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Privacy Notice – Candidates, Clients and Suppliers

WHAT IS THE PURPOSE OF THIS DOCUMENT?

Planet Equity Group is made up of different legal entities, Planet Forward-UK, Planet Technology, Planet Forward, Planet Professional, Planet Interactive, Planet Forward Energy Solutions, Strive Consulting, and 110 Holdings, LLC (DBA Launch Consulting) (referred to as the “Group”). This privacy notice is issued on behalf of all the companies in The Planet Group so when we mention "The Planet Group," “we”, “us” or “our” in this privacy notice, we are referring to the relevant company in The Planet Group responsible for processing your data. Each entity is committed to protecting the privacy and security of your personal information.

This Privacy Notice describes how we collect and use personal information about you, in accordance with the relevant data protection legislation in force from time to time.

Each company within the Planet Equity Group is a “data controller”. This means that we are responsible for deciding how we hold and use personal information about you. We are required under data protection legislation to notify you of the information contained in this Privacy Notice.

We are a recruitment agency and recruitment business. This Privacy Notice applies to our candidates, other people we may have contact with to find out more about our candidates or whose details have been provided in the event of an emergency, our clients and our suppliers.

This Privacy Notice applies in relevant countries throughout our international network.  Different countries may approach data protection in a different way but the process outlined in this notice will apply to all.

This Privacy Notice does not form part of any contract. We may update this notice at any time.

It is important that you read this notice so that you are aware of how and why we are using such information.

DATA PROTECTION PRINCIPLES

We will comply with data protection legislation. This says that the personal information we hold about you must be:

  1. Used lawfully, fairly and in a transparent way.
  2. Collected only for valid purposes that we have clearly explained to you and not used in any way that is incompatible with those purposes.
  3. Relevant to the purposes we have told you about and limited only to those purposes.
  4. Accurate and kept up to date.
  5. Kept only as long as necessary for the purposes we have told you about.
  6. Kept securely.

THE INFORMATION WE HOLD AND HOW WE COLLECT IT

Personal data, or personal information, means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymous data).

There are “special categories” of more sensitive personal data which require a higher level of protection. We only hold this type of data in relation to candidates.

We will collect, store, and use the categories of personal information set out below.  The lists are not intended to be exhaustive and not every category of information will apply to you:

CANDIDATE DATA

  • Name
  • Title
  • Address
  • Email address
  • Telephone number
  • Age/date of birth
  • Birth certificate
  • Proof of name change
  • Sex/gender
  • Marital status
  • Education details
  • CV/work history
  • Job preferences including role, geographical areas, and salary
  • Any other work-related information you provide, for example, education or training
  • Proof of qualifications or training
  • Industry registration
  • Emergency contacts and details of any dependants
  • Referee details
  • A copy of your passport/identity card
  • Permits and visas
  • Immigration status
  • Nationality/citizenship/place of birth
  • A copy of your driving license
  • National insurance number/Social Security Number
  • Full details of job offers and placements
  • Disclosure and Barring Service (DBS) checks
  • Drug screening results
  • Education verifications
  • Employment history verifications
  • Diversity information including racial or ethnic origin, religion or similar beliefs, physical or mental health including disability related information
  • Medical information
  • References
  • Details of current remuneration package and benefits
  • Financial information (including but not limited to payment terms, bank statements, payroll details, HMRC data, pension scheme details, Court orders, and statutory payments)
  • Personal credit details
  • Self-employed/business credit details
  • Information in relation to your limited company including certificate of incorporation, insurance policy, VAT certificate, and tax registration documents
  • Any extra information you tell us, your references tell us, our clients tell us or from third party sources such as job board
  • A log of our communications with you by email and telephone

This information will have been collected by us in the following ways:

  • Provided by you directly through our website, application forms or registration process
  • Provided by a third party who we work with such as a job board company or another employment business or our clients or referral
  • Other third-party searches such as LinkedIn and other job sites
  • If you like our page on Facebook or follow us on Twitter we will receive information from these sites
  • Your references will be provided by your previous employers or other named referees.
  • Medical information may be supplied by your doctor, consultant or occupational health.
  • DBS checks, other background checks, where relevant, will be supplied by the Disclosure and Barring Service or other external companies

If you fail to provide certain information when requested, we may not be able to provide our services as an employment business or perform the contract we have entered into with your limited company or may be prevented from complying with our legal obligations (such as health and safety).

