PRIVACY POLICY

FirstMind LTD, UK

Privacy & Cookies Policy

FirstMind LTD (“we”, “our”, and “us”) is committed to ensuring that your privacy is protected. Set out below is how we use the information we collect and receive and how you can tell us if you would prefer us not to use the information, or to limit its use.

ABOUT US 

We are FirstMind LTD, a limited liability company registered in England and Wales with company registration number 1245330. Our registered office address is 21 Buckingham Gate, SW1E 6LB.

We provide a web-based and/or app-based platform that allows to assess candidates, customers and other people (“FirstMind Platform”). The FirstMind Platform enable leaders to make informed people decisions by providing insights. Customers are provided with a questionnaire on the FirstMind Platform and, on completion, FirstMind generates a Talent Discovery report.  The FirstMind Platform can be accessed via your personal subdomain, www.<your company name>.firstmind.com.

As a FirstMind LTD customer, you are the data controller of any personal data you collect using the FirstMind Platform. FirstMind LTD and the customer collecting the data has access to destroy any data collected and is subject to applicable data protection laws.

Contacting Us

If you have any questions about this data privacy policy or your information, or to exercise any of your rights as described in this policy or under applicable data protection laws, you can contact the Data Protection Officer at:

Data Protection Officer

FirstMind LTD

21 Buckingham Gate

London

SW1E 6LB

By email:          insights@firstmind.com

DATA PROTECTION PRINCIPLES

Anyone processing personal data must comply with the principles of processing personal data as follows:

  • Lawfulness, fairness and transparency – data must be processed lawfully, fairly and in a transparent manner.
  • Purpose limitation – data must be collected for specified, explicit and legitimate purposes and not further processed in a manner that is incompatible with those purposes.
  • Data minimization – data must be adequate, relevant and limited to what is necessary in relation to the purposes for which they are processed.
  • Accuracy – data must be accurate and, where necessary, kept up to date.
  • Storage limitation – data must be kept in a form which permits identification of data subjects for no longer than is necessary for the purposes for which the personal data are processed.
  • Integrity and confidentiality – data must be processed in a manner that ensures appropriate security of the personal data, including protection against unauthorised or unlawful processing and against accidental loss, destruction or damage by using appropriate technical or organisational measures.

This privacy policy describes the personal information that we collect from and about customers using the FirstMind Platform, and explains how we comply with these principles. 

INFORMATION WE MAY COLLECT

Information you give us

You may give us information about you by registering or filling in forms on the FirstMind Platform or by corresponding with us by phone, email or otherwise. This includes information you provide when you:

  • register and create a user profile on the FirstMind Platform (for example, your name, telephone number, address, and email address)
  • communicate with us by phone, e-mail, through the FirstMind Platform or otherwise;
  • sign up to receive our newsletter;
  • enter a competition, promotion or survey; and
  • participate in any social media functions on the FirstMind Platform or with us on social media platforms directly

Information we collect from respondents

The FirstMind platform allows respondents to fill out questionnaires to generate the Talent Discovery report and discover their talents. FirstMind and FirstMind clients has access to the respondent full report. All respondents gives consent to FirstMind storing this report and may at any time demand all data destroyed. 

FirstMind LTD hashes the personal data to anonymize all stored, filled questionnaires and reports for analytical purposes.

WHAT WE DO WITH YOUR INFORMATION

FirstMind Website and FirstMind Client Platform: We may process your personal data for the following purposes for FirstMind’s own:

  • to administer platform log-ins (where applicable) and to deliver our services to our clients under the agreed terms of service;
  • to process your enquiries to reply and provide support, including providing you and/or your organisation with information about the services Cognism offers;
  • to keep you updated via our mailing list with information on news, offers, and updates about Cognism (see below for how to unsubscribe);
  • to compile reports on how visitors use the Cognism website and improve the website;
  • to conduct remarketing for Cognism, which allows us to show Cognism ads to people who’ve previously visited our website;
  • to conduct advertising on social networks for Cognism, which means that if you link to one of our social media platforms you may be subject to targeted marketing displaying Cognism ads via that site.

We work with the third party advertising networks and social media platforms as set out in our cookie policy here. If you would like to find out more about the way these third parties collect and process your information, please refer to their respective privacy policies.

HOW LONG WE KEEP YOUR INFORMATION

Personal information received by us will only be retained for as long as necessary to fulfil the purposes described in this policy or for the maximum period of time as required by law, after which time it will be destroyed in a secure manner. Please note that if your personal information is shared with third parties (as detailed above) they may have different retention policies.

