Privacy Policy

PRIVACY POLICY BACKGROUND: Digital Business Development Limited understands that your privacy is important to you and that you care about how your personal data is used. We respect and value the privacy of everyone who visits this website, http://dbdmedia.co.uk/ (“Our Site”) and will only collect and use personal data in ways that are described here, and in a way that is consistent with our obligations and your rights under the law. Please read this Privacy Policy carefully and ensure that you understand it. Your acceptance of this Privacy Policy is requested when you navigate to a Digital Business Development Limited website or mobile view.

  1. Definitions and Interpretation In this Policy the following terms shall have the following meanings: “Account” means an account required to access and/or use certain areas and features of Our Site; “Cookie” means a small text file placed on your computer or device by Our Site when you visit certain parts of Our Site and/or when you use certain features of Our Site. Details of the Cookies used by Our Site are set out in Part 14, below; and “Cookie Law” means the relevant parts of the Privacy and Electronic Communications (EC Directive) Regulations 2003;

  2. Information About Us Our Site is owned and operated by Digital Business Development Limited, a Limited Company registered in England under company number 05095762. Registered address: 78 Chamber Street, London, United Kingdom, Post code: E1 8BL. Main trading address: 78 Chamber Street, London, United Kingdom, Post code: E1 8BL. VAT number: 752152256. Data Protection Officer: Nil Bhatt. Email address: nil@verbbrands.com. Telephone number: +44 (0) 20 8977 2994. Postal address: 78 Chamber Street, London, United Kingdom, Post code: E1 8BL. Representative: Nil Bhatt. Email address: nil@verbbrands.com. Telephone number: +44 (0) 20 8977 2994. Postal address: 78 Chamber Street, London, United Kingdom, Post code: E1 8BL.

  3. We are regulated by Information Commissioner’s Office. We are a member of Information Commissioner’s Office

  4. What Does This Policy Cover? This Privacy Policy applies only to your use of Our Site. Our Site may contain links to other websites. Please note that we have no control over how your data is collected, stored, or used by other websites and we advise you to check the privacy policies of any such websites before providing any data to them.

  5. What Is Personal Data? Personal data is defined by the General Data Protection Regulation (EU Regulation 2016/679) (the “GDPR”) and the Data Protection Act 2018 (collectively, “the Data Protection Legislation”) as ‘any information relating to an identifiable person who can be directly or indirectly identified in particular by reference to an identifier’. Personal data is, in simpler terms, any information about you that enables you to be identified. Personal data covers obvious information such as your name and contact details, but it also covers less obvious information such as identification numbers, electronic location data, and other online identifiers.

  6. What Are My Rights? Under the Data Protection Legislation, you have the following rights, which we will always work to uphold: a) The right to be informed about our collection and use of your personal data. This Privacy Policy should tell you everything you need to know, but you can always contact us to find out more or to ask any questions using the details in Part 15. b) The right to access the personal data we hold about you. Part 13 will tell you how to do this. c) The right to have your personal data rectified if any of your personal data held by us is inaccurate or incomplete. Please contact us using the details in Part 15 to find out more. d) The right to be forgotten, i.e. the right to ask us to delete or otherwise dispose of any of your personal data that we hold. Please contact us using the details in Part 15 to find out more. e) The right to restrict (i.e. prevent) the processing of your personal data. f) The right to object to us using your personal data for a particular purpose or purposes. g) The right to withdraw consent. This means that, if we are relying on your consent as the legal basis for using your personal data, you are free to withdraw that consent at any time. h) The right to data portability. This means that, if you have provided personal data to us directly, we are using it with your consent or for the performance of a contract, and that data is processed using automated means, you can ask us for a copy of that personal data to re-use with another service or business in many cases.

3 i) Rights relating to automated decision-making and profiling. We do not use your personal data in this way. For more information about our use of your personal data or exercising your rights as outlined above, please contact us using the details provided in Part 15. It is important that your personal data is kept accurate and up-to-date. If any of the personal data we hold about you changes, please keep us informed as long as we have that data. Further information about your rights can also be obtained from the Information Commissioner’s Office or your local Citizens Advice Bureau. If you have any cause for complaint about our use of your personal data, you have the right to lodge a complaint with the Information Commissioner’s Office. We would welcome the opportunity to resolve your concerns ourselves, however, so please contact us first, using the details in Part 15.

