Privacy & Cookies Policy

Last updated at: February 20, 2024, 11:39:57

1. PRIVACY POLICY OF PRIMEENG GROUP LIMITED

This Privacy Policy explains what we do with your personal data. It describes the way we gather, use and handle your personal data and, by doing so, how we comply with our legal obligations towards you. Your privacy is important to us and we are focused on protecting and safeguarding your personal data. Please take a few moments to get to know our privacy practices. If you have any question, contact us through the email address info@weareprime.com, or through the postal address address Aspen House, Ground Floor Rear, 25 Dover Street, London, W1S 4LX London. We try to keep this Privacy Policy as simple as possible but, in the case you are not familiar with any of the terms used or if you have any questions, don’t hesitate to contact PRIMEENG GROUP LIMITED to know more. Occasionally, we may alter this Privacy Policy. If you want to keep up to date, visit this page, as all alterations shall be published here.

2. Who gathers your personal data and who is the authority responsible for its handling

The handling of any personal data gathered by PRIMEENG GROUP LIMITED , or provided to them, are responsibility of the company PRIMEENG GROUP LIMITED, a public limited company, legal person no. 8958587, with registered office at address Aspen House, Ground Floor Rear, 25 Dover Street, London, W1S 4LX London, which contact data may be found later on this Privacy Policy (hereinafter referred to as “PRIMEENG GROUP” or “we”).

3. How is your personal data gathered and what type of data is gathered

Please be aware that you are not forced to provide us your personal data that the company might request (being able to, at any time, exercise your right of opposition), but, if you choose not to do so, we might not be able to provide you our services, manage your application or answer to any question you might have. We may gather your personal data on many ways, namely when you subscribe our newsletter, send us spontaneous applications, register yourself on University’s employment platforms, job fairs, references of collaborators or ex-collaborators, workshops and partnerships aimed to be contacted by us, enter a contract with us (work, provision of services or other), fill your customer’s form or communicate with our customer support teams. If you are a candidate, aiming to identify and find the best job opportunities and/or possible services adapted to you, we have to handle certain information about you. We only request data that will be relevant to us, such as your name, age, contact data, information on training, employment history, emergency contact, immigration status, financial information (in case we need to verify the financial context) and social security number (and, obviously, you may opt to share with us other relevant information). When it is appropriate, and accordingly to the law, we may also gather diverse information or data on any criminal convictions. If you are a PRIMEENG GROUP customer, we need to gather and use information about you or about the people of your company in the scope of our provision of services, in order to provide to you a service as complete as possible and so that our contractual relationship may correctly progress. As so, in this scope, we may request some personal data such as your name, email address, position and contact number of relevant employees for the provision of services. If you’re a supplier, we need a small amount of information concerning your personal data in order to ensure that everything works correctly. We need the contact data of certain people of your company, so we can communicate with you, as well as other information, such as your bank data so we can pay you for the services provided (if that is part of the contractual provisions entered between us). We may also hold information that someone from your company has chosen to share with us. When we talk about suppliers, we aim to include any companies (including traders working individually) and atypical service providers, such as independent contractors and freelance workers, which provide services to us. Under certain circumstances, we shall subcontract the services provided to customers to third-party suppliers that perform their services on behalf of us. In this context, the suppliers who are traders working individually, freelance workers or supplier’s collaborators shall be treated as candidates for the purposes of data protection. Be aware that, in this context, we demand that the suppliers inform their collaborators of the relevant parts of this Privacy Policy (namely the sections aimed for the candidates). Certain personal data categories, such as the ones which reveal the racial or ethnic origin, political opinions, religious or philosophic beliefs or the union membership, the genetic data, the biometric data to unquestionably identify a person, the data concerning health, sexual life or sexual orientation, are classified as “special categories of personal data” and benefit from an additional protection under the terms of the General Data Protection Regulation (“GDPR”). We limit, as much as possible, the circumstances in which it gathers and handles these special categories of data, only doing so when your consent has been given. In order to give our users a greater speed and customization of the services provided by PRIMEENG GROUP, this company shall resort to a browser operation called “cookies”, which allows us to customize your services and website accordingly to your interests and needs, enabling the optimization of your future activities and experience on the PRIMEENG GROUP website. Therefore, data concerning parameters and configuration of your browser, operating system and geolocation may be gathered. During part of your browsing on PRIMEENG GROUP website, we may also use software tools to measure and gather information about the session, including response times of the pages, download errors, duration of the visit to certain pages, information concerning your interaction with them and methods used to leave them. We may also gather technical information to help us identify your device for purposes of fraud prevention and diagnosis.

