Privacy Statement - 3 Story Software

3SS PRIVACY POLICY

INTRODUCTION

This Privacy Policy explains what we do with your personal data. It describes how we collect, use and process your personal data, and how, in doing so, we comply with our legal obligations to you. Your privacy is important to us, and we are committed to protecting and safeguarding your data privacy rights.
The 3 Story Software SAAS platform ("3SS Platform") is a VMS and workforce solution that we provide to our Clients to enable them to manage their Workers and support projects.
This Privacy Policy applies to the personal data of our Clients, their Workers, our Suppliers, and Website Users.
For the purpose of applicable data protection legislation (including but not limited to the General Data Protection Regulation (Regulation (EU) 2016/679) (the "GDPR"), the company responsible for your personal data is 3 Story Software, LLC. of 63 Bridge St., New Milford, CT 06776, USA ("3 Story Software" or "us"). While this Privacy Policy describes how we will process your personal data across the organisation, the GDPR, a European piece of legislation, requires us to set out certain information which will only apply to individuals based within the European Union. This information is set out in Annex A of the Privacy Policy. We have also set out certain information about our compliance with certain US legislation which will only apply to individuals based in the US. This information is set out in Annex B of the Privacy Policy.
If you are a Worker, our primary purpose for using your personal data is to provide the 3SS Platform to your Client organisation. When we use your personal data to allow you to access and use the 3SS Platform, we do so on the instructions of your Client organisation and on behalf of your Client organisation. This makes us a "data processor" for the purposes of the GDPR.
If you are a Client, Supplier, or Website User, we use your information for our own purposes. This makes us a "data controller" for the purposes of the GDPR. Please see here for more information.
We may use personal information pertaining to a Client, Supplier and/or Worker that has been anonymized such that it cannot be associated with a particular person or entity, for our benefit and for that of our Clients.
It is important to point out that we may amend this Privacy Policy from time to time. Please just visit this page if you want to stay up to date, as we will post any changes here.
If you are dissatisfied with any aspect of our Privacy Policy, you may have legal rights and, where relevant, we have described these as well.

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WHAT KIND OF PERSONAL DATA DO WE COLLECT?

So you're looking for a bit more insight into what data we collect about you? Here's a more detailed look at the information we may collect. The information described below is, of course, in addition to any personal data we are required by law to process in any given situation.

WORKER DATA: Depending on the relevant circumstances and applicable local laws and requirements, we may collect some or all of the information listed below to enable us to provide the 3SS Platform to your Client organisation:

Name;
Age/date of birth;
Birth number;
Sex/gender;
Photograph;
Marital status;
Contact details;
Education details;
Employment history;
A copy of your CV or résumé;
Emergency contacts and details of any dependants;
Referee details;
Immigration status (whether you need a work permit);
Nationality/citizenship/place of birth;
A copy of your driving licence and/or passport/identity card;
Financial information (where we need to carry out financial background checks);
Social security number (or equivalent in your country) and any other tax-related information;
Diversity information including racial or ethnic origin, religious or other similar beliefs, and physical or mental health, including disability-related information;
Details of any criminal convictions if this is required for a role that you are interested in applying for;
Details about your current remuneration, pensions and benefits arrangements;
Details about any qualifications;
Information on your interests and needs regarding future employment, both collected directly and inferred, for example from jobs viewed or articles read on our website;
Extra information that you choose to tell us;
Extra information that your referees chooses to tell us about you;
Extra information that our Clients may tell us about you, or that we find from other third party sources such as job sites;
IP address; and
The dates, times and frequency with which you access our services.

Please note that the above list of categories of personal data we may collect is not exhaustive.

To the extent that you access our website we will also collect certain data from you. If you would like more information about this, please click here.

