We collect, use and are responsible for certain personal information about you. When we do so we are subject to the General Data Protection Regulation ((EU) 2016/679) (“GDPR”), which applies across the European Union (including in the UK), and the Data Protection Act 2018, together the “Data Protection Legislation”) under which we are responsible as ‘controller’ of that personal information for the purposes of those laws.
It would be helpful to start by explaining some key terms used in this policy:
|we, us, our||Miramar Global Holdings Ltd, a company registered in England and Wales under company number 07043459 with its registered office of 3rd Floor, 83-84 George Street, Richmond, Surrey, England, TW9 1HE and our group companies;|
|you, your||website users, candidates, client and suppliers;|
Personal information we collect about you
We may collect and use the following personal information about you:
|Personal information||Website users||Clients||Suppliers||Candidates|
|Your name and contact information, including email address and telephone number and company details.|
This personal information is required to provide services to you (in the case of clients, candidates or website users), or (in the case of suppliers) to purchase goods and/or services from you. If you do not provide the personal information we ask for, it may delay or prevent us from providing services to you or purchasing goods and/or services from you.
How your personal information is collected
- from publicly accessible sources – for example, Companies House or HM Land Registry;
- directly from a third party – for example:
- sanctions screening providers;
- credit reference agencies;
- client due diligence providers
- from a third party with your consent – for example, a referee;
- via our IT systems – for example:
- door entry systems and reception logs
- automated monitoring of our websites and other technical systems, such as our computer networks and connections, CCTV and access control systems, communications systems, email and instant messaging
How and why we use your personal information
Under the Data Protection Legislation, we can only use your personal information if we have a proper reason for doing so, for example:
- to comply with our legal and regulatory obligations;
- for the performance of our contract with you or to take steps at your request before entering into a contract;
- for our legitimate interests or those of a third party; or
- where you have given consent.
A legitimate interest is when we have a business or commercial reason to use your information, so long as this is not overridden by your own rights and interests.
The table below explains what we use (process) your personal information for and our reasons for doing so:
|What we use your personal information for||Our reasons|
|To provide services to you (in the case of clients or candidates) or purchase goods and/or services from you (in the case of suppliers).||For the performance of our contract with you or to take steps at your request before entering into a contract.|
The above table does not apply to special category personal information, which we will only process with your explicit consent.
We may use your personal information to send you updates (by email, text message, telephone or post) about our services, candidates or available roles.
We have a legitimate interest in processing your personal information for promotional purposes (see above ‘How and why we use your personal information’). This means we do not usually need your consent to send you promotional communications. However, where consent is needed, we will ask for this consent separately and clearly.
We will always treat your personal information with the utmost respect and never sell or share it with other organisations outside the Miramar group for marketing purposes.
You have the right to opt out of receiving promotional communications at any time by:
We may ask you to confirm or update your marketing preferences if you instruct us to provide further services in the future, or if there are changes in the law, regulation, or the structure of our business.
Who we share your personal information with
We routinely share personal information with:
- companies within the Miramar group;
- third parties we use to help deliver our services to you: for example, payment service providers;
- other third parties we use to help us run our business: for example, marketing agencies, website hosts or software providers, such as Invenias Limited, Skype and SharePoint;
- third parties approved by you: for example, social media sites you choose to link your account to or third-party payment providers, such as LinkedIn or XING;
- our banks;
- if you are a candidate, prospective employer or hirer
We only allow our service providers to handle your personal information if we are satisfied that they take appropriate measures to protect your personal information. We also impose contractual obligations on service providers relating to ensuring that they can only use your personal information to provide services to us and to you. We may also share personal information with our accountants, MHA Carpenter Box, in relation to the proper preparation of our accounts.
We may disclose and exchange information with law enforcement agencies and regulatory bodies to comply with our legal and regulatory obligations.
We may also need to share some personal information with other parties, such as potential buyers of some or all of our business or during a re-structuring. Usually, information will be anonymised, but this may not always be possible. The recipient of the information will be bound by confidentiality obligations.
Where your personal information is held
Information may be held at our offices and those of our group companies, third party agencies, service providers, representatives and agents as described above (see above: ‘Who we share your personal information with’).
Some of these third parties may be based outside the European Economic Area. For more information, including on how we safeguard your personal information when this occurs, see below: ‘Transferring your personal information out of the EEA’.
How long your personal information will be kept
We will keep your personal information while you have an account with us (in relation to clients), while we have an account with you (in relation to suppliers) or whilst we are providing services to you (in relation to clients and/or candidates). Thereafter, we will keep your personal information for as long as is necessary:
- to respond to any questions, complaints or claims made by you or on your behalf;
- to show that we treated you fairly; and
- to keep records required by
When it is no longer necessary to retain your personal information, we will delete or anonymise it.
Transferring your personal information out of the EEA
To deliver services to you, it is sometimes necessary for us to share your personal information outside the European Economic Area (EEA), for example:
- with our offices outside the EEA, being in the USA and Singapore;
- with your and our service providers located outside the EEA;
- with potential employers or hirers located outside the EEA;
- if you are based outside the EEA; or
- where there is an international dimension to the services, we are providing to
These transfers are subject to special rules under European and UK data protection law.
These non-EEA countries do not have the same data protection laws as the UK and EEA. We will, however, ensure the transfer complies with data protection law and all personal information will be secure. Our standard practice is to use standard data protection contract clauses that have been approved by the European Commission. https://ico.org.uk/
If you would like further information, please contact us (see ‘How to contact us’ below).
You have the following rights, which you can exercise free of charge:
|Access||The right to be provided with a copy of your personal information (the right of access).|
|Rectification||The right to require us to correct any mistakes in your personal information.|
For further information on each of those rights, including the circumstances in which they apply, please contact us or see the guidance on the Information Commissioner’s Office website on individuals’ rights under the Data Protection Legislation.
If you would like to exercise any of those rights, please:
- email, call or write to us – see below: ‘How to contact us’; and
- let us have enough information to identify you (for example your full name and address;
- let us have proof of your identity and address (a copy of your driving licence or passport and a recent utility or credit card bill); and
- let us know what right you want to exercise and the information to which your request
Keeping your personal information secure
We have appropriate security measures to prevent personal information from being accidentally lost or used or accessed unlawfully. We limit access to your personal information to those who have a genuine business need to access it. Those processing your information will do so only in an authorised manner and are subject to a duty of confidentiality. We continually test our systems and are ISO 27001 certified, which means we follow top industry standards for information security.
We also have procedures in place to deal with any suspected data security breach. We will notify you and any applicable regulator of a suspected data security breach where we are legally required to do so.
How to complain
We hope that we can resolve any query or concern you may raise about our use of your information.
The Data Protection Legislation also gives you right to lodge a complaint with a supervisory authority, in particular in the European Union (or EEA) state where you work, normally live or where any alleged infringement of data protection laws occurred. The supervisory authority in the UK is the Information Commissioner who may be contacted at https://ico.org.uk/concerns or by telephone: 0303 123 1113.
This privacy notice was published in 2020.
We may change this privacy notice from time to time— when we do, we will inform you via our website.
How to contact us
Our contact details are shown below:
83-84 George Street
+44(0)203 8622 080