4. Purposes and grounds for the handling of your personal data

The purposes and grounds based on which we handle your personal data depends on your quality as a candidate, collaborator or supplier. If you are a candidate (where we include suppliers who are traders working individually, freelance workers or supplier’s collaborators), please know that your personal data is gathered and handled, namely, for the following purposes:

• Recruitment – includes recruiting activities for the provision of services or backoffice functions, such as research and selection. In the case of provision of services, there is an approach to the companies of the Group, to current and potential customers of it, aiming to find an opportunity, be placed at any of the Group’s companies, as well as related activities. In this scope, data concerning the processing of salaries and human resources management will also be handled;

• Contract execution – includes activities such as entering contracts with us or a Group’s company and partners, as well as the communication with third parties involved in the contracts (insurance companies, beneficiaries, intermediates);

If you’re a supplier or a customer, your personal data are gathered and handled, namely, for the following purposes:

• Contract execution – includes all the necessary activities for the execution of the provision of services contract, namely concerning the payment processing;

• Communications – includes the necessary contacts so we can contact you about our contracts;

• Service development and improvement – includes the necessary activities for the development and improvement of the services provided to or by PRIMEENG GROUP, analysis of the activity, processing for statistical and scientific purposes, as well as to offer you services and obtain support and services from you;

• Compliance with the legal obligations;

• In certain circumstances, to help us with the statement, exercise or defense of a right.

We may resort to third parties, external service providers, which operate on our behalf, such as companies which hold and operate the PRIMEENG GROUP website, process payments, analyze data, provide services to the customer, and sponsors and other third parties which directly collaborate with the activity developed by PRIMEENG GROUP, so that your personal data may be handled by these third parties for the purposes described on this Privacy Policy. These third entities shall process your personal data accordingly to this Privacy Policy and accordingly to the applicable law. When we gather your personal data for the above-mentioned purposes or for other purposes, we inform you previously or upon the moment of the gathering, and we aim to get your consent whenever necessary to legitimize the handling of your data. When you have consented to the handling activities, you shall have the right to withdraw your consent at any time. Nevertheless, there may be some cases in which it is not your consent that legitimizes the handling of your personal data, but one of the following grounds:

• When the handling is necessary to enter a contract with you or carry out its execution;

• When the handling is necessary for the compliance with the legal obligations to which PRIMEENG GROUP is subject;

• When the handling is necessary to reach a legitimate interest sustained by PRIMEENG GROUP, which doesn’t endanger your interests, rights and fundamental freedoms that demand the protection of personal data – this legal base shall only be used if there is no less intrusive way to handle your personal data. We can assure that if the legitimate interest is used as a reason to handle your personal data, we shall keep a registry of this action and you shall have the right to request this information;

• When the handling is necessary for purposes of declaration, exercise or defense of a right on a legal process.

5. The safety of your personal data

We use all the possible measures to ensure the confidentiality and safety of your personal data, carrying out all the efforts and safety measures to protect your personal data from misuse, interference, loss, non-authorized access, modification or disclosure. Our measures include the implementation of appropriate access control, to ensure that we encrypt, pseudo-denominate and make anonymous the personal data whenever possible. The access to your personal data is only allowed on the above-mentioned terms, always according to the effective need for your knowledge and subject to strict contractual confidentiality obligations whenever processed by third parties. Even though the data transfer through the internet or website may not ensure complete safety against intrusions, PRIMEENG GROUP and their service providers use the best efforts to implement and maintain physic, electronic and procedural safety measures aimed to protect your personal data, accordingly to the applicable data protection requirements.