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CLIENT DATA: The data we collect about Clients is actually very limited. We generally only need to have your contact details or the details of individual contacts at your organisation (such as their names, telephone numbers and email addresses) to enable us to ensure that our relationship runs smoothly. We also hold information relating to your online engagement with Worker profiles and other material published by 3 Story Software, which we use to ensure that our marketing communications to you are relevant and timely. We may also hold extra information that someone in your organisation has chosen to tell us. In certain circumstances, such as when you engage with our Finance and Debt Recovery teams, our calls with you may be recorded, depending on the applicable local laws and requirements. If we need any additional personal data for any reason, we will let you know.
To the extent that you access our website we will also collect certain data from you. If you would like more information about this, please click here.

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SUPPLIER DATA: We don't collect much data about Suppliers – we simply need to make sure that our relationship runs smoothly. We'll collect the details for our contacts within your organisation, such as names, telephone numbers and email addresses. We'll also collect bank details, so that we can pay you. We may also hold extra information that someone in your organisation has chosen to tell us. In certain circumstances, such as when you engage with our Finance and Debt Recovery teams, our calls with you may be recorded, depending on the applicable local laws and requirements.
To the extent that you access our website we will also collect certain data from you. If you would like more information about this, please click here.

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WEBSITE USERS We collect a limited amount of data from our Website Users which we use to help us to improve your experience when using our website and to help us manage the services we provide. This includes information such as how you use our website, the frequency with which you access our website, your browser type, the location you view our website from, the language you choose to view it in and the times that our website is most popular. If you contact us via the website, for example by using the chat function, we will collect any information that you provide to us, for example your name and contact details.
If you would like to find out more information about what data we collect about you when you visit our website, please click here.

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HOW DO WE COLLECT YOUR PERSONAL DATA?

WORKER DATA: We collect Worker personal data in the following ways:

Personal data that you, the Worker, give to us;
Personal data that we receive from other sources; and
Personal data that we collect automatically.

Personal data you give to us

3 Story Software needs to know certain information about you in order to provide a tailored service to your Client organisation. This will also enable us to provide you with the best opportunities.
You can share your information with us by entering in, or editing your pre-existing, personal data on the 3SS Platform.

Personal data we receive from other sources

We also receive personal data about Workers from other sources. Depending on the relevant circumstances and applicable local laws and requirements, your Client organisation may share personal information about you with us.

Personal data we collect automatically

To the extent that you access the 3SS Platform, our website or read or click on an email from us, where appropriate and in accordance with any local laws and requirements, we may also collect your data automatically or through you providing it to us. For more information please click here.

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CLIENT DATA: We collect Client personal data in the following ways:

Personal data that we receive directly from you;
Personal data that we receive from other sources; and
Personal data that we collect automatically.

Personal data that we receive directly from you

We will receive data directly from you in three ways:

Where you contact us proactively, usually by phone or email;
Where you share your information with us by entering in your personal data on the 3SS Platform or instruct us to do so on your behalf; and/or
Where we contact you, either by phone or email, or through our consultants' business development activities more generally.

Personal data we receive from other sources

Where appropriate and in accordance with any local laws and requirements, we may seek more information about you or your colleagues from other sources generally by way of due diligence or other market intelligence including:

From third party market research and by analysing online and offline media (which we may do ourselves, or employ other organisations to do for us);
From delegate lists at relevant events; and
From other limited sources and third parties (for example from our Workers to the extent that they provide us with your details via the 3SS Platform).

Personal data we collect via our website

To the extent that you access our website or read or click on an email from us, where appropriate and in accordance with any local laws and requirements, we may also collect your data automatically or through you providing it to us. For more information please click here.

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SUPPLIERS: If you are a Supplier, we collect your personal data during the course of our work with you, either where you contact us proactively, usually by phone or email, or where we contact you, either by phone or email.
To the extent that you access our website or read or click on an email from us, where appropriate and in accordance with any local laws and requirements, we may also collect your data automatically or through you providing it to us. For more information please click here.

