security measures, policies and procedures to prevent your personal data from being accidentally lost, used, interfered with or accessed in an unauthorised manner, altered or disclosed; and
- procedures to address any suspected personal data breaches and will notify you and any applicable regulator of a breach where we are legally required to do so.
- We review our security measures periodically. We also ensure that our employees receive appropriate data security training.
- We have put in place:
- HOW LONG DO WE KEEP YOUR PERSONAL DATA?
- We will only keep your personal data for as long as is necessary to fulfil the relevant purposes as set out in this privacy policy and more widely to comply with our legal obligations.
- The exact time period will depend on your relationship with us and the type of personal data we hold.
- CONTACTING US
If you have any queries about how we handle your personal data, the contents of this privacy policy, your data protection rights under applicable data protection laws, how to update your records or how to obtain a copy of the personal data that we hold about you, please email us at privacy@grouplevin.com or write to us at: 17 St Helen’s Place, London, England, EC3A 6DG.
We may change or update parts of this Notice from time to time in order to maintain compliance with applicable Data Protection Laws and any changes to other laws or following an update to our internal practices. We will publish the updated version of the privacy policy and you can check our website https://grouplevin.com/privacy-policy/ periodically to view it.
