Privacy Policy
PLEASE READ THESE CAREFULLY
Oxiway Ltd ("us", "we", or "our") is committed to protecting and respecting your privacy. This privacy policy applies to all products and services offered by Oxiway Ltd.
At Oxiway Ltd, trading under the name “MeVitae”, we take your privacy seriously. The following privacy policy explains what personal data we collect from you, or that you provide to us, how we process it and what we do to keep it safe.
Oxiway Ltd complies with the UK General Data Protection Regulation (UK GDPR) and Data Protection Act 2018.
Please read the following carefully to understand our views and practices regarding your personal data and how we will treat it.
For the purposes of data protection legislation the data controller is Oxiway Ltd. We are registered in England and Wales under company number 08286045 having our registered office at F25, R27 Atlas Building, Harwell Oxford, OX11 0QX
This Policy sets out the basis on which any personal data we collect from users (each, a "User"), or that you provide to us, will be processed by us. It also provides you with information regarding our use of cookies. Please read the following carefully to understand our views and practices regarding your personal data and how we will treat it. By using our website www.mevitae.com (the “Website” or “Site”) you are accepting and consenting to the practices set out in this Privacy and Cookie Policy and also agreeing to abide by our Terms of Use. If you have not already read our Terms of Use.
We will not use or share your information with anyone except as described in this Privacy Policy.
WHO WE ARE AND WHAT WE DO
We are a recruitment technology company and we may also from time to time provide services, such as consultancy. We collect personal data of the following types of people to allow us to undertake our business;
Prospective and live client contacts. We will process your personal data for the purposes of communication with our customers and suppliers, ensuring any products or services exchanged between us satisfy agreed requirements and maintaining records. The legal basis for this processing is that it is necessary to achieve our legitimate interest, namely the supply of our services and maintaining a business relationship with your employer;
Supplier contacts to support our services;
Employees, consultants, temporary workers;
Employees of organisations with which we are seeking to establish a business relationship. We will process your personal data for the purpose of communication with your employer. The legal basis for this processing is that it is necessary to achieve our legitimate interest, namely providing information on our services that may be of value and establishing a business relationship with your employer;
It applies to employees of our customers or suppliers who appear in our promotional material;
Job applicants. We will store your personal data relating to recruitment for two years following the completion of the recruitment process.
We collect information about you to carry out our core business and ancillary activities.
INFORMATION YOU GIVE TO US OR WE COLLECT ABOUT YOU
We collect and process some or all of the following types of information from you:
Information that you provide by filling in forms on the www.mevitae.com website (“Website”). This includes information provided at the time of registering to use the Website, subscribing to our Services, posting material or requesting further information or services. We may also ask you for information when you report a problem with the Website.
If you contact us, we may keep a record of that correspondence.
We may also ask you to complete surveys that we use for research purposes, although you do not have to respond to them. It includes information you provide when you register to use our site, to enter our database, subscribe to our services, attend our events, participate in discussion boards or other social media functions on our site, enter a competition, promotion or survey, and when you report a problem with our site.
Details of all actions that you carry out through the Website and of the provision of services to you.
Details of your visits to the Website including, but not limited to, traffic data, location data, weblogs and other communication data, the site that referred you to our site and the resources that you access.
We collect and process some or all of the following types of information from you:
The information you give us or we collect about you may include your name, address, private and corporate e-mail address and phone number, financial information, compliance documentation and references verifying your qualifications and experience and your right to work in the United Kingdom, curriculum vitae and photograph, links to your professional profiles available in the public domain e.g. LinkedIn, Twitter, business Facebook or corporate website.
INFORMATION WE COLLECT ABOUT YOU WHEN YOU VISIT OUR WEBSITE
With regard to each of your visits to our site we will automatically collect the following information:
Technical information, including the Internet protocol (IP) address used to connect your computer to the Internet, your login information if applicable, browser type and version, browser plug-in types and versions, operating system and platform;
Information about your visit, including the full Uniform Resource Locators (URL) and how you interact with our site.
INFORMATION WE OBTAIN FROM OTHER SOURCES
This is information we obtain about you from other sources such as LinkedIn, corporate websites, job board websites, online CV libraries, your business card, personal recommendations, and others for the purposes of our recruitment services and ancillary support services.
We may use different methods to collect data from and about you including through:
o Direct interactions. You may give us your Identity and Contact Data by filling in an online form or by corresponding with us by mail, phone, email or otherwise. This includes personal data you may provide when you:
o Ask us to supply you with a product demonstration;
o apply for a job with us;
o request one of our newsletters; or
o provide us with feedback.
o We may receive Identity and Contact Data about you from public sources.
We may work closely with third parties and other companies, business partners, sub-contractors in technical, professional, payment and other services, advertising networks, analytics providers, search information providers, credit reference agencies, professional advisors AND OTHERS. We may receive information about you from them for the purposes of our recruitment services and ancillary support services.
Information we receive from third parties. We may receive personal data about you from employers and potential employers who you apply to with our help, who provide us with feedback and decision outcomes relating to your performance during the recruitment process, during internships and/or work placements.
