Nolea Privacy Policy

Important Information and Who We Are

Purpose of This Privacy Policy

Welcome to Nolea's privacy policy. We respect your privacy and are committed to protecting your data. This privacy policy explains how we process your personal data when you visit our website or use our services and informs you about your privacy rights and how the law protects you.

This website is not intended for children, and we do not knowingly collect data relating to children.

It is important that you read this privacy policy together with any other privacy policy or fair processing notice we may provide on specific occasions when we collect or process personal data about you so that you are fully aware of how and why we are using your data.

Controller

Nolea Technology Ltd, trading as Nolea Health, is the data controller and is responsible for your personal data (collectively referred to as "Nolea Health", "we", "us" or "our" in this privacy policy).

We have appointed a data privacy manager who is responsible for overseeing questions about this privacy policy. If you have any questions, including any requests to exercise your legal rights, please get in touch with the data privacy manager using the details set out below.

Contact Details

• Full name of legal entity: Nolea Technology Ltd, trading as Nolea Health

• Email address: [e-mail]

• Postal address: 2, Television Centre, 101 Wood Ln, London W12 7FR, United Kingdom

You have the right to make a complaint at any time to the Information Commissioner's Office (ICO), the UK regulator for data protection issues (www.ico.org.uk). We would, however, appreciate the chance to deal with your concerns before you approach the ICO so please contact us in the first instance.

Third-party links

This website may include links to third-party websites, plug-ins and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites and are not responsible for their privacy statements. When you leave our website, we encourage you to read the privacy policy of every website you visit.

We do not collect or process special categories of personal data, such as religious views, political views, genetic data, biometric data, sexual orientation, or information concerning mental or physical health.

We do not make automated decisions that would have legal effects on you, nor do we have e-recruiting practices without any human intervention. We only perform an automated search in publicly available data for our clients; recruitment decisions are made by humans working at our client companies.

We respect the data processing principles set out by the General Data Protection Regulation:

• We adhere to data minimisation and only collect and process personal data necessary to provide talent search services or comply with public authorities' requests. This may include the personal data specified above.

• We adhere to data accuracy and review all personal data we store at least twice yearly to ensure it is accurate, up-to-date, and complete. If, during the review, we find that some personal data becomes inaccurate, outdated, or incomplete, we rectify or erase it without delay. However, we cannot guarantee the accuracy of the public sources we use to collect data.

• We respect the principle of storage limitation and keep personal data in a form which permits the identification of data subjects and storage for no longer than is necessary to provide talent search services or comply with public authorities' requests. As explained above, we revise all personal data in our systems at least twice yearly. If we find that some personal data is no longer necessary for our purposes, we erase that personal data.

• We ensure the integrity and confidentiality of personal data by having appropriate technical and organisational measures in place. If we learn of a security system breach, we may notify you electronically so that you can take appropriate protective steps. We may post a notice on our website if a security breach occurs. If you become aware of any possible security breach of our systems, please notify us using the email address above.

We may collect, use, store and transfer different kinds of personal data about you, which we have grouped as follows:

Identity Data includes first name, last name, email address, address, date of birth, and telephone number.

Contact Data includes address, email address and telephone number.

Engagement Data includes details about how you use our platform, profiles you have seen, profiles contacted, feedback about your progress, and messages you sent.

Technical Data includes internet protocol (IP) address, login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform, and other technology you use to access this website.

Usage Data includes information about how you use our website, products and services.

Marketing and Communications Data includes your preferences in receiving marketing from us and our third parties and your communication preferences.

Special Categories of Data include details about your ethnicity, sexual orientation, and gender identity. By providing this data, you consent to its processing as further described in this privacy policy.

We may also collect, use and share Aggregated Data, such as statistical or demographic data, for any purpose. Aggregated data could be derived from your data but is not considered personal data by law, as this data will not directly or indirectly reveal your identity. For example, we may aggregate your Usage Data to calculate the percentage of users accessing a specific website feature. However, suppose we combine or connect aggregated data with your data so that it can directly or indirectly identify you. In that case, we treat the combined data as personal data that will be used in accordance with this privacy policy.

