Privacy notice

Our Candidate Privacy Notice can be found here

Our Marketing Privacy Notice can be found here

Introduction

WEBSITE PRIVACY NOTICE 

Welcome to Newton’s privacy notice which applies to users of our website. We may update it at any  time.  

We have separate Privacy Notices for the following groups of people: 

- employees and contractors; 

- candidates applying for roles at Newton; 

- those agreeing to take part in our marketing activities/events; and 

- those whose data we may process on behalf of one or more of our clients. 

Newton respects your privacy. We think that it is important to be transparent about how we collect  and use your personal data and are committed to protecting the privacy and security of the  information we hold about you. This privacy notice provides more information about how we do this  and provides you with certain information that must be provided under the retained EU law version of  the General Data Protection Regulation (UK GDPR).  

PURPOSE OF THIS PRIVACY NOTICE 

This privacy notice aims to give you information on how Newton collects and processes your personal  data through your use of this website, including any data you may provide through this website when  you sign up to receive more information from us or register to attend an event.  

This website is not intended for children and we do not knowingly collect data relating to children. 

It is important that you read this privacy notice together with any other privacy notice or fair processing  notice we may provide on specific occasions when we are collecting or processing personal data about  you so that you are fully aware of how and why we are using your data. This privacy notice supplements  the other notices and is not intended to override them.  

CONTROLLER 

Newton Europe Limited is the “data controller” and responsible for your personal data (referred to as  “Newton”, "we", "us" or "our" in this privacy notice). This means that we decide how we hold and use  personal information about you.  

If you have any questions about this privacy notice, including any requests to exercise your legal rights,  please contact us using the details set out below: 

Full name of legal entity: Newton Europe Limited 

Email address: info@newtoneurope.com

Postal address: 2 Kingston Business Park, Kingston Bagpuize, Abingdon, Oxfordshire, OX13  5FE 

Telephone: 01865 950969 

THIRD-PARTY LINKS 

This website may include links to third-party websites, plug-ins and applications. Clicking on those links  or enabling those connections may allow third parties to collect or share data about you. We do not  control these third-party websites and are not responsible for their privacy statements. When you  leave our website, we encourage you to read the privacy notice of every website you visit. 

DATA PROTECTION PRINCIPLES 

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

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, maiden name, last name, username or similar identifier,  marital status, title, date of birth and gender. 

Contact Data includes address, email address and telephone numbers.

Financial Data including bank account details. 

Technical Data includes internet protocol (IP) address, browser type and version, time zone  setting and location, browser plug-in types and versions, operating system and platform and  other technology on the devices you use to access this website.  

Usage Data includes information about how you use our website.

Marketing and Communications Data includes your preferences in receiving marketing from  us and your communication preferences. 

We also collect, use, store and share Aggregated Data such as statistical or demographic data for any  purpose. Aggregated Data may be derived from your personal data but is not considered personal data  in law as this data does not directly or indirectly reveal your identity. For example, we may aggregate  your Usage Data to calculate the percentage of users accessing a specific website feature. However, if  we combine or connect Aggregated Data with your personal data so that it can directly or indirectly  identify you, we treat the combined data as personal data which will be used in accordance with this  privacy notice. 

We do not collect any Special Categories of Personal Data about you (this 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). Nor do we  collect any information about criminal convictions and offences. 

HOW IS YOUR PERSONAL DATA COLLECTED? 

We use different methods to collect data from and about you including through:

You may give us your Identity and 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: 

o subscribe to our service or publications;  

o request marketing to be sent to you; 

o enter into any of our competitions or prize draws; 

o register to attend one of our events; or 

o give us some feedback.  

As you interact with our website, we may automatically collect Technical Data about your equipment,  browsing actions and patterns. We collect this personal data by using cookies, server logs and other  similar technologies. We may also receive Technical Data about you if you visit other websites  employing our cookies. Please see our cookie policy [https://www.newtoneurope.com/legal] for further details. 

We may receive personal data about you from various third parties and public sources as set out below:  

o Technical Data from the following parties: analytics providers such as Google based outside  the EU, advertising networks and search information providers;

o Identity and Contact Data from publicly availably sources such as Companies House and the  Electoral Register based inside the EU. 