From time to time we also obtain personal data from other sources as follows:
o names and contact details of Customer personnel who will be added as account members for the Customer’s account, may be added by existing account members;
o names and contact details of individual contacts at prospective Customers from third party data providers and/or public sources, such as social networks, company websites and other online sources.
o Information we receive from third parties when you apply for a position directly with that third party. Many employers use MeVitae’s system in the context of their application processes. This means that when you apply for a position with some employers. Your CV isthen passed to MeVitae (only with your consent) to help assess job suitability. The results of MeVitae’s data processing are then passed back to the employer who can link the result to your individual application and further assess your application. If you consent to it when you apply for a position directly with a third party which uses MeVitae’s system, the data which MeVitae receives from employers may also be used by MeVitae for further research purposes (e.g. to identify trends).
Any personal information we hold will be bound by this Privacy Notice.
PURPOSES OF THE PROCESSING AND THE LEGAL BASIS FOR THE PROCESSING
We use information held about you in the following ways:
To carry out our obligations arising from any contracts we intend to enter into or have entered into between you and us and to provide you with the information, products and services that you request from us or we think will be of interest to you because it is relevant to your career or to your organisation.
To provide you with information about other goods and services we offer that are similar to those that you have already purchased, been provided with or enquired about.
Our legal basis for the processing of personal data is our legitimate business interests, described in more detail below, although we will also rely on contract, legal obligation and consent for specific uses of data.
We will rely on contract if we are negotiating or have entered into a placement agreement with you or your organisation or any other contract to provide services to you or receive services from you or your organisation.
We will rely on legal obligation if we are legally required to hold information on to you to fulfil our legal obligations.
We will in some circumstances rely on consent for particular uses of your data and you will be asked for your express consent, if legally required. Examples of when consent may be the lawful basis for processing include permission to introduce you to a client
As you are providing us with your personal data, it is important to us that you are aware of the following rights that you have in relation to our processing of that personal data.
You can withdraw your consent to our processing of your personal data at any time.
You can be provided with a copy of any personal data concerning you that we process, unless that would affect the rights and freedoms of others. You can also be provided with information on how that personal data is processed by us.
You can have us rectify any personal data of yours that we hold that is inaccurate or incomplete. In certain circumstances, you can also ask us to erase or restrict the use of any of your personal data that we process.
OUR LEGITIMATE BUSINESS INTERESTS
Our legitimate interests in collecting and retaining your personal data is described below:
In order to support our clients’ resourcing needs we require a database of candidate and client personal data containing historical information as well as current resourcing requirements.
To maintain, expand and develop our business we need to record the personal data of client contacts.
Customer and Suppliers Employees in Promotional Material - we will process your personal data for the purpose of creating marketing material. The legal basis for this processing is that it is necessary to achieve our legitimate interests, namely promoting the services supplied by us.
CONSENT
Should we want or need to rely on consent to lawfully process your data we will request your consent orally, by email or by an online process for the specific activity we require consent for and record your response on our system. Where consent is the lawful basis for our processing you have the right to withdraw your consent to this particular processing at any time.
Other Uses we will make of your data:
Use of our website;
to notify you about changes to our service;
to ensure that content from our site is presented in the most effective manner for you and for your computer
We will use this information:
to administer our site and for internal operations, including troubleshooting, data analysis, testing, research, statistical and survey purposes;
to improve our site to ensure that content is presented in the most effective manner for you and for your computer;
to allow you to participate in interactive features of our service, when you choose to do so;
as part of our efforts to keep our site safe and secure;
to measure or understand the effectiveness of advertising we serve to you and others, and to deliver relevant advertising to you;
to make suggestions and recommendations to you and other users of our site about goods or services that may interest you or them.
COOKIES
Our website uses cookies to distinguish you from other users of our website. This helps us to provide you with a good experience when you browse our website and also allows us to improve our site. For detailed information on the cookies we use and the purposes for which we use them see our Cookie notice here.
DISCLOSURE OF YOUR INFORMATION INSIDE AND OUTSIDE OF THE UK AND EEA
We will share your personal information with:
Any member of our group both in the UK and EEA and outside of the UK and EEA.
Selected third parties including:
clients, business partners, suppliers and sub-contractors for the performance and compliance obligations of any contract we enter into with them or you;
subcontractors including email marketing specialists, event organisers, payment and other financial service providers.
advertisers and advertising networks that require the data to select and serve relevant adverts to you and others. We do not disclose information about identifiable individuals to our advertisers, but we will provide them with aggregate information about our users (for example, we may inform them that 500 men aged under 30 have clicked on their advertisement on any given day). We may also use such aggregate information to help advertisers reach the kind of audience they want to target (for example, women in SW1). We may make use of the personal data we have collected from you to enable us to comply with our advertisers’ wishes by displaying their advertisement to that target audience;
analytics and search engine providers that assist us in the improvement and optimisation of our site;
credit reference agencies, our insurance broker, compliance partners and other sub-contractors for the purpose of assessing your suitability for a role where this is a condition of us entering into a contract with you.
We will disclose your personal information to third parties:
In the event that we sell or buy any business or assets, in which case we will disclose your personal data to the prospective seller or buyer of such business or assets.
