Notice
Please read this Monks Recruitment Privacy Notice carefully to understand our policies and practices regarding our collection and use of your information.
If you do not agree with our notices policies and practices, you may not apply to a Monks role through the career section in the Monks website. If you are asked to accept this Notice during any stage of the recruitment process, that acceptance will be considered as your consent to process your Personal Data only in countries where such consent is necessary. In all other countries, clicking on acceptance or agreement buttons will be seen as simply acknowledging this statement.
We may revise this Notice from time to time, You acknowledge and agree that your continued participation in the recruitment and/or hiring process after we have made such revisions is deemed to be your acceptance of any such revisions. Thus, please check this Notice periodically and be mindful of the “Last updated” date, which will inform you as to the date this Notice was last revised.
As shown as a disclaimer on our career section, your security and privacy is important to us, therefore no one at Monks will ever request your passwords, usernames, credit card information, or other Personal Data through unsolicited emails, telephone calls, or other communications. If you receive an email, telephone call or other communication purportedly from us that requests Personal Data from you (including passwords, usernames, or credit card information), please inform us immediately without providing any information to the requestee. You may delete after the communication/request is reported to us and necessary steps are taken.
Overview
S4 Capital Plc and its subsidiaries (“Monks”, “we”, “us”, “our”) are committed to protecting the Personal Data we process and control when candidates (“you”) use Monks´ online career resources, when apply for a job in Monks, when are interested in applying for a job and when undertaking pre-hire and/or onboarding actions. As part of this commitment, we have prepared this Notice which describes our recruitment and hiring privacy practices and explains how we collect, use, disclose, or otherwise process the Personal Data about candidates at global level.
In this Notice, our use of the term “Personal Data” includes other similar terms under applicable privacy laws—such as “Personal Data”, “personal information”,“personally identifiable information, and “PII”. In general, Personal Data includes any information that identifies, relates to, describes, or is reasonably capable of being associated, or reasonably linked or linkable with a particular individual and/or, under applicable laws, a household. Learn more about what types of Personal Data we collect in the PERSONAL DATA WE COLLECT AND PROCESS section.
This Notice applies to you if you are a current or former candidate that: a) Use or used Monks´ online career resources; b) Applied or is interested in applying for a job in Monks; and/or c) Undertaking pre-hire and/or onboarding actions.
The controllers for your Personal Data are:
- (i) the Monks group company who manages your recruitment and/or hiring process (please see here the list of Monks entities);
- (ii) S4 Capital, plc. the ultimate parent company of the Monks group, who manages Monks’s IT, business operations, strategy and planning, compliance, and other centralized operations and functions.
Please, review the Notice in full below:
Table of Contents
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Personal Data We Collect And Process
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Sources Of Personal Data
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How Do We Process Personal Data?
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The Lawful Basis Of Our Processing
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Sharing Of Personal Data
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Transfer Of Personal Data
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Data Security
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Data Retention
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Automated Decisions
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Your Rights
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Changes To Our Privacy Notice
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Contact Us
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Additional Information For Individuals In Certain Jurisdictions
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A. Important Information For California Residents
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B. Important Information For Individuals In The EU / European Economic Area / UK
1. Personal Data We Collect And Process
The types of information requested from you and the manner in which that information is collected and accessed are determined by the requirements of the country in which the position is located.
Monks will collect information about you and in some cases from other third parties (cf. Section SOURCES OF PERSONAL DATA). We refer to such information in this Notice as "Personal Data". Typically, the categories of Personal Data we may receive through electronic, written and verbal communications include the following:
Personal details: such as full name, maiden name, home address, telephone number, personal email address, date of birth, country of birth, nationality, national identification number (as permitted by applicable law), gender, family status, employee identification number, beneficiary information, emergency contact information, and information about your dependents;
Identity and verification information (as permitted by applicable law): such as government issued identification card information, citizenship, passport data, and details of residency, visa status or work permit, as well as any other documentation required under immigration laws;
Professional and Employment related data: details contained in letters of application and resumes / CVs letters, previous employment background, education history, professional qualifications, language and other relevant skills, details on feedback, career development details; as well as information about training and courses attended and certifications received or renewed, as well data generated by interviewers and recruiters, based on their interactions with you or basic Internet searches where allowed under applicable law;
Background check data: Where applicable and allowed under applicable law, credit history, criminal records or other data revealed during background screenings;
Images, audio, and footage recorded on CCTV or other video systems during your visit to our office, as well as materials captured during recruitment events, including photographs, audio, video, and transcripts from interviews and assessments;
Recommendations provided on your behalf by others;
Other information: Personal Data requested to provide during the recruitment process, to the extent allowed by applicable law, and other information you voluntarily provide to us during the course of your employment, such as when you participate in our employee survey responses.
