PRIVACY POLICY

PRIVACY NOTICE FOR CANDIDATES

What is the purpose of this document?

The Company is a “data controller”. This means that we are responsible for deciding how we hold and use personal data about you. You are being sent a copy of this privacy notice because you are applying for work with us (whether as an employee, worker or contractor). It makes you aware of how and why your personal data will be used, namely for the purposes of the recruitment exercise, and how long it will be retained for. It provides you with certain information that must be provided under the General Data Protection Regulation (GDPR).

Data protection principles

We will comply with data protection law and principles, which means that your data will be:

  • Used lawfully, fairly and in a transparent way.
  • Collected only for valid purposes that we have clearly explained to you and not used in any way that is incompatible with those purposes.
  • Relevant to the purposes we have told you about and limited only to those purposes.
  • Accurate and kept up to date.
  • Kept only as long as necessary for the purposes we have told you about.
  • Kept securely.

The kind of information we hold about you

In connection with your application for work with us, we will collect, store, and use the following categories of personal information about you:

  • The information you may have provided to us in your CV and any covering letter.
  • The information you have provided on our application form, including name, title, address, telephone number, personal email address, gender, employment history, qualifications and disciplinary warnings.
  • Any information you provide to us during an interview.
  • A copy of any work based test which may be conducted as part of the recruitment process.
  • Information which is available in the public domain on the internet, including but no limited to social media sites such as Twitter, LinkedIn and Facebook.

We may also collect, store and use the following “special categories” of more sensitive personal information:

  • Information about your race or ethnicity, religious beliefs, sexual orientation and political opinions.
  • Information about your health, including any medical condition, health and sickness records.
  • Information about current criminal convictions and offences.

How is your personal information collected?

We collect personal information about candidates from the following sources:

  • You, the candidate.
  • Recruitment agencies from our preferred supplier list, from which we collect the following categories of data:
  • Your named referees, from whom we collect the following categories of data:
    • Name
    • Current position
    • Employment history
    • Start date
    • End Date
    • Final salary and benefits package
    • Attendance record/timekeeping
    • Suitability for the proposed role
    • Reasons for leaving previous employment
    • Current disciplinary record

How we will use information about you

We will use the personal information we collect about you to:

  • Assess your skills, qualifications, and suitability for the role.
  • Communicate with you about the recruitment process.
  • Keep records related to our hiring processes.
  • Comply with legal or regulatory requirements.
  • Carry out reference checks, where applicable (as above)

Lawful Basis

The lawful basis upon which we will process your personal data is that it is necessary for the purposes of a contract with you or in anticipation we may enter into a contract with you.

We will process the information provided as part of the recruitment process to decide whether you meet the basic requirements to be shortlisted for the role. If you do, we will decide whether your application is strong enough to invite you for an interview. If we decide to call you for an interview, we will use the information you provide to us at the interview to decide whether to offer you the role. If we decide to offer you the role, we will then take up references before confirming your appointment.

If you fail to provide personal information

If you fail to provide information when requested, which is necessary for us to consider your application (such as evidence of qualifications or work history), we will not be able to process your application successfully. For example, if we require a credit check or references for this role and you fail to provide us with relevant details, we will not be able to take your application further.

How we use particularly sensitive personal information

We will use your particularly sensitive personal information in the following ways:

  • We will use information about your disability status to consider whether we need to provide appropriate adjustments during the recruitment process, for example whether adjustments need to be made.
  • We will use information about your race or national or ethnic origin, religious, philosophical or moral beliefs, or your sexual life or sexual orientation, to ensure meaningful equal opportunity monitoring and reporting.
  • The lawful basis upon which we will process this special category data is either that it is in the public interest or to assess your working capacity / health and safety purposes.

Information about criminal convictions

We will collect information about your current criminal convictions history as part of the application form process. There is no obligation to disclose convictions that are spent under the Rehabilitation of Offenders Act 1974. Any offer of employment will subject to our checks including references, being satisfactory.

