Cookie Policy

What’s a cookie?

A “cookie” is a piece of information that is stored on your computer’s hard drive and which records your navigation of a website so that, when you revisit that website, it can present tailored options based on the information stored about your last visit. Cookies can also be used to analyse traffic and for advertising and marketing purposes.

Cookies are used by nearly all websites and do not harm your system. If you want to check or change what types of cookies you accept, this can usually be altered within your browser settings. We also provide information about this in our Marketing preferences page on the Ashton Rose Ltd. website.

How do we use cookies?

We use cookies to do two things:

• to track your use of our website. This enables us to understand how you use the site and track any patterns that emerge individually or from larger groups. This helps us to develop and improve our website and services in response to what our visitors want and need; and
• to help us advertise services to you that we think you’ll be interested in. Hopefully this means less time for you trawling through endless pages and will get you the services and advice you want more quickly.

• Cookies are either:

– Session cookies: these are only stored on your computer during your web session and are automatically deleted when you close your browser – they usually store an anonymous session ID allowing you to browse a website without having to log in to each page but they do not collect any information from your computer; (We collect PHPSESSID cookie for that regard and a cookie to serve your browser with Google Fonts.) or
– Persistent cookies: a persistent cookie is stored as a file on your computer and it remains there when you close your web browser. The cookie can be read by the website that created it when you visit that website again. We use persistent cookies for Google Analytics and for personalisation (see below).

• Cookies can also be categorised as follows:

– Strictly necessary cookies: These cookies are essential to enable you to use the website effectively and therefore cannot be turned off. Without these cookies, the services available to you on our website cannot be provided. These cookies do not gather information about you that could be used for marketing or remembering where you have been on the internet.
– Performance cookies: These cookies enable us to monitor and improve the performance of our website. For example, they allow us to count visits, identify traffic sources and see which parts of the site are most popular.
– Functionality cookies: These cookies allow our website to remember choices you make (such as your user name, language or the region you are in) and provide enhanced features. For instance, we may be able to provide you with news or updates relevant to the services you use. These cookies can also be used to remember changes you have made to text size, font and other parts of web pages that you can customise. They may also be used to provide services you have requested such as viewing a video or commenting on a blog. The information these cookies collect is usually anonymised.

OUR LEGAL BASES FOR PROCESSING YOUR DATA

LEGITIMATE INTERESTS

• Article 6(1)(f) of the GDPR is the one that is relevant here – it says that we can process your data where it “is necessary for the purposes of the legitimate interests pursued by [us] or by a third party, except where such interests are overridden by the interests or fundamental rights or freedoms of [you] which require protection of personal data.”

• We don’t think that any of the following activities prejudice individuals in any way – in fact, they help us to offer you a more tailored, efficient service, so everyone’s a winner! However, you do have the right to object to us processing your personal data on this basis.

CLIENT DATA:

• To ensure that we provide you with the best service possible, we store your personal data and/or the personal data of individual contacts at your organisation as well as keeping records of our conversations, meetings, services requested. From time to time, we may also ask you to undertake a customer satisfaction survey. We think this is reasonable – we deem these uses of your data to be necessary for our legitimate interests as an organisation providing various recruitment services to you.

SUPPLIER DATA:

• We use and store the personal data of individuals within your organisation in order to facilitate the receipt of services from you as one of our Suppliers. We also hold your financial details, so that we can pay you for your services. We deem all such activities to be necessary within the range of our legitimate interests as a recipient of your services.

PEOPLE WHOSE DATA WE RECEIVE FROM CLIENTS AND STAFF, SUCH AS DEPENDANTS:

• If a Client or Staff member has given us your details as a dependant or an emergency contact, we will use these details to contact you in the case of an accident or emergency. We are sure you will agree that this is a vital element of our people-orientated organisation, and so is necessary for our legitimate interests.

CONSENT

• • In certain circumstances, we are required to obtain your consent to the processing of your personal data in relation to certain activities. Depending on exactly what we are doing with your information, this consent will be opt-in consent or soft opt-in consent.
• • Article 4(11) of the GDPR states that (opt-in) consent is “any freely given, specific, informed and unambiguous indication of the data subject’s wishes by which he or she, by a statement or by a clear affirmative action, signifies agreement to the processing of personal data relating to him or her.” In plain language, this means that:
  • you have to give us your consent freely, without us putting you under any type of pressure;
  • you have to know what you are consenting to – so we’ll make sure we give you enough information;
  • you should have control over which processing activities you consent to and which you don’t; and
  • you need to take positive and affirmative action in giving us your consent – we’re likely to provide a tick box for you to check so that this requirement is met in a clear and unambiguous fashion.

We will keep records of the consents that you have given in this way.

• We have already mentioned that, in some cases, we will be able to rely on soft opt-in consent. We are allowed to market products or services to you which are related to other services which we already provide to you presently as long as you do not actively opt-out from these communications.

• As we have mentioned, you have the right to withdraw your consent to these activities. You can do so at any time, please contact us should you wish to do so.

ESTABLISHING, EXERCISING OR DEFENDING LEGAL CLAIMS

• Sometimes it may be necessary for us to process personal data and, where appropriate and in accordance with local laws and requirements, sensitive personal data in connection with exercising or defending legal claims. Article 9(2)(f) of the GDPR allows this where the processing “is necessary for the establishment, exercise or defence of legal claims or whenever courts are acting in their judicial capacity”.
• This may arise for example where we need to take legal advice in relation to legal proceedings or are required by law to preserve or disclose certain information as part of the legal process
.

GLOSSARY

• Clients – while it speaks for itself, this category covers our customers, clients, and others to whom Ashton Rose Ltd. companies provide services in the course of its business.
• Delete – while we will endeavour to permanently erase your personal data once it reaches the end of its retention period or where we receive a valid request from you to do so, some of your data may still exist within our systems, for example if it is waiting to be overwritten. For our purposes, this data has been put beyond use, meaning that, while it still exists on an archive system, this cannot be readily accessed by any of our operational systems, processes or Staff.
• General Data Protection Regulation (GDPR) – a European Union statutory instrument which aims to harmonise European data protection laws. It has an effective date of 25 May 2018, and any references to it should be construed accordingly to include any national legislation implementing it.
• Staff – includes employees and interns engaged directly in the business of Ashton Rose (or who have accepted an offer to be engaged) as well as certain other workers engaged in the business of providing services to Ashton Rose Ltd. companies (even though they are not classed as employees). Independent contractors and consultants performing services for Ashton Rose Ltd. fall within the definition of a “Supplier” for the purposes of this Privacy Policy.
• Suppliers – refers to partnerships and companies (including sole traders), and atypical workers such as independent contractors and freelance workers, who provide services to Ashton Rose Ltd.. In certain circumstances Ashton Rose Ltd. will sub-contract the services it provides to Client to third party suppliers who perform services on Ashton Rose’s behalf.
• Website Users – any individual who accesses any of the Ashton Rose Ltd. websites.

For questions and/or comments about our Cookie Policy and this statement, please contact us by using the following contact details:

ASHTON ROSE LTD
5 Stratford Place, London, United Kingdom, W1C 1AX
United Kingdom
Website: https://ashtonrose.com
Email: