YY CIRCLE UK LTD – PRIVACY POLICY

YY Circle UK Ltd, a company registered in England and Wales, with company number 15873679 (we, us or our), understands that protecting your personal data is important. This Privacy Policy sets out our commitment to protecting the privacy of personal data provided to us, or otherwise collected by us when providing our mobile application and website (Services) or when otherwise interacting with you.

It is important that you read this Privacy Policy together with any other detailed privacy notices we may provide when we are collecting or processing personal data about you so that you understand our privacy practices in relation to your data.

The information we collect

Personal data: is information that relates to an identified or identifiable individual.

    We may collect, use, store and disclose different kinds of personal data about you which we have listed below:

  • Identity Data including first name, middle name, last name, title, date of birth, gender, job title, National Insurance number, and photographic identification.
  • Contact Data including billing address, delivery address, email address and telephone numbers.
  • Financial Data including bank account and payment card details (through our third party payment processor, Stripe).
  • Background Verification Data including your passport number, your passport and birth certificate information, your parents’ names, driving licence number, photographic identification or other details requested as part of our onboarding process to comply with our due diligence obligations, anti-money laundering laws and related ongoing monitoring commitments.
  • Transaction Data including details about payments from you to us or from your employer, and other details of products and services you have purchased from us.
  • Technical and Usage Data including internet protocol (IP) address, your login data, your browser session and geo-location data, device and network information, statistics on page views and sessions, acquisition sources, search queries and/or browsing behaviour, information about your access and use of our website, including through the use of Internet cookies, your communications with our website, the type of browser you are using, the type of operating system you are using and the domain name of your Internet service provider.
  • Profile Data including your username and password for our mobile application, profile picture, purchases or requests you have made with us, support requests you have made, content you post, send, receive and share through our platform, information you have shared with our social media platforms, your interests, preferences, feedback and survey responses.
  • Interaction Data including information you provide to us when you participate in any interactive features of our Services, including surveys, contests, promotions, activities or events.
  • Marketing and Communications Data including your preferences in receiving marketing from us and our third parties and your communication preferences.
  • Professional data including where you are a worker of ours or applying for a role with us or with the businesses seeking workers on our mobile application, your professional history such as your previous positions and professional experience.
  • Special Categories of Personal Data is a special category of personal data that includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health and genetic and biometric data. In the course of providing our Services, we may collect, or come across such special categories of personal data, in different situations including during the course of conducting a background verification check on you, where you are a worker and you are using facial recognition technology to sign in and out at jobs, when reviewing your CV, and when assessing your right to work in the United Kingdom.

How we collect personal data

    We collect personal data in a variety of ways, including:

  • Directly: We collect personal data which you directly provide to us, including when you register for an account, through the ‘contact us’ form on our website/mobile application or when you request our assistance via email, or over the telephone.
  • Indirectly: We may collect personal data which you indirectly provide to us while interacting with us, such as when you use our website, our mobile application, in emails, over the telephone and in your online enquiries.
  • From third parties: We collect personal data from third parties, such as from your employer where they invite you to access our Services and details of your use of our website from our analytics and cookie providers and marketing providers. See the “Cookies” section below for more detail on the use of cookies.
  • From publicly available sources: We collect personal data from publicly available resources such as Companies House and professional networking sites such as LinkedIn.

End User Data

Where your personal data is input into our Services, or where our Services are made available to you through a third party (e.g. your employer), that business is the ‘controller’ of any personal data input into the Services (End User Data), and we act as a ‘processor’ to process End User Data on behalf of the controller. The controller is responsible for complying with any regulations or laws that require providing notice, disclosure, and/or obtaining your consent prior to transferring the End User Data to us to process on their behalf, and therefore End User Data is not covered by this Privacy Policy. You should view the controller’s privacy policy and/or contact the controller to understand their privacy practices in relation to your End User Data.