Automated decision-making

You will not be subject to decisions based solely on automated decision-making.

Data sharing

Why might you share my personal information with third parties?

We will only share your personal information with the Recruiting Managers, Commercial Director, Managing Director and Office Manager for the purposes of processing your application. All our third-party service providers and other entities in the group are required to take appropriate security measures to protect your personal information in line with our policies. We do not allow our third-party service providers to use your personal data for their own purposes. We only permit them to process your personal data for specified purposes and in accordance with our instructions.

Data security

We have put in place appropriate security measures to prevent your personal information from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your personal information to those employees, agents, contractors and other third parties who have a business need-to-know. They will only process your personal information on our instructions and they are subject to a duty of confidentiality.

We have put in place procedures to deal with any suspected data security breach and will notify you and any applicable regulator of a suspected breach where we are legally required to do so.

Data retention

How long will you use my information for?

We will retain your personal information for a period of 12 months after we have communicated to you our decision about whether to appoint you to role. We retain your personal information for that period so that we can show, in the event of a legal claim, that we have not discriminated against candidates on prohibited grounds and that we have conducted the recruitment exercise in a fair and transparent way. After this period, we will securely destroy your personal information in accordance with applicable laws and regulations.

If we wish to retain your personal information on file, on the basis that a further opportunity may arise in future and we may wish to consider you for that, we will write to you separately, seeking your explicit consent to retain your personal information for a fixed period on that basis.

Rights of access, correction, erasure, and restriction

Your rights in connection with personal information

Under certain circumstances, by law you have the right to:

  • Request access to your personal information (commonly known as a “data subject access request”). This enables you to receive a copy of the personal information we hold about you and to check that we are lawfully processing it.
  • 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.

If you wish to exercise any of your rights, please contact Kenny Cox in writing.

Data protection officer

We have appointed a Data Compliance Officer (DCO) to oversee compliance with this privacy notice. If you have any questions about this privacy notice or how we handle your personal information, please contact Kenny Cox the DCO. You have the right to make a complaint at any time to the Information Commissioner’s Office (ICO), the UK supervisory authority for data protection issues.

PRIVACY NOTICE FOR THIRD PARTY/CLIENTS

Please read this Privacy Notice. It relates to how Live and Breathe (”us” / “we” / “our”) hold and process your information (data) and your rights in relation to that data.

Live and Breathe is the trading name of The Breathe Network Limited. We are registered with the Information Commissioners Office. Our registration number is Z3139855. We are a limited company. Our company registration number is 05965458 and our registered office is at Giles House, John Charles Way, Leeds, LS12 6QB. The person responsible for data protection at Live and Breathe is Kenny Cox (“Data Compliance Manager”) who can be contacted by email at Kenny.Cox@liveandbreathe.co.uk or in writing to our registered office address above.

Our website is www.liveandbreathe.com (“website”)

We are a “data controller”. This means that we are responsible for deciding how we hold and use data about you. We are required under data protection legislation to notify you of the information contained in this privacy notice. We have a duty to keep your data secure and maintain your confidentiality and we will do so.

The Breathe Network Limited is an associate of other companies being Make and Do Limited, Love and Rockets Limited, and Live and Breathe Limited (“Associates”). Your data may be shared with our Associates but they will maintain your rights and maintain your confidentiality in exactly the same way as The Breathe Network Limited does. We, and the Associates, are joint data controllers of your data accordingly and equally responsible and the basis for processing set out in this notice applies to our Associates.

However, in some instances we act as a data processor of data on behalf of others.

The data that we process

The data we process depends upon our relationship with you, why we obtained the data, and for what purpose.

  1. Our clients

We obtain and hold data about from our clients and customers. This data includes details of the client business name, contact details (such as email addresses and direct and mobile telephone numbers), and addresses. We also obtain details of clients’ bank accounts and payment information and details of work we have carried out for clients and the cost of that work.

We obtain this data for the purpose of carrying out work for the client.