OTHER PERSONAL DATA RECEIVED FROM CANDIDATES

In order to provide services as an employment business and progress opportunities for individuals, we will also be provided with personal data about individuals by candidates.  This includes but is not limited to referee details and emergency contact details.  The information held will be limited to contact details such as name, address, email address and telephone number.

CLIENT DATA

The information we hold in relation to clients is to enable us to provide our services to them as an employment business.  This data will be limited and will include:

  • Name
  • Telephone number
  • Email address
  • Information about the business

This information is usually provided by:

  • The individuals themselves
  • By third parties e.g. candidates
  • From market research

SUPPLIER DATA

The information we hold in return to suppliers is to enable them to provide services to us.  This data will be limited and will include:

  • Name
  • Telephone number
  • Email address

This information is usually provided by:

  • The individuals themselves
  • By third parties

HOW AND WHY WE USE YOUR PERSONAL DATA

We will only use your personal information where the law allows us to.  The tables below explain what we process your data for and the legal basis for this.

CANDIDATES

Most commonly we will use your personal information in the following circumstances:

  1. Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override these interests, i.e. providing you with our service
  2. Where we need to comply with a legal obligation
  3. Where you have given consent.

“Special Categories” of particularly sensitive data require higher levels of protection. For the purpose of this Notice, this includes criminal convictions.  We need to have further justifications for processing this type of data.  We may process this type of data in the following circumstances:

  • With your explicit written consent.
  • Where we need to carry out our obligation or exercise rights in connection with employment law.
  • Where it is needed in the public interests such as equal opportunity monitoring.

Less commonly we may process this information where it is needed in relation to legal claims.

What We Use Your Personal Data For

Legal Basis

Collecting your data from you and other sources
For our legitimate interests, i.e. providing you with our services
Storing your details on our database
For our legitimate interests, i.e. providing you with our services
Providing you with our recruitment services and to facilitate the recruitment process
For our legitimate interests, i.e. providing you with our services
To match your skill sets with job vacancies
For our legitimate interests, i.e. providing you with our services
To put forward your details to our clients and prospective employers for you to be considered for vacancies
For our legitimate interests, i.e. providing you with our services
To place you with our clients and prospective employers
For our legitimate interests, i.e. providing you with our services
To keep you informed of available opportunities as they arise
For our legitimate interests, i.e. providing you with our services
Checking you are legally entitled to work in the UK
To comply with our legal obligations
To put in place contractual arrangements and documentation once a role has been secured
To comply with our legal obligations
For the performance of our contract with your limited company
To comply with our legal obligations
What We Use Your Special Personal Data For
Legal basis
To undertake relevant DBS checks
To comply with our legal obligations in connection with employment law and/or with your explicit consent
To deal with any medical and health and safety issues arising in relation to certain positions
To comply with our legal obligations in respect to employment law and/or your explicit consent
Equal opportunities monitoring and compliance with discrimination law
To comply with our legal (or in public interest)
To help us establish to exercise, establish or defend legal claims (this could involve personal data and special data)
Our legitimate interests i.e. defending a claim and as it is necessary for dealing with claims

OTHER PERSONAL DATA RECEIVED FROM CANDIDATES

What We Use Your Personal Data For

Legal Basis

To contact individuals in an emergency
For our legitimate interests i.e. to ensure an emergency situation is properly managed
To obtain references
For our legitimate interest – to ensure we offer a good service to our clients to check credentials

CLIENTS

What We Use Your Personal Data For

Legal Basis

To enable us to contact our clients
For our legitimate interest – to enable us to offer our services to clients

SUPPLIERS

What We Use Your Personal Data For

Legal Basis

To enable us to contact our suppliers
For our legitimate interest – to allow our suppliers to provide a service to us

HOW WE HOLD THIS INFORMATION

All the personal data we have is stored on our database and in our encrypted cloud-based server within the EU. This will also include emails if personal data was received via this method.

