Introduction

This Privacy Policy explains what personal information Spacewalk Group Ltd and its group entities (collectively referred to as “Spacewalk”, “we”, “us”, or “our”) collects and the ways in which we use that personal information.

This policy applies to your use of our website (https://www.gospacewalk.com), to personal information we handle about our website visitors, registered users of our services and their employers and/or employees and to personal information that we process through offline interactions with you in the course of running our business and delivering our services.  This includes our interactions with our existing or potential customers, their personnel and our suppliers.

By accessing our website or using our services, you agree to be bound by the terms of this Privacy Policy.

Types of personal information obtained, purposes and legal basis

We collect and use personal information for several different purposes. The personal information we collect may include names, address, telephone number, e-mail address, and employment related information including job title, salary information, and work contact details. The kind of personal information we collect about you will depend on the type of dealings you have with us.  We may also collect information about your interests and preferences, other demographic information such as your gender and location

Generally, we collect personal information when you voluntarily provide it to us.  We may also request information from you for the purpose of our services. You can choose not to provide your personal information to us, but generally the information we request from you is required in order for us to provide you the services we offer.

The legal basis for processing your personal information typically include:

• your consent
• to perform a contract with you or a relevant party
• legitimate interests in operating our business which includes dealing with your enquiries, requests and instructions, providing services to clients, inviting you to events and conducting research and analysis for our internal purposes, or
• to comply with our legal obligations.

The following section sets out the types of personal information we collect and the purposes we will use it for:

• If you contact us, submit an online form on our website or register for our services, we will hold personal information you provide to us (over the phone, by email, via our website or other methods). This is likely to be your name, contact details, and any other information you choose to provide. We will use this information for the purpose of communicating with you about our services, responding to your queries and business development.
• If you update an online profile that includes personal information such as your name and contact details.
• If you receive our email newsletters or marketing materials, we will hold your email address for the purpose of sending you updates and news that we think you will find interesting and occasionally inviting you to events. You can unsubscribe from these at any time by using the “unsubscribe” links at the bottom of each email.
• If you work for one of our customers or a partner organisation or if you are an industry contact, we may hold your name, company, job title and contact details and in certain situations. We will have been provided with this information either by you or your employer or in some cases we may have sourced it from publicly available sources, such as LinkedIn and internet searches. We need this information in order to interact with you (or your employer) for the purposes of providing our service, to verify your identity and experience as a potential candidate for our service.
• If you are a supplier or work for a supplier, we may hold your name and contact details in order to interact with you or your employer to procure and pay for goods and services.

We may also use your personal information to send you communications and contact you about our services, programs, events, campaigns, functions or news updates that may be relevant or of interest to you. From time to time we may also send you communications and information about third party products and offers. We will generally give you the option to opt-out of receiving promotional and marketing communications at the time you subscribe to our products and/or services. If you do not wish to be contacted for these purposes you can let us know at any time by contacting us at the details below or selecting the unsubscribe facility to opt out of such communications.

When you visit or log in to our website, cookies  and similar technologies may be used by our online data partners or vendors to associate these activities with other personal information they or others have about you, including by association with your email or home address.  We (or service providers on our behalf) may then send communications and marketing to these email or home addresses.  You may opt out of receiving this advertising by visiting https://app.retention.com/optout.

Providing us with personal information about someone else

There may be circumstances when we collect personal information from someone other than the individual concerned, for example, in relation to employees or employers of registered users of Spacewalk’s services.  If you provide us with personal information about someone else you must make sure that you are entitled to disclose that personal information to us for the purpose of you using our services.

Cookies

Please refer to our Cookie Policy (https://www.gospacewalk.com/cookie-policy) to understand how we store information relating to cookies.

