Privacy Policy

1. Scope

Reconomy (UK) Limited (“We”, “Us”, “Our”) respects your privacy and is committed to protecting your personal data.
This policy explains how Reconomy collects, processes and shares your personal data,

This privacy notice applies to the processing of your personal data when you visit our website www.reconomy.com, when you
contact us by e-mail, post or telephone, when we subsequently provide services to you or when you are providing services to
us.

2. Definitions

Data protection law

“Data Protection Laws” Means applicable law and regulatory requirements relating to the processing, privacy and use
of personal data and protection of individuals, including, but not limited to.

(i) Regulation (EU) 2016/679 (“GDPR”)
(ii) Regulation (EU) 2016/679 (“GDPR”) as incorporated into domestic UK law by the European Union (Withdrawal Agreement) Act 2020 and amended by The Data
Protection, Privacy and Electronic Communications (Amendments etc.) (EU Exit) Regulations 2020 (together the “UK GDPR”).
(iii) any legislation enacted in the country of establishment1of the data controller in
respect of the protection of personal data or any corresponding or equivalent national laws or regulations.all as amended, updated, or replaced from time to time;

Personal data

Means any information relating to an identified or identifiable natural person, who can be identified, directly or indirectly, such as a name, identification number, location, online
identifier.

3. Our Contact Details

Name: Reconomy (UK) Limited Phone Number: 0800 9885618
Address: Kelsall House
Stafford Court
Stafford Park 1
Telford
Shropshire TF3 3BD E-mail: contactus@reconomy.com

4. Type of Personal Data we Collect

The personal data we currently collect may include the following:

Contact details, including your name, job title, address, e-mail address and phone number
Demographic information, such as postcode, preferences and interests
Financial and credit card information
IP address
Website usage data, such as duration of visit, browser and operating system used, referrer URL, time of server request and content retrieved
Information relevant to your enquiry
Information relating to your job application (educational background, employment background , job qualifications/skills, CV/resume or transcripts, and any supporting documentation attached to your resume, such as copies of certificates,
passport, cover letters, etc. )
Information pertaining to special offers and surveys
Social media interactions

5. How we get your Personal Data and why we have it

Most of the personal data we process is provided to us directly by you for one of the following reasons, in accordance with a lawful basis described in Section 6:

To fulfil any contracts entered into between you and us, including processing any payments.
To provide you with information about our products and services that you request from us.
To respond to an enquiry or request from us.
You wish to attend, or have attended, an event.
To send you promotional emails or mailings, or to call you, about products, services and offers that we think might be relevant to you.
To contact you for market research purposes.
To ask you to complete customer satisfaction surveys to assist us in improving our products and services.
To subscribe to our newsletter.
You have applied for a job or secondment with us.

When you are applying for a job, we collect personal data about you from the following sources:

You, the candidate, via an online job site, career site, email, in person at video interviews, and/or by any other method.
From those who referred you.
Trusted third-party vendors who recommend you as a candidate.
From publicly accessible sources, such as LinkedIn or source boosters,.

We also receive personal data indirectly when you visit our website, for the following reasons:

To customise the website for you.
To measure or understand the effectiveness of advertising we serve to you and others, and to deliver relevant advertising
to you.
To administer the website and for internal operations, including troubleshooting, data analysis, testing, research,
statistical and survey purposes.
To make the site easier to visit again and more useful to you through the use of cookies.

6. Why we share your information

We may share your information with third parties in the following scenarios:

We may share your information with third parties in the following scenarios:
To provide goods or services to fulfil contractual obligations, for example, with transport, shipping or payment service
providers.
If we are obliged to do so by law, by court order or due to an enforceable official order.
To enable other companies within the Reconomy Group to fulfil contractual obligations or provide information to you about similar products or services which you have requested, or which we think may be relevant for you, we will share your information with other companies within the Reconomy Group.
To provide you, or permit carefully selected third parties to provide you, by telephone, post or email, with information
about other goods and services that are similar to those that you have already purchased or enquired about.
To provide you with targeted information about services or products, so you get relevant messages from us.

In the event that we transfer your personal data to a data processor, we will ensure that a data processing agreement (DPA) is in place.