DATA SHARING

We will only share your personal information where it is required by law, where it is necessary to administer the working relationship with you, where we have another legitimate business interest or we have your consent.

CANDIDATES

We may share your information with the following third parties:-

  • Prospective employers and our clients with your consent to secure a placement and if you are successful to enable the placement to proceed
  • Any of the companies with the Group to find you a role and/or for administrative purposes
  • HMRC or local tax authorities for tax reasons
  • Pension providers to facilitate access to the scheme
  • External companies for the purpose of undertaking DBS or other background checks, where required by law or where your consent has been obtained
  • External companies for the purpose of paying you
  • To previous employers or other nominated referees for the purpose of obtaining a reference
  • To legal advisors to establish, exercise or defend legal claims
  • To a new owner of the business should we merge or be acquiesced by another business
  • Service Providers, if any, who perform functions on our behalf, including lawyers and IT support

PERSONAL DATA PROVIDED BY CANDIDATES

Referees personal data will be shared with any company within the Group, Service Providers and clients we provide services to.

CLIENT DATA

Client data will be shared with any company within the Group, Service Providers, clients we provide services to and candidates.

SUPPLIERS’ DATA

Suppliers’ data will be shared with any company within the Planet Group, service providers, candidates, and clients.

TRANSFERRING INFORMATION OUTSIDE THE EU

Your data may be accessed by our companies within the Planet Equity Group in the US, who have access to our database and it may be further processed by these companies if opportunities are being considered for you by these companies.  There is not an adequacy decision by the European Commission in respect of the US. This means that the country to which we transfer your data is not deemed to provide an adequate level of protection for your personal information.

However, to ensure that your personal information does receive an adequate level of protection we have trained all of our US-based employees to follow our GDPR privacy policies and measures in those cases when EU data, that is governed by GDPR, is transferred outside the EU. Our repositories for personal data are stored under certified EU-US Privacy Shield databases via our trusted suppliers. If you require further information about this protective measure, you can request it from [email protected].

DATA SECURITY

We have put in place measures to protect the security of your information. Details of these measures are available on our company websites.

Third parties will only process your personal information on our instructions and where they have agreed to treat the information confidentially and to keep it secure.

We have put in place appropriate security measures to prevent your personal information from being accidentally lost, used or accessed in an unauthorized way, altered or disclosed. In addition, we limit access to your personal information to those employees, agents, 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. Details of these measures can be found in the security policies.

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

DATA RETENTION

We will only retain your personal information for as long as necessary to fulfill the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements. Details of retention periods are available in our retention policy which is available from the company website. 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 personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal requirements.

For candidates where you are not in an active engagement, we will seek your consent to continue to hold your data every [ 6 ] years.  After this period it is likely that your data will no longer be relevant and it will be deleted subject to any legal requirements we have to hold your data.

In some circumstances, we may anonymize your personal information so that it can no longer be associated with you, in which case we may use such information without further notice to you. Once you are no longer a contractor of the company we will retain and securely destroy your personal information in accordance with our data retention policy.

RIGHTS OF ACCESS, CORRECTION, ERASURE, AND RESTRICTION

Your duty to inform us of changes

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 your working relationship with us.

