Privacy Policy: Clients and Suppliers
We are Van Kaizen Limited, a company registered in the Isle of Man #132444C that provides a recruitment platform to independent headhunters. We believe in maximising your privacy and confidentiality, in keeping with good business practice and the law, which for us is the Isle of Man’s data protection legislation and regulation. This policy explains what personal data we use, as well as why and how we use it and what it means for you as a representative of a Client or Supplier. For policies relating to other relationships with Van Kaizen, see here.
Why do we collect your data?
As a prospective Client our Supplier, we collect your data so we can communicate with you about the services that we might provide to you, or that you might provide to us.
As an existing Client or Supplier, we collect your data to allow us to communicate with you about the performance of our contract with you.
What data do we collect?
We collect the following data about representatives of Clients and Suppliers:
Name
Location
Work contact details
Bank account details (suppliers only)
None of the personal data above will include any special category data (as defined in the prevailing Isle of Man data protection legislation and regulations (IOMDPR)).
We also collect purely anonymous data on visitors to our website (which may include you) using cookies, which are explained in more detail below.
How do we collect your data?
Some data may be taken from public sources such as LinkedIn or company websites, but most will be provided directly by you or your employer.
As a prospective Client or Supplier, you may provide us with some data using forms on our website. We also collect anonymous data via browser cookies when you visit our website, which are explained in more detail below.
How do we store your data and how long do we keep it for?
Data are stored in searchable digital formats in our cloud hosting environment. We maintain a highly secure digital infrastructure with rigorous security and redundancy standards and policies. To minimise the risk of losing data, they are not held in physical form.
If you are a prospective Client. i.e. a Client with which we have not signed terms of business, your data will be held for two years from our initial contact with you to provide sufficient time for terms of business to be signed taking into account the internal and external factors that can affect your recruitment initiatives.
If you are a client with which we have signed terms of business, your data will be held for six years from the date of the termination of the terms of business by either party.
If you are a supplier, your data will be held for six years from the date of termination of our contract with you with the exception of your bank details which will be deleted after the last payment has been made to you.
Anonymous website visitor data is held in the analytics engine of our website hosting provider.
What do we do with your data?
As a prospective Client, we may reach out to you with personalised communications to discuss the services we may provide to you.
As an existing client or supplier, we use your data to communicate with you about the services we are contracted with you for. For Clients, we may pass your data to Candidates for the purposes of setting up necessary communications, such as interviews.
We may also share your data with third parties to whom we may choose to sell, transfer, or merge parts of our business or our assets. Alternatively, we may seek to acquire other businesses or merge with them. If a change happens to our business, then the new owners may use your personal data in the same way as set out in this privacy policy.
Who can see my data?
We share your personal data within Van Kaizen, with contracted recruitment consultants, and with various software suppliers and service providers with whom Van Kaizen has entered into agreements. They will only see your data in the context of our systems and policies.
Where is my data held?
Our top-tier data hosting providers store your data in various secure locations within the EEA. This is where your data rests when it is on Van Kaizen’s systems, regardless of the location of anyone interacting with that data.
We may on occasion need to transfer your personal data out of the EEA. When we do, we will ensure a similar degree of protection is afforded to it by ensuring at least one of the following safeguards is implemented:
We will transfer your personal data to countries that have been deemed to provide an adequate level of protection for personal data by the European Commission. For further details, see:
https://www.inforights.im/organisations/data-protection-law-2018/transfers-to-third-countries/We may use specific contracts approved by the European Commission which give personal data the same protection it has in Europe. For further details, see
https://www.inforights.im/organisations/data-protection-law-2018/transfers-to-third-countries/
Please contact us if you want further information on the specific mechanism used by us when transferring your personal data out of the EEA.
What is the legal basis on which we collect and process your data?
As a prospective Client, we believe we have a legitimate interest to process your data, because they are essential to undertaking new business. We do not collect data that we do not need for this purpose and we do not believe that our collection and processing infringes on your rights.
If we are successful in securing employment for you with a Client, we will then retain and process your data on the revised basis that it is required for the performance of our contract.
Our basis for processing supplier data is for the performance of a contract.
What are your rights to that data?
You are entitled to all the following rights, and we will actively seek to uphold these rights for you:
The right to access: You have the right to ask us for copies of your personal data.
The right to rectification: You have the right to request that we correct or complete any information you believe is inaccurate or incomplete.
The right to erasure: You have the right to request that we erase your personal data, under certain conditions.
The right to restrict processing: You have the right to request that we restrict the processing of your personal data, under certain conditions.
The right to object to processing: You have the right to object to our processing of your personal data, under certain conditions, particularly when we are relying on legitimate interest to process your data (see previous section).
The right to data portability: You have the right to request that we transfer the data that we have collected to another organization, or directly to you, under certain conditions.
If you make a request, we have one month to respond to you. If you would like to exercise any of these rights, please email us. You can find out more about these rights here.
Who do I contact if I have questions or concerns?
If you would like to discuss this policy with us, please contact our Data Protection Officer who is Graeme Brooks, (Director).
+44 7624 487045
You have the right to make a complaint at any time to the Isle of Man Information Commissioner's Office (ICO) (www.inforights.im), the Isle of Man supervisory authority for data protection issues.
We would, however, appreciate the chance to deal with your concerns before you approach the ICO so please contact us in the first instance.
Changes to our privacy policy
We keep our privacy policy under regular review and place any updates on this web page. This privacy policy was last reviewed in July 2023.
Privacy policy of other websites
Our privacy policy applies only to our website, so if you click on a link to another website, you should read their privacy policy.
Cookies
Cookies are text files placed on your computer to collect visitor behaviour information. When you visit our websites, we will try to collect information from you automatically through these cookies, unless you have them disabled in your browser. For further information, visit www.allaboutcookies.org.
How do we use cookies?
We use cookies to understand how you use our website. We don’t use them to identify or store any personal information about you as an individual, all the browsing data we use is anonymous.
What types of cookies do we use?
There are a number of different types of cookies used by our website hosting and analytics provider, an up-to-date list of which can be found here.
How to manage cookies
You can set your browser not to accept cookies, and the above website tells you how to remove cookies from your browser. However, in a few cases, some of our website features may not function as a result.