WEBSITE USERS: When you visit our website there is certain information that we may automatically collect, whether or not you decide to use our services. This includes your IP address, browser data, the date and the times and frequency with which you access the website and the way you browse its content. We will also collect data from you where you use the social media features on our website (e.g. one of the features on our website is a 'share this' button that is linked to Facebook).
We collect your data automatically via cookies, in line with cookie settings in your browser. If you are also a Worker or Client of 3 Story Software, we may use data from your use of our websites to enhance other aspects of our communications with or service to you. If you would like to find out more about cookies, including how we use them and what choices are available to you, please click here.

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HOW DO WE USE YOUR PERSONAL DATA?

Having obtained data about you, we then use it in a number of ways.

WORKER DATA: We generally use Worker data in three ways:

To run the 3SS Platform;
For our benefit and for that of our Clients; and
To help us to establish, exercise or defend legal claims.

Here are some more details about each:

Running the 3SS Platform

The personal data we collect is used to process information in order to provide the 3SS Platform to your Client organisation. When we use your personal data to allow you to access and use the 3SS Platform, we do so on the instructions of your Client organisation and on the behalf of your Client organisation. This makes us a "data processor" for the purposes of the GDPR. We've listed below various ways in which we may use and process your personal data for this purpose, where appropriate and in accordance with any local laws and requirements. Please note that this list is not exhaustive.

Processing transactions related to recruitment and employment of Workers;
Scheduling interviews;
To perform evaluations and assessments;
Recording and calculating financial information relating to invoicing, and payment of Workers;
Sending notifications via emails such as: notifications of events, reminders, password reset emails, etc.;
Providing customer service or support regarding a question or issue reported by you or someone else.

If you are based within the European Union, please click here for information about the legal bases we rely upon to process your personal data.
If you are based within the European Union, in certain circumstances you have the right to object and can find out more about how and when to do this here.

For our benefit and for that of our Clients

We may anonymize data you provide to us so that this data no longer contains any personal data. We will use this strictly anonymous data for our own purposes and for that of our Clients.

To help us to establish, exercise or defend legal claims

In more unusual circumstances, we may use your personal data to help us to establish, exercise or defend legal claims.
If you are based within the European Union, please click here for information about the legal bases we rely upon to process your personal data.
If you are based within the European Union, in certain circumstances you have the right to object and can find out more about how and when to do this here.

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CLIENT DATA: We use Client information for:

Providing the 3SS Platform;
Our benefit and for that of our Clients;
Marketing Activities; and
To help us to establish, exercise or defend legal claims.

Here are some more details about each:

Providing the 3SS Platform

The personal data we collect is used to process information in order to provide the 3SS Platform to you and your organisation. This makes us a "data controller" for the purposes of the GDPR. We've listed below the various ways in which we use your data in order to facilitate this.

Storing your details (and updating them when necessary) on our database, so that we can contact you in relation to the services provided by the 3SS Platform;
Keeping records of our conversations and meetings, so that we can provide targeted services to you; and
Undertaking customer satisfaction surveys.

If you are based within the European Union, please click here for information about the legal bases we rely upon to process your personal data.
If you are based within the European Union, in certain circumstances you have the right to object and can find out more about how and when to do this here.

For our benefit and for that of our Clients

We may anonymize data you provide to us so that this data no longer contains any personal data. We will use this strictly anonymous data for our own purposes and for that of our Clients.

To help us to establish, exercise or defend legal claims

In more unusual circumstances, we may use your personal data to help us to establish, exercise or defend legal claims.
If you are based within the European Union, please click here for information about the legal bases we rely upon to process your personal data.
If you are based within the European Union, in certain circumstances you have the right to object and can find out more about how and when to do this here.

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SUPPLIER DATA: We realise that you're probably busy, and don't want us to be contacting you about all sorts of things. To find the right balance, we will only use your information:

To store (and update when necessary) your details on our database, so that we can contact you in relation to our agreements;

To offer services to you or to obtain support and services from you;

To perform certain legal obligations;

[To help us to target appropriate marketing campaigns;] and

In more unusual circumstances, to help us to establish, exercise or defend legal claims.