Your rights in connection with personal information

Under certain circumstances, by law, you have the right to:

  • Request access to your personal information (commonly known as a “data subject access request”). This enables you to receive a copy of the personal information we hold about you and to check that we are lawfully processing it.
  • Request correction of the personal information that we hold about you. This enables you to have any incomplete or inaccurate information we hold about you corrected.
  • Request erasure of your personal information. This enables you to ask us to delete or remove personal information where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal information where you have exercised your right to object to processing (see below).
  • Object to processing of your personal information where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground. You also have the right to object where we are processing your personal information for direct marketing purposes.
  • Request the restriction of processing of your personal information. This enables you to ask us to suspend the processing of personal information about you, for example, if you want us to establish its accuracy or the reason for processing it.
  • Request the transfer of your personal information to another party.

If you want to review, verify, correct or request the erasure of your personal information, object to the processing of your personal data, or request that we transfer a copy of your personal information to another party, please contact [email protected] in writing.

No fee usually required

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

What we may need from you

We may need to request specific information from you to help us confirm your identity and ensure your right to access the information (or to exercise any of your other rights). This is another appropriate security measure to ensure that personal information is not disclosed to any person who has no right to receive it.

RIGHT TO WITHDRAW CONSENT

In the limited circumstances where you may have provided your consent to the collection, processing, and transfer of your personal information for a specific purpose, you have the right to withdraw your consent for that specific processing at any time. To withdraw your consent, please contact [email protected]. Once we have received notification that you have withdrawn your consent, we will no longer process your information for the purpose or purposes you originally agreed to, unless we have another legitimate basis for doing so in law.

DATA PROTECTION OFFICER

We have appointed a Data Protection Officer (DPO), Steven Jorgenson, to oversee compliance with this privacy notice. If you have any questions about this privacy notice, please contact [email protected]. You have the right to make a complaint at any time to the Information Commissioner’s Office (ICO), the UK supervisory authority for data protection issues.

CHANGES TO THIS PRIVACY NOTICE

We reserve the right to update this privacy notice at any time, and we will provide you with a new privacy notice when we make any substantial updates. We may also notify you in other ways from time to time about the processing of your personal information.

If you have any questions about this privacy notice, please contact [email protected] .

INTRODUCTION

Welcome to our privacy notice.

 

We respect your privacy and are committed to protecting yourpersonal data. This privacy notice will inform you as to how we look after yourpersonal data when you visit our website (regardless of where you visit itfrom) and tell you about your privacy rights and how the law protects you.

 

This privacy notice is provided in a layered format so you can clickthrough to the specific areas set outbelow. Alternatively you can download a pdf version of the policy here. Pleasealso use the Glossary to understand the meaning of some of the terms used inthis privacy notice.

 

1.  IMPORTANT INFORMATION AND WHO WE ARE

 

2.  THE DATA WE COLLECTABOUT YOU

 

3.  HOW IS YOUR PERSONALDATA COLLECTED

 

4.  HOW WE USE YOUR PERSONAL DATA

 

5.  DISCLOSURES OF YOUR PERSONALDATA

 

6.  INTERNATIONAL TRANSFERS

 

7.  DATA SECURITY

 

8.  DATA RETENTION

 

9.  YOUR LEGAL RIGHTS

 

10. YOUR CALIFORNIAPRIVACY RIGHTS

 

11.  GLOSSARY

 

1.   IMPORTANT INFORMATION AND WHO WE AREPURPOSE OF THIS PRIVACY NOTICE

This privacy notice aims to give you information on how we collectand process your personal data through your use of this website. This policy also explains what type ofservices are provided through our online websites.

 

This website is not intendedfor children and we do not knowinglycollect data relatingto children.

 

It is important that you read this privacy notice together with anyother privacy notice or fair processing notice we may provide on specificoccasions when we are collecting or processing personal data about you so thatyou are fully aware of how and why we are using your data. This privacy noticesupplements the other notices and is not intended to override them.

 

CONTROLLER

 

Planet Equity Group is made up of different legal entities, PlanetForward-UK, Planet Healthcare, Planet Technology, Planet Forward, PlanetProfessional, Planet Forward Energy Solutions, Strive Consulting, and 110Holdings, LLC (DBA Launch Consulting) (referred to as the “Group”). Thisprivacy notice is issued on behalf of all the companies in the Group so when wemention the Group, “we”, “us” or “our” in this privacy notice, we are referringto the relevant company in the Group responsible for processing your data. Wewill let you know which entity will be the controller for your data whenprovide a service to you. Our Chief Technical Officer is the controller andresponsible for this website.