This data is processed by us as it is necessary for us to do so to perform our contract with the client or in anticipation that we will enter into a contract. We then continue to hold the data as we consider that is necessary for us to do so both in the legitimate interests of our business but also in the legitimate interests of our clients as the information we hold assists with future business relationships with our clients.

  1. Third parties

(A) In the case of other companies, businesses, organisations or associations with whom we have a professional relationship or potentially common interest, the contact details including names, company / business name, email address/es, contact telephone numbers, and postal address. Where the third parties have any form of transactional relationship with us, we also may hold their bank details.

The purpose we hold this data is for the professional relationship or in common interest with the other organisation. We consider that it is necessary for us to process this data on the lawful basis that it is in the legitimate interests of our business to enhance and preserve those relationships.

(B) We are passed data by our clients and third parties relating to individuals such as competition winners and models In these instances we usually process the information in line with instructions and directions that are given to us and do so as data processors. Where this is the case, we have agreements in place with those who pass this data to us which regulates our use of the same, what we will do with the data, how long we will hold it for, and when it will either be deleted by us or passed back to the data controller.

In instances where we are given this data for our own use, then we will process the data only if it is necessary in the legitimate interests of our business and usually the specific work we are to undertake on behalf of our client, and as such it is necessary for us to do so in their legitimate interests also. The type of data we process in these instances can be varied, but in the main comprises for competition winners names, addresses, email addresses, telephone contact numbers and, for models, can include dates of birth, details of height, weight, eye colour, ethnicity, religious beliefs, dietary requirements, shoe size, links to social media and photographs.

In relation to this data, we are joint data controllers with the client or third party who passes the information to us. Where we can we will provide a copy of this privacy notice or details of where the privacy notice can be found, but in most cases (and particularly for models), we are usually unable to contact them directly because we do not have their addresses, but even where we are supplied with an address, we have determined that it would involve a disproportionate effort to notify all models whose details we hold.

  1. Visitors to our website

At present, we do not use cookies on our website although our website host may do so. Our website host is www.liveandbreathe.com. We do not have access therefore to the cookies they may use and they are the data controllers of any use of your data obtained by cookies. Please refer to their cookie policy on the website for information.

  1. CCTV

Our premises may be monitored by closed circuit television (CCTV).

The data that the CCTV captures comprise still and moving images of visitors to our premises, or employees, as well as those who pass close by our premises.

We obtain this data for the security of our business and of our employees to prevent, detect or deter crime. We consider this necessary in the legitimate interests of our business to do so, and we feel in the legitimate interests of those who work for us.

Retention of data

  1. Our Clients

We may retain your data indefinitely, except that:

(A)       We will delete and destroy any bank or payment details once payment has been processed;

(B)       We regularly review the data that we hold, at least annually, and if we hold data about a client with whom we have not had any dealings for over two years then we will destroy the data (except that we will retain basic contact details for reference and those clients become contacts and paragraph 2 (A) will apply.

  1. Third Parties

(A) We retain the information under paragraph 2(A) above indefinitely. This is because it is in the interests of our business to retain a database of such third parties and in doing so we believe that this will not affect the rights and freedoms of the individuals concerned. We will however destroy bank details after 12 months.

(B) Where we are acting as a data processor of this data, we do not retain the data unless we are instructed to do so through the agreement we have with the controller of the data.

Otherwise, where we are the controller of the data;

(i) Competition winners – we retain the data for seven years after the competition has closed as we need to retain the data in case of query or complaint. Thereafter it is destroyed.

(ii) Models – we retain the data for up to seven years. We review the data at least annually and if the model has not been used for a period of time, or is likely to be out of date (for example due to the individual’s age) then it will be deleted.

  1. CCTV

We retain the images taken by CCTV for 30 days after which time it is deleted.

Data sharing

We may also share data with our legal advisers and accountants where we deem it necessary to do so.

Your data will not otherwise be shared with any other third party without your consent.

Your data will not be held outside the EEA.

Automated processing

We do not deal with the automated processing of data.

