Privacy policy
We periodically review and update this Privacy Notice to ensure ongoing compliance and relevance. The current version was last revised on March 11, 2024. ARKITER LTD, a company incorporated in England and Wales (Company No. 14065426), has its registered office at Foundry Building 2, Smiths Square, 77 Fulham Palace Road, London, England, W6 8AF. Throughout this document, the terms "we", "us", and "our" refer to ARKITER LTD. As detailed herein, our role in the processing of personal information, unless stated otherwise, is that of a Data Processor. This document outlines our practices regarding the collection, holding, and usage of your personal information.
This Privacy Notice pertains to our website [www.arkiter.com / www.arkiter.io] (the "Site") and the range of services we provide therein. At ARKITER LTD, we specialize in offering pre-screening services and facilitating interviews for candidates on behalf of our clientele. This policy extends to all clients, candidates, and any individuals who interact with our Site ("Users"). Typically, we serve as a Data Processor under the direction of our clients, adhering strictly to their guidelines. For detailed information on how your data is managed in such instances, we recommend consulting the privacy policies of the respective clients. However, in specific scenarios where we function as a Data Controller, we assume full responsibility for the management of your data, strictly in alignment with the provisions of this Privacy Notice.
You can contact us through the following methods:
Email us at privacy@arkiter.com
Send a message via our contact page: https://arkiter.com
We prioritize the confidentiality and security of your personal information. This privacy notice aims to elucidate our practices regarding the collection, storage and use of your personal data. We encourage you to read this document thoroughly to understand our methods and reasons for processing your information.
For any questions or concerns regarding privacy or data protection, please contact us at privacy@arkiter.com. Our team is committed to ensuring the security and confidentiality of your personal information and is available to address your inquiries.
We may issue you with other privacy notices from time to time, including when we collect personal information from you. This privacy notice is intended to supplement these and does not override them.
1. Key definitions
For clarity, the key terms that we use throughout this privacy notice are defined below:
Data Controller: In accordance with UK data protection law, this refers to the entity or individual that determines the purposes and means of processing personal information.
Data Processor: An entity or individual engaged by the Data Controller to process personal information based on explicit instructions. Responsibilities might include data storage, email marketing, or hosting services, all performed under the Data Controller"s directive.
Personal Information: This term denotes any data that can identify a living person. Anonymized data, where the identity has been permanently removed, is not included under this definition.
Special Information: This category encompasses highly sensitive data that demands additional safeguards as per data protection legislation. It includes, but is not limited to, data on health, racial and ethnic origins, political opinions, religious beliefs, trade union membership, sexual orientation, as well as genetic and biometric data.
Technical Information: Refers to details on a user"s website interaction and device specifications, such as IP address, browser type, operating system, and device settings. This information, collected either directly or via analytics providers, helps improve our website and user experience.
2. Details of personal information that we collect and hold about you:
Set out below are the general categories and in each case the types of personal information that we collect or may collect, use and hold about you:
- Identity information : This is information relating to your identity such as your name (including any previous names and any titles that you use), gender, marital status and date of birth.
- Contact information : This is information relating to your contact details such as email address, addresses, telephone numbers.
- Account information : This is information relating to your account with us (including username and password).
- Payment information : This category includes details about the methods you use to make payments to us, such as bank account details, credit or debit card details, and the records of transactions between us, including amounts and dates.
- Services information : This is information relating to services and/or digital content provided to you.
- Marketing information : This is information relating to your marketing and communications preferences.
- Other information : Career related information, such as education, job history, any information saved in your account, communications between you and us.
- Website, Device and Technical Information : This is information about your use of our website and technical data which we collect (including your IP address, the type of browser you are using and the version, the operating system you are using, details about the time zone and location settings on the device and other information we receive about your device).
- Log File information : This category encompasses data transmitted by your browser when you visit our Site, such as your computer"s Internet Protocol address, browser type and version, the pages of our Site that you visit, the date and time of your visit, the time spent on those pages, and other related statistics.