Purposes and legal bases for processing

We collect and process personal data about you only where we have legal bases for doing so under applicable laws. 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 reach out to us if you need further 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 of use / disclosure Type of Data Legal Basis for processing
To enable you to access and use our mobile application, including to provide you with a login.
  • Identity Data
  • Contact Data
  • Performance of a contract with you
To assess whether you have the appropriate rights to work in the United Kingdom, including to perform anti-money laundering, anti-terrorism, sanction screening, fraud and other background checks on you. Where you are required to sign in and out at a shift as a worker, facial recognition technology will be used for administrative purposes.
  • Identity Data
  • Contact Data
  • Background Verification Data
  • Special Categories of Data
  • Performance of a contract with you
  • To comply with a legal obligation
  • Public interest
  • Legitimate interests: ensuring we do not deal with proceeds of criminal activities or assist in any other unlawful or fraudulent activities for example terrorism
  • Consent
To provide our Services to you, including to assess your application for an account, manage your work shifts and employment related requests.
  • Identity Data
  • Contact Data
  • Background Verification Data
  • Transaction Data
  • Professional Data
  • Performance of a contract with you
  • Legitimate interests: ensuring you have the appropriate rights to work in the United Kingdom.
To contact and communicate with you about our Services including in response to any support requests you lodge with us or other enquiries you make with us.
  • Identity Data
  • Contact Data
  • Profile Data
  • Performance of a contract with you
To contact and communicate with you about any enquiries you make with us via our website.
  • Identity Data
  • Contact Data
  • Legitimate interests: to ensure we provide the best client experience we can offer by answering all of your questions.
For internal record keeping, administrative, invoicing and billing purposes.
  • Identity Data
  • Contact Data
  • Financial Data
  • Transaction Data
  • Performance of a contract with you
  • To comply with a legal obligation
  • Legitimate interests: to recover debts due to us and ensure we can notify you about changes to our terms and conditions and any other administrative points.
For analytics including profiling on our mobile application, market research and business development, including to operate and improve our Services, associated applications and associated social media platforms.
  • Profile Data
  • Technical and usage Data
  • Legitimate interests: to keep our website updated and relevant, to develop our business, improve our Services and to inform our marketing strategy
For advertising and marketing, including to send you promotional information about our events and experiences and information that we consider may be of interest to you.
  • Identity Data
  • Contact Data
  • Technical and usage Data
  • Profile Data
  • Marketing and communications Data
  • Legitimate interests: to develop our Services and grow our business
To run promotions, competitions and/or offer additional benefits to you.
  • Identity Data
  • Contact Data
  • Profile Data
  • Interaction Data
  • Marketing and communications Data
  • Legitimate interests: to facilitate engagement with our business and grow our business
If you have applied to work with us; to consider your application. If you are applying for roles on our mobile application, to enable businesses to consider your application.
  • Identity Data
  • Contact Data
  • Professional Data
  • Legitimate interests: to consider your employment application
To comply with our legal obligations or if otherwise required or authorised by law.
  • All relevant Personal Data
  • To comply with a legal obligation

If you have consented to our use of data about you for a specific purpose, you have the right to change your mind at any time, but this will not affect any processing that has already taken place. Where we are using your data because we or a third party have a legitimate interest to do so, you have the right to object to that use though, in some cases, this may mean no longer using our services. Further information about your rights is available below.

Our disclosures of personal data to third parties

    We may disclose personal data to:

  • our employees, contractors and/or related entities;
  • IT service providers, data storage, web-hosting and server providers such as Amazon Web Services (AWS);
  • marketing or advertising providers such as “Google Ads”
  • professional advisors, bankers, auditors, our insurers and insurance brokers;
  • payment systems operators such as Stripe;
  • where you are a job seeker: potential employers, such as vendors in the hospitality industry;
  • our existing or potential agents or business partners;
  • sponsors or promoters of any promotions or competition we run;
  • anyone to whom our business or assets (or any part of them) are, or may (in good faith) be, transferred;
  • courts, tribunals and regulatory authorities, in the event you fail to pay for goods or services we have provided to you;
  • courts, tribunals, regulatory authorities and law enforcement officers, as required or authorised by law, in connection with any actual or prospective legal proceedings, or in order to establish, exercise or defend our legal rights;
  • third parties to collect and process data, such as Google Analytics (To find out how Google uses data when you use third party websites or applications, please see www.google.com/policies/privacy/partners/ or any other URL Google may use from time to time), Meta Pixel or other relevant analytics businesses; and
  • any other third parties as required or permitted by law, such as where we receive a summons.