Some of the Personal Data that we may collect is deemed sensitive and referred to as “Special Categories of Personal Data”. For example, where necessary and authorized by law, we process special categories of Personal Data relating to your health, race and ethnicity, religious affiliation, and trade union membership.
To the extent legally permissible, we may collect data about: 1) Your health or disability where it is relevant to your ability or availability to work or to a workplace accommodation, subject to legal limits on the timing of collection of such data and other applicable limitations; and 2) Data about race, ethnicity, religion, disability, sexual orientation and gender identity, military/veteran status, for purposes of government reporting where legally required, as well as to support Monks’ diversity goals, evaluate the effectiveness of our equal opportunity standards and promote Monks’ diversity best practices.
Where the collection of one or more Special Categories of Personal Data is not legally required for recruitment and hiring purposes, you are not obligated to provide any requested information to Monks to participate in the recruitment and hiring process and not doing so will not affect your ability to proceed with your job application.
By submitting your information, you confirm that all statements made by you are true and accurate to the best of your knowledge and that you have not intentionally left out any relevant negative information. Providing false information may disqualify you from employment.
2. Sources Of Personal Data
We collect Personal Data – as permitted by applicable law – from the following sources:
- From you, when you submit resumes or other information online, other electronic or manual means of communication or in person;
- Publicly available sources;
- From other Monks affiliates and/or subsidiaries;
- From discussions with recruiters and interviews with hiring managers and other representatives of Monks, some of which may be recorded. Additionally, this includes internet searches conducted by these individuals (where permitted by law) and data obtained from job search or professional networking sites (such as LinkedIn) where you may have made your information publicly accessible.
- From your previous employers (e.g. when performing background checks to confirm prior employment dates);
- From third-party recruiters, applicant matching platforms, staffing agencies, or websites that introduce you to Monks. While Monks does not accept unsolicited resumes from third-party recruitment agencies, we may occasionally work with these agencies under a formal written agreement.
- Through background checks, as applicable. Where legally allowed, Monks may engage a third party to conduct a pre-employment background screening. The details of the background check can differ by country to meet local regulations, but may include data from publicly available sources, your previous employers or colleagues, educational institutions, credit reporting agencies, and criminal records databases. You will receive additional information about the background check process prior to its initiation. If required by local law, you may need to provide specific background check information, which could include sensitive data, directly to Monks.
3. How Do We Process Personal Data?
We may process your Personal Data in electronic and paper format. The types of Personal Data we process will vary depending on the jurisdiction requirements for recruitment and hiring process and the terms and conditions to be met for the role that you are applying for.
We process Personal Data for the purposes listed below.
- Evaluate your suitability for the position you are applying for, as well as potential future roles that may arise (subject to your choices and as permitted by and in compliance with applicable law), for which a recruiter might reach out to you directly;
- Transfer your contact details, educational background, employment information, application data, and CV, all provided by you in Monks recruitment systems;
- Carry out administrative tasks;
- Create candidate profiles by analyzing data to assess fit for specific roles and predict future performance. Selection and hiring decisions are reviewed and made by a Monks recruiting team member, and no automated decisions regarding candidacy occur without their oversight;
- Oversee your application and carry out pre-hire and onboarding activities;
- In certain situations, capture photos, record, and/or transcribe your online interview and assessment (potentially utilizing AI-driven support features) for evaluation by other recruiters and hiring managers;
- Enable communication with you, which may involve AI-driven support features such as scheduling meetings, summarizing discussions, and suggesting email content;
- Carry out any mandatory reporting and address legal proceedings;
- Conduct data analytics, which may include AI technologies like machine learning, to analyze our applicant pool and gain insights into who is applying for positions at Monks. This helps us attract and retain top talent and aids in sourcing and screening (though not for final recruitment decisions) when handling a large volume of applications;
The processing of Personal Data for the above activities are implemented in accordance with applicable law and local authority’s guidance.