3. Analytics and Remarketing Services:
We utilize third-party analytics tools to analyze traffic and usage patterns on our website. These tools, employing cookies—text files stored on your device—gather anonymous data, including pages visited and interactions, to enhance site functionality. Our use of aggregated analytics ensures individual users cannot be identified.
- Google Analytics : This service places a persistent cookie in your browser to track user interactions. The use of data by Google is governed by their Analytics Terms of Use and Privacy Policy. You can opt-out by disabling cookies or using the Google Analytics Opt-out Browser Add-on.
- DoubleClick Cookie by Google : As a third-party, Google employs DoubleClick cookies to deliver ads based on your visits to our site and others on the internet. Opt-out via Google Ads Settings for more control over interest-based ads.
- Remarketing Efforts : We engage in remarketing to present ads on third-party sites, based on your past visits to our website, using cookies to tailor and optimize ad delivery.
- Google Ads : For ads personalization and opting out, visit Google Ads Settings.
- Perfect Audience : Opt-out options are available at Perfect Audience"s Site Opt-out and Partner Opt-out pages. More on their privacy practices can be found on the Perfect Audience Privacy Policy page.
- AdRoll : To opt-out of AdRoll"s remarketing, visit their AdRoll Advertising Preferences. Their Privacy Policy offers additional information.
- AppNexus : For opting out of AppNexus remarketing, refer to the AppNexus Privacy page.
For comprehensive details on opting out and privacy practices, please refer to the respective services" policies.
The types of personal data we collect about you may differ from person to person, depending on who you are and the relationship between us.
4. Diversity in Data Collection:
We recognize the diversity of our users and understand that the types of personal data we collect may vary. This variation is influenced by the nature of your interaction with our services and our relationship with you.
5. Children"s Privacy:
Protecting the privacy of young users is especially important to us. Our website is not intended for individuals under the age of 16, and we do not knowingly collect personal data from children under this age. Should any parent or guardian discover that their child has provided us with their personal information, we urge you to reach out to us immediately. Upon learning of any such collection without appropriate consent, we are committed to taking prompt action to remove the data from our systems.
6. Handling of Sensitive Information:
In alignment with the definitions provided earlier, we take extra precautions with sensitive data, which demands higher protection levels under data protection laws. We do not collect or store any special categories of personal information that could reveal sensitive aspects of your identity.
7. Use of Personal Information
We use your personal information in accordance with data protection laws, for specific legal reasons outlined below:
- Contractual Necessity: To fulfill our contractual obligations to you.
- Legitimate Interests: For our legitimate business interests or those of a third party, provided your rights and interests do not override these interests.
- Legal Obligations: To comply with our legal obligations.
- Consent: When you have explicitly consented to the use of your personal information for one or more specific purposes.
For certain sensitive personal data requiring additional protection, we process it under the following conditions:
- With your explicit consent.
- When necessary for legal claims.
- If the data has been made public by you.
Providing us with your personal information is essential for us to deliver our services. Without it, we may be unable to serve you. Please ensure your personal information is up-to-date, and inform us immediately of any changes.
Should you wish to withdraw your consent for processing your personal information, you can do so at any time by contacting us. If you withdraw consent for a specific purpose, we will cease processing your data for that purpose unless another legal basis applies, in which case we will inform you.
Below are the purposes for which we use your personal information, along with the corresponding legal bases:
- Customer Enrollment: To provide you with services and/or digital content, based on our contractual necessity and legitimate interests in business development.
- Order Processing: To process transactions, including payments, updates, and any necessary enforcement actions, under contractual necessity and legitimate interests.
- Contract Management and Notifications: To manage our contract and communicate any changes, as required by contractual necessity and legal obligations.
- Compliance and Record Keeping: For auditing and maintaining records, including any guarantees or warranties, as mandated by legal obligations.
- Service Improvement: To enhance the quality of our services and digital content for future customers, driven by our legitimate business interests.
- Marketing Communications: To inform you about relevant services and content, based on our legitimate interests in business growth and your consent.
- Website Operation: To ensure the efficient and secure operation of our website, supported by our legitimate interests.