7. Lawful Basis for Processing

Under Data Protection Laws, the lawful bases we rely on for processing this information are:

We have a contractual obligation: We process your personal data to fulfil contractual obligations.
We have a legal obligation: We are obligated to retain certain information due to legal requirements, such as for tax and
business regulations.
We have a legitimate interest. The legitimate interests can be our own interests or the interests of third parties. When necessary, we will conduct a Legitimate Interests Assessment, in order to consider the impact that any processing activities could have on individuals, including in the following scenarios:
– Promotion of our offers and services;
– Analysis of the use of our website;
– Recruitment;
– Social media engagement analysis;
– Ensuring the confidentiality and integrity of our IT systems; and
– Cooperation with authorities.
You have given consent.
- If you have given us explicit consent to process your personal data, we will process it within that scope and based on your
  consent. Your consent might refer to, for example, sending a newsletter. You can remove your consent at any time. You
  can do this by contacting contactus@reconomy.com.
- We may utilize Artificial Intelligence (AI) technologies to enhance our services and internal operations. When doing so, we
  are committed to protecting your personal data with the highest standards of security and privacy. All AI systems used
  within our company operate under strict data protection protocols and are designed to process data in compliance with
  applicable Data Protection Legislation.
- Any data processed by AI systems is handled in a secure, access-controlled environment and is used solely for the
  purposes explicitly stated in this Privacy Policy. We implement appropriate technical and organizational safeguards to
  ensure that your personal information remains confidential, protected, and is never repurposed for unauthorized AI
  training or profiling.

8. How we store your Personal Information

We have implemented appropriate technical and organisational measures to protect your personal data against accidental or unlawful destruction, loss, unauthorised change or damage. All personal data we collect will be stored on our secure servers. All electronic transactions entered into via our website will be protected by SSL encryption technology. We will store your personal information for as long as necessary to fulfil the purposes for which we collect the personal data, in accordance with our legal obligations and legitimate business interests. We may also store your personal data collected through the recruitment process for future roles that may become available, based on your consent and unless you choose otherwise. We may retain any personal data to investigate or defend claims against us, or to prosecute or bring claims against you, us or any third party.

9. Your Data Protection Rights

Under Data Protection Laws, you have the following rights:

Right of access: You have the right to ask us for copies of your personal information.
Right to rectification: You have the right to ask us to rectify personal information you think is inaccurate. You also have the right to ask us to complete information you think is incomplete.
Right to erasure: You have the right to ask us to erase your personal information in certain circumstances, for example when the organisation no longer needs it for the original reason it was collected, or the organisation has collected or used your data unlawfully.
Right to restriction of processing: You have the right to ask us to restrict the processing of your personal data in certain circumstances, for example the organisation no longer needs your personal data, but you want the organisation to keep it in order to create, exercise or defend a legal claim.
Right to object to processing: You have the right to object to the processing of your personal information in certain circumstances.
Right to data portability: You have the right to ask that we transfer the personal information you gave us to another organisation, or to you, in certain circumstances.

You can exercise your rights at any time by emailing us at gdpr@reconomy.com however there are certain circumstances when a request may be refused, for example when it is manifestly unfounded or excessive, for example when:

the individual clearly has no intention to exercise their right of access.
the request is malicious in intent and is being used to harass an organisation with no real purpose other than to cause disruption.
the request is clearly or obviously unreasonable.; the request should be proportionate when balanced with the burden or costs involved in dealing with the request.

You are not required to pay any charge for exercising your rights. If you make a request, we have one month to respond to you.

10. EU & UK Representation

Where a UK-established Reconomy entity is processing and monitoring the personal data of individuals in the EU, and is required by Data Protection Laws to designate an EU Representative, the following person is hereby appointed:

Managing Director
Cycleon B.V.
Vliegend Hertlaan 71 14e etage
3526 KT Utrecht
Netherlands
Tel: +31 30 299 5500

Where an EU-established Reconomy entity is processing and monitoring the personal data of individuals in the UK, and is required by Data Protection Laws to designate a UK Representative, the following person is hereby appointed:

Company Secretary
Reconomy (UK) Limited
Kelsall House
Stafford Court
Stafford Park 1
Telford
Shropshire TF3 3BD
UK
Tel: 0800 988 5618
Email: gdpr@reconomy.com

11. Lodging a complaint

If you are dissatisfied with our actions and wish to make a complaint, this should be made in writing to contactus@reconomy.com or sent to the following address:

Kelsall House
Stafford Court
Stafford Park 1
Telford
Shropshire TF3 3BD

If you would like to make a complaint to the Reconomy Group, email gdpr@reconomy.com. You also have the right to lodge a complaint with your local Supervisory Authority (“SA”) if you are unhappy with how we have
used your data. A list of EU SAs is maintained by the European Data Protection Board (EDPB) and can be accessed here.

The ICO’s address:
Information Commissioner’s Office
Wycliffe House
Water Lane
Wilmslow
Cheshire
SK9 5AF
Helpline number: 0303 123 1113 or 01625 545 745 or email: enquiries@ico.org.uk
ICO website: https://www.ico.org.uk

12. Changes to our Privacy Notice

Any changes we make to our Privacy Notice in the future will be posted on this page and, where appropriate, notified to you by email. Please check back frequently to see any updates or changes to our Privacy Notice.