This makes us a "data controller" for the purposes of the GDPR.
If you are based within the European Union, please click here for information about the legal bases we rely upon to process your personal data.
If you are based within the European Union, in certain circumstances you have the right to object and can find out more about how and when to do this here.

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WEBSITE USERS: We use your data to help us to improve our customer service, and your experience of using our website. We also use your data to respond to your enquiries, and to notify you of news, events and product changes. This makes us a "data controller" for the purposes of the GDPR.
If you would like to find out more about cookies, including how we use them and what choices are available to you, please click here.
If you are based within the European Union, please click here for information about the legal bases we rely upon to process your personal data.
If you are based within the European Union, in certain circumstances you have the right to object and can find out more about how and when to do this here.

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WHO DO WE SHARE YOUR PERSONAL DATA WITH?

Where appropriate and in accordance with local laws and requirements, we may share your personal data, in various ways and for various reasons, with the following categories of people:

Any of our group companies;
Tax, audit, or other authorities, when we believe in good faith that the law or other regulation requires us to share this data (for example, because of a request by a tax authority or in connection with any anticipated litigation);
Third party service providers who perform functions on our behalf (including Suppliers such as external consultants, business associates and professional advisers such as lawyers, auditors and accountants, technical support functions and IT consultants carrying out testing and development work on our business technology systems);
Third party outsourced IT and document storage providers where we have an appropriate processing agreement (or similar protections) in place;
In the case of Workers: with your Client organisation;
If 3 Story Software merges with or is acquired by another business or company in the future, (or is in meaningful discussions about such a possibility) we may share your personal data with the (prospective) new owners of the business or company.

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HOW DO WE SAFEGUARD YOUR PERSONAL DATA?

The security of your personal data is important to us. We follow generally accepted industry standards and best practices to protect the personal data submitted to us, both during transmission and once we receive it.
These standards include but are not limited to physical security at our datacenters, data encryption, firewalls, and active monitoring. Any personal data being transmitted over the internet via the 3SS application is encrypted using industry standard SSL encryption.
Third parties are not provided access to the 3SS servers or facilities without being monitored at all times.

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HOW LONG DO WE KEEP YOUR PERSONAL DATA FOR?

We will retain your information for as long as is necessary for the purposes for which we have collected it. We will also retain your information as necessary to comply with legal obligations, resolve disputes, and enforce our agreements.
If you are a Worker, and you wish to cancel your account or request that your personal data be removed, you should contact the Client or Supplier with whom you have the relationship, or send us an email to privacy@3storysoftware.com and we will direct you to the proper resource. If the Client requests that we remove the personal data, we will respond to their request within 30 business days.

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WHO IS RESPONSIBLE FOR PROCESSING YOUR PERSONAL DATA ON THE 3 STORY SOFTWARE WEBSITE?

We, 3 Story Software, are responsible for processing personal data that is collected via the 3 Story Software website.
Please note that we cannot offer technical support to Workers. Technical support issues should be directed to your Client organisation.
If you have privacy concerns please contact us at 3 Story Software, 63 Bridge Street, New Milford, CT, 06776 (or privacy@3storysoftware.com)

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CAN I UPDATE, ACCESS, OR DELETE MY PERSONAL DATA?

If your personal data changes, or if you no longer desire our service, you may request that your information be updated, or deleted by contacting us at privacy@3storysoftware.com. We will respond to your request within 30 days.
If you are a Worker and you wish to make a request in relation to our use of your personal data in connection with our provision of the 3SS Platform to your Client organisation (and in respect of which we are a data processor), please contact your Client organisation in the first instance to handle your request. If you contact us, we will refer your request to your Client organisation.
If you are based within the European Union, please click here for more information about your rights in regards to data privacy under the GDPR.

