PRIVACY & COOKIE POLICY

We appreciate how important your privacy is and recognise that we are being trusted with protecting it, so the purpose of this privacy notice is to give you a clear explanation about how we collect and use your personal data.

We’d recommend you read the policy so you understand what data we collect about you, how we collect, use and look after that data, what privacy rights you have and how the law protects you.

The terms and conditions addressed in this document apply to FOTWLive trading as FlyOnTheWall and specifically the website www.flyonthewall.com. From herein the organisation will be referred to as FlyOnTheWall.

This policy sets out the manner in which information about users is collected, used, stored and transferred.

The personal data we collect about you

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).

Depending on how you use our site, we may collect, use and transfer different kinds of personal data:

• Information that you provide to us for the purpose of subscribing to our website services, email notifications and/or newsletters;
• Other information given as part of an application to join FlyOnTheWall.
• Marketing preferences – this includes your preferences in receiving marketing from us and your communication preferences.
• Survey responses and competition entries
• Customer service history – this includes interactions with us over the phone, via the website or on social media.
• Information about your device and how you use our websites and apps – this includes information you give us when you browse our websites or apps, including your internet protocol (IP) address, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform, as well as how you use our websites and apps.
• Administer payments to associates/suppliers;
• Associates – can include personal information such as name, contact details, work history, education, skills, training, and other onboarding compliance requirements. We may use this information to provide work-seeking services, to assess your suitability to work as well as administrative and management purposes in connection with providing work seeking services;
• Data captured for surveys/delivery of services to clients;
• Any other information that you choose to send to us.

How we collect your personal data

We collect personal data from and about you when you do things like sign up to our blog, newsletters and mailing lists. We also use cookies to understand your browsing behaviour on our website to enable us to improve your experience on this and future visits.

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

• Request information about our services
• Subscribe to our mailing lists, blog or newsletters;
• Request marketing materials to be sent to you;
• Take part in a survey; or
• Give us some feedback.

How we use your personal data

We will only use your personal data when there is a lawful basis.

• To perform a contract with you
• Because it is in our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests.
• To comply with a legal or regulatory obligation.
• To complete certain processing purposes such as seeking consent to send communications to you about our products or services.

We may use your data for the following purposes:

• Send you general (non-marketing) commercial communications;
• Administering the website including improving your browsing experience and enabling your use of the services available on the website;
• Supply you with emails you have opted into;
• Send you service messages, such as upcoming broadcasts from FlyOnTheWall
• Update you on our privacy notice;
• Provide customer service and support;
• Send to you our newsletter and other marketing communications relating to our business which we think may be of interest to you by email or similar technology where you have specifically agreed to this (you can inform us at any time if you no longer require marketing communications); deal with enquiries and complaints made by or about you relating to the website, and services or other correspondence;
• Provide sourced consultancy and work opportunities services which include holding information provided by associates including contact details, work history, skills and information required by HMRC for processing and retaining associates;
• Where you submit personal information for publication on our website or other online media and publications, we will publish and otherwise use that information in accordance with the license or consent you grant to us;

Marketing messages and promotional offers

With your permission and/or where permitted by law, we may also use your data to send you marketing communications relating to our products and services.

You can unsubscribe to stop receiving marketing communications from us at any time. You can do this by clicking on the unsubscribe link in any email we send you or by contacting us directly by email, post, or phone.

Sharing your personal data

We do not sell any of your personal data to any third party. We are committed to protecting your privacy. We may disclose your personal information:

• To the extent that we are required to do so by law;
• In connection with any legal proceedings or prospective legal proceedings;
• In order to establish, exercise or defend our legal rights (including providing information to others for the purposes of fraud prevention and reducing credit risk);
• To the purchaser (or prospective purchaser) of any business or asset which we are (or are contemplating) selling; and
• To any person who we reasonably believe may apply to a court or other competent authority for disclosure of that personal information where, in our reasonable opinion, such court or authority would be reasonably likely to order disclosure of that personal information.

International Data Transfers

Information that we collect may be stored, processed and transferred between any of the countries in which we operate in or supply from to enable us to use the information in accordance with this privacy statement.

