Privacy Policy

PLEASE READ THIS POLICY CAREFULLY BEFORE USING FOUNDLEY

We are Foundley Limited, a limited company registered in England and Wales with registration number 12445835. Our registered address is 71-75 Shelton Street, London, WC2H 9JQ. This web page sets out when and how we use your personal information that you or others provide to us when using our Website (“Foundley”).

Please take time to read this Policy, which together with the Foundley Terms and Conditions, describes our policy and practices with regard to all processing of Personal Information (as defined below) we undertake in relation to your use of:

  • the Website;

  • any Work Experience; and

  • any of the services accessible through Foundley.

By accessing, browsing or otherwise using Foundley, you are agreeing to be bound by this Policy (and our Terms and Conditions. If you do not agree to any part of this Policy, you should not use Foundley. We have designated a Director who is responsible for overseeing questions in relation to this privacy notice. If you have any questions about this privacy notice, including any requests to exercise your legal rights, please contact us by email at hello@foundley.com.

Definitions

In this Policy:

"Employer" means a company, person or partner who uses Foundley to offer Work Experience;

"Offer" means means an offer for Work Experience made by an Employer in response to an application by a Student;

"Personal Information" means information that relates to a living individual who can be identified from that information that is held by us or is likely to be held by us;

"Website" means the websites www.foundley.com to be used to arrange Employer encounters including Work Experience;

"Work Experience" means work experience undertaken by the Student with the Employer in the UK, which has been organised through Foundley; and

"Student" means a Student who uses Foundley to find Work Experience;

Personal Information - the basics

We take your privacy seriously and are committed to protecting the privacy of any Personal Information you give us or we collect from you.

In order to provide services offered by Foundley, we need to collect and process certain Personal Information (as set out in this Policy) from you. Except to the extent that we are permitted or required by law, any Personal Information we collect will be used, processed and shared only for the purposes and in ways set out in this Policy.

Personal Information we collect and process about you

  • Personal Information you give to us ("Submitted Information"): when you use Foundley, you will give us Personal Information by filling out forms on Foundley or by corresponding with us (for example, by email). It includes Personal Information you provide when you register for Foundley, make an application for Work Experience, make an offer to provide Work Experience, provide feedback on Work Experience and when you report a problem with Foundley or any Work Experience.

The Personal Information you give us may include:

If you are a Student:

  • your name;

  • your age/ date of birth;

  • your gender;

  • the job roles you are seeking;

  • the dates you are available from and until;

  • your employment skills;

  • your personal attributes;

  • your phone and e-mail details;

If you are an Employer:

  • your name;

  • email address;

  • contact number (which may include a landline number and/or mobile number);

  • address (which may include work and/or home address).

You may also be asked to make a payment before you can accept an Offer (if you are a Student) or to enable a Student to accept an Offer (if you are an Employer), or in order to make a donation to Foundley. This payment can be made using the following third party sites and applications found on Foundley 12445835. These third party payment applications may require that you provide to them Personal Information in order to make a payment, in which case this Policy will not apply and the privacy policy for the relevant third party application will apply to the Personal Information you provide to it. However, we may collect certain data in relation to your payment through these third party sources, and we process the information provided to us from these third party sources in accordance with this Policy.

  • Personal Information we collect about you and your device: each time you use Foundley we will automatically collect the following information from you and/or your device:

    • technical information, including the Internet protocol (IP) address used to connect your device/computer to the Internet, the type of mobile device you use, your login information and operating system and platform,. We may ask you if you want to receive push notifications about activity on your account (for example, if you are a Student, to let you know that an Employer has responded to your Work Experience application and/or to let you know about other Employers who we consider may be appropriate for you). If you opt in to these notifications and no longer want to receive them, you may turn them off through your device;

  • Information about your visit, including the full Uniform Resource Locators (URL), clickstream to, through and from Foundley (including date and time and page response times

Please note that we don't track any location-based information from your mobile device. We may collect anonymised details about visitors to Foundley for the purposes of aggregate statistics or reporting purposes.

Cookies: Foundley uses cookies to distinguish you from other users of Foundley. This helps us to provide you with a good experience when you browse/use Foundley and also allows us to make improvements. For further details on the cookies we use and the purposes for which we use them, please refer to our Cookies Policy

Students’ Personal Information: As part of our services we may seek to collect Personal Information in order to help Students to use Foundley and find work experience with companies that they may be interested in working for. We value Students’ privacy and do, and will, not knowingly collect Personal Information from any Student under the age of 16 without having first obtained consent from that child's Permission Grantor (other than such information as is necessary in order to obtain such Permission Grantor's consent). If you are under the age of 16, you cannot use Foundley unless you have the consent of, and are supervised by, a Permission Grantor.

Until we have established the age of a user we only store anonymised data locally on the user’s device and do not transmit it to our servers or third party servers. We ask children to confirm their age and, if that child tells us that they are under 16, we will ask them to provide us with their Permission Grantor's contact details. We will only use those details for the purpose of obtaining permission from such Permission Grantor for the child's use of Foundley.

If you are a Permission Grantor with a child under the age of 16 who is using Foundley and you have not provided permission, please let us know as soon as possible, by contacting us by email at: hello@foundley.com.

How we may use, process and share your Personal Information

We may process your Personal Information for the following purposes:

Submitted Information:

  • to make Foundley available to you;

  • to help arrange any Work Experience. For example, if you are a Student we will send your applications to your chosen potential Employer(s) and those applications will contain Personal Information about you;

  • to send you system alert messages, such as version updates and changes to our Policy; and

  • to post your Employer feedback on Foundley, which will be visible to other user of Foundley as an aggregate.

Please refer to the Annex below for a summary of our processing activities.