Monks does not anticipate that you will be subject to automated decisions based solely on the use of AI technologies. Monks will notify you if this position changes in the future.
Monks will not utilize your personal information for any purposes that differ from those outlined in this privacy notice, unless mandated or permitted by law, or if it is necessary for your critical well-being (such as in a medical emergency).
4. The Lawful Basis Of Our Processing
Certain laws, including the EU General Data Protection Regulation 2016/679 (GDPR), require that we inform you of the lawful basis of our processing of your Personal Data. Following this line, our data processing activities will rely on different lawful grounds as a basis for the processing of the Personal Data. Pursuant to the GDPR (and other similar laws), we generally rely on the following lawful basis:
- The necessity to comply with a legal obligation: Including, reviewing eligibility for work and applicable regulatory requirements;
- The legitimate interest: Our legitimate business interests balanced against your rights (where our interests are not overridden by your interests, fundamental rights or freedoms), based for example in Monks' legitimate interests of ensuring that it recruits the appropriate employees for current or future roles;
- Your explicit consent: We will process your personal information for the reasons specified in Section 3, based on your prior consent where required by applicable law. If you are asked to accept this Notice during any stage of the recruitment process, that acceptance will be considered as your consent to process your Personal Data only in countries where such consent is necessary. In all other countries, clicking on acceptance or agreement buttons will be seen as simply acknowledging this statement.
- Protection of vital interests : In exceptional circumstances such as an emergency health issue, the necessity to protect your vital interests and you are incapable of giving consent (e.g. interviews performed in our facilities).
5. Sharing Of Personal Data
Access to your personal information will generally be limited to reduce the number of individuals within Monk’s global organization who require it for the purposes outlined in this Notice. This may include potential future managers and their designees, as well as personnel from Talent Acquisition, People, IT, Compliance, Legal, Finance, Accounting and Internal Audit. As a global entity with interconnected IT systems, your Personal Data may be transferred to other Monks offices worldwide. Monks has established internal policies to ensure that an equivalent level of protection is maintained across its global organization.
Additionally, if necessary, Monks may share your personal information with third parties, including external service providers and public authorities. Before doing so, Monks take measures to safeguard your Personal Data. All service providers and professional advisors who receive your Personal Data are required to maintain its confidentiality and security and may only use it in accordance with applicable data protection laws.
The following categories of third parties will have access to your Personal Data:
Affiliates: Where considered appropriate, we share your Personal Data internally among the Monks group companies, affiliates, and subsidiaries, which may include the S4 Capital Group (and its group entities), particularly with individuals involved in HR management and employees who require access to the Personal Data about you to perform their work such as:
- Recruiters employed by Monks in the country of the position you are applying for. These individuals may be located in a different country;
- Hiring managers and other interviewers, who may be based in the same country as the position, although some may be situated in other locations;
- The global Monks Talent Management team or similar teams, made up of a limited number of individuals across various countries;
- Individuals providing administrative and IT support functions.
Service Providers: We also share Personal Data with service providers which its authorized personnel act and process data on our behalf, including those that:
- Host and manage Monks' talent acquisition systems, talent connection, or similar hiring, recruitment, talent management, or HR-related platforms;
- Conduct virtual or online interviews, which may include recording sessions if live interviews are not feasible;
- Provide analytics services to enhance and optimize the screening and sourcing processes for finding and hiring candidates (always subject to a final human decision);
- Send recruitment experience feedback surveys to candidates who have applied for open positions;
- Carry out background screenings when applicable and permitted by applicable law. These companies may operate from another country and may collect data from other countries where you have lived, worked, or studied, as relevant for the background check. You will receive more details about any such check before it commences;
- Assist Monks in conducting psychological, technical, or behavioral assessments, as well as other recruitment, onboarding, and HR-related service providers associated with Monks.
Government officials: When legal reporting obligations are in place, or law enforcement agencies or private litigants in response to a valid legal process (such as a warrant, subpoena, or court order);
Third Party Business Transfer: A third party involved in any proposed or actual reorganization, merger, sale, joint venture, assignment, transfer, or other disposition of all or part of Monks' business, assets, or stock (including in the context of bankruptcy or similar proceedings);
The data processing conducted by our vendors (processors) is carried out on the basis of a contract within the meaning of Art. 28 para. 3 of the GDPR, which binds processors with regard to the controller and which sets out the activity and duration of the processing, the nature and purpose of the processing, the type of Personal Data and categories of data subjects and the obligations and rights of the controller.
We encourage you to check the terms and policies when you use third-party apps, platforms, websites or products integrated with our systems, for instance when applying for a role, to make sure you are comfortable with them.
6. Transfer Of Personal Data
Monks entities have entered into an Intra-Group Data Transfer Agreement (IGDTA) in order to ensure compliance with data protection laws when transferring personal data between different entities within the group. Unless you are informed otherwise, any transfers of your Personal Data from within the European Economic Area (EEA) to third parties outside the EEA will be based on an adequacy decision or will be governed by the EU standard contractual clauses. Any other international transfers of your Personal Data originating outside the EEA will comply with the relevant international data transfer mechanisms and safeguards. If your consent is necessary in your country for transferring your Personal Data to another country or third party, agreeing to our Notice will be considered your consent for such transfers.
7. Data Security
Monks is committed to safeguarding the security of personal information in its custody and control and will take appropriate measures to protect Personal Data that are consistent with applicable privacy and data security laws and regulations, including requiring service providers to use appropriate measures to protect the confidentiality and security of Personal Data.
Access to Personal Data within Monks will be limited to those who have a need to know the information for the purposes described above, and may include personnel in Talent Acquisition, People, IT, Compliance, Legal, Finance, Accounting and Internal Audit. All personnel will generally have access to Monks employees’ business contact information such as name, position, telephone number, postal address and email address.
We have implemented safeguards and technical measures to protect the Personal Data that we have under our control from unauthorized access, use or disclosure in alignment with the ISO 27001:2022 standard. More information about security controls can be found in the Information Security & Compliance section. However, no data security measures can guarantee 100% security.
8. Data Retention
If you receive and accept a job offer from Monks, any Personal Data collected during your pre-employment phase will become part of your personnel records, which will be kept throughout your employment and for a period afterward. If Monks does not hire you, it may still retain and use the Personal Data gathered during the recruitment process to consider you for future positions and, if necessary, to reference your earlier application if you submit your resume or other information again. This data may also be used for system administration, research, and analysis.
Monks set the retention period for your information based on the following criteria:
- Monks retain your Personal Data as long as there is an ongoing relationship with you;
- As permitted by and in compliance with applicable law, Monks retain your Personal Data to consider you for future job openings;
- Monks retain your Personal Data when required to comply with legal obligations;
- Monks keep your Personal Data when it is prudent to protect or enhance its legal position (for example, in relation to statutes of limitations, litigation, or regulatory inquiries).
Monks implements by default a data retention period of one year, after which your Personal Data will be securely disposed of, unless otherwise required by law. As permitted by and in compliance with applicable law, acceptance of this notice will be deemed as your provision of consent for this one-year data retention period.
If you have any further questions on data retention practices based on the region and data processing activity, please reach out to privacy@monks.com.
9. Automated Decisions
Monks does not envisage that you will be subject to decisions that will have a significant impact on you based solely on automated decision-making. Monks will notify you if this position changes.
10. Your Rights
You have certain rights as a data subject in relation to your information. While some of these rights are general and unrestricted, other rights only apply in certain circumstances. Please see below:
Access, Amend and Correct. If you wish to access Personal Data that you have submitted to us, to request the correction of any inaccurate information you have submitted to us, to request deletion of or object to processing of your information, please send your request to privacy@monks.com. We may ask you for additional information so that we can confirm your identity.
Direct Marketing. You may always opt-out of direct marketing emails from us by following the instructions in such emails or emailing privacy@monks.com.