All personal data stored and processed by us is securely stored within the UK or EEA. There is no systematic transfer of data outside of the UK or EEA for any other purpose than outlined above.

Security of your personal information and retention

We continue to take all reasonable technical and organisational precautions to prevent the loss, misuse, or alteration of your personal information. 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.

How long we will keep your personal data for

We retain your personal information for only as long as stipulated within our Data Retention Policy or where required in accordance with our client contractual retention period. We do not seek to retain data for any longer than necessary to carry out our service and fulfill our statutory and contractual obligations. For further details on the retention periods of your personal data, please contact us using the details further below.

Third party websites

This privacy notice is strictly for the FlyOnTheWall website and services only. Where this website contains links to other websites, users should review the privacy notices on those other websites on how their personal data is handled.

Cookie policy

Web Site Navigational Information

FlyOnTheWall uses commonly-used information-gathering tools, such as cookies and Web beacons, to collect information as you navigate the Company’s websites (“Web Site Navigational Information”). This section describes the types of website navigational information the Company may collect and how the Company may use this information.

(a) Cookies

A cookie, also known as a web cookie, browser cookie or HTTP cookie, is information sent between our web server and your web browser. Cookies are used by the web server to identify you when you revisit the site and to track how you navigate around the site. Session cookies only exist for the duration of your browser session while persistent cookies remain on your computer until they are either deleted or reach their specific expiry date. Your web browser may allow you to block all or specific third-party cookies; however, doing so may have a negative impact on your browsing experience on many websites including this one.

(b) Web Beacons

FlyOnTheWall uses Web beacons alone or in conjunction with cookies to compile information about members and visitors’ usage of the Company websites and interaction with emails from the Company. Web beacons are clear electronic images that can recognize certain types of information on your computer, such as cookies, when you viewed a particular website tied to the Web beacon, and a description of a website tied to the Web beacon. For example, FlyOnTheWall may place Web beacons in marketing emails that notify the Company when you click on a link in the email that directs you to one of the Company’s websites. FlyOnTheWall uses

(c) IP Addresses

When you visit FlyOnTheWall website, the Company collects your Internet Protocol (“IP”) addresses to track and aggregate non-personally identifiable information. For example, FlyOnTheWall uses IP addresses to monitor the regions from which members and visitors navigate the Company’s websites.

FlyOnTheWall also collects IP addresses from members when they log into the service as part of the Company “Identity Confirmation” and “IP Range Restrictions” security features.

Your rights

We recognize your rights relating to your personal data under the GDPR. These rights include:

• The right to request access to your personal data – you have the right to obtain a copy of your personal data that we hold. Please contact us with a description of the exact information you are seeking using the information below;
• The right to request correction of your personal data – if any of your personal data is incorrect or has changed, please contact us and we will correct it;
• The right to request erasure of your personal data – your right to have your information deleted or no longer used for processing unless there is a legal or other reason for continuing to process it. Please contact us if you have any queries or requests;
• The right to restrict processing or object to processing – you have the right to restrict or stop us processing your information any further, but will not affect any processing which has taken place. If you no longer wish your data to be processed or used, please contact us;
• The right to restrict processing or object to processing – you have the right to restrict or stop us processing your information any further, but will not affect any processing which has taken place. If you no longer wish your data to be processed or used, please contact us;
• The right to data portability – you have the right to request a copy of your data in a machine-readable format for any personal data provided by you;
• The right to complain to the Supervisory Authority – if you are unhappy with our response, you have the right to complain to the Supervisory Authority, the details of which are below:

Supervisory Authority: JERSEY OFFICE OF THE INFORMATION COMMISSIONER (JOIC)

Website: https://jerseyoic.org/

Email: enquiries@jerseyoic.org

Telephone: +44 (0) 1534 716530

How to contact us

If you wish to contact us to make a Subject access request, request rectification, object to processing, or have any other queries relating to this website, your personal data, or have a complaint, please contact us using the information below:

49 Greek Street, Soho London, W1D 4EG, UK

Tel: +44 20 7183 3584

Email: team@flyonthewall.com

Data controller

The data controller responsible for information collected on the FlyOnTheWall website is FOTWlive Ltd.