For further details or if you require clarification on the specific legal basis we are relying on for processing your personal data, please reach out to us.
We may anonymize personal information, rendering it unidentifiable, for internal uses such as analysis and research. Additionally, we might aggregate your data with others" for statistical purposes without compromising individual privacy.
Per data protection regulations, our use of your personal information is confined to the purposes specified to you, except where a new purpose aligns with the original ones. Should we need to use your data for an incompatible new purpose, we will inform you and clarify the lawful basis allowing such use.
8. Details of how we collect personal information and special information
We collect the following information from our clients, who request the pre-screening and interview services:
- Identity information: This is information relating to your identity such as your name (including any previous names and any titles that you use), gender, marital status and date of birth.
- Contact information: This is information relating to your contact details such as email address, addresses, telephone numbers.
- Account information: This is information relating to your account with us (including username and password).
- Payment information: Where applicable, this is information relating to the methods by which you provide payment to us such as bank account details, credit or debit card details and details of any payments (including amounts and dates) that are made between us.
- Services information: This is information relating to services and/or digital content provided to you.
- Marketing information: This is information relating to your marketing and communications preferences.
- Other information: Career related information, such as education, job history, any information saved in your account, communications between you and us.
We may also collect some of your personal data directly from you (e.g. when you fill out a form, survey or questionnaire, contact us by email, telephone, in writing or otherwise).
We may receive some of your personal information from third parties or publicly available sources. This includes:
Identity Information and Contact Information from publicly available sources such as Companies House and others;
Website, Device and Technical Information from third parties such as analytics providers (such as Google);
We may also receive Website, Device and Technical Information automatically from technologies such as cookies that are installed on our website. To find out more about these please see our cookie policy, which is available here.
9. Details about with whom personal information may be shared:
We may need to share your personal information with other organizations or individuals. These entities include:
- Other companies within our group, which may serve as joint data controllers or data processors. These companies require access to personal information for services such as IT and may share data for purposes like management reporting.
- Third parties outside our group, which may include:
- Suppliers, such as providers of IT support services, payment processing, administrative services, and marketing agencies, located in various countries worldwide.
- Government and regulatory bodies, such as HMRC and fraud prevention agencies, also based in multiple countries.
- Our professional advisors, including lawyers, accountants, auditors, and insurance companies, located internationally.
- Our banking partners and credit reference agencies.
- Email service providers.
- Any organizations considering the acquisition of our business and assets, to whom we may disclose your personal information.
We ensure that any sharing of personal information with Data Processors is governed by contractual agreements that specify both parties" responsibilities, especially concerning data security.
We do not sell or trade any personal information that you have provided to us.
10. International Transfers of Personal Information
When transferring personal information outside the European Economic Area (EEA), we commit to maintaining a protection level comparable to EEA standards. This compliance aligns with data protection laws and considers available legal exceptions for international data transfers.
Such transfers may be necessary to entities within our corporate group or third-party organizations located outside the EEA, as described in the previous sections of this policy.
To safeguard your personal information, we adhere to the following measures:
- Transferring data only to countries recognized by the European Commission as providing adequate data protection.
- Applying binding corporate rules within our group for international data transfers.
- Utilizing standard contractual clauses approved by the European Commission.
- Following codes of conduct approved by relevant data protection authorities, like the Information Commissioner’s Office (ICO) in the UK.
- Engaging in certification mechanisms to ensure data protection.
Please note that the EU-US Privacy Shield is no longer a valid mechanism for EEA-US data transfers following recent legal developments.
11. Retention of Personal Information
We retain personal information only as necessary, based on the purpose of data collection and legal requirements, such as those related to accounting, auditing, and taxation. This is also to protect against potential legal claims or to uphold any guarantees or warranties associated with our services.
Candidates" Information: Names, email addresses, and test scores are kept for 5 years.
Webcam Images: Images captured during interviews are stored for 6 months.
Video Recordings: Interviews are archived for 2 years.