Complaints. We will take steps to try to resolve any complaint you raise regarding our treatment of your Personal Data. You also have the right to raise a complaint with the privacy regulator in your jurisdiction.
Additional Information for Certain Jurisdictions. We are committed to respecting the privacy rights of individuals under all privacy laws applicable to us. Some privacy and data protection laws require that we provide specific information about individual rights to applicable consumers, which we have set forth at the end of this privacy notice:
- California: if you are a California resident, you have certain rights, under California privacy laws, regarding your Personal Data as set forth below, under the IMPORTANT INFORMATION FOR CALIFORNIA RESIDENTS AND RESIDENTS OF OTHER U.S. STATES section.
- EU/EEA/UK: if you are in the European Union / European Economic Area / UK, below we provide further details about your rights under the General Data Protection Regulation and the United Kingdom’s Data Protection Act 2018 (collectively referred to as GDPR in this Notice), under the IMPORTANT INFORMATION FOR INDIVIDUALS IN THE EUROPEAN / EUROPEAN ECONOMIC AREA / UK section.
If you believe that your data privacy rights have been violated, despite our commitment and efforts to safeguard your Personal Data, we encourage you to approach Monks first to seek resolution for any complaints. You always have the right to register a complaint directly with the appropriate supervisory authority or to file a claim against Monks in a competent court (either in the country where you reside, the country where you work, or the country where you believe data privacy laws have been breached).
11. Changes To Our Privacy Notice
From time to time, we may update this Notice to reflect new or different privacy practices or to reflect changes in industry standards or legal requirements. We will place a notice online when we make material changes to this Notice. Additionally, if the changes will materially affect the way we use or disclose Information, we will notify you in advance of the change by sending a notice to the primary email address associated with your account or by posting a notice on our Site. We encourage you to periodically review this Notice for the latest information on our privacy practices.
12. Contact Us
If you have questions or concerns regarding the way in which your Personal Data is being processed or this Notice, please email us at privacy@monks.com or reach out to Monks using the contact information below: Monks, 15 Bonhill Street, London, England, EC2A 4DN.
13. Additional Information For Individuals In Certain Jurisdictions
A. Important Information For California Residents
Categories of Personal Data We Collect. The California Consumer Privacy Act (“CCPA”) requires that we disclose certain information about the categories of Personal Data that we collect about California residents. In the preceding 12 months, we may have collected the following categories of Personal Data relating to California residents. These categories are defined by California law. We may not gather all the information listed within a specific category, and we may not collect all categories of information for every individual. While the information we collect varies depending upon the circumstances, such as our interactions with you, we may collect the following categories of Personal Data (subject to applicable legal requirements and restrictions):
Category: Personal Identifiers
- Examples: Name, alias, postal or mailing address, email address, telephone number, etc.
- Business Purpose: To evaluate job candidacy and communicate with you regarding your application; To maintain internal business employment records; and To comply with our policies, procedures, and legal obligations, including complying with law enforcement or governmental authority requests, investigating fraudulent activity, resolving disputes, and enforcing our legal agreements and policies.
- Categories of third parties to whom we may “disclose” Personal Data for a business purpose:
- Affiliates, TA Service Providers (including professional advisors), Government Officials and/or Third Party Business Transfer.
- Sold or Shared: No
Category: Professional or employment-related information
- Examples: Details contained in letters of application and resumes / CVs letters, previous employment background, education history, professional qualifications, language and other relevant skills, details on feedback, career development details; as well as information about training and courses attended and certifications received or renewed, background checks, etc.
- Business Purpose: To evaluate job candidacy and communicate with you regarding your application; To maintain internal business employment records; and To comply with our policies, procedures, and legal obligations, including complying with law enforcement or governmental authority requests, investigating fraudulent activity, resolving disputes, and enforcing our legal agreements and policies.
- Categories of third parties to whom we may “disclose” Personal Data for a business purpose: Affiliates, TA Service Providers (including professional advisors), Government Officials and/or Third Party Business Transfer.
- Sold or Shared: No
Category: Educational information
- Examples: Education history, professional qualifications, language and other relevant skills, etc.