    • Google Analytics: We have enabled Google Analytics Advertising Features including Remarketing Features, Advertising Reporting Features, Demographics and Interest Reports, Store Visits, and Google Display Network Impression reporting. We and third-party vendors use first-party cookies (such as the Google Analytics cookie) or other first-party identifiers, and third-party cookies (such as Google advertising cookies) or other third-party identifiers together.

    You can opt-out of Google Analytics Advertising Features including using a Google Analytics Opt-out Browser add-on found here. To opt-out of personalised ad delivery on the Google content network, please visit Google’s Ads Preferences Manager here or if you wish to opt-out permanently even when all cookies are deleted from your browser you can install their plugin here. To opt out of interest-based ads on mobile devices, please follow these instructions for your mobile device: On android open the Google Settings app on your device and select “ads” to control the settings. On iOS devices with iOS 6 and above use Apple’s advertising identifier. To learn more about limiting ad tracking using this identifier, visit the settings menu on your device.

Overseas transfers

    Where we disclose personal data to the third parties listed above, these third parties may store, transfer or access personal data outside of the United Kingdom, including Singapore. The level of data protection in countries outside of the United Kingdom may be less comprehensive than what is offered in the United Kingdom. Where we transfer your personal data outside of the United Kingdom, we will perform those transfers using appropriate safeguards in accordance with the requirements of applicable data protection laws and we will protect the transferred personal data in accordance with this Privacy Policy. This includes:

  • only transferring your personal data to countries that have been deemed by applicable data protection laws to provide an adequate level of protection for personal data; or
  • including standard contractual clauses in our agreements with third parties that are overseas.

Data retention

    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. 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.

    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.

Your rights and controlling your personal data

    Your choice: Please read this Privacy Policy carefully. If you provide personal data to us, you understand we will collect, hold, use and disclose your personal data in accordance with this Privacy Policy. You do not have to provide personal data to us, however, if you do not, it may affect our ability to provide our Services to you and your use of our Services.

    Information from third parties: If we receive personal data about you from a third party, we will protect it as set out in this Privacy Policy. If you are a third party providing personal data about somebody else, you represent and warrant that you have such person’s consent to provide the personal data to us.

    Access, correction, processing and portability: You may request details of the personal data that we hold about you and how we process it (commonly known as a “data subject request”). You may also have a right in accordance with applicable data protection law to have your personal data rectified or deleted, to restrict our processing of that information, to object to decisions being made based on automated processing where the decision will produce a legal effect or a similarly significant effect on you, to stop unauthorised transfers of your personal data to a third party and, in some circumstances, to have personal data relating to you transferred to you or another organisation.

    Unsubscribe: To unsubscribe from our e-mail database or opt-out of communications (including marketing communications), please contact us using the details below or opt-out using the opt-out facilities provided in the communication.

    Withdraw consent: Where we are relying on consent to process your personal data, you have the right to withdraw your consent at any time. 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 products or services to you. We will advise you if this is the case at the time you withdraw your consent.

    Complaints: If you wish to make a complaint, please contact us using the details below and provide us with full details of the complaint. We will promptly investigate your complaint and respond to you, in writing, setting out the outcome of our investigation and the steps we will take to deal with your complaint. 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.

Storage and security

    We are committed to ensuring that the personal data we collect is secure. In order to prevent unauthorised access or disclosure, we have put in place suitable physical, electronic and managerial procedures, to safeguard and secure personal data and protect it from misuse, interference, loss and unauthorised access, modification and disclosure.