  1. What Data Do You Collect and How? Depending upon your use of Our Site, we may collect and hold some or all of the personal and non-personal data set out in the table below, using the methods also set out in the table. Please also see Part 14 for more information about our use of Cookies and similar technologies and our Cookie Policy http://dbdmedia.co.uk/privacy-policy/. The General Data Protection Regulation defines certain personal data as special categories of personal data (commonly referred to as ‘sensitive data’). These categories of personal data are date referring to racial or ethnic origin, political opinions, religious beliefs, trade union membership, physical or mental health, sexual life, criminal proceedings and offences. If you make an application to us, we may ask you for personal data which falls into one or more of these special categories of personal data. Where we need to use this information to process your application and we will ask for your explicit consent to that end. The sensitive data we may collect in your application process include: • Racial or ethnic origin for diversity reporting • Criminal proceedings and offences for background checking Data Collected How We Collect the Data • Personal data contained within your CV; • Identity verification data and proof of address you provide to us; • Proof of employment and academic history; • Personal data provided to us by your designated referees (please ensure they have consented to your use of this data; • Social media comments you have made; Through your explicit providing of this data in our application process linked to our HR System, operated by PeopleHR Ltd.

4 • Employment screening information including sensitive personal data collected by us or on our behalf; • Samples of work you provide us (please ensure any personal data contained has been collected legitimately according to the General Data Protection Regulation as Digital Business Development Limited is not responsible for its contents) Contact information including Email, name, phone number Registration box

  1. How Do You Use My Personal Data? Under the Data Protection Legislation, we must always have a lawful basis for using personal data. The following table describes how we may use your personal data, and our lawful bases for doing so: What We Do What Data We Use Our Lawful Basis Registering you on Our Site. Email, name, phone number Consent Communicating with you. Email, name, phone number Consent. Supplying you with information by email or post that you have opted-in-to (you may opt-out at any time by email) Email, name, phone number Consent Managing your application . We use the personal data you provide us to evaluate your application and to contact you regarding your application. Except for sensitive information which we will process only with your explicit consent, we process your personal data in accordance with this privacy policy as it is in our legitimate interests to ensure our appropriate checks are undertaken in connection you provide to us as part of the recruitment process and to ensure we can communicate with you through the process. With your permission and/or where permitted by law, we may also use your personal data for marketing purposes, which may include contacting you by email and/or telephone and/or text message and/or post with information, news, and offers on our products and services. You will not be sent any unlawful marketing or spam. We will always work to fully protect your rights and comply with our obligations under the Data

5 Protection Legislation and the Privacy and Electronic Communications (EC Directive) Regulations 2003, and you will always have the opportunity to opt-out. We will always obtain your express opt-in consent before sharing your personal data with third parties for marketing purposes and you will be able to opt-out at any time. Third Parties whose content appears on Our Site may use third-party Cookies, as detailed below in Part 14. Please refer to Part 14 for more information on controlling cookies. Please note that we do not control the activities of such third parties, nor the data that they collect and use themselves, and we advise you to check the privacy policies of any such third parties. We use the following automated systems for carrying out certain kinds of decisionmaking and profiling. If at any point you wish to query any action that we take on the basis of this or wish to request ‘human intervention’ (i.e. have someone review the action themselves, rather than relying only on the automated method), the Data Protection Legislation gives you the right to do so. Please contact us to find out more using the details in Part 15. When you apply for a position Digital Business Development Limited may use an automated process as part of our decision making. However, our decision on whether to recruit a candidate will never be made solely as a result of this automated processing. We will only use your personal data for the purpose(s) for which it was originally collected unless we reasonably believe that another purpose is compatible with that or those original purpose(s) and need to use your personal data for that purpose. If we do use your personal data in this way and you wish us to explain how the new purpose is compatible with the original, please contact us using the details in Part 15. If we need to use your personal data for a purpose that is unrelated to, or incompatible with, the purpose(s) for which it was originally collected, we will inform you and explain the legal basis which allows us to do so. In some circumstances, where permitted or required by law, we may process your personal data without your knowledge or consent. This will only be done within the bounds of the Data Protection Legislation and your legal rights.