- Business Purpose: To evaluate job candidacy and communicate with you regarding your application; To maintain internal business employment records; and To comply with our policies, procedures, and legal obligations, including complying with law enforcement or governmental authority requests, investigating fraudulent activity, resolving disputes, and enforcing our legal agreements and policies.
- Categories of third parties to whom we may “disclose” Personal Data for a business purpose: Affiliates, TA Service Providers (including professional advisors), Government Officials and/or Third Party Business Transfer.
- Sold or Shared: No
Category: Protected classifications under California or federal law
- Examples: i) Government identifiers, such as your Social Security number, driver’s license, state identification card, or passport number; ii) Racial or ethnic origin; iii) Citizenship or immigration information; iv) Religious or philosophical beliefs; v) Health information; and vi) Sex life, or sexual orientation information.
- Business Purpose: To evaluate job candidacy and communicate with you regarding your application; To maintain internal business employment records; and To comply with our policies, procedures, and legal obligations, including complying with law enforcement or governmental authority requests, investigating fraudulent activity, resolving disputes, and enforcing our legal agreements and policies.
- Categories of third parties to whom we may “disclose” Personal Data for a business purpose: Affiliates, TA Service Providers (including professional advisors), Government Officials and/or Third Party Business Transfer.
- Sold or Shared: No
Category: Sensory Data
- Examples: Photos, record, and/or transcribe your online interview and assessment (potentially utilizing AI-driven support features).
- Business Purpose: To evaluate job candidacy and communicate with you regarding your application; To maintain internal business employment records; and To comply with our policies, procedures, and legal obligations, including complying with law enforcement or governmental authority requests, investigating fraudulent activity, resolving disputes, and enforcing our legal agreements and policies.
- Categories of third parties to whom we may “disclose” Personal Data for a business purpose: Affiliates, TA Service Providers (including professional advisors), Government Officials and/or Third Party Business Transfer
- Sold or Shared: No
Data Retention
Monks set the retention period for your information based on the following criteria:
- Monks retain your Personal Data as long as there is an ongoing relationship with you;
- As permitted by applicable law, Monks retain your Personal Data to consider you for future job openings;
- Monks retain your Personal Data when required to comply with legal obligations;
- Monks keep your Personal Data when it is prudent to protect or enhance its legal position (for example, in relation to statutes of limitations, litigation, or regulatory inquiries).
Additionally, Monks is implementing by default a data retention period of one year, after which your Personal Data will be securely disposed of, unless otherwise required by law. Acceptance of this notice will be deemed as your provision of consent for this one-year data retention period.
California Residents’ Rights
California law grants California residents certain rights and imposes restrictions on particular business practices as set forth below.
Do-Not-Sell: California residents have the right to opt-out of our sale of their Personal Data. Opt-out rights can be exercised by submitting a request to us online at privacy@monks.com. We do not sell Personal Data about residents who we know are younger than 18 years old without opt-in consent.
Notice before collection: We are required to notify California residents, at or before the point of collection of their Personal Data, the categories of Personal Data collected and the purposes for which such information is used.
Request to delete: California residents have the right to request, at no charge, deletion of their Personal Data that we have collected about them and to have such Personal Data deleted, except where an exemption applies. We will respond to verifiable requests received from California residents as required by law.
Request to know: California residents have the right to request and, subject to certain exemptions, receive a copy of the specific pieces of Personal Data that we have collected about them in the prior 12 months and to have this delivered, free of charge, either (a) by mail or (b) electronically in a portable and, to the extent technically feasible, readily useable format that allows the individual to transmit this information to another entity without hindrance. California residents also have the right to request that we provide them certain information about how we have handled their Personal Data in the prior 12 months, including:
- categories of Personal Data collected;
- categories of sources of Personal Data;
- business and/or commercial purposes for collecting and selling their Personal Data;
- categories of third parties/with whom we have disclosed or shared their Personal Data;
- categories of Personal Data that we have disclosed or shared with a third party for a business purpose; and
- categories of third parties to whom the residents’ Personal Data has been sold and the specific categories of Personal Data sold to each category of third party.
California residents may make a Request to Know up to twice every 12 months, at no charge. We will respond to verifiable requests received from California residents as required by law.
- Request to Correct: California residents have the right to request the correction or update of any incomplete or inaccurate Personal Data that we may have about them.