6. Storage period of your personal data

We shall store your data only for the strictly necessary time to fulfill the purpose for which they have been gathered. Namely in the case of the personal data gathered on the scope of recruitment processes, these shall be stored for a period of 10 (ten) years after the last contact with the candidate. In the case of the personal data of our suppliers and customers, it shall be stored for a period of 10 (ten) years.

7. With who will your personal data be shared

PRIMEENG GROUP is comprised on a business group, so your data may be disclosed to other companies of the group within the context of the provision of services shared between the companies of the group and for the purposes of internal report. On the other hand, your personal data may be shared with our customers, in the scope of technological consulting services. As mentioned on Point C of this Privacy Policy, your personal data may be shared with external service providers that operate on behalf of PRIMEENG GROUP. In this scope, your personal data shall be shared with the companies currently subcontracted by PRIMEENG GROUP, as well as with other service providers to which we may resort in the future. Pursuant to the applicable law, PRIMEENG GROUP is bound to disclose data to the Tax Administration, Social Security, Work Conditions Authority and, in the aftermath of judicial mandates, to the legal authorities.

8. International data transfers

PRIMEENG GROUP shares your personal data internally or with third parties for the purposes described on this Privacy Policy. PRIMEENG GROUP shall only send personal data gathered within the European Economic Area (EEA) to foreign countries in cases in which this is necessary to follow their instructions, comply with a legal obligation or work with agents and consultants that help us manage our businesses and services. If a personal data transfer to the exterior of EEA occurs, PRIMEENG GROUP shall ensure that these are protected as if they were being used in the EEA. For this purpose, we shall use one of the following safeguards:

• Transfer to a country non-belonging to the EEA in which privacy legislation ensures an adequate level of personal data protection similar to the ones on the EEA.

• Implementation of a contract with the foreign authority which bounds them to protect the personal data accordingly to the same standards used in the EEA; or

• Transfer of personal data to organizations with specific agreements of international data transfers with the European Union (for instance, the Privacy Shield, a structure which defines standards of data privacy shared between the United States and the European countries).

9. Which are your rights?

As the holder of your personal data, you are granted a set of rights concerning your personal data and the way they are handled, as follows:

• Right of opposition – that is, the right to oppose, at any moment, for reasons concerning your individual situation, to the handling of your personal data, under the terms of the GDPR;

• Right of information – that is, the right that you are granted to be given a concise, transparent, understandable and easy to access information, using a clear and simple language about the way we use your personal data and about your rights.

• Right of access – that is, the right to access, at all time, to your personal data.

• Right of rectification – that is, the right to rectify your inaccurate personal data or complete it if they are incomplete;

• Right of limitation – in certain situations, the holder of the data has the right to limit the handling of your personal data;

• Right of deletion – in certain situations, the holder of the data has the right to make the responsible for the handling delete their personal data, with no justified delay;

• Right of portability of your personal data – that is, the right to receive your personal data or the data you have provided, on a structured format, of current use and automatic reading, as well as the right to transfer these data to an other responsible for the handling, in certain situations;

• Right to present a claim to the control authority on the way we handle your personal data – which shall be the UK Information Commissioner’s Office, domiciled at Wycliffe House, Water Lane, Wilmslow, Cheshire, SK9 5AF, telephone 0303 123 1113, Fax 01625 524510, website https://ico.org.uk/. For further information, please visit the ICO’s website.

• Right to withdraw your consent – in this case, the withdrawal of the consent doesn’t compromise the lawfulness of the performed handling based on the previously given consent;

• Right not to be subject to decisions uniquely based on automatized processes which produce legal effects or other significant effects.

The above-mentioned rights may be exercised at all times through a communication sent to PRIMEENG GROUP LIMITED, for the contacts established on this Privacy Policy. Your requests will be handled with exceptional care in order to ensure the efficiency of your rights. You may be requested to prove your identity in order to ensure that the sharing of personal data is only carried out with its holder.