Your rights

(1) We are obliged to ensure that the data we hold about you is correct. You have the right to ask for the data to be rectified if it is not and we will then take appropriate action to do so.

(2) You have the right to seek to restrict the processing of your data in some circumstances.

(3) Where we rely on legitimate interests as the basis for processing, you may ask for the data to be erased and if there is no overriding legitimate interest for us to continue the processing then we will do so.

(4) You can also object to the processing of your data where we rely on legitimate interests as the basis for processing.

(5) You have the right to seek confirmation of the fact that we are processing your data, to ask what that data comprises, and also to ask for copies of your data.

How to exercise your rights

If you would like to exercise any of the rights in paragraph 6, please email Kenny.Cox@liveandbreathe.co.uk or write to us at the registered address given at the top of this Notice. We will then consider your request and action the same as necessary although in some circumstances we may have a legitimate reason for not being able to action your request. If this should be the case then we will notify you of the reason why.

If you have cause for complaint

If you have any cause for complaint, or do not believe that we are processing your data fairly or in line with our obligations as a data controller, then we would ask that you contact us in the first instance with your concerns although you are not obliged to do so and you may contact the Information Commissioner’s Office whose details can be found at www.ico.org.uk

PRIVACY NOTICE FOR EMPLOYEES

Live and Breathe is committed to protecting the privacy and security of your personal information.

This privacy notice describes how we collect and use personal information about you during and after your working relationship with us, in accordance with the General Data Protection Regulation (GDPR). It applies to all employees, workers and contractors.

The Company is a “data controller”. This means that we are responsible for deciding how we hold and use personal information about you. We are required under data protection legislation to notify you of the information contained in this privacy notice.

This notice applies to current and former employees, workers and contractors. This notice does not form part of any contract of employment or other contract to provide services. We may update this notice at any time.

Data protection principles

We will comply with data protection law. This says that the personal information we hold about you must be:

  1. Used lawfully, fairly and in a transparent way.
  2. Collected only for valid purposes that we have clearly explained to you and not used in any way that is incompatible with those purposes.
  3. Relevant to the purposes we have told you about and limited only to those purposes.
  4. Accurate and kept up to date.
  5. kept only as long as necessary for the purposes we have told you about.
  6. Kept securely.

The kind of information we hold 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).

There are “special categories” of more sensitive personal data which require a higher level of protection.

We will collect, store, and use the following categories of personal information about you:

  • Personal contact details such as name, title, addresses, telephone numbers, and personal email addresses
  • Date of birth
  • Passport details and nationality
  • Gender
  • Marital status
  • Next of kin and emergency contact information.
  • National Insurance number
  • Bank account details, payroll records and tax status information
  • Salary, annual leave, pension and benefits information
  • Start date, end of employment date and review date
  • Location of employment or workplace
  • Copy of driving licence
  • Recruitment information (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)
  • Employment records (including job titles, work history, working hours, training records and professional memberships)
  • Compensation history
  • Performance information
  • Disciplinary and grievance information
  • CCTV footage and other information obtained through electronic means such as swipe card records
  • Information about your use of our information and communications systems.
  • Photographs
  • Car registration(s) numbers

We may also collect, store and use the following “special categories” of more sensitive personal information:

  • Information about your race or ethnicity, religious beliefs, sexual orientation and political opinions
  • Information about your health, including any medical condition, health and sickness records
  • Information about criminal convictions and offences.

How is your personal information collected?

We collect personal information about employees, workers and contactors through the application and recruitment process, either directly from candidates or sometimes from an employment agency or background check provider. We may sometimes collect additional information from third parties including former employers, credit reference agencies or other background check agencies.

We will collect additional personal information in the course of job-related activities throughout the period of you working for us.

How we will use information about you

We will only use your personal information when the law allows us to. Most commonly, we will use your personal information in the following circumstances:

  1. Where we need to perform the contract we have entered into with you.
  2. Where we need to comply with a legal obligation.
  3. Where 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 may also use your personal information in the following situations, which are likely to be rare:

  1. Where we need to protect your interests (or someone else’s interests).
  2. Where it is needed in the public interest.

