Privacy Policy

Effective date: April 3, 2023

This Privacy Notice explains how The Tilton Consultancy Ltd. uses any personal data (also referred to as ‘information’) we collect about you. It describes:

what information we collect about you;
how we use your information;
who we share your information with;
your rights regarding our use of your information;
how long we keep your information; and
how to contact us.

What information do we collect?
We collect information about you:

when you register with us to make a career enquiry;
if you make an enquiry about our services;
when you voluntarily complete customer surveys, provide feedback and participate in competitions or research studies, or agree to be on our contact lists in relation to our client communications;
when we use cookies to collect information about your use of our website. For more information about how we use cookies please see our cookie policy below and
when we use a third-party service (e.g. Google Analytics) to collect information about how visitors to our website use the site, including collecting information about what country you logged on from, which pages you visited and how long you were on our site.

How will we use your information?
We use your information to:

process your request for news items about our company and, if you agree, to email you about other services we think may be of interest to you;
process your personal data for research purposes as outlined in the consent process through which you supplied this to us;
email you about similar goods and services to those you’ve purchased from us which you may be interested in; and
enter and perform a contract with you or to perform any steps you require from us before entering into the contract. If you do not provide information required by us to enter into a contract with you, we will not be able to enter into that agreement with you or provide you the services you require.

We will rely on one of the following legal grounds (as appropriate) to process your personal data:

to enter and perform a contract with you or to perform any steps you require from us before entering into a contract;
to pursue our legitimate business interests in providing and marketing our products and services;
your specific consent to us using your information, which you can withdraw at any time;
to comply with our legal obligations and establish, exercise or defend our legal rights; and
those other purposes that you have agreed with us.

Who do we share your information with?
We share information with the following third parties:

data processors, who are our suppliers who provide us services;
if you become an employee or freelancer your information will be passed on to and stored with our processing partners in relation to payroll, healthcare and invoice payments. The use of this personal data is restricted to the extent necessary for the performance of the contract between us;
persons connected with any sale, merger, acquisition, disposal, reorganisation or similar change of our business;
local and foreign regulators, governments, law enforcement authorities, advisors, courts, tribunals and arbitrators; and
other third parties, with your consent.

If we do transfer your information from the EEA to a jurisdiction outside the EEA, we will take appropriate steps to protect that information which includes: (i) entering into an agreement with the third party which includes clauses that the EU Commission has determined offers adequate protection for your information, a template copy of which is available at https://ec.europa.eu/info/law/law-topic/data-protection/data-transfers-outside-eu/model-contracts-transfer-personal-data-third-countries_en; or (ii) otherwise ensuring that information would only be transferred to third parties in jurisdictions that the EU Commission has determined offers adequate protection for your personal information.

Third Party Processors
Our carefully selected partners and service providers may process personal information about you on our behalf as described below:
Digital Marketing Service Providers
We periodically appoint digital marketing agents to conduct marketing activity on our behalf, such activity may result in the compliant processing of personal information. Our appointed data processors include:
(i)Prospect Global Ltd (trading as Sopro) Reg. UK Co. 09648733. You can contact Sopro and view their privacy policy here: http://sopro.io. Sopro are registered with the ICO Reg: ZA346877 their Data Protection Officer can be emailed at: dpo@sopro.io

What are your data protection rights?
You have rights under data protection law in relation to our use of your personal data, including to:

request access to your information by submitting a request;
update or amend your information if it is inaccurate or incomplete;
object to certain uses of your personal data including direct marketing and processing based on legitimate interests and processing for purposes of scientific or historical research and statistics on grounds relating to your particular situation;
request the deletion of your information, or restrict its use, in certain circumstances (for example, subject to lawful exceptions applying, you can request that we erase your information where the information is no longer necessary for the purpose for which it was collected;
to withdraw any consents you have provided in respect of our use of your information;
to request a copy of the information you have provided to us, to use for your own purposes (often called your right to data portability); and
to lodge a complaint with the relevant data protection supervisory authority in your jurisdiction.

If you would like to exercise any of these rights, please contact us at jon@tiltonconsultancy.com

How long do we keep your information
Personal data of employees and freelancers will be kept for no longer than is necessary, and that period of time will be determined with reference to applicable statutory limitation periods in your jurisdiction.

Our policy is to destroy employment applications 1 (one) year after their submission if they have not led to an offer of employment. If you are engaged with us ‘to perform a contract’, then local market data retention legislation may apply to elements of the information you supply us.

Any other information obtained as set out in section 2 above will be kept for no longer than is necessary and will be determined with reference to applicable statutory limitation periods in your jurisdiction, or otherwise as agreed between us.

We will keep our retention processes under review to ensure that your data is not stored for longer than is strictly necessary.

How to contact us?
If you have any questions about this Privacy Notice or the information we hold about you, you can contact us by email: jon@tiltonconsultancy.com

Changes to this Privacy Notice
We keep this Privacy Notice under regular review and we will place any updates on this webpage.

This Privacy Notice was last updated on 30 April 2024.

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