    While we are committed to security, we cannot guarantee the security of any information that is transmitted to or by us over the Internet. The transmission and exchange of information is carried out at your own risk.

Cookies

    We may use cookies on our website and mobile application from time to time. Cookies are text files placed in your computer's browser to store your preferences and to provide a better user experience. Cookies, by themselves, do not tell us your email address or other personally identifiable information. If you choose to provide our online services with personal data, this data may be linked to the data stored in the cookie. Where required by law, we will always seek your consent before placing any non-essential cookies on your device. For more information about the cookies we use, or to update your consent preferences, please see our Cookie Policy available at https://www.yycircle.com/privacy.html.

Links to other websites

    Our website may contain links to other party’s websites. We do not have any control over those websites and we are not responsible for the protection and privacy of any personal data which you provide whilst visiting those websites. Those websites are not governed by this Privacy Policy.

Personal data from social network accounts

    If you connect your account with us to a social network account, such as Facebook, we will collect your personal data from the social network. We will do this in accordance with the privacy settings you have chosen on that social network.

    The personal data that we may receive includes your name, ID, user name, handle, profile picture, gender, age, language, list of friends or followers and any other personal data you choose to share.

    We use the personal data we receive from the social network to create a profile for you on our mobile application.

    If you agree, we may also use your personal data to give you updates on the social network which might interest you. We will not post to your social network without your permission.

    Where we have accessed your personal data through your Facebook account, you have the right to request the deletion of personal data that we have been provided by Facebook. To submit a request for the deletion of personal data we acquired from Facebook, please send us an email at the address at the end of this Privacy Policy and specify in your request which personal data you would like deleted. If we deny your request for the deletion of personal data, we will explain why.

Use of Google API Services (this section applies to personal data accessed through Google API Services)

    We use Google’s Application Programming Interface (API) Service to collect user behaviour on our mobile application.

    Our use of information received from Google APIs will adhere to the Google API Services User Data Policy, including the Limited Use requirements (set out in the Google API Services User Data Policy).

    We limit our use of the personal data that we collect to providing or improving our Services. We do not use the personal data for any other purposes.

    We only transfer the personal data to others if it is necessary to provide or improve our Services or as necessary to comply with applicable law or as part of a merger, acquisition or sale of assets where we notify you of this.

    We do not use or transfer the personal data for serving ads, including retargeting, personalised or interest based advertising.

    These restrictions apply to the raw data we obtain from the restricted scopes and data that is aggregated, anonymised or derived from them.

    We have policies and procedures in place setting out appropriate safeguards for protecting your personal data obtained with the Google APIs. We will also ensure that our employees, agents, contractors and successors comply with the Google API Services Data Policy.

Use of geo-localisation data

    We collect your precise or approximate location via our mobile application for the following purposes:

  • determine your location to find jobs near you in real time (where you are a jobseeker) and where you are a business, to allow jobseekers to find vacancies; and
  • as permitted by law.

    • We collect this information when our mobile application is open (whether on-screen or not). If you do not want us to use your location for the purposes above, you should turn off the location services in your account settings in the mobile application or in your mobile phone settings. If you do not provide location information to us, we may not be able to provide our Services to you.

Amendments

We may change this Privacy Notice from time to time. We will notify you if we make a significant change to this Privacy Notice, by contacting you through the contact details you have provided to us and by publishing an updated version on our website.

Children

We do not provide our Services to anyone under the age of 18. If you believe we are holding personal data for someone under the age of 18, please let us know and we will verify the information and delete as needed.

    For any questions or notices, please contact our data protection officer (DPO) at:

    YY Circle UK Ltd, a company registered in England and Wales, with company number 15873679.

    Data Protection Officer or Data Privacy Manager: Keith Budden IAPP IAAP, Ensurety, 28 Inwood Rd, Liss GU33 7LZ.  Contact details email keith@ensurety.co.uk telephone 07858 138218

    Last update: 8 October 2024

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