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: 

In this context, “legitimate interest” means the interest of our business in conducting and  managing our business to enable us to give you the best service and the best and most secure  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). 

Generally, we do not rely on consent as a legal basis for processing your personal data. If we expressly  tell you that we are relying on consent as a legal basis for processing your personal data, you can  withdraw consent at any time by contacting us at info@newtoneurope.com.  

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 at info@newtoneurope.com 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 manage our relationship  with you which may include: 

(a) Notifying you about  

changes to our terms or  

privacy policy

(a) Identity  

(b) Contact  

(c) Profile 

(a) Performance of a contract with  you  

(b) Necessary to comply with a legal  obligation

(b) Asking you to leave a review  or take a survey (d) Marketing and  Communications (c) Necessary for our legitimate  interests (to keep our records  updated and to study how clients use  our services)
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 and advertisements to  you and measure or  understand the effectiveness  of the advertising we serve to  you

(a) Identity  

(b) Contact  

(c) Profile  

(d) Usage  

(e) Marketing and  

Communications  

(f) Technical 

Necessary for our legitimate interests (to study how clients use  our website and services, to develop  them, to grow our business and to  inform our marketing strategy)
To administer any  competitions or prize draws  that we may run from time to  time

(a) Identity  

(b) Contact  

(c) Profile  

(d) Usage 

Necessary for our legitimate  interests (to run competitions and  prize draws which are of interest to  our clients and to promote Newton)
To use data analytics to  improve our website, services,  marketing, client relationships  and experiences

(a) Technical  

(b) Usage 

Necessary for our legitimate  interests (to define types of clients for our products and services, to  keep our website updated and  relevant, to develop our business and  to inform our marketing strategy)

THIRD-PARTY MARKETING  

We won’t share your personal data with any third party for their marketing purposes.  

OPTING OUT 

You can ask us or third parties to stop sending you marketing messages at any time by contacting us  at info@newtoneurope.com.  

COOKIES 

You can set your browser to refuse all or some browser cookies, or to alert you when websites set or  access cookies. If you disable or refuse cookies, please note that some parts of this website may  become inaccessible or not function properly. Please see our cookie policy  [https://www.newtoneurope.com/legal] for further details. 

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 you wish to get an explanation as to how the processing for the new purpose is compatible  with the original purpose, please contact us at info@newtoneurope.com.  

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. 

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. 

WHO HAS ACCESS TO YOUR PERSONAL DATA? 

We may have to share your personal data with the parties set out below for the purposes set out in the  table above. 

External Third Parties such as: 

Service providers acting as processors based inside and outside the UK who provide IT and system administration services. 

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. 

INTERNATIONAL TRANSFERS 

Many of our external third parties are based outside the United Kingdom (UK) so their processing of  your personal data will involve a transfer of data outside the UK. 

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:  

Please contact us at info@newtoneurope.com if you want further information on the specific  mechanism used by us when transferring your personal data out of the UK.  

HOW DO WE PROTECT YOUR PERSONAL DATA? 

We have put in place measures to protect the security of your information. Details of these measures  are available upon request.  

We have also 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. 

Where we engage third parties to process personal data on our behalf, they do so on the basis of  written instructions, are under a duty of confidentiality and are obliged to implement appropriate  technical and organisational measures to ensure the security of data 

FOR HOW LONG DO WE KEEP YOUR PERSONAL DATA? 

We will only retain your personal data 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. After this  period, we will securely destroy your personal information in accordance with applicable laws. 

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 you can ask us to delete your data: see Request erasure below for further  information. 

In some circumstances we may anonymise your personal data (so that it can no longer be associated  with you) for research or statistical purposes in which case we may use this information indefinitely  without further notice to you.  

WHAT ARE YOUR RIGHTS? 

Under certain circumstances, you have rights under data protection laws in relation to your personal  data, including:  

If you wish to exercise any of the rights set out above, please contact us at info@newtoneurope.com

If you believe that we have not complied with your data protection rights, you can complain to the  Information Commissioner's Office (ICO), the UK supervisory authority 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. 

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 may 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 may 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. 

CHANGES TO THE PRIVACY NOTICE OR TO YOUR PERSONAL DATA  

We keep our privacy policy under regular review and may update this privacy notice at any time. 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.