Privacy and cookies policy
1. Important information and who we are
Our services and this website are not intended for children and we do not knowingly collect data relating to children.
- you provide your personal data directly to Tangent Marketing Services Limited;
- your personal data is provided to Tangent Marketing Services Limited by a customer in connection with a contract for the provision of services by Tangent Marketing Services Limited to that customer;
- your personal data is provided to us by a supplier, outsourcing company or other third party in connection with a contract for the provision of goods or services by that organisation to us; or
- your personal data is provided to us by a recruiter in respect of a job application.
It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during your relationship with us.
2. The 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). We may collect, use, store and transfer different kinds of personal data about you which we have grouped together as follows:
|Identity data||includes first name, last name, title, date of birth and gender.|
|Contact data||includes home addresses, email address and telephone numbers.|
|Profile data||includes your interests, preferences and feedback given as part of market research we conduct or recruitment information in the case of a job application (including copies of right to work documentation, references and other information included in a CV or cover letter or as part of the application process).|
|Marketing and communications data||includes your preferences in receiving marketing from us and your communication preferences.|
|Technical data||includes internet protocol (IP) address, web browser type and version, operating system and platform, a list of URLs starting with a referring site, your activity on this website, and the site you exit to.|
|Usage data||information about your preferences and interests and how you use our website and services.|
We will only collect Special Category Data or Criminal Convictions Data about you if you apply for a job with us and have disclosed this to us or a DBS check has been carried out.
|Special category data||includes information about your race or ethnicity, religious beliefs, sexual orientation and political opinions, health (including any medical condition), health and sickness records, genetic information and biometric data.|
|Criminal convictions data||includes information about your criminal convictions and offences.|
Special Category Data is considered as being sensitive personal data, which requires a higher level of protection. We need to have further justification for collecting, storing and using this type of personal data.
We will only collect Criminal Conviction Data if it is appropriate given the nature of the role and where we are legally able to do so. Where appropriate, we will collect Criminal Conviction Data as part of the recruitment process, or we may be notified of such information directly by you in the course of you working for us, or we may conduct additional background checks in the course of your employment but will notify you beforehand.
If you fail to provide personal data
Where we need to collect personal data by law, under the terms of a contract we have with you or when you apply for a job with us, and you fail to provide that data when requested, we may not be able to perform the contract we have or are trying to enter into with you (for example, to provide you with services or properly assess your suitability for a role with us), nor comply with our legal obligations (such as to ensure the health and safety of candidates). In this case, we may have to cancel a service or contract you have with us, not enter into a contract we are trying to enter into with you, or not be able to properly assess your suitability for a role with us, but we will notify you if this is the case at the time.
3. How is your personal data collected?
We use different methods to collect data from and about you including through:
|Direct interactions||You may give us your Identity, Contact and Financial Data by filling in forms or by corresponding with us by post, phone, email or otherwise. This includes personal data you provide when you: purchase our services; request information or marketing to be sent to you; take part in market research we conduct, give us feedback or contact us; or apply for a job with us.|
|Automated technologies or interactions||As you interact with our website, we will automatically collect Technical Data about your equipment, browsing actions and patterns. We collect this personal data by using cookies and other similar technologies.|
|Third-parties or publicly available sources||We will receive personal data about you from various third-parties or public sources including: 1. Identity, Contact and Profile Data from employment agencies or background check providers, if you apply for a job with us; 2. Identity, Contact and Profile Data from former employers, credit reference agencies or other background check agencies such as recruitment agents, if you apply for a job with us; 3. Technical Data and Usage Data from analytics and search information providers such as Google based outside the UK; 4. Identity and Contact Data from publicly available sources such as social media websites based outside the UK or Companies House and the Electoral Register based inside the UK.|
4. How we use your personal data
We will only use your personal data when the law allows us to. Most commonly, we will use your personal data in the following circumstances:
- where it is necessary for our legitimate interests. This means the interest of our company in conducting and managing our company to enable us to give you as our customer or as an applicant for a job with us the best service or experience. We make sure we consider and balance any potential impact on you (both positive and negative) and your rights before we process your personal data for our legitimate interests. We do not use your personal data for activities where our interests are overridden by the impact on you (unless we have your consent or are otherwise required or permitted to by law). You can obtain further information about how we assess our legitimate interests against any potential impact on you in respect of specific activities by contacting us.
- where we need to perform a contract that we have entered into with you. This means processing your data where it is necessary for the performance of a contract to which our customer (for which you are a contact) is a party or relating to your application for a job with us, or to take steps at your request before entering into such a contract.
- where we need to comply with a legal obligation. This means processing your personal data where it is necessary for compliance with a legal obligation that we are subject to.
Generally, we do not rely on consent as a legal basis for processing your personal data although we will get your consent before sending third-party direct marketing communications to you via email or text message. You have the right to withdraw consent to marketing at any time by contacting us.
Purposes for which we will use your personal data
We have set out below, in a table format, a description of all the ways we plan to use your personal data, and which of the legal bases we rely on to do so. We have also identified what our legitimate interests are where appropriate.
Note that we may process your personal data for more than one lawful ground depending on the specific purpose for which we are using your data. Please contact us if you need details about the specific legal ground we are relying on to process your personal data where more than one ground has been set out in the table below.
|Purpose/Activity||Type of data||Lawful basis for processing including basis of legitimate interest|
|To register you as a contact for a new customer||(a) Identity, (b) Contact||Performance of a contract with our customer|
|To provide services to you including: (a) Manage payments, fees and charges, (b) Collect and recover money owed to us||(a) Identity, (b) Contact, (c) Marketing and Communications||(a) Performance of a contract with our customer, (b) Necessary for our legitimate interests (to recover debts due to us)|
|To administer and protect our business and this website (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data)||(a) Identity, (b) Contact, (c) Technical||(a) Necessary for our legitimate interests (for running our business, provision of administration and IT services, network security, to prevent fraud and in the context of a business reorganisation or group restructuring exercise), (b) Necessary to comply with a legal obligation|
|To deliver relevant website content to our customer and measure or understand the effectiveness of the advertising we serve to our customer||(a) Identity, (b) Contact, (c) Profile, (d) Usage, (e) Marketing and Communications, (f) Technical||Necessary for our legitimate interests (to study how our customers use our services, to develop them, to grow our business and to inform our marketing strategy)|
|To use data analytics to improve our website, services, marketing, customer relationships and experiences||(a) Technical, (b) Usage||Necessary for our legitimate interests (to define types of customers for our products and services, to keep our website updated and relevant, to develop our business and to inform our marketing strategy)|
|To make suggestions and recommendations to you about services that may be of interest to you as a contact for our customer||(a) Identity, (b) Contact, (c) Technical, (d) Usage, (e) Profile, (f) Marketing and Communications||Necessary for our legitimate interests (to develop our services and grow our business)|
|To manage your relationship with us as an applicant for a job with us, which will include: (a) Making a decision about your recruitment or appointment, (b) Determining the terms on which you work for us, (c) Checking you are legally entitled to work in the UK, (d) Assessing qualifications for a particular job or task, (e) Education, training and development requirements, (f) Ascertaining your fitness to work, (g) Providing appropriate workplace adjustments, (h) Complying with health and safety obligations, (i) Conducting data analytics studies to review and better understand employee retention and attrition rates, (j) Equal opportunities monitoring||(a) Identity, (b) Contact, (c) Profile, (d) Special Category, (e) Criminal Convictions||(a) Necessary for our legitimate interests (to assess applications for jobs with us), (b) Necessary to comply with a legal obligation (such as to ensure the health and safety of candidates)|
Processing Special Category Data and Criminal Conviction Data
We may process Special Category Data in the following circumstances:
- in limited circumstances, with your explicit written consent;
- where we need to carry out our legal obligations or exercise rights in connection with employment (please see the ‘Purposes for which we will use your personal data’ table below for further information);
- where it is needed in the public interest; and/or
- where it is necessary to protect you or another person from harm.
We may process Criminal Conviction Data in the following circumstances:
- to assess your suitability for a role;
- where it is necessary in relation to legal claims,
- where it is necessary to protect your interests (or someone else's interests) and you are not capable of giving your consent, and/or
- where you have already made the information public.
We strive to provide you with choices regarding certain personal data uses, particularly around marketing and advertising. We may use your Identity, Contact, Technical, Usage and Profile Data to form a view on what we think you may want or need, or what may be of interest to you. This is how we decide which products, services and offers may be relevant for you (we call this marketing). You will receive marketing communications from us if you have requested information from us or purchased services from us and you have not opted out of receiving that marketing.
You can ask us to stop sending you marketing messages at any time by contacting us at any time. Where you opt out of receiving these marketing messages, this will not apply to personal data provided to us as a result of a service purchase, service experience review or other transactions.
Change of purpose
We will only use your personal data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If we need to use your personal data for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so.
If you wish to get an explanation as to how the processing for the new purpose is compatible with the original purpose, please contact us. Please note that we may process your personal data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.
A cookie is a small file of letters and numbers that we store on your browser or the hard drive of your computer if you agree. Cookies contain information that is transferred to your computer's hard drive.
We use the following cookies:
- Strictly necessary cookies. These are cookies that are required for the operation of our website.
- Analytical or performance cookies. These allow us to recognise and count the number of visitors and to see how visitors move around our website when they are using it. This helps us to improve the way our website works, for example, by ensuring that users find what they are looking for easily.
- Functionality cookies. These are used to recognise you when you return to our website and remember your preferences.
