Our Group Policies 

Personal data 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 use different kinds of personal data about you. The data we collect will be dependent on the product and/or service you are interested in or have to agreed to receive information on.  We have grouped together examples of the type of data we collect as follows: 

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• Identity Data: first name, last name, middle name, title, date of birth, gender, marital status, next of kin, national insurance number, nationality, job title, qualifications, documentation including identity data about you, including utility bills, driving licence, visa, settled and residency status information and passport; 

• Contact Data: email (personal and work), address and telephone number(s), emergency contact numbers;   

• Transaction Data includes details about payments to and from You, and other details of products and services you have purchased from Us or purchased from or provided to other members of a chain;   

• Chain Data includes data associated with your participation in a chain, including your relationship with members above or below you, including any project specific data where applicable; 

• 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 and/or platform; 

• Financial Data bank account information (including account number, payroll information, sort code, bank name and account holders name), salary, pension and benefits, student loan information and tax status; 

• Profile Data includes your username and password, purchases made by you, your interests, trade membership details (excluding trade unions) preferences, feedback and survey responses, and verification results; 

• Usage Data includes information about how you use Our website, platform, products and services; 

• Payroll and HR Data: Identity Data, Profile Data and Financial Data together with annual leave, start date, leave date, reason for leaving, recruitment information including CV and job application date, employment records including job title, work history, working hours, holidays, training records, performance data, disciplinary and grievance information, HMRC employment status information; 

• Marketing and Communications Data includes your preferences in receiving marketing from Us and Our third parties and your communication preferences; 

• Special Categories: strictly as necessary to enable us to carry out our rights and responsibilities, We may collect information about your medical history, sickness and absence records and any criminal convictions and offences. 

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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 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 or platform feature. 

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Where verification checks are undertaken, we may process biometric data to verify your identity through a liveness test. We do not collect any other 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, criminal convictions and offences, trade union membership, information about your health and genetic 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 Data, Contact Data and Financial Data by filling in forms or by corresponding with Us by post, online, phone, email or otherwise. This includes personal data you provide when you: 

• apply for Our products, services or features; 

• create an account on Our platform; 

• subscribe to Our products, services, features or publications; 

• respond to an invitation by a member to provide information to Us; 

• request marketing to be sent to you; 

• enter a competition, promotion or survey; or 

• give Us some feedback. 

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• Automated technologies or interactions. As you interact with Our website and/ or platform, 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 [link to cookies policy] for further details. 

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• Third parties or publicly available sources. We may receive personal data about you from various third parties and public sources as set out below: 

• Chain, transaction, project or other data from members of a chain; 

• Technical Data from the following parties:                                                                  (a) analytics and search information providers such as Google or Bing based outside the EU;                                                                                                           (b) advertising networks based inside the UK or EU. 

• Contact, Financial and Transaction Data from providers of technical, payment and delivery services such as Creditsafe based inside the EU; 

• Identity and Contact Data from data brokers, aggregators or publicly available sources such as Companies House, Land Registry and the Electoral Register based inside the EU;  

• Marketing Data from third parties which may include Hubspot Inc, Barbour ABI  and Glenigan Limited; 

• Phone calls may also be recorded for security and for the purpose of assisting and enabling us to perform any contract or obligation with you. We may also record calls for the purpose of internal training and information. 

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We only use your personal data when the law allows Us to. Most commonly, We use your personal data where: 

• we are performing a contract We are about to enter into or have entered into with you; 

• 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 need to comply with a legal or regulatory obligation.  

We have set out below, a description of the ways We may use your personal data, and which of the legal bases We rely on to do so. 

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