 

We have appointed a data protection officer (DPO) who is responsiblefor overseeing questions in relation to this privacy notice. If you have anyquestions about this privacy notice, including any requests to exercise your legal rights, please contact theDPO using the details set out below.

 

CONTACT DETAILS

 

Full name of legal entity: Planet Equity Group LLC

 

Name or title of DPO: StevenJorgenson, Legal Operations Director Email address: [email protected]

Postal address (US): 800 Hillgrove Ave, #201, Western Springs, IL60558

Postal address(outside US): 10 GreycoatPlace, London, SW1P 1SB

Telephone number (US): +1 708.286.1199

Telephone number: +44 203 868 1000

You have the right to make a complaint at any time to theInformation Commissioner’s Office (ICO), the UK supervisory authority for dataprotection issues (www.ico.org.uk).We would, however, appreciate the chance to deal with your concerns before youapproach the ICO so please contact us in the first instance.

 

CHANGES TO THE PRIVACYNOTICE AND YOUR DUTY TO INFORM US OF CHANGES

 

This version was last updatedon February 21, 2023 and historicversions can be obtained by contacting us.

 

It is important that the personal data we hold about you is accurateand current. Please keep us informed if your personal data changes during yourrelationship with us.

 

THIRD-PARTY LINKS

 

This website may include links to third-party websites, plug-ins andapplications. Clicking on those links or enabling those connections may allowthird parties to collect or share data about you. We do not control thesethird-party websites and are notresponsible for their privacy statements. When you leave our website, weencourage you to read the privacy notice of every website you visit.

 

2.   THE DATA WE COLLECT ABOUT YOU

 

Personal data, or personal information, means any information aboutan individual from which that person can be identified. It does not includedata where the identity has been removed (anonymous data).

 

We may collect, use, store and transfer different kinds of personaldata about you which we have groupedtogether follows:

 

•       Identity Data includes first name, maidenname, last name. email address, IP addresses and accountusername.

•       Contact Data includes email address and telephone numbers.

•       Work Data includes CV/workhistory.

•      Technical Data includes browser type and version,time zone settingand location, browser plug-intypes and versions, operating systemand platform and other technology on the devices you use to access thiswebsite.

•       Usage Data includes information about how you use our website.

•       Characteristics of Protected Classifications UnderCalifornia or Federal Law includes gender and age.

•       Internet Or Other Electronic Network Activity Information including pages visited onCompany’s websites and links clicked; IP address; location information; browserand device data; and language preferences.

•       Profile Information, including results of self-assessment questionnaires and inferencesdrawn from the categories of Personal Information listed above to create aprofile reflecting a California Consumer’s preferences.

 

We only collectIdentity, Contact and Work Data if you apply to a job on our websites, or submit your information to one of ourrepresentatives directly, or submit your information indirectly through anotherwebsite or platform.

 

We also collect, use and share Aggregated Data such as statistical or demographic data for anypurpose. Aggregated Data may be derived from your personal data but is notconsidered personal data in law as this data does not directly or indirectlyreveal your identity. For example, we may aggregate your Usage Data tocalculate the percentage of users accessing a specific website feature.However, if we combine or connect Aggregated Data with your personal data sothat it can directly or indirectly identify you, we treat the combined data aspersonal data which will be used in accordance with this privacy notice.

 

We do not collect any Special Categories of Personal Data about you (this includes details about yourrace or ethnicity, religious or philosophical beliefs, sex life, sexualorientation, political opinions, trade union membership, information about yourhealth and genetic and biometric data). Nor do we collect any information aboutcriminal convictions and offences.