We may disclose your Personal Information to third parties:

  • (with regard to Submitted Information) who are Employers (for the purposes set out above);

  • who are our service providers / suppliers and need to know the information in order to provide us or you with a service;

  • banks and payment providers to authorize and complete payments;

  • in the event that we sell or buy any business or assets, in which case we will disclose your Personal Information to the prospective seller or buyer of such business or assets;

  • if we, or substantially all of our assets, are acquired by a third party, in which case Personal Information held by it about its users and customers will be one of the transferred assets;

  • if we are under a duty to disclose or share your Personal Information in order to comply with any legal or regulatory obligation or request; and

  • in order to:

    • enforce or apply the Foundley Terms and Conditions or to investigate potential breaches; or

    • protect the rights, property or safety of Foundley, our users or customers, or any other person.

We will keep you informed about our work and services, as such we process certain of your Personal Information to provide you with further information about us and our services, for instance, we may send registered users service reminder messages via the App from time to time and/or Foundley newsletters which we send by email once a month. You can unsubscribe from receiving such newsletters at any time by clicking the "Unsubscribe" option at the bottom of our emails. Please note that if you unsubscribe you will no longer receive our newsletters via email until such time as you re-subscribe.

We do not sell or pass your Personal Information to third parties for their own marketing purposes.

Where we store your Personal Information

We may transfer your Personal Information to third parties (as set out above) located in countries that are outside of the European Economic Area (EEA), for example we may send your application to potential Employers whose headquarters are located outside the EEA. Your Personal Information may also be processed by staff operating outside the EEA who work for us or for one of our service providers / suppliers.

Different privacy laws may apply in these countries, and you understand and unambiguously agree (by submitting your Personal Information) to such transfer, storing or processing of your Personal Information to these countries and third parties..

Whenever we transfer your personal information outside of the EEA, we ensure it is protected by making sure at least one of the following safeguards is in place:

  • by transferring your personal information to a country that has been deemed to provide an adequate level of protection by the European Commission;

  • by using specific contracts approved by the European Commission which give your personal information the same protection it has within the EEA; and

  • where we use providers based in the US, we may transfer data to them if they are part of the Privacy Shield which requires them to provide similar protection to personal data shared between Europe and the US.

To keep this privacy policy as short and easy to understand as possible, we have not set out the specific circumstances when each of these protection measures are used. You can contact us at hello@foundley.com for the details as to how we protect specific transfers of your data.

Please note that countries which are outside the EEA may not offer the same level of data protection as the UK, although our collection, storage and use of your Personal Information will continue to be governed by this Policy.

How long we store your Personal Information

We will only retain your personal information for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting or legal requirements. If you are a Student, we will store your Personal Information until you reach the age of 26 in order to try and ensure that each Student obtains 100 hours of Work Experience per year.

For any other personal information, in order to decide our retention period, we consider the amount, nature and sensitivity of the personal information, the risk of harm from unauthorised use or disclosure of your personal information, the reasons why we handle your personal information and whether we can achieve those purposes through other means, and the applicable legal requirements.

Security of your Personal Information

Whilst we take appropriate technical and organisational measures to safeguard your Personal Information, no transmission over the Internet can ever be guaranteed to be secure. Therefore, we cannot guarantee the security of any Personal Information that you transfer over the Internet to us and any such transmission is at your own risk.

You should avoid sharing any information on Foundley (including when providing Work Experience feedback) that you would not be comfortable sharing in public.

Your rights and access to Personal Information

You have the right to ask us to:

  • provide you with copies of the Personal Information that we hold about you at any time by sending an email or writing to us at the relevant address set out below;

  • update and correct any out-of-date or incorrect Personal Information that we hold about you free of charge by sending an email or writing to us at the relevant address set out below;

  • by sending an email or writing to us at the relevant address set out below, erase your Personal Information in limited circumstances 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);

    • you have asked us not to process your Personal Information for marketing purposes or objected to the processing your Personal Information (see 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 Personal Information if the processing of your Personal Information is necessary:

  • for compliance with a legal obligation; or

  • for the establishment, exercise or defence of legal claims;

  • not process your Personal Information for marketing purposes. We will usually inform (before collecting your information) if we intend to use such information for marketing purposes or if we intend to disclose your information to any third party for such purposes. You can exercise your right to prevent such processing by checking certain boxes on the forms we use to collect your information. In addition, you can exercise this right at any time by emailing or writing to us at the addresses set out below;

  • object to any processing of your Personal Information which has our legitimate interests as its legal basis, if you believe your fundamental rights and freedoms outweigh our legitimate interests. If you raise an objection, we have an opportunity to demonstrate that we have compelling legitimate interests which override your rights and freedoms;

  • obtain a copy of, or reference to, the safeguards under which your Personal Information is transferred outside of the European Union. We may redact data transfer agreements to protect commercial terms; and

  • lodge a complaint with your local supervisory authority if you have concerns about how we are processing your personal information. We ask that you please attempt to resolve any issues with us first, although you have a right to contact your supervisory authority at any time.

If you wish to exercise any of the above rights, please send us an email to: hello@foundley.com..

 

Third party sites and applications

Foundley contains links to other websites operated by third parties. Please note that this Policy applies only to the Personal Information we collect through Foundley and we are not responsible for any Personal Information that third parties may collect, store and use through their app(s) or website(s). You should always read the privacy policy of each such third party app/website you visit carefully.

Changes to our Policy

This Policy was last updated on 6th February 2020. This Policy may change from time to time and, if it does, the up-to-date version will always be available on Foundley. Please note that by continuing to use Foundley you are agreeing to any updated versions of this Policy.

Queries and our contact details

If you have any questions, comments and/or requests relating to this Policy, please get in touch with us or, if you are under the age of 16, ask your parents to get in touch with us by email at: hello@foundley.com.

London

United Kingdom

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