Situations in which we will use your personal information

We need all the categories of information in the list above primarily to allow us to perform our contract with you (“Contract”) and to enable us to comply with legal obligations (“Legal”). In some cases we may use your personal information to pursue legitimate interests of our own or those of third parties (“Legitimate interests”), provided your interests and fundamental rights do not override those interests. The situations in which we will process your personal information are listed below.

  • Making a decision about your recruitment or appointment (Contract).
  • Determining the terms on which you work for us (Contract).
  • Checking you are legally entitled to work in the UK (Legal).
  • Paying you and, if you are an employee, deducting tax and National Insurance contributions (Legal and Contract).
  • Liaising with your pension provider (Legal and Contract).
  • Administering the contract we have entered into with you (Contract).
  • Business management and planning, including accounting and auditing (Legitimate interests).
  • Conducting appraisals, performance reviews, managing performance and determining performance requirements (Contract).
  • Making decisions about salary reviews and compensation (Contract).
  • Assessing qualifications for a particular job or task, including decisions about promotions (Contract and Legitimate interests).
  • Gathering evidence for possible grievance or disciplinary hearings (Contract).
  • Making decisions about your continued employment or engagement (Contract, Legal and Legitimate interests).
  • Making arrangements for the termination of our working relationship (Contract, Legal and Legitimate interests).
  • Education, training and development requirements (Contract and Legitimate interests).
  • Dealing with legal disputes involving you, or other employees, workers and contractors, including accidents at work (Contract and Legal)
  • Ascertaining your fitness to work (Contract and Legal).
  • Managing sickness absence (Contract and Legal).
  • Complying with health and safety obligations (Legal).
  • To prevent fraud (Legal).
  • To monitor your use of our information and communication systems to ensure compliance with our IT policies (Contract, legal and legitimate interests).
  • To ensure network and information security, including preventing unauthorised access to our computer and electronic communications systems and preventing malicious software distribution (Contract, legal and legitimate interests).
  • To conduct data analytics studies to review and better understand employee retention and attrition rates (Legitimate interests).
  • Equal opportunities monitoring and dealing with our regulators and quality assurance (Legal and Legitimate interests).
  • Some of the above grounds for processing will overlap and there may be several grounds which justify our use of your personal information.

If you fail to provide personal information

If you fail to provide certain information when requested, we may not be able to perform the contract we have entered into with you (such as paying you or providing a benefit), or we may be prevented from complying with our legal obligations (such as to ensure the health and safety of our workers).

Change of purpose

We will only use your personal information 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.

Please note that we may process your personal information without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.

How we use particularly sensitive personal information

“Special categories” of particularly sensitive personal information require higher levels of protection. We need to have further justification for collecting, storing and using this type of personal information. We may process special categories of personal information in the following circumstances:

  1. in limited circumstances, with your explicit written consent;
  2. Where we need to carry out our legal obligations;
  3. Where it is needed in the public interest, such as for equal opportunities monitoring;
  4. Where it is needed to assess your working capacity on health grounds, subject to appropriate confidentiality safeguards.

Less commonly, we may process this type of information where it is needed in relation to legal claims or where it is needed to protect your interests (or someone else’s interests) and you are not capable of giving your consent, or where you have already made the information public.

Our obligations as an employer

We will use your particularly sensitive personal information in the following ways:

  • We will use information relating to leaves of absence, which may include sickness absence or family related leaves, to comply with employment and other laws.
  • We will use information about your physical or mental health, or disability status, to ensure your health and safety in the workplace and to assess your fitness to work, to provide appropriate workplace adjustments, to monitor and manage sickness absence and to administer benefits.
  • We will use information about your race or national or ethnic origin, religious, philosophical or moral beliefs, or your sexual life or sexual orientation, to ensure meaningful equal opportunity monitoring and reporting.