If you fail to provide personal data

Where we need to collect personal data by law or under the terms of a contract we have with you, and you fail to provide that data when requested, we may not be able to perform the contract we have or are trying to enter into with you (for example, to provide you with goods or services). In this case, we may have to cancel a product or service you have with us, but we will notify you if this is the case at the time.

How your data is collected

We use different methods to collect data from and about you, including through

Direct interactions. You may give us your Identity, Contact, Profile, Engagement, Marketing and Communications and Special Categories of Data by entering data on our website or corresponding with us by post, phone, email or otherwise.

Automated technologies or interactions. We will automatically collect technical and usage data as you interact with our website. We collect this personal data by using cookies and other similar technologies. Please see our cookie policy for further details.

How we use your personal data

We will only use your personal data when the law allows us to. Most commonly, we will use your personal data in the following circumstances:

• Where we need to perform the contract we are about to enter or have entered with you.

• Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights, do not override those interests.

• Where we need to comply with a legal obligation.

• Where we have your consent, when processing Special Categories of Data or when the law requires us to seek your consent before sending marketing emails to you, you can withdraw consent to marketing at any time by contacting us.

Purposes for which we will use your personal data

Below, we describe the ways we may use your personal data and the legal bases on which we rely. We have also identified our legitimate interests where appropriate.

Note that we may process your data for more than one lawful ground, depending on the specific purpose for which we are using your data. Please get in touch with us if you need details about the specific legal grounds we rely on to process your personal data, which are more than one of the grounds set out in the table below.

Purpose / Activity	Type of data	Lawful basis for processing including basis of legitimate interest
To register you as a new customer and allow you to access our website and services, including our job matching service.	Identity Contact Engagement Profile Usage Marketing and Communications Special Categories	Performance of a contract with you Consent (Special Categories only)
To manage our relationship with you which may include contacting you with updates or information about our service.	Identity Contact Profile	Performance of a contract with you Necessary to comply with a legal obligation Necessary for our legitimate interests (to keep our records updated and provide relevant information to our customers)
To operate, administer and protect our business and this website (including dealing with our customers, troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data).	Identity Contact Technical Engagement Profile Usage Special Categories	Necessary for our legitimate interests (for running our business, provision of administration and IT services, network security, to prevent fraud, to enforce our Terms and Conditions or other legal rights, and in the context of a business reorganisation or group restructuring exercise) Necessary to comply with a legal obligation Consent (Special Categories only)
To deliver relevant website content and advertisements to you, and measure or understand the effectiveness of the information we serve to you.	Identity Contact Engagement Profile Usage Marketing and Communications Technical	Necessary for our legitimate interests (to study how customers use our products/services, to develop them, to grow our business and to inform our marketing strategy)
To use data analytics to improve our website, products/services, marketing, customer relationships and experiences.	Technical Usage	Necessary for our legitimate interests (to define types of customers for our products and services, to keep our website updated and relevant, to develop our business and to inform our marketing strategy)
To make suggestions and recommendations to you about roles and companies that may be of interest to you, and to allow companies to reach out to you about roles that may be of interest.	Identity Contact Engagement Profile Usage Marketing and Communications Technical Special Categories	Necessary for our legitimate interests (to develop our products / services and grow our business) Consent (Special Categories only)

Tailored Content and Marketing

We may use your Identity, Engagement, Profile, Technical, Usage and Special Categories of Data to form a view on jobs or services that you may be interested in or that may be suitable for you and may display relevant content on our website or send it to you by email. You may also receive marketing communications if you have opted in to receive marketing or if you have requested information from us or purchased services from us and have yet to opt out of receiving that marketing.

Opting out

You can ask us to stop sending you marketing or job notification messages at any time by following the opt-out links on any marketing message sent to you.

Cookies

We may use cookies and other tracking technologies on our website. Cookies are small data files (text or pixels) stored on your computer or mobile device. We may use cookies to facilitate your website browsing, optimise our website, and analyse website traffic. Thus, cookies help to improve our website and your browsing experience.

You can set your browser to refuse all or some browser cookies or to alert you when websites set or access cookies. If you disable or refuse cookies, please note that some parts of this website may become inaccessible or malfunction. For more information about the cookies we use, please see our Cookie Policy.