 

IF YOU FAIL TO PROVIDE PERSONAL DATA

 

If you fail to provide that data when requested, we may not be ableto provide the services to you. Wewill notify you if this is the case at the time.

 

3.   HOW IS YOUR PERSONAL DATA COLLECTED?

 

We use different methods to collectdata from and about you including through:

 

•      Directinteractions. You may give us your Identity, Contactand Work Data by filling in forms or by corresponding with us by post,phone, email or otherwise. This includes personal data you provide when you:

• apply to use our services;

• give us some feedback.

•      Automatedtechnologies or interactions. As you interact with our website, we mayautomatically collect Technical Data about your equipment, browsingactions and patterns.We collect this personal data by using cookies, server logsand other similar technologies.

•      Third parties orpublicly available sources. We may receive personal data about you from variousthird parties as set out below

• Technical Data from the following parties:

 

(a)   analytics providerssuch as Google based outsidethe EU;

(b)   advertising networkssuch as Job Boards based inside the EU; and

(c)   search information providers.

 

4.   HOW WE USE YOUR PERSONALDATA

 

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

 

•      Where it is necessary for our legitimate interests(or those of a third party) and yourinterests and fundamental rights do not override those interests (providing jobseeking service to you).

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

•       Where we need to comply with a legalor regulatory obligation.

 

Generally we do not rely on consent as a legal basis for processingyour personal data. other than in relation to sending third party direct marketing communications to you via email ortext message.

 

PURPOSES FOR WHICH WE WILL USE YOUR PERSONALDATA

 

We have set out below, in a table format, a description of all theways we plan to use your personal data, and which of the legal bases we rely onto do so. We have also identified what our legitimate interests are whereappropriate.

 

Note that we mayprocess your personaldata for more than one lawful grounddepending on the specific purpose for which we are using your data.Please Contact us if you need details about the specific legalgrounds we are relying on to process your personal data where more than one basishas been 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 candidate
(a)  Identifiers

(b) Non-Public Education Information Characteristics of Protected  Classifications Under California or Federal Law Professional or  Employment-Related Information

(c)  Commercial Information

(d) Sensory Information

(e) Internet or Other Electronic Network Activity Information

(f)  Profile Information
(a) Legitimate interest(to provide our services to you)
 To manage our relationship with you
(a) Identity 

(b) Contact 

(c) Marketing and Communications
(a) Legitimate interest(to provide our services to you)
 To administer and protect our business and  this website (including troubleshooting, data analysis, testing, system maintenance, support, reporting and  hosting of data)
(a) Identity 

(b) Contact 

(c) Technical
(a) Necessary for our legitimate interests (for running our business, provision of administration and IT services, network security, to prevent fraud and in the context of a business reorganization or group restructuring exercise)

(b)Necessary to comply with a legal obligation
To deliver relevant website content to you
(a) Identity 

(b) Contact 

(c) Usage 

(d) 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, relationships and experiences
(a) Technical

(b) 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
To make suggestions and recommendations to you about goods or services that may be of interest to you
(a) Identity 

(b) Contact 

(c) Technical

(b) Usage
Necessary for our  legitimate interests (to develop our products/services and grow our business)

SOURCES OF PERSONAL INFORMATION COLLECTED

In the last 12 months, Company collected the following categories of Personal Information about California Consumers from the following sources:

• Directly From California Consumers: (a) Identifiers; (b) Characteristics of Protected Classifications Under California or Federal Law; (c) Commercial Information; (d) Sensory Information; (e) Professional or Employment-Related Information; (f) Non-Public Education Information; (g) Profile Information.

• Data Collection Technologies (described above): Internet Or Other Electronic Network Activity Information.

COOKIES

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 not function properly. For more information about the cookies we use, please see our Cookies Policy available on our website.

CHANGE OF PURPOSE

We will only use your personal data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If you wish to get an explanation as to how the processing for the new purpose is compatible with the original purpose, please Contact us.