If Oxiway Limited or substantially all of its assets are acquired by a third party, in which case personal data held by it about its customers will be one of the transferred assets.
If we are under a duty to disclose or share your personal data in order to comply with any legal obligation, and other agreements; or to protect the rights, property, or safety of our company or our customers, or others. This includes exchanging information with other companies and organisations for the purposes of fraud protection and credit risk reduction.
The lawful basis for the third-party processing will include:
Their own legitimate business interests in processing your personal data, in most cases to fulfil their internal resourcing needs;
satisfaction of their contractual obligations to us as our data processor;
for the purpose of a contract in place or in contemplation;
to fulfil their legal obligations.
WHERE WE STORE AND PROCESS YOUR PERSONAL DATA
The data that we collect from you may be transferred to, and stored at, a destination outside the UK and European Economic Area (”EEA”). It may be transferred to third parties outside of the UK and EEA for the purpose of our recruitment services. It may/will also be processed by staff operating outside the UK and EEA who work for us or for one of our suppliers. This includes staff engaged in, among other things, our recruitment services and the provision of support services. By submitting your personal data, you agree to this transfer, storing or processing. We will take all steps reasonably necessary to ensure that your data is treated securely and in accordance with the UK and/or EU GDPR.
All information you provide to us is stored on our secure servers. Any payment transactions will be encrypted. Where we have given you (or where you have chosen) a password which enables you to access certain parts of our site, you are responsible for keeping this password confidential. We ask you not to share a password with anyone.
Unfortunately, the transmission of information via the internet is not completely secure. Although we will do our best to protect your personal data, we cannot guarantee the security of your data transmitted to our site; any transmission is at your own risk. Once we have received your information, we will use strict procedures and security features to try to prevent unauthorised access.
RETENTION OF YOUR DATA
We understand our legal duty to retain accurate data and only retain personal data for as long as we need it for our legitimate business interests and that you are happy for us to do so.
Prospective Employees - We will store your personal data relating to recruitment for two years following the completion of the recruitment process.
Customer and Suppliers Employees in Promotional Material - We will store your personal data relating to marketing material for as long as the marketing material remains relevant to the services supplied by us for up to a maximum of 10 years.
Customer and Supplier Employees - We will retain all personal data we have obtained relating to you for a maximum of 10 years to fulfil the purposes for which we collected it, including for the purposes of satisfying any legal, accounting or reporting requirements.
Prospective Customer Employees - We will share your personal data with our suppliers only to the extent that the disclosure is reasonably necessary for the purposes of seeking to establish a business relationship with your employer and enhancing the relevance of any communications we have with you and/or your employer. We will retain all personal data we have obtained relating to you for a maximum of 5 years to fulfil the purposes for which we collected it, including for the purposes of satisfying any legal, accounting or reporting requirements.
YOUR RIGHTS
You have the right to ask us not to process your personal data for marketing purposes. We will usually inform you (before collecting your data) if we intend to use your data for such purposes or if we intend to disclose your information to any third party for such purposes and we will collect express consent from you if legally required prior to using your personal data for marketing purposes.
Our site may, from time to time, contain links to advertisers and affiliates. If you follow a link to any of these websites, please note that these websites have their own privacy policies and that we do not accept any responsibility or liability for these policies. Please check these policies before you submit any personal data to these websites.
The UK GDPR provides you with the following rights. To:
Request correction of the personal information that we hold about you. This enables you to have any incomplete or inaccurate information we hold about you corrected
Request erasure of your personal information. This enables you to ask us to delete or remove personal information 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 information where you have exercised your right to object to processing (see below).
Object to processing of your personal information 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. You also have the right to object where we are processing your personal information for direct marketing purposes.
Request the restriction of processing of your personal information. This enables you to ask us to suspend the processing of personal information about you, for example if you want us to establish its accuracy or the reason for processing it.
Request the transfer of your personal information to another party in certain formats, if practicable.
Make a complaint to a supervisory body which in the United Kingdom is the Information Commissioner’s Office. The ICO can be contacted through this link: https://ico.org.uk/concerns/
ACCESS TO INFORMATION
The Data Protection Act 2018 and the GDPR give you the right to access information held about you. We also encourage you to contact us to ensure your data is accurate and complete.
Your right of access can be exercised in accordance with the Data Protection Act (and GDPR). You can exercise any of the rights listed above by contacting us using the details at the bottom of this notice. If you are unhappy with any aspect of how we processed your personal data or your request to exercise a right, you can lodge a complaint with the Information Commissioner’s Office.
CHANGES TO OUR PRIVACY NOTICE
We may update our Privacy Policy from time to time. We will notify you of any changes by posting the new Privacy Policy on this page. We encourage you to frequently check this page for any changes to stay informed about how we are helping to protect the personal information we collect. You are advised to review this Privacy Policy periodically for any changes and become aware of modifications. Changes to this Privacy Policy are effective when they are posted on this page.
CONTACT
Questions, comments and requests regarding this privacy notice are welcomed and should be addressed to dpo@mevitae.com.