Updated: 15th March 2018
- Only those within your organisation with the appropriate access level are able to view your information & we restrict access on our end.
- If you’d like to access, amend or delete any information please contact [email protected]
- We’re ISO27001 certified.
If at any time you are concerned or have questions about how we might be handling your data, please reach out to our Data Protection Officer at [email protected]
Charlie OS Limited (“CharlieHR”, "We", “Us” and “Our”) remain fully committed to the protection of your and your Users’ privacy at all times. The information contained in this policy has been published to inform you of the way in which any Personal Data (as defined below) you provide us with or we collect from you will be used. Please read this information carefully in order to fully understand how we treat such Personal Data.
We will collect, store, use and disclose Personal Data in accordance with all applicable laws relating to the protection of Personal Data, including the EU Data Protection Directive 95/46/EC, the EU General Data Protection Regulation 2016/679, the EU ePrivacy Directive 2002/58/EC as amended by Directive 2009/136/EC, as amended or superseded from time to time, and any national implementing legislation (“Data Protection Laws”).
For the purpose of Data Protection Laws, in relation to any Personal Data you or any Users submit to our platform, you will be the data controller and we will be a data processor of such Personal Data.
PERSONAL DATA WE MAY OBTAIN FROM YOU
“Personal Data” means any information relating to an identified or identifiable natural person; an identifiable person is one who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, an online identifier or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person.
We may obtain and use the following Personal Data about you and anyone you chose to add to our platform:
- Any correspondence we have with you and your Users should you or your Users contact us.
- Data you or your Users provide when you fill out forms on our Website, including but not limited to data you provide when you register to become a user of the Service.
- Any data and information you or your user provide to us in respect of our delivery of any service you have procured from CharlieHR.
- Data and information you or your Users submit or upload to Charlie or the Service, including employee data (which may include, among other things, dates of birth, residential addresses, names, email addresses, telephone numbers, National Insurance numbers, bank details, passport details, payroll numbers, salary and pension details, a record of sick days, certain medical information of Users).
- Details of transactions made by you through the Website.
- Responses to optional research surveys we ask you or Users to complete.
- Details of your or your Users’ visits to our Website, which includes without limitation location and traffic data, weblogs, resources you access and other communication data.
You will be submitting and providing Client Data which may contain Personal Data (and potentially Sensitive Personal Data of Users and third parties. “Sensitive Personal Data” means any data revealing racial or ethnic origin, political opinions, religious or philosophical beliefs, or trade union membership, genetic or biometric data, data concerning health, data concerning sex life or sexual orientation and data concerning the commission or alleged commission of any offence.
You agree to indemnify us in accordance with Clause 14 of the EULA for any claims made by any Users arising from any unauthorised access or accidental loss, damage, corruption or disclosure of Client Data arising from or in connection with your and/ or our use or disclosure of Client Data.
COOKIES AND IP ADDRESSES
We may obtain information about your and your Users’ computer, which includes your and your Users’ IP address, browser type and operating system where available. This accumulation of data is used to assist system administration.
We may also collect information regarding your or your Users’ browsing activity and interests through use of a cookie file. This cookie file is stored on the hard drive of your or your Users’ computer, and contains information that is transferred to your or your Users’ computer's hard drive. We use the collection of this data to help us improve the experience of users on our Website and Service, and to deliver a more personalised service with more relevant content. The collection of this data allows us to:
- store data indicative of your or your Users’ preferences, allowing us to adjust our Website to appeal to your individual interests; estimate the size and usage patterns of our audience;
- record the details of any transactions carried out by you through our Website;
- identify you or your Users upon your/their return to our Website; and/or
- increase the speed of your or your Users’ searches.
We use the following cookies:
- Strictly necessary cookies. These are cookies that are required for the operation of our Website and Service. They include, for example, cookies that enable you or your Users to log into secure areas of our Website or Service.
- Analytical/performance cookies. They allow us to recognise and count the number of visitors and to see how visitors move around our Website and Service when they are using it. This helps us to improve the way our Website and Service works.
- Functionality cookies. These are used to recognise you and your Users when you/they return to our Website. This enables us to personalise our content for you and your Users, greet you and your Users by name and remember your/their preferences.
- Targeting cookies. These cookies record your and your Users’ visit to our Website, the pages you and your Users have visited and the links you and your Users have followed. We will use this information to make our Website and the advertising displayed on it (if any) more relevant to your and your Users’ interests. We may also share this information with third parties for this purpose.
You can find more information about some of the individual cookies we use and the purposes for which we use them below. Example of cookies used by the Service:
WHERE WE STORE PERSONAL DATA
The Personal Data we obtain from you and your Users (including, without limitation, Client Data) may be moved to and stored at a destination within the European Economic Area ("EEA"). Staff members operating within the EEA who work for or on behalf of us may process this information. Such staff members may, among other things, be involved in the processing of payment details, the provision of support services and the delivery of your and your Users’ request(s) for us to provide the Service.