10. Contact details concerning PRIMEENG GROUP

If you have any question about this Privacy Policy or about the handling and use we carry out with your personal data, or if you want to present a claim on a possible breach of the privacy laws, please contact the responsible for the data handling through the email info@weareprime.com, or through the postal address Aspen House, Ground Floor Rear, 25 Dover Street, London, W1S 4LX London. PRIMEENG GROUP will update this Privacy Policy whenever necessary to reflect the feedback of the data holders, the changes on your services, as well as to comply with all the requirements legally required. In the case these alterations imply a significant modification of this Privacy Policy, the data holders shall be duly notified, and their consent might be requested whenever necessary. Your satisfaction is very important to us. As such, don’t hesitate to contact us with any question you might have, through the indicated contacts.

11. Cookie Policy - Definition of Cookies

Cookies are small text files that are placed on the User’s computer or mobile device through an internet browser, during a visit to a digital platform. Cookies are used to make websites function, or to work more efficiently, as well as to provide statistical information to site owners. Some cookies also allow the display of relevant advertising when Users move from websites to website.  Most cookies do not collect information that allows Users to be identified and are limited to collecting data of a general nature, serving to measure attendance or determine the approximate location of users who access this Website.

This Cookie Policy forms part of our Privacy Policy. For more information, please see our Privacy Policy available on this Website.

12. Types of Cookies

Necessary

Necessary cookies help make a website usable by enabling basic functions like page navigation and access to secure areas of the website.  These cookies can’t be rejected as they are strictly necessary to provide a functional website.

Preferences

Preferences cookies enable a website to remember information that changes the way the website behaves or looks, like User’s preferred language or the region that the User are in.

Statistics

Statistic cookies help website owners to understand how visitors interact with websites by collecting and reporting information anonymously. These cookies are used anonymously for the purposes of creating and analyzing statistics, allowing to record visits and traffic sources, in order to improve the functioning of the website. The User’s browser records the history of Users visits, which by default is anonymized. The User can choose not to have the browser history anonymized for this website. To find out more about providers privacy policies and how to opt-out of their analytics cookies please check the following links:

Google Tag Manager: https://policies.google.com/privacy?hl=en

Linkedin: https://www.linkedin.com/legal/privacy-policy

Marketing

Marketing cookies are used to track visitors across websites. The intention is to display ads that are relevant and engaging for the individual User and thereby more valuable for publishers and third-party advertisers.

Find more about Providers Privacy Policy:

Google Analytics: http://www.google.com/analytics/learn/privacy.html

Intercom: https://www.intercom.com/legal/privacy

Linkedin: https://www.linkedin.com/legal/privacy-policy

Meta (Facebook): https://www.facebook.com/privacy/policy/

 

13. How long do cookies remain on Users' devices

How long cookies stay on a device depends on whether it is a “persistent” cookie or a “session” cookie. A persistent cookie will be stored on a website and will remain valid until the expiry date for which it was set unless the User deletes it before that expiration date. A session cookie will be deleted at the end of a web session and when the web browser is closed.

 

14. How to control and manage cookies

Users can control and manage cookies in multiple ways. The removal or blocking of cookies may affect the user experience and may limit access to some features of this website.

Where cookies are not strictly necessary for the operation of our website, we will ask for User consent to our use of cookies on User’s first visit to our website. Consent can be given or withdrawn by clicking on “Selection” at the top of this page.

The links below provide instructions on how to control cookies in the most popular browsers:

Google Chorme: https://support.google.com/accounts/answer/61416?hl=en&co=GENIE.Platform%3DDesktop

Safari: https://allaboutcookies.org/how-to-clear-cookies-safari

Firefox: https://support.mozilla.org/en-US/kb/block-websites-storing-cookies-site-data-firefox

Microsoft Edge: https://support.microsoft.com/en-us/microsoft-edge/delete-cookies-in-microsoft-edge-63947406-40ac-c3b8-57b9-2a946a29ae09

Any consent to accept or reject cookies is limited to the website where this Cookies Policy is located and does not apply to other websites or pages, which may have been linked to this website. For more information about how cookies are used by these websites, please consult the specific privacy and cookie policies of those websites.

15. Changes to the Cookie Policy

This Cookie Policy may be revised at any time at our discretion. When such changes are made, the revision date at the top of the page will be changed. The amended Cookie Policy will be effective as of the date of revision.

We recommend that users of our website review the Cookie Policies periodically in order to be informed about our management of cookies.