Circumstances in which we may disclose personal information

We may share your personal information with the following third parties in certain circumstances:

• To our customers and your employers for the purpose of providing our service (for example, if you are shortlisted for a Spacewalk we may provide your contact details to the host of the relevant Spacewalk so that they can conduct interviews and/or finalise selection).
• IT service providers acting as data processors (see below) who provide services or cloud-based software to enable us to operate our business. Our ‘data processors’ only process information on our behalf. They won’t use your personal information for their own purposes and we only permit them to use it in accordance with our instructions, our contract with them and the law.
• Our professional advisors, such as lawyers, in order to provide us with professional services and certain entities from whom we procure services to help us run our business.
• To the extent that we are required to do so by law, including in connection with any legal proceedings or anticipated legal proceedings, or in order to comply with any legal obligation, or to establish, exercise or defend our legal rights.
• We also reserve the right to disclose your information to a third party as part of a merger or transfer, acquisition or sale, or in the event of a bankruptcy. If any of these events happen, we will require the relevant third parties to provide comparable levels of protection that we provide to you with respect to the information we share.
• Please be aware that your personal information may be accessed by third parties from countries whose laws provide various levels of protection for personal data which are not always equivalent to the level of protection that may be provided in your own country. Where we transfer your information internationally we will take reasonable steps to ensure that your information is treated securely and the means of transfer provides adequate safeguards.

Your personal information rights

The personal information we hold about you is your information, and you have certain rights over the information under applicable data protection laws. You have the right to request a copy of all personal information we hold about to you. You also have the right to require us to correct any mistakes in the personal information we hold about you, so please let us know if we need to update any of your personal information we hold. Under some applicable data protection laws you may also have the following rights:

• Where we are processing your information based on your consent you may be able to withdraw that consent, however we may still be able to process your personal information to the extent permitted by applicable data protection laws.
• Where we process your information based on a legitimate interest you may have the right to object to our processing of that information if you feel it impacts on your fundamental rights and freedoms.
• You may have the right to object where we are processing your personal information for direct marketing purposes. The easiest way to do this is to use the unsubscribe links at the bottom of all marketing emails.
• In certain situations, you may have the right to require us to erase personal information where there is no good reason for us continuing to process it, or to request restriction of processing of your personal information.
• Finally, you may have the right to request the transfer of your personal information to you or a third party in a structured, commonly used, machine- readable format in certain circumstances.

Please contact us if you would like to exercise any of these rights.

Keeping your personal information secure

We have appropriate security measures in place to prevent personal information from being accidentally lost, misused or accessed in an unauthorised way. In addition, we limit access to your personal information to those employees, contractors and other third parties who have a business need to know. They will only process your personal information on our instructions and they are subject to a duty of confidentiality.

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.

Please help keep your personal information secure by maintaining the confidentiality of any passwords and account details used on our website.  It is your sole responsibility to maintain such confidentiality and we will not be liable for any damage, loss or expense suffered due to such disclosure.

Storage of personal information

We may transfer the personal information we collect to, and store such information in, other countries which may have different data protection laws than the country you are in.

Users shall have their personal information hosted on Amazon Web Services (AWS) (Ireland region). AWS operates a “cloud-based system”, which means they could hold information in information data centres outside your country of residence. By providing their personal information, Users consent to any transfer and processing in accordance with this Privacy Policy.

In each case where your personal information is transferred overseas, we take measures to safeguard your privacy rights, such as:

• Certain processors may only transfer your personal information to countries that have been deemed to provide an adequate level of protection for personal information by the relevant regulator.
• Providers storing information in the US, may be self-certified to the EU-US Privacy Shield which requires them to provide similar protection to personal information shared between the Europe and the US.
• With certain service providers, we use specific contractual clauses approved by the relevant regulator which give personal information the same protection it has in the country in which it was collected.

Rights to lodge a complaint with the Regulator

At all times, you have the right to report a concern or lodge a complaint with any relevant regulator.

Changes to this Privacy Policy

We may change this Privacy Policy from time to time by amending this page.

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Last updated 19 April 2024