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HOW DO WE STORE AND TRANSFER YOUR DATA INTERNATIONALLY?

So you want to know more about how we store and transfer your data internationally? In order to provide you with the best service and to carry out the purposes described in this Privacy Policy, your data may be transferred:

between and within entities within our group;

to third parties (such as regulatory authorities, advisers or other Suppliers to the 3 Story Software business);
to overseas Clients;
to Clients within your country who may, in turn, transfer your data internationally;
to a cloud-based storage provider; and
to other third parties, as referred to here.

If you are based within the European Union, please click here for information on how we transfer your data internationally.
To ensure that your personal data receives an adequate level of protection, we have put in place appropriate procedures with the third parties we share your personal data with to ensure that your personal data is treated by those third parties in a way that is consistent with and which respects the law on data protection.

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COOKIES 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 3 Story Software website.

How do we use cookies?

We use cookies to do several things:

ensure the proper operation of the 3SS Platform;
to analyse trends;
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 gather demographic information about your user base as a whole.

Clear Gifs and Log Files

We also employ (or our third party tracking utility partner employs) a software technology called clear gifs (a.k.a. Web Beacons/Web Bugs), that help us better manage content on our site by informing us what content is effective. Clear gifs are tiny graphics with a unique identifier, similar in function to cookies, and are used to track the online movements of Website Users. In contrast to cookies, which are stored on a user's computer hard drive, clear gifs are embedded invisibly on webpages and are about the size of the period at the end of this sentence. We do not tie the information gathered by clear gifs to our customers' personal data.
As true of most sites, we also gather certain information automatically and store it in log files. This information includes: internet protocol (IP) addresses, browser type, internet service provider (ISP), referring/exit pages, operating system, date/time stamp, and clickstream data.

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annex a

eu – residents – additional information

The GDPR requires us to set out certain information which only applies to individuals based within the European Union. We have listed this additional information below. This section of the Privacy Policy will only apply to you if you are based in the European Union.

HOW CAN YOU ACCESS, AMEND OR TAKE BACK THE PERSONAL DATA THAT YOU HAVE GIVEN TO US?

One of the GDPR's main objectives is to protect and clarify the rights of EU citizens and individuals in the EU with regards to data privacy. This means that you retain various rights in respect of your data, even once you have given it to us. These are described in more detail below.
To get in touch about these rights, please contact us. We will seek to deal with your request without undue delay, and in any event within one month (subject to any extensions to which we are lawfully entitled). Please note that we may keep a record of your communications to help us resolve any issues which you raise.
If you are a Worker and you wish to make a request in relation to our use of your personal data in connection with our provision of the 3SS Platform to your Client organisation (and in respect of which we are a data processor), please contact your Client organisation in the first instance to handle your request. If you contact us, we will refer your request to your Client organisation.

You can also modify/update basic personal information directly in the 3SS Platform by going to your profile. To modify advanced information not available for editing in the interface, you will need to contact a manager at the Client or Supplier with whom you have the relationship. If you are uncertain who to contact, you may send an email to privacy@3storysoftware.com and we will help you contact the proper resource. We cannot directly modify your information for you.

Right to object: this right enables you to object to us processing your personal data where we do so for one of the following four reasons: (i) our legitimate interests; (ii) to enable us to perform a task in the public interest or exercise official authority; (iii) to send you direct marketing materials; and (iv) for scientific, historical, research, or statistical purposes.
The "legitimate interests" and "direct marketing" categories above are the ones most likely to apply to our Website Users, Workers, Clients and Suppliers. If your objection relates to us processing your personal data because we deem it necessary for your legitimate interests, we must act on your objection by ceasing the activity in question unless:

we can show that we have compelling legitimate grounds for processing which overrides your interests; or
we are processing your data for the establishment, exercise or defence of a legal claim.

If your objection relates to direct marketing, we must act on your objection by ceasing this activity.

