Privacy Policy

by Startacus Admin

This is the privacy policy of Startacus, trading as The Employable. In this document, "we", "our", or "us" refer to Startacus, trading as The Employable. We are company number NI609106, registered in N. Ireland. Our office is c/o 16 Elmvale, Derry, Northern Ireland, BT48 8DH.

Introduction
This is a notice to inform you of our policy about all information that we record about you. It sets out the conditions under which we may process any information that we collect from you, or that you provide to us. It covers information that could identify you (“personal information”) and information that could not. In the context of the law and this notice, “process” means collect, store, transfer, use or otherwise act on information.
We regret that if there are one or more points below with which you are not happy, your only recourse is to leave our website immediately.
We take seriously the protection of your privacy and confidentiality. We understand that all visitors to our website are entitled to know that their personal data will not be used for any purpose unintended by them, and will not accidentally fall into the hands of a third party.
We undertake to preserve the confidentiality of all information you provide to us, and hope that you reciprocate.
Our policy complies with UK law accordingly implemented, including that required by the United Kingdom General Data Protection Regulation (UK GDPR) and Data Protection Act 2018.
The law requires us to tell you about your rights and our obligations to you in regards to the processing and control of your personal data. We do this now, by requesting that you read the information provided at ICO and at www.knowyourprivacyrights.org
Except as set out below, we do not share, or sell, or disclose to a third party, any information collected through our website.

The bases on which we process information about you
The law requires us to determine under which of six defined bases we process different categories of your personal information, and to notify you of the basis for each category.
If a basis on which we process your personal information is no longer relevant then we shall immediately stop processing your data.
If the basis changes then if required by law we shall notify you of the change and of any new basis under which we have determined that we can continue to process your information.

Information we process because we have a contractual obligation with you
When you create an account on our website, buy a service from us, or otherwise agree to our terms and conditions, a contract is formed between you and us. In order to carry out our obligations under that contract we must process the information you give us. Some of this information may be personal information.
We may use it in order to: verify your identity for security purposes, sell products to you, provide you with our services, provide you with suggestions and advice on products, services and how to obtain the most from using our website.
We process this information on the basis there is a contract between us, or that you have requested we use the information before we enter into a legal contract.
Additionally, we may aggregate this information in a general way and use it to provide class information, for example to monitor our performance with respect to a particular service we provide. If we use it for this purpose, you as an individual will not be personally identifiable.
We shall continue to process this information until the contract between us ends or is terminated by either party under the terms of the contract.

Information we process with your consent
Through certain actions when otherwise there is no contractual relationship between us, such as when you browse our website or ask us to provide you more information about our business, including our services, you provide your consent to us to process information that may be personal information.
Wherever possible, we aim to obtain your explicit consent to process this information, for example, by asking you to agree to our use of cookies. Sometimes you might give your consent implicitly, such as when you send us a message by e-mail to which you would reasonably expect us to reply. Except where you have consented to our use of your information for a specific purpose, we do not use your information in any way that would identify you personally. We may aggregate it in a general way and use it to provide class information, for example to monitor the performance of a particular page on our website.
If you have given us explicit permission to do so, we may from time to time pass your name and contact information to selected associates whom we consider may provide services or products you would find useful.
We continue to process your information on this basis until you withdraw your consent or it can be reasonably assumed that your consent no longer exists.
You may withdraw your consent at any time by instructing us iam@startacus.net. However, if you do so, you may not be able to use our website or our services further.

Information we process for the purposes of legitimate interests
We may process information on the basis there is a legitimate interest, either to you or to us, of doing so. Where we process your information on this basis, we do after having given careful consideration to: whether the same objective could be achieved through other means, whether processing (or not processing) might cause you harm, whether you would expect us to process your data, and whether you would, in the round, consider it reasonable to do so. For example, we may process your data on this basis for the purposes of: record-keeping for the proper and necessary administration of our business, responding to unsolicited communication from you to which we believe you would expect a response,
protecting and asserting the legal rights of any party, insuring against or obtaining professional advice that is required to manage business risk, protecting your interests where we believe we have a duty to do so.

Information we process because we have a legal obligation
We are subject to the law like everyone else. Sometimes, we must process your information in order to comply with a statutory obligation. For example, we may be required to give information to legal authorities if they so request or if they have the proper authorisation such as a search warrant or court order. This may include your personal information.