- Targeting cookies. These cookies record your visit to our website, the pages you have visited and the links you have followed. We will use this information to make our advertising more relevant to your interests. We may also share this information with third parties for this purpose. Third parties may place cookies, web beacons and other storage technologies on your web browser to enable Tangent Marketing Services to serve you with advertising relevant to you and your interests.
- Retargeting cookies. We may use services provided by Google, Facebook and LinkedIn for cookie-based retargeting advertising. During retargeting, the following data may be collected: your browsing activity, IP address, mobile device type and what advertisements you interacted with and how. This information will help us regulate the advertisements you are served and measure their effectiveness.
You can block cookies by activating the setting on your browser that allows you to refuse the setting of all or some cookies. However, if you use your browser settings to block all cookies (including essential cookies) you may not be able to access all or parts of our website.
6. Disclosures of your personal data
We may share your personal data with the third-parties set out below for the purposes set out in the ‘Purposes for which we will use your personal data’ table above.
- Service providers acting as processors who provide IT and system administration services, including for dealing with certain processes necessary for the operation of the website.
- Analytics and search engine providers that assist us in the improvement and optimisation of our website.
- Professional advisers such as lawyers, bankers, auditors and insurers based in the UK who provide consultancy, legal, banking, accounting and insurance services.
- HM Revenue & Customs, regulators and other authorities based in the UK who require reporting of processing activities in certain circumstances.
We require all third-parties to respect the security of your personal data and to treat it in accordance with the law. We do not allow our third-party service providers to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our instructions.
7. International transfers
Whenever we transfer your personal data out of the UK, we ensure a similar degree of protection is afforded to it by ensuring at least one of the following safeguards is implemented:
- We will only transfer your personal data to countries that have been deemed to provide an adequate level of protection for personal data.
- Where we use certain service providers, we may use specific contracts approved for use in the UK which give personal data the same protection it has in the UK.
Please contact us if you want further information on the specific mechanism used by us when transferring your personal data out of the UK.
8. Data security
We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. 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.
We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.
9. Data retention
Generally speaking, if you have not applied for a job with us, we will only retain your personal data for 3 (three) months. If you have applied for a job with us and unless you are employed by us, we will only retain your personal data for 12 (twelve) months of your application for a role with us.
In either case we will only retain your personal data for as long as reasonably necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, regulatory, tax, accounting or reporting requirements.
To determine the appropriate retention period for personal data, we consider the amount, nature and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal, regulatory, tax, accounting or other requirements.
We may retain your personal data for a longer period in the event of a complaint or if we reasonably believe there is a prospect of litigation in respect to our relationship with you.
By law, for tax purposes, we have to keep some of your personal data for seven years from the end of the tax year or accounting period to which it relates.
In some circumstances you can ask us to delete your personal data. Please see the ‘Your legal rights’ section below for further information.
10. Your legal rights
Under certain circumstances, you have rights under data protection laws in relation to your personal data. You have the right to:
- Request access to your personal data (commonly known as a "data subject access request"). This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it.
- Request correction of the personal data that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.
- Request erasure of your personal data. This enables you to ask us to delete or remove personal data 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 data where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your personal data to comply with local law. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.
- Object to processing of your personal data 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 as you feel it impacts on your fundamental rights and freedoms. You also have the right to object where we are processing your personal data for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms.
Request restriction of processing of your personal data
. This enables you to ask us to suspend the processing of your personal data in the following scenarios:
- If you want us to establish the data's accuracy.
- Where our use of the data is unlawful, but you do not want us to erase it.
- Where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims.
- You have objected to our use of your data, but we need to verify whether we have overriding legitimate grounds to use it.
- Request the transfer of your personal data to you or to a third-party. We will provide to you, or a third-party you have chosen, your personal data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.
- Withdraw consent at any time where we are relying on consent to process your personal data. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain services to you. We will advise you if this is the case at the time you withdraw your consent.
If you wish to exercise any of the rights set out above, please contact us.
No fee usually required
You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we could refuse to comply with your request in these circumstances.
What we may need from you
We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.
Time limit to respond
We try to respond to all legitimate requests within one month. Occasionally it could take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.
- Full name of legal entity: Tangent Marketing Services Limited (a company registered in England and Wales with company number 04323657)
- Email address: firstname.lastname@example.org
- Postal address: The Varnish Works, 3 Bravingtons Walk, London, N1 9AJ
- Telephone number: 020 7462 6100
You have the right to make a complaint at any time to the Information Commissioner's Office (ICO), the UK regulator for data protection issues (www.ico.org.uk
). We would, however, appreciate the chance to deal with your concerns before you approach the ICO so please contact us in the first instance.
|11 May 2018||Created|
|8 January 2020||Updated with more detailed information about retargeting cookies|
|26 May 2021||Updated in compliance with data protection legislation|