Do we need your consent?

We do not need your consent if we use special categories of your personal information in accordance with our written policy to carry out our legal obligations or exercise specific rights in the field of employment law. In limited circumstances, we may approach you for your written consent to allow us to process certain particularly sensitive data. If we do so, we will provide you with full details of the information that we would like and the reason we need it, so that you can carefully consider whether you wish to consent.

Information about criminal convictions

We may only use information relating to criminal convictions where the law allows us to do so. This will usually be where such processing is necessary to carry out our obligations.

Less commonly, we may use information relating to criminal convictions 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, or where you have already made the information public.

We will only collect information about criminal convictions if it is appropriate given the nature of the role and where we are legally able to do so.

Data sharing

We may have to share your data with third parties, including third-party service providers and other entities in the group. We require third parties to respect the security of your data and to treat it in accordance with the law.

We may transfer your personal information outside the EU. If we do, you can expect a similar degree of protection in respect of your personal information.

Why might you share my personal information with third parties?

We will share your personal information with third parties where required by law, where it is necessary to administer the working relationship with you or where we have another legitimate interest in doing so.

Which third-party service providers process my personal information?

“Third parties” includes third-party service providers (including contractors and designated agents) and other entities within our group.

How secure is my information with third-party service providers and other entities in our group?

All our third-party service providers and other entities in the group are required to take appropriate security measures to protect your personal information in line with our policies. We do not allow our third-party service providers to use your personal data for their own purposes. We only permit them to process your personal data for specified purposes and in accordance with our instructions.

What about other third parties?

We may share your personal information with other third parties, for example in the context of the possible sale or restructuring of the business. We may also need to share your personal information with a regulator or to otherwise comply with the law.

Data security

We have put in place measures to protect the security of your information. Third parties will only process your personal information on our instructions and where they have agreed to treat the information confidentially and to keep it secure.

We have put in place appropriate security measures to prevent your personal information from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your personal information to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal information on our instructions and they are subject to a duty of confidentiality.

We have put in place procedures to deal with any suspected data security breach and will notify you and any applicable regulator of a suspected breach where we are legally required to do so.

Data retention

How long will you use my information for?

We will only retain your personal information for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, 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 requirements.

In some circumstances we may anonymise your personal information so that it can no longer be associated with you, in which case we may use such information without further notice to you. Once you are no longer an employee, worker or contractor of the company we will retain and securely destroy your personal information in accordance with applicable laws and regulations.

Rights of access, correction, erasure, and restriction

Your duty to inform us of changes

It is important that the personal information we hold about you is accurate and current. Please keep us informed if your personal information changes during your working relationship with us.

Your rights in connection with personal information

Under certain circumstances, by law you have the right to:

  • Request access to your personal information (commonly known as a “data subject access request”). This enables you to receive a copy of the personal information we hold about you and to check that we are lawfully processing it.
  • 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.

If you want to review, verify, correct or request erasure of your personal information, or object to the processing of your personal data, please contact the Commercial Director in writing.

No fee usually required

You will not have to pay a fee to access your personal information (or to exercise any of the other rights). However, we may charge a reasonable fee if your request for access is clearly unfounded or excessive. Alternatively, we may refuse to comply with the request in such 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 the information (or to exercise any of your other rights). This is another appropriate security measure to ensure that personal information is not disclosed to any person who has no right to receive it.

Right to withdraw consent

In the limited circumstances where you may have provided your consent to the collection, processing and transfer of your personal information for a specific purpose, you have the right to withdraw your consent for that specific processing at any time. To withdraw your consent, please contact the Commercial Director in writing. Once we have received notification that you have withdrawn your consent, we will no longer process your information for the purpose or purposes you originally agreed to, unless we have another legitimate basis for doing so in law.

Changes to this privacy notice

We reserve the right to update this privacy notice at any time, and we will provide you with a new privacy notice when we make any substantial updates. We may also notify you in other ways from time to time about the processing of your personal information.