Specific uses of information you provide to us

Information provided on the understanding that it will be shared with a third party
Our website allows you to post information with a view to that information being read, copied, downloaded, or used by other people.
Examples include: posting a message our forum. In posting personal information, it is up to you to satisfy yourself about the privacy level of every person who might use it. We do not specifically use this information except to allow it to be displayed or shared. We do store it, and we reserve a right to use it in the future in any way we decide. Once your information enters the public domain, we have no control over what any individual third party may do with it. We accept no responsibility for their actions at any time. Provided your request is reasonable and there is no legal basis for us to retain it, then at our discretion we may agree to your request to delete personal information that you have posted. You can make a request by contacting us at iam@startacus.net.

Complaints regarding content on our website
Our website is a publishing medium. Anyone may register and then publish information about himself, herself or some other person. We attempt to moderate user generated content, but we are not always able to do so as soon as that content is published.
If you complain about any of the content on our website, we shall investigate your complaint.
If we feel it is justified or if we believe the law requires us to do so, we shall remove the content while we investigate. Free speech is a fundamental right, so we have to make a judgment as to whose right will be obstructed: yours, or that of the person who posted the content that offends you. If we think your complaint is vexatious or without any basis, we shall not correspond with you about it.

Sending a message to our support team
When you contact us, whether through our website or by e-mail, we collect the data you have given to us in order to reply with the information you need. We record your request and our reply in order to increase the efficiency of our business. We keep personally identifiable information associated with your message, such as your name and email address so as to be able to track our communications with you to provide a high quality service.

Complaining
When we receive a complaint, we record all the information you have given to us. We use that information to resolve your complaint. If your complaint reasonably requires us to contact some other person, we may decide to give to that other person some of the information contained in your complaint. We do this as infrequently as possible, but it is a matter for our sole discretion as to whether we do give information, and if we do, what that information is. We may also compile statistics showing information obtained from this source to assess the level of service we provide, but not in a way that could identify you or any other person.

Affiliate and business partner information
This is information given to us by you in your capacity as an affiliate of us or as a business partner.
It allows us to recognise visitors that you have referred to us, and to credit to you commission due for such referrals. It also includes information that allows us to transfer commission to you. The information is not used for any other purpose. We undertake to preserve the confidentiality of the information and of the terms of our relationship.
We expect any affiliate or partner to agree to reciprocate this policy.

Third Party Sites, Social Login and Third Party Suppliers
Our website may, on occasion, contain links to the websites of other businesses, advertisers and/or affiliates. If you follow a link to any of these websites, please be aware that these websites have their own privacy policies and that we do not accept any responsibility for their policies. Please check the relevant policies before you share any personal data with these websites.
We also offer you the opportunity to use your social media login (Twitter and/or LinkedIn) when registering or signing on to our website. If you do so, please be aware that you will be sharing your profile information with us. The personal data that is shared will depend on your social media platform settings. Please check the relevant social media platform and its individual privacy policy in order to understand how your personal data is shared and used in this context.

Your personal data may be processed on our behalf by our trusted third party suppliers. We utilize trusted third parties to undertake certain business operations on our behalf. We provide them with the information they require to undertake the service and we request that they do not use your personal data for any other purpose or reason. We will always endeavour to ensure that any third parties we work with will keep your personal data secure.
Third parties that we work with include:
Third parties that enable us to undertake web analytics and measure what online visitors do on our website.
For this purpose, we currently use Google Analytics which is the most common online analytics tool. We look at information such as which articles are the most popular and which sections of the website are visited most frequently. This helps us to improve our content for our readers and learn about what a good user experience is for our website visitors.
Google Analytics records data including your geographical location, device and internet browser used, however this information does not enable us to personally identify you. Google does record your computer’s IP address which could personally identify you, however we do not have access to this information from Google. In line with current United Kingdom General Data Protection Regulation (UK GDPR) and Data Protection Act 2018 legislation, we consider Google to be a third party data processor.
Google Analytics does make use of cookies - full details of these can be found on Google’s developer guides. If you disable cookies on your internet browser, this will prevent Google Analytics from tracking any of the pages that you visit on our website.
Third parties that assist us in providing IT services such as our website hosting, maintenance and support.
For this purpose, we currently use Big Wet Fish Hosting Ltd. This company provides cloud hosting for our website on the latest hardware architecture. Within their own terms and conditions, they will not sell, distribute or reveal any of our website information, including any personal data that is stored by our members or site visitors.
Third parties that assist us in providing security on our website.
For this purpose, we currently use Cloudflare who protect and secure our website against denial-of-service attacks, customer data compromise, and abusive bots. Cloudflare’s revised privacy policy, effective as of October 27, 2020 is in adherence with both European Union General Data Protection Regulations and its United Kingdom GDPR counterpart. 