Right to withdraw consent: Where we have obtained your consent to process your personal data for certain activities (for example, for our marketing arrangements or automatic profiling), you may withdraw this consent at any time and we will cease to carry out the particular activity that you previously consented to unless we consider that there is an alternative reason to justify our continued processing of your data for this purpose in which case we will inform you of this condition.
Data Subject Access Requests (DSAR): You may ask us to confirm what information we hold about you at any time, and request us to modify, update or Delete such information. We may ask you to verify your identity and for more information about your request. If we provide you with access to the information we hold about you, we will not charge you for this unless your request is "manifestly unfounded or excessive". If you request further copies of this information from us, we may charge you a reasonable administrative cost where legally permissible. Where we are legally permitted to do so, we may refuse your request. If we refuse your request we will always tell you the reasons for doing so.
Right to erasure: You have the right to request that we erase your personal data in certain circumstances. Normally, the information must meet one of the following criteria:

the data are no longer necessary for the purpose for which we originally collected and/or processed them;
where previously given, you have withdrawn your consent to us processing your data, and there is no other valid reason for us to continue processing;
the data has been processed unlawfully (i.e. in a manner which does not comply with the GDPR);
it is necessary for the data to be erased in order for us to comply with our legal obligations as a data controller; or
if we process the data because we believe it necessary to do so for our legitimate interests, you object to the processing and we are unable to demonstrate overriding legitimate grounds for our continued processing.

We would only be entitled to refuse to comply with your request for one of the following reasons:

to exercise the right of freedom of expression and information;
to comply with legal obligations or for the performance of a public interest task or exercise of official authority;
for public health reasons in the public interest;
for archival, research or statistical purposes; or
to exercise or defend a legal claim.

When complying with a valid request for the erasure of data we will take all reasonably practicable steps to Delete the relevant data.
Right to restrict processing: You have the right to request that we restrict our processing of your personal data in certain circumstances. This means that we can only continue to store your data and will not be able to carry out any further processing activities with it until either: (i) one of the circumstances listed below is resolved; (ii) you consent; or (iii) further processing is necessary for either the establishment, exercise or defence of legal claims, the protection of the rights of another individual, or reasons of important EU or Member State public interest.
The circumstances in which you are entitled to request that we restrict the processing of your personal data are:

where you dispute the accuracy of the personal data that we are processing about you. In this case, our processing of your personal data will be restricted for the period during which the accuracy of the data is verified;
where you object to our processing of your personal data for our legitimate interests. Here, you can request that the data be restricted while we verify our grounds for processing your personal data;
where our processing of your data is unlawful, but you would prefer us to restrict our processing of it rather than erasing it; and
where we have no further need to process your personal data but you require the data to establish, exercise, or defend legal claims.

If we have shared your personal data with third parties, we will notify them about the restricted processing unless this is impossible or involves disproportionate effort. We will, of course, notify you before lifting any restriction on processing your personal data.
Right to rectification: You also have the right to request that we rectify any inaccurate or incomplete personal data that we hold about you. If we have shared this personal data with third parties, we will notify them about the rectification unless this is impossible or involves disproportionate effort. Where appropriate, we will also tell you which third parties we have disclosed the inaccurate or incomplete personal data to. Where we think that it is reasonable for us not to comply with your request, we will explain our reasons for this decision.

Right of data portability: If you wish, you have the right to transfer your personal data between data controllers. In effect, this means that you are able to transfer your 3 Story Software account details to another online platform. To allow you to do so, we will provide you with your data in a commonly used machine-readable format that is password-protected so that you can transfer the data to another online platform. Alternatively, we may directly transfer the data for you. This right of data portability applies to: (i) personal data that we process automatically (i.e. without any human intervention); (ii) personal data provided by you; and (iii) personal data that we process based on your consent or in order to fulfil a contract.