Without limiting the foregoing, you agree that Personal Data we obtain from you and your Users (including, without limitation, Client Data) may be processed by our service providers based in, countries outside of the EEA for the purposes of providing you with the Service. Such countries may not have laws offering the same level of protection for Personal Data as those inside the EEA; however where such transfers of data occur, we will take steps to prevent the transfer of Personal Data without adequate safeguards being put in place and will ensure that your and your Users’ Personal Data collected in the EEA and transferred internationally is afforded the same level of protection as it would be inside the EEA. For further information on, or a copy of, the adequate safeguards adopted by us for the international transfer of Personal Data, please email [email protected].
We store the Personal Data you and your Users provide us with on our secure servers. In the event of us giving you or your Users (or you/they choosing) a password which grants you/them access to specific areas within our Website or Service, it remains your/their responsibility to maintain the confidentiality of this password. This includes the responsibility to refrain from sharing your/their password with other parties.
As the transmission of data via the Internet cannot be assumed completely secure, we cannot guarantee the security of any of your or your Users’ data transmitted to our Website or Service; you are therefore responsible for any risk associated with such transmission. We will however at all times take all reasonable steps to ensure the transmission of your and your Users’ data is executed as securely as possible, and upon receipt of your/their data we will continue at all times to enforce strict security procedures and features in an attempt to prevent any unauthorised access.
HOW WE PROTECT YOUR PERSONAL DATA
We will take reasonable steps to maintain appropriate technical and organizational measures to protect the Personal Data you provide to us against accidental or unlawful destruction, loss, alteration, unauthorised disclosure of, or access to your Personal Data. We are also ISO27001 certified.
HOW WE USE YOUR PERSONAL DATA
The Personal Data we hold about you and your Users may be used in any of the following ways:
- To provide you and your Users with the Service, including administration and management of your account.
- To allow you to upload, store and access Client Data.
- To enable Users to access certain aspects of Charlie and limited Client Data pertinent to themselves.
- To provide you and Users with user support.
- To moderate your account.
- For research and analytics purposes (for example, to improve the quality of the Service).
- To ensure security for you, the Users, our staff and other users of the Service.
- To comply with applicable Laws, court orders, government and law enforcement agencies’ requests.
- To send you further information about our services for which we think you may have an interest. This information will be supplied only where you have given consent.
- To send you further information about our services based on a request we have received from you.
- To fulfil the obligations we have in relation to any contracts we have in place with you (including, without limitation, the EULA).
- To provide you with notification about any changes to the Service.
DISCLOSURE OF YOUR INFORMATION
Disclosure of your and your Users’ Personal Data (including, without limitation, Client Data) to third parties will only occur in any of the following events:
- We sell or purchase any business or assets. In such case, we may authorise the disclosure of your personal data to prospective sellers or buyers of such business or assets.
- All or the substantial majority of our assets are sold to a third party. In such case, your personal data may be one of the transferred assets.
- We are required to disclose your or your Users’ personal data in order to fulfil any legal obligation, to enforce our EULA, or to protect the property, rights or safety of Charlie, users of our services or others. In such case, information may be exchanged with third party companies or organisations in order to prevent fraud or reduce credit risk.
You acknowledge and agree that we may also disclose Personal Data (including, without limitation, Client Data) with: (i) our service providers involved in the provision, distribution, delivery and support of the Service, including the storage of any Client Data; (ii) fraud prevention agencies; (iii) law enforcement agencies, regulators, courts and public authorities; and (iv) emergency services.
Our service providers have to follow our express instructions when processing the Personal Data you or your Users provide and must have in place appropriate technical and organisational security measures to safeguard such Personal Data, and we do not allow them to use this information for their own commercial purposes.
You retain the right to request us to refrain from processing your data for the purposes of marketing. To exercise such right, you may reply to any information we send you, detailing your request that we refrain from sending any marketing correspondence, or you can exercise this same right by contacting us electronically via email at [email protected] If at any time we intend to use your data for such marketing purposes however, it is standard practice for us to make you aware in advance of collecting such data.
We may at times provide links on our Website to third party websites, including without limitation those owned or managed by our partner networks, affiliates or advertisers. These websites have separate privacy policies, and we therefore cannot accept any responsibility for the content. As such, choosing to follow these links is a choice you make at your own risk, and we advise that you check these websites' individual privacy policies before submitting any personal data.
You retain at all times the right to access / amend / delete any Personal Data we hold about you or to exercise your right of data portability or to object to, or restrict, the purposes for which your Personal Data is processed on certain grounds. You may exercise this right by making a request in accordance with Data Protection Laws, by emailing [email protected]. You may also lodge a complaint with the UK data protection regulator, the Information Commissioner should you be dissatisfied with the way that we handle your Personal Data.
HOW LONG WE KEEP PERSONAL DATA FOR
We will keep your and your Users’ Personal Data for the duration of the Service and in accordance with your instructions or for such periods as may be required by law.
If at any time we make a change to this policy, we will update this page to reflect such change. Where we feel it appropriate, we will notify you by email, however we recommend you review this page periodically to ensure you remain happy with the latest version.
QUESTIONS, COMMENTS AND GETTING IN TOUCH