Third parties that may assist us in creating and facilitating events - both online and in-person. We do this if it is necessary to administer and manage any events that you are invited to and/or attend and/or participate in that are either hosted by us virtually or in-person.

Our use of re-marketing
Re-marketing involves placing a cookie on your computer when you browse our website in order to be able to serve to you an advert for our products or services when you visit some other website. We may use a third party to provide us with re-marketing services from time to time. If so, then if you have consented to our use of cookies, you may see advertisements for our products and services on other websites.

Disclosure and sharing of your information
Information we obtain from third parties
Although we do not disclose your personal information to any third party (except as set out in this notice), we sometimes receive data that is indirectly made up from your personal information from third parties whose services we use. No such information is personally identifiable to you.

Third party advertising on our website
Third parties may advertise on our website. In doing so, those parties, their agents or other companies working for them may use technology that automatically collects information about you when their advertisement is displayed on our website. They may also use other technology such as cookies or JavaScript to personalise the content of, and to measure the performance of their adverts. We do not have control over these technologies or the data that these parties obtain. Accordingly, this privacy notice does not cover the information practices of these third parties.

Data may be processed outside the European Union
Our website is hosted in Northern Ireland. We may also use outsourced services in countries outside the European Union from time to time in other aspects of our business. Accordingly data obtained within the UK or any other country could be processed outside the European Union. For example, some of the software our website uses may have been developed in the United States of America or in Australia.
We use the following safeguards with respect to data transferred outside the European Union: the processor is within the same corporate group as our business or organisation and abides by the same binding corporate rules regarding data processing, the data protection clauses in our contracts with data processors include transfer clauses written by or approved by a supervisory authority in the European Union, specifically that in the UK, we comply with a code of conduct approved by a supervisory authority in the European Union, specifically that in the UK, we are certified under an approved certification mechanism as provided for in the GDPR, both our organisation and the processor are public authorities between whom there is either a legally binding agreement or administrative arrangements approved by a supervisory authority in the European Union relating to protection of your information

Access to your own information

Access to your personal information
At any time you may review or update personally identifiable information that we hold about you, by signing in to your account on our website. To obtain a copy of any information that is not provided on our website you may send us a request at iam@startacus.net. After receiving the request, we will tell you when we expect to provide you with the information, and whether we require any fee for providing it to you.

Removal of your information
If you wish us to remove personally identifiable information from our website, you may contact us at iam@startacus.net. This may limit the service we can provide to you.

Verification of your information
When we receive any request to access, edit or delete personal identifiable information we shall first take reasonable steps to verify your identity before granting you access or otherwise taking any action. This is important to safeguard your information.

Other matters
Encryption of data sent between us
We use Secure Sockets Layer (SSL) certificates to verify our identity to your browser and to encrypt any data you give us. Whenever information is transferred between us, you can check that it is done so using SSL by looking for a closed padlock symbol or other trust mark in your browser’s URL bar or toolbar.

How you can complain
If you are not happy with our privacy policy or if have any complaint then you should tell us by email. Our address is iam@startacus.net. If a dispute is not settled then we hope you will agree to attempt to resolve it by engaging in good faith with us in a process of mediation or arbitration. If you are in any way dissatisfied about how we process your personal information, you have a right to lodge a complaint with the Information Commissioner's Office. This can be done at https://ico.org.uk/concerns/

Retention period for personal data
Except as otherwise mentioned in this privacy notice, we keep your personal information only for as long as required by us: to provide you with the services you have requested; to comply with other law, including for the period demanded by our tax authorities; to support a claim or defence in court.

Compliance with the law
Our privacy policy has been compiled so as to comply with the law of every country or legal jurisdiction in which we aim to do business. If you think it fails to satisfy the law of your jurisdiction, we should like to hear from you. However, ultimately it is your choice as to whether you wish to use our website.

Review of this privacy policy
We may update this privacy notice from time to time as necessary. The terms that apply to you are those posted here on our website on the day you use our website. We advise you to print a copy for your records. If you have any question regarding our privacy policy, please contact us.

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Published on: 24th May 2018