Submitting Verifiable Requests
For requests to know and requests to delete please contact us at privacy@monks.com. We will respond to verifiable requests received from California residents as required by law.
B. Important Information For Individuals In The EU / European Economic Area / UK
This section explains the rights that data subjects in the European Union / European Economic Area (“EEA”) / United Kingdom have. More specifically, pursuant to the GDPR and the United Kingdom’s Data Protection Act 2018 (UK GDPR,) -here collectively referred to as GDPR- individuals in the EU and UK are granted specific rights concerning their Personal Data.
Rights under the GDPR.
Individuals in the EU/EEA/UK have the below rights with respect to their Personal Data.
- Right of access: You can ask us to: confirm whether we are processing your Personal Data; give you a copy of that information; provide you with other information about your Personal Data such as what data we have, what we use it for, who we disclose it to, whether we transfer it abroad and how we protect it, how long we keep it for, what rights you have, how you can make a complaint, where we got your information from and whether we have carried out any profiling, to the extent that such information has not already been provided to you in this Notice.
- Right to rectify and complete Personal Data: You can ask us to rectify inaccurate information. We may seek to verify the accuracy of the data before rectifying it.
- Right of erasure: You can ask us to erase your Personal Data, but only where: it is no longer needed for the purposes for which it was collected; you have withdrawn your consent (where the data processing was based on consent); following a successful right to object (see ‘Objection’ below); it has been processed unlawfully; or to comply with a legal obligation to which we are subject. We are not required to comply with your request to erase your Personal Data if the processing of your Personal Data is necessary: for compliance with a legal obligation; or for the establishment, exercise or defense of legal claims. There are certain other circumstances in which we are not required to comply with your erasure request, although these two are the most likely circumstances in which we would deny that request.
- Right of restriction: You can ask us to restrict (i.e. keep but not use) your Personal Data, but only where: its accuracy is contested, to allow us to verify its accuracy; the processing is unlawful, but you do not want it erased; it is no longer needed for the purposes for which it was collected, but we still need it to establish, exercise or defend legal claims; you have exercised the right to object, and verification of overriding grounds is pending. We can continue to use your Personal Data following a request for restriction, where: we have your consent; to establish, exercise or defend legal claims; or to protect the rights of another natural or legal person.
- Right to object to our use of your Personal Data for direct marketing purposes: You can request that we change the manner in which we contact you for marketing purposes. You can request that we not transfer your Personal Data to unaffiliated third parties for the purposes of direct marketing or any other purposes.
- Right to object for other purposes: You have the right to object at any time to any processing of your Personal Data which has our legitimate interests as its Lawful Basis. You may exercise this right without incurring any costs. If you raise an objection, we have an opportunity to demonstrate that we have compelling legitimate interests which override your rights and freedoms. The right to object does not exist, in particular, if the processing of your Personal Data is necessary to take steps prior to entering into a contract or to perform a contract already concluded.
- Right to (data) portability: You can ask us to provide your Personal Data to you in a structured, commonly used, machine-readable format, or you can ask to have it ‘ported’ directly to another Data Controller, but only where our processing is based on your consent and the processing is carried out by automated means.
- Right to withdraw consent: You can withdraw your consent in respect of any processing of Personal Data which is based upon a consent which you have previously provided.
- Right to obtain a copy of safeguards: you can ask to obtain a copy of, or reference to, the safeguards under which your Personal Data is transferred outside the EU/EEA. We may redact data transfer agreements to protect commercial terms.
- Right to lodge a complaint with your local supervisory authority: You have a right to lodge a complaint with your local supervisory authority if you have concerns about how we are processing your Personal Data. We ask that you please attempt to resolve any issue with us first, although you have a right to contact your supervisory authority at any time. If you are located in the EEA or UK and you believe we are unlawfully processing your Personal Data, you have the right to complain to your Member State Data Protection Authority or UK Data Protection Authority. If you are located in Switzerland, you may contact the Federal Data Protection and Information Commissioner.
Submitting GDPR Data Subject Request
For exercising your rights under GDPR and submitting a Data Subject Request, please contact us at privacy@monks.com.