Marketing emails

You can subscribe to our newsletter on our website. Should you wish to opt out of receiving these emails in the future, you can unsubscribe from our marketing email list at any time by clicking on the unsubscribe link in the emails we send or by contacting us using the details above. You will then be removed from the marketing email list.

Third-party apps

App's use and transfer of information received from Google APIs to any other app will adhere to Google API Services User Data Policy, including the Limited Use requirements.

Nolea Technology explicitly affirm that Google Workspace APIs are not used to develop, improve, or train generalized AI and/or ML models.

Change of purpose

We will only use your data for the purposes we collected it unless we consider that we need to use it for another reason. That reason is compatible with the original purpose. If you wish to explain how the processing for the new purpose is compatible with the original purpose, please get in touch with us.

If we need to use your data for an unrelated purpose, we will notify you and explain the legal basis that allows us to do so.

Please note that we may process your data without your knowledge or consent in compliance with the above rules, where this is required or permitted by law.

Disclosures of your data

When processing your data as described above, we may share your data with the parties set out below:

Business Partners: only for recruitment purposes and to the extent they have expressed interest in our products and services, which is required to fulfil our contractual obligations.

Service providers act as processors that provide IT, software, and/or system administration services.

Professional advisers acting as processors, including our lawyers, bankers, auditors, and insurers, provide us with consultancy, banking, legal, insurance, and accounting services.

When required by law or regulation, HM Revenue & Customs, regulators and other authorities act as processors or joint controllers.

Third parties to whom we may choose to sell, transfer or merge parts of our business or our assets. Alternatively, we may seek to acquire other businesses or merge with them. If a change happens to our business, the new owners may use your data the same way as set out in this privacy policy. We use certain trusted third parties, such as workflow providers and web service providers, to help us provide and improve our products and services. We share your data only to the extent necessary to provide our talent search services.

We require all third parties to respect the security of your personal data and treat it in accordance with the law. We do not allow our third-party service providers to use your personal data for their own purposes and only permit them to process it for specified purposes and in accordance with our instructions.

Data security

We have implemented appropriate security measures to prevent your data from being accidentally lost, used or accessed unauthorised, altered or disclosed. In addition, we limit access to your data to those employees, agents, contractors and other third parties who have a business need to know. They will only process your data on our instructions and are subject to a duty of confidentiality.

We have internal procedures to deal with any suspected personal data breach. We will notify you and any applicable regulator of a breach where we are legally required to do so.

Data retention

How long we will use your personal data

We will only retain your personal data for as long as reasonably necessary to fulfil the purposes we collected it for, including satisfying any legal, regulatory, tax, accounting, or reporting requirements. We may retain your data for a longer period in case of a complaint or if we reasonably believe there is a prospect of litigation regarding our relationship with you.

To determine the appropriate retention period for personal data, we consider the amount, nature and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your data, the purposes for which we process your data and whether we can achieve those purposes through other means, and the applicable legal, regulatory, tax, accounting or other requirements.

In some circumstances, we will anonymise your data (so that it can no longer be associated with you) for research or statistical purposes, in which case we may use this information indefinitely without you giving further notice.

Your legal rights

Under certain circumstances, you have rights under data protection laws in relation to your data. These rights are to:

• Request access to your data.

• Request correction of your data.

• Request erasure of your data.

• Object to processing of your data.

• Request restriction of processing your data.

• Request transfer of your data.

• Right to withdraw consent.

If you wish to exercise any of the rights set out above, please get in touch with us or our representative using the contact details set out above.

[e-mail]

In response to a request, we might ask you to verify your identity, and to provide additional information needed to handle your request.

We will respond to you as soon as possible, within a maximum of 30 days.

No fee usually required

You will not have to pay a fee to access your data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is unfounded, repetitive or excessive. Alternatively, we could refuse to comply with your request in these circumstances.

What we may need from you

We may request specific information from you to help us confirm your identity and ensure your right to access your data (or to exercise any of your other rights). This security measure ensures that personal data is not disclosed to anyone with no right to receive it. We may also contact you to ask you for further information about your request to speed up our response.

Time limit to respond

We try to respond to all legitimate requests within one month. Occasionally, it could take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.