Right to lodge a complaint with a supervisory authority: You also have the right to lodge a complaint with your local supervisory authority. The supervisory authority in the United Kingdom is the Information Commissioner's Office at: Information Commissioner's Office, Wycliffe House, Water Lane, Wilmslow, Cheshire, SK9 5AF (T: 0303 123 1113 M: casework@ico.org.uk).
If you would like to exercise any of these rights, or withdraw your consent to the processing of your personal data (where consent is our legal basis for processing your personal data), details of how to contact us can be found here. Please note that we may keep a record of your communications to help us resolve any issues which you raise.

It is important that the personal information we hold about you is accurate and current. Please keep us informed if your personal information changes during the period for which we hold your data.

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OUR LEGAL BASES FOR PROCESSING YOUR DATA

We have set out below the legal bases that we rely on to process the personal data of individuals within the European Union.

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. If you would like to know more about how to do so, please click here.

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WORKER DATA:
We think it's reasonable to expect that we collect and otherwise use your personal data to offer or provide the 3SS Platform to your Client organisation.

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CLIENT DATA:

To ensure that we provide you with the 3SS Platform and any related services, 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, registered jobs and placements.
We will also need to process your personal data to allow us to perform our obligations under the contract that we have entered into with you in relation to the 3SS Platform.
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.

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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.

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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. We provide these finer controls within our privacy preference centre; 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.

As we have mentioned, you have the right to withdraw your consent to these activities. You can do so at any time, and details of how to do so can be found here.

ESTABLISHING, EXERCISING OR DEFENDING LEGAL CLAIMS

We have our own obligations under the law. If we believe in good faith that it is necessary, we may therefore share your data in connection with crime detection, tax collection or actual or anticipated litigation.
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.

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HOW DO WE STORE AND TRANSFER YOUR DATA INTERNATIONALLY?

We want to make sure that your data are stored and transferred in a way which is secure. If you are based within the European Union, we will therefore only transfer data outside of the European Economic Area or EEA (i.e. the Member States of the European Union, together with Norway, Iceland and Liechtenstein) where it is compliant with data protection legislation and the means of transfer provides adequate safeguards in relation to your data, for example:

by way of data transfer agreement, incorporating the current standard contractual clauses adopted by the European Commission for the transfer of personal data by data controllers in the EEA to data controllers and processors in jurisdictions without adequate data protection laws; or
transferring your data to a country where there has been a finding of adequacy by the European Commission in respect of that country's levels of data protection via its legislation; or
where it is necessary for the conclusion or performance of a contract between ourselves and a third party and the transfer is in your interests for the purposes of that contract (for example, if we need to transfer data outside the EEA in order to meet our obligations under that contract if you are a customer of ours); or
where you have consented to the data transfer.

annex b

us legislation – additional information

In order to further safeguard your personal data, we also comply with the following items of US legislation. This section of the Privacy Policy will only apply to you if you are based in the US.

COMPLIANCE WITH CHILDREN'S ONLINE PRIVACY PROTECTION ACT

We are in compliance with the requirements of COPPA (Children's Online Privacy Protection Act). We do not knowingly collect any information from anyone under 13 years of age. Our website, products and services are all directed to people who are at least 13 years old or older.

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COMPLIANCE WITH CALIFORNIA ONLINE PRIVACY PROTECTION ACT

Because we value your privacy we have taken the necessary precautions to be in compliance with the California Online Privacy Protection Act. We therefore will not distribute your personal data to third parties [which we have not expressly identified in this Privacy Policy] without your consent.

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GLOSSARY

Workers – are the individuals that our Clients wish to manage using the 3SS Platform and will include their employees, managers, contractors, candidates and contingent workers.

Clients – will include our clients to whom Hays provides the 3SS Platform. Typically, our Clients will be managed service providers, employers or staffing agencies.

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.

Suppliers – refers to partnerships and companies (including sole traders), and atypical workers such as independent contractors and freelance workers, who provide services to 3 Story Software.

Website Users - any individual who accesses any of the 3 Story Software websites.

Annex C Cookies List