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

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

5. DISCLOSURES OF YOUR PERSONAL DATA

We may have to share your personal data with the parties set out below for the purposes set out in the table above.

• Internal Third Parties as set out in the Glossary.

• External Third Parties as set out in the Glossary.

• 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, then the new owners may use your personal data in the same way as set out in this privacy notice.

• Government agencies, law enforcement, and other parties as required by law, including in litigation

We require all third parties to respect the security of your personal data and to 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 your personal data for specified purposes and in accordance with our instructions.

6. INTERNATIONAL TRANSFERS

We share your personal data with companies within the Planet Equity Group. This will involve transferring your data outside the European Economic Area (EEA), and outside of the United States from time to time for entities located inside the United States.

Whenever we transfer your personal data out of the EEA, we ensure a similar degree of protection is afforded to it by ensuring at least one of the following safeguards is implemented:

• We will only transfer your personal data to countries that have been deemed to provide an adequate level of protection for personal data by the European Commission.

• We may use specific contracts approved by the European Commission which give personal data the same protection it has in Europe.

• We use Standard Contractual Clauses as a transfer mechanism between third parties.

Please Contact us if you want further information on the specific mechanism used by us when transferring your personal data out of the EEA.

7. DATA SECURITY

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

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

8. DATA RETENTION

HOW LONG WILL YOU USE MY PERSONAL DATA FOR?

We will only retain your personal data for as long as necessary to fulfill the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements.

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 personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal requirements.

Details of retention periods for different aspects of your personal data are [available in our retention policy which you can request from us by Contacting us.

9. YOUR LEGAL RIGHTS

Under certain circumstances, you have rights under data protection laws in relation to your personal data. Please click on the links below to find out more about these rights:

• Request access to your personal data.

• Request correction of your personal data.

• Request erasure of your personal data.

• Object to processing of your personal data.

• Request restriction of processing your personal data.

• Request transfer of your personal data.

• Right to withdraw consent.

If you wish to exercise any of the rights set out above, please Contact us

NO FEE USUALLY REQUIRED

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

WHAT WE MAY NEED FROM YOU

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

TIME LIMIT TO RESPOND

We try to respond to all legitimate requests within one month. Occasionally it may 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.

YOUR LEGAL RIGHTS

You have the right to:

Request access to your personal data (commonly known as a “data subject access request”). This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it.

Request correction of the personal data that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.

Request erasure of your personal data. This enables you to ask us to delete or remove personal data where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal data where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your personal data to comply with local law. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.

Object to processing of your personal data where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms. You also have the right to object should we process your personal data for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms.

Request restriction of processing of your personal data. This enables you to ask us to suspend the processing of your personal data in the following scenarios: (a) if you want us to establish the data’s accuracy; (b) where our use of the data is unlawful but you do not want us to erase it; (c) where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims; or (d) you have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.

Request the transfer of your personal data to you or to a third party. We will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.

Withdraw consent at any time where we are relying on consent to process your personal data. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain products or services to you. We will advise you if this is the case at the time you withdraw your consent.

10. YOUR CALIFORNIA PRIVACY RIGHTS

Right to Know

California Consumers have the right to submit a verifiable request to know:

• The categories and specific pieces of Personal Information that Group has collected about them;

• The categories of sources from which Group collected the Personal Information;

• The categories of Personal Information that Group sold or disclosed to a third party (other than a service provider) for a business purpose and the categories of recipients of that information; and

• The business or commercial purposes for Group’s collection, disclosure, or sale of the Personal Information.

Right to Delete

California Consumers have the right to submit a verifiable request for deletion of their Personal Information that Group has collected from the Consumer.

Request Update

California Consumers can also submit verifiable request updates to their Personal Information that Group has collected from the Consumer.

Right to opt out of the Sale of Personal Information

California Consumers have a right to opt-out of the sale of the Personal Information. However, as stated above, Company does not and will not sell Personal Information

How to Exercise Your Rights

Group will respond to requests in accordance with applicable law if it can verify the identity of the individual submitting the request and validate the request itself. California Consumers can exercise their rights in the following ways:

• Complete the "Online Request Form" to create a new Consumer Request.