 

YOUR RIGHTS

Access to your information and updating your information

You have the right to access information which we hold about you. If you so request, we shall provide you with a copy of your personal information which we are processing (“subject access request”);

You also have the right to receive your personal information in a structured and commonly used format so that it can be transferred to another data controller (“data portability“).

We want to make sure that your personal information is accurate and up to date. You may ask us to correct or remove information you think is inaccurate.

Right to object

You have the right to object at any time to our processing of your personal information for direct marketing purposes.

Where we process your information based on our legitimate interests

You also have the right to object, on grounds relating to your particular situation, at any time to processing of your personal information which is based on our legitimate interests. Where you object on this ground, we shall no longer process your personal information unless we can demonstrate compelling legitimate grounds for the processing which override your interests, rights and freedoms or for the establishment, exercise or defence of legal claims.

Your other rights

You also have the following rights under data protection laws to request that we rectify your personal information which is inaccurate or incomplete.

In certain circumstances, you have the right to:

  • request the erasure of your personal information erasure (“right to be forgotten”);
  • restrict the processing of your personal information to processing to which you have given your consent or for the establishment, exercise or defence of legal claims or for the protection of the rights of others.

Please note that the above rights are not absolute, and we may be entitled to refuse requests, wholly or partly, where exceptions under applicable law apply.

 

EXERCISING YOUR RIGHTS

You can exercise any of your rights as described in this policy and under data protection laws by contacting the Data Protection Officer.

Save as provided under applicable data protection laws, there is no charge for the exercise of your legal rights. However, if your requests are manifestly unfounded or excessive, in particular because of their repetitive character, we may either: (a) charge a reasonable fee (subject to any limits imposed by applicable law) taking into account the administrative costs of providing the information or taking the action requested; or (b) refuse to act on the request.

Where we have reasonable doubts concerning the identity of the person making the request, we may request additional information necessary to confirm your identity.

 

COOKIES

A cookie is a small amount of data which often includes a unique identifier that is sent to your computer or mobile phone (your “device”) from the FirstMind Website and Platform and is stored on your device’s browser or hard drive.

The cookies we use on the FirstMind Platform won’t collect personally identifiable information about you and we won’t disclose information stored in cookies that we place on your device to third parties.

By continuing to browse the FirstMind Platform, you are agreeing to our use of cookies.

If you don’t want us to use cookies when you use the FirstMind Platform, you can set your internet browser not to accept cookies. However, if you block cookies some of the features on the FirstMind Platform may not function as a result.

You can find more information about how to do manage cookies for all the commonly used internet browsers by visiting www.allaboutcookies.org.  This website will also explain how you can delete cookies which are already stored on your device.

For use where Google Analytics used only. We only use “Google Analytics” on this Site. This cookie provides us with a visitor count and an understanding of how visitors move around and use the website.  We can then use this information to improve navigability and the Site generally.  The cookies we use on the Site won’t collect personally identifiable information about you and we won’t disclose information stored in cookies that we place on your device to third parties.

Visitors to our Site can adjust their browsers to refuse cookies but if not adjusted, the Site will deliver the cookie as soon as the Site is visited. You can find more information about how to manage cookies for all the commonly used internet browsers by visiting www.allaboutcookies.org.  This website will also explain how you can delete cookies which are already stored on your device.

We are obliged by Google Analytics to state the following:

This website uses Google Analytics, a web analytics service provided by Google Inc. (“Google”). Google Analytics uses “cookies”, which are text files placed on your computer, to help the website analyse how users use the site.  The information generated by the cookie about your use of the website (including your IP address) will be transmitted to and stored by Google on servers in the United States.  Google will use this information for the purpose of evaluating your use of the website, compiling reports on website activity for website operators and providing other services relating to website activity and internet usage.  Google may also transfer this information to third parties where required to do so by law, or where such third parties process the information on Google’s behalf. Google will not associate your IP address with any other data held by Google.  You may refuse the use of cookies by selecting the appropriate settings on your browser, however please note that if you do this you may not be able to use the full functionality of this website.  By using this website, you consent to the processing of data about you by Google in the manner and for the purposes set out above.

LINKS

The FirstMind Platform contains links to other websites for ease of reference. We do not endorse any sites that are linked from the FirstMind Platform and do not assume any responsibility for the content of any such website.

You may not link the homepage or any other parts of this website without out prior written consent.

 

UPDATES TO THIS POLICY

We may review and, if appropriate, update this policy from time to time. We will place notice of any such amendments on the FirstMind Platform. Please visit the FirstMind Platform for the most recent version of this policy.

This policy was last reviewed and updated on 12 September 2019.

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