12. Anonymized Data Retention:
In our commitment to continuous improvement and to enhance platform functionality, we anonymize and indefinitely retain data related to candidate interactions with our platform. This anonymization process rigorously removes all personal identifiers, ensuring the impossibility of tracing data back to any individual. The anonymized data serves as a valuable resource for analytical insights, feature development, and service optimization, all while strictly adhering to data protection principles.
13. Candidate Feedback and Consent:
In addition to the data retention policies outlined above, we also value the feedback provided by candidates regarding their experience with our platform. This feedback is crucial for our ongoing improvement and to ensure the effectiveness of our services.
- Feedback Collection: At the conclusion of the interview process, candidates may be invited to participate in a survey to share their experience. Participation is entirely voluntary, and any personal information provided in feedback is processed and protected with the same level of care as all other candidate data.
- Data Use and Consent: While our primary service agreements are with our hiring clients, the collection of candidate feedback directly from candidates involves a separate consent process. By participating in the feedback survey, candidates expressly consent to the use of their responses for service improvement purposes. This consent is distinct from any agreements or understandings with our clients and does not impact the candidates" rights or our obligations under data protection laws.
- Anonymity and Use: Whenever possible, feedback data is anonymized and aggregated for analysis. If specific feedback requires addressing or follow-up, any personal identifiers are used solely for that purpose and are handled according to the strict privacy standards set forth in this notice.
We are dedicated to ensuring transparency and respect for privacy in all interactions. If candidates or clients have any concerns or questions about the use of feedback data or any other privacy matters, we encourage direct communication through the channels provided in this notice.
14. Automated decision making
‘Automated decision making’ involves decisions made automatically, without human involvement. Under data protection laws, this includes profiling. ‘Profiling’ is the automated processing of personal data to evaluate or analyse certain personal aspects of a person (such as their behaviour, characteristics, interests and preferences).
15. Your Rights Under Data Protection Law
You are entitled to various rights under data protection legislation concerning your personal information:
Right to Access: Often referred to as "subject access," this right enables you to receive a copy of the personal information we hold about you and to understand how it is used.
Right to Correction: You can request the correction of inaccurate personal information and completion of incomplete data.
Right to Erasure: Also known as the "right to be forgotten," this applies in specific contexts, allowing you to request the deletion of your personal information.
Right to Restrict Processing: In certain situations, you have the right to request a halt on the processing of your personal information.
Right to Data Portability: This right allows you to move, copy, or transfer personal information easily from one IT environment to another.
Right to Object: You may object to the processing of your personal information for direct marketing or when processing is based on legitimate interests. This includes objecting to profiling activities related to direct marketing.
Should you choose to withdraw consent for processing your personal information, you are at liberty to do so at any time.
To exercise your rights, please reach out to us via the contact details provided. Note that we may require specific information to confirm your identity for security purposes. There is no fee for exercising your rights, except in cases where requests are deemed unfounded or excessive, at which point we may charge a nominal fee or decline the request.
16. Marketing Communications
You may receive marketing communications from us related to services similar to those you"ve engaged with, provided you"ve given consent or under circumstances where we are legally permitted to do so.
We ensure you have control over these communications. Every marketing email includes options to unsubscribe, opt-out, or adjust your preferences. Additionally, if you hold an account with us, you may directly manage your marketing preferences within your account settings. For further adjustments to your marketing preferences or to cease all marketing communications, please reach out to us using the contact information provided at the start of this document.
Please note, opting out of marketing communications does not exclude you from receiving essential service-related information, such as updates on purchases or changes to our services. Your personal information is not shared with third parties for their marketing purposes.
17. Complaints
If you have concerns about how we"ve handled your personal information, you"re entitled to lodge a complaint with the Information Commissioner’s Office (ICO), the UK"s data protection authority. We encourage you to contact us as we"re committed to resolving any issues directly and value the opportunity to address any concerns. Please reach out to us using the contact information provided at the start of this privacy notice.
18. Third-party websites
Our website may contain links to third-party websites. Clicking on these links will redirect you to external sites. It"s important to note that these third-party sites may collect your personal information. We advise you to review their privacy policies to understand how they handle your data.