Privacy Policy

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Introduction

Incognewco Limited is a Business Advisory firm centred on assessing, building and advising leadership teams and boards of technology startups. We are committed to helping our clients address their most essential business needs- advising on leadership & talent identification, screening, recruitment and retention. Incognewco Limited is committed to protecting the privacy of our candidates, clients and users of our website. We want to provide a safe and secure user experience.

Here we summarise our policies regarding how Incognewco Limited collects, uses and transfers your personal data, the security measures we employ to protect such data and your rights regarding your personal data.

It is important that you read this notice, together with any additional privacy notice we may provide on specific occasions when we are collecting or processing personal information about you, so that you are aware of how and why we are using such information.

Data protection principles

We will comply with all relevant data protection laws. This states that the personal information we hold about you must be:

1. Used lawfully, fairly and in a transparent way
2. Collected only for valid purposes and not used in a manner that is incompatible with      those purposes
3. Relevant to the purposes we have told you about and limited only to those purposes
4. Kept only as long as is necessary
5. Kept securely
6. Disposed of confidentially

Personal Data

Personal data, or personal information, means any information about an individual from which the person can be identified. It does not include data where the identity has been removed (anonymous data). All data held by Incognewco Limited is stored in a secure and confidential database accessible only by authorised Incognewco Limited employees.

The personal data we hold includes, but is not limited to, employment history, contact details, CVs, references, job preferences, compensation details or qualifications. We may from time to time also collect, store, handle and use the following “special categories” of more sensitive personal information, such as information about health or disabilities, criminal convictions, offences and court judgements, but only where we are legally permitted to do so. You will be contacted if we require explicit consent to hold this information. We may also hold references from third parties as well as a record of our contact history with you. If provided to us we may retain CVs and any other documents we deem relevant.

Personal data held by Incognewco Limited will be gathered from LinkedIn, Google, Company websites and other publicly available sources or provided by you and third parties known to you (ie referees). Within the process we may also collect, receive and process personal information from former employers and reference checkers.

How we use personal data

By choosing to provide Incognewco Limited with your personal information you indicate your willingness to share and have your information stored by Incognewco Limited and to be considered, when appropriate, for one of Incognewco’s executive searches. We use candidate data to provide our recruitment and search services to you and to facilitate our clients’ recruitment processes. This information will only be used for the purpose for which we collected it, unless we reasonably consider that we need to use if for another reason which is compatible with the original purpose. If we need to use your personal data for an unrelated purpose we will notify you and explain the legal basis which allows us to do so.

Personal information may be transferred or duplicated to our offices, and also clients outside the European Economic Area to enable them to provide you with recruitment services and for the purposes of business development, systems development and testing. In the event of a transfer, we will seek to ensure the appropriate safeguards to protect your data are in place which could include entering into a data transfer agreement to ensure adequate protection of your information. Therefore, if we do, you can expect a similar degree of protection in respect of your personal information.

We may also use personal Information to respond to your inquiries and answer your questions, to provide you with requested information, and to undertake activities in connection with the conduct and management of our executive search. Also for other services, such as evaluating candidate qualifications, contacting potential candidates for further personal Information, contacting named references, and communicating with clients about potential candidates. We also may use personal Information for the purposes of testing and maintaining our company databases, networks, and computer systems, and for training and other internal purposes.

Personal information may also be provided to approved third party processors who will only process data as per our instructions. These third parties may include our secure database and relevant reference checking companies. They are required to take appropriate security measures to protect your personal data in line with our policies.

Data Security and Integrity

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

We use our best efforts to ensure that data is accurate, complete, current and reliable for its intended use. We use appropriate technical and organisational measures and safeguards to help protect your personal data from unauthorised access, misuse, alteration or loss. Our internal policies and procedures are designed to help ensure we, minimise risk and safeguard the privacy and accuracy of all data we collect or process. To the extent that if we do disclose personal data to clients or third parties, we will request that they properly protect the security and confidentiality of such information and otherwise process such data in accordance with applicable law. Our candidate database is encrypted. We will maintain adequate safeguards to ensure the security and integrity of the personal data we hold.

We have put in place procedures to deal with any suspected data security breach and will notify you of a suspected breach where we are legally required to do so, or if deemed necessary.

We reserve the right to transfer personal data to a third party in the event of a sale of Erevena, a merger or liquidation. You will be notified in the event of such transfer.

Use of Cookies

This site uses cookies – small text files that are placed on your machine to help the site provide a better user experience. In general, cookies are used to retain user preferences, store information for things like shopping carts, and provide anonymised tracking data to third party applications like Google Analytics. As a rule, cookies will make your browsing experience better. However, you may prefer to disable cookies on this site and on others. The most effective way to do this is to disable cookies in your browser. We suggest consulting the Help section of your browser or taking a look at the About Cookies website which offers guidance for all modern browsers.

How Long We Keep Your Data

We will only retain your personal data for as long as necessary to fulfil the purposes we collected it for, and not keep for longer than 5 years after we last attempted to make contact with you. After this time some information may be kept and anonymised and used in order for us to put together industry, marketing or employment statistics. This would be non-identifying so it can no longer be associated with you, in which case we may use such information without further notice to you. After this time we will securely and permanently destroy your personal information in accordance with our data retention policy and applicable laws and regulations.

Your Rights

Under certain circumstances, by law you have the right to:

• Request correction of the personal information that we hold about you. This      enables you to have any incomplete or inaccurate information we hold about      you corrected.
• Request erasure of your personal information. This enables you to ask us to      delete or remove personal information where there is no good reason for us      continuing to process it. You also have the right to ask us to delete or remove your personal information where you have exercised your right to object to processing (see below).
• Object to processing of your personal information where we are relying on a      legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground.
• Request access to your personal information (commonly known as a “data      subject access request”). This enables you to receive a copy of the personal information we hold about you.
• Request the restriction of processing of your personal information. This enables you to ask us to suspend the processing of personal information about you, for example if you want us to establish its accuracy or the reason for processing it.
• Request the transfer of your personal information to another party.

If you want to review, verify, correct or request erasure of your personal information, object to the processing of your personal data, or request that we transfer a copy of your personal information to another party, we may need to request specific information from you to help us confirm your identity and ensure your right to access the information. This is another appropriate security measure to ensure that personal information is not disclosed to any person who does not have the right to receive it. To get in touch regarding any of your rights above please email contact@incognewco.com

Changes to the Privacy Policy

Incognewco Limited reserves the right to modify or amend this Privacy Policy at any time and for any reason, as permitted by applicable law. If there are material changes to the Privacy Policy, we will post those changes here.