• Contact by telephone: xxxxxxxxxx for assistance with the Online Request Form.

Requests by Authorized Agents

You may designate an authorized agent to exercise your right to know, your right to delete and request updates by submitting to us a completed “Authorized Agent Designation” form. You can obtain the designation form by writing to:

The Planet Group

Attn: Data Privacy Officer

800 Hillgrove Ave, #201

Western Springs, IL 60558

If an authorized agent submits a request on your behalf, the authorized agent must submit with the request either (a) a power of attorney that is valid under California law, or (b) a document signed by you that authorizes the authorized agent to submit the request on your behalf. In addition, we may ask you to follow the applicable process described above for verifying your identity.

How We Will Verify Your Requests

The processes that we follow to provide access and verify the identity of the person making a request to know, update or delete data about whom we have collected personal information are described below. All consumer requests require multiple verifications to confirm the identity of the person making any requests and to provide the requested accesses. All Consumer Requests require verification of a consumer’s identity to confirm they are who they say they are and additional documentation if you are submitting requests on behalf of someone else.

Under the CCPA, a business is only required to respond to requests that are "Verifiable Consumer Requests." A verifiable consumer request is defined as a request that is made by a consumer, by a consumer on behalf of the consumer’s minor child, or by a natural person or a person registered with the Secretary of State, authorized by the consumer to act on the consumer’s behalf, and that the business can reasonably verify to be the consumer about whom the business has collected personal identifiable information.

All Consumer Requests for Personal Information:

• Consumer will need to provide one of the following to verify their personal identity: Scanned Driver License, Birth Certificate, Utility Bill or Passport when making a request for themselves.

• Consumer will additionally need to provide a scanned Power-Of-Attorney if the consumer request is on behalf of someone else for any reason.

All Consumer Update Requests To Personal Information also require:

• Consumer will additionally need to provide proof of the changes requested.

Your Right to Information About Disclosures of Personal Information for Direct Marketing Purposes:

Under California law, California Consumers can request information from us about whether we have disclosed Personal Information to any third parties for the third parties' direct marketing purposes. We will not sell your Personal Information to, or share it with, third-party companies for their direct marketing purposes without your consent. California Consumers desiring to request further information about our compliance with these laws or who have questions or concerns about our privacy practices and policies are welcome to contact us using the contact information below.

Minors Under 13 Years of Age

We respect the privacy of children. Our Services are not designed to attract an audience younger than thirteen (13), and we do not knowingly collect Personal Information from children under thirteen (13). If you are under the age of thirteen (13), you are not permitted to use our Services and should not send any information about yourself to us through the Services. Please contact us using the contact details below if you believe we may have collected information from your child under the age of thirteen (13), and we will work to delete it.

11. GLOSSARY

LEGITIMATE INTEREST means the interest of our business in conducting and managing our business to enable us to give you the best service and the best and most secure experience. We make sure we consider and balance any potential impact on you (both positive and negative) and your rights before we process your personal data for our legitimate interests. We do not use your personal data for activities where our interests are overridden by the impact on you (unless we have your consent or are otherwise required or permitted to by law). You can obtain further information about how we assess our legitimate interests against any potential impact on you in respect of specific activities by Contacting us.

PERFORMANCE OF CONTRACT means processing your data where it is necessary for the performance of a contract to which you are a party or to take steps at your request before entering into such a contract.

COMPLY WITH A LEGAL OR REGULATORY OBLIGATION means processing your personal data where it is necessary for compliance with a legal or regulatory obligation that we are subject to.

EXTERNAL THIRD PARTIES

Service Providers, including other companies we provide services to, providers of data collection technologies, providers of data analytics services, and website providers, or third-party advertising networks

INTERNAL THIRD PARTIES

Other companies in the Group and who are based in the UK and US.

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