  1. How Long Will You Keep My Personal Data? We will not keep your personal data for any longer than is necessary in light of the reason(s) for which it was first collected. Your personal data will therefore be kept for the following periods (or, where there is no fixed period, the following factors will be used to determine how long it is kept): Type of Data How Long We Keep It • Personal data contained within your CV; • Identity verification data and proof of address you provide to us; • Proof of employment and academic history; • Personal data provided to us by your designated referees (please ensure Following the conclusion of the recruitment process, we retain your personal data in compliance with our retention and deletion policies. If your application was and is unlikely to remain unsuccessful we will delete your data automatically after 90 days. If your application was unsuccessful, and we believe that you may be suitable for future opportunities we will retain your data for 24 months from the date on which 6 they have consented to your use of this data; • Social media comments you have made; • Employment screening information including sensitive personal data collected by us or on our behalf; • Samples of work you provide us (please ensure any personal data contained has been collected legitimately according to the General Data Protection Regulation as Digital Business Development Limited is not responsible for its contents) you are notified that your application has been unsuccessful unless you object to our continued processing of your personal data using the procedure outlined below. We will delete any sensitive data (as described above) provided to us by you automatically after 30 days. . Contact information including Name, Email, Phone number, 2 years .

  2. How and Where Do You Store or Transfer My Personal Data? We share your data within the group of companies of which we are a part. Where this involves the transfer of personal data outside the EEA, our group ensures that personal data is protected by requiring all companies within the group to follow the same rules with respect to personal data usage. These are known as “binding corporate rules”. More information on binding corporate rules is available from the European Commission. AND We use specific contracts with external third parties that are approved by the European Commission for the transfer of personal data to third countries. These contracts require the same levels of personal data protection that would apply under the Data Protection Legislation. More information is available from the European Commission. Please contact us using the details below in Part 15 for further information about the particular data protection mechanisms used by us when transferring your personal data to a third country. The security of your personal data is essential to us, and to protect your data, we take a number of important measures, including the following: • limiting access to your personal data to those employees, agents, contractors, and other third parties with a legitimate need to know and ensuring that they are subject to duties of confidentiality; • procedures for dealing with data breaches (the accidental or unlawful destruction, loss, alteration, unauthorised disclosure of, or access to, your personal data) including notifying you and/or the Information Commissioner’s Office where we are legally required to do so; 7

  3. Do You Share My Personal Data? We may disclose your personal data to legal entities within our corporate group, to authorised third parties and where legally compelling grounds for disclosure exist. We protect your information using measures that reduce the risks of loss, misuse, unauthorised access, disclosure and alteration. We minimise the amount of personal data we disclose to what is directly relevant and necessary to accomplish the specified purpose. In so doing we may disclose your personal data to authorised third party service providers who help us to provide our services. Categories of service provider used by us in connection with your employment application include service providers who conduct background checks on our behalf and service providers who connect recruitment process administration on our behalf. We may also disclose your personal data to law enforcement agencies, in the context of legal proceedings, and as otherwise authorized by law given legally compelling grounds. If we were to be acquired by another company, we may share information with them and we will require that company to agree follow this Privacy Policy with respect to your personal data.
  4. How Can I Control My Personal Data? 11.1 In addition to your rights under the Data Protection Legislation, set out in Part 5, when you submit personal data via Our Site, you may be given options to restrict our use of your personal data. In particular, we aim to give you strong controls on our use of your data for direct marketing purposes (including the ability to opt-out of receiving emails from us which you may do by unsubscribing using the links provided in our emails or, at the point of providing your details and by managing your Account). 11.2 You may also wish to sign up to one or more of the preference services operating in the UK: The Telephone Preference Service (“the TPS”), the Corporate Telephone Preference Service (“the CTPS”), and the Mailing Preference Service (“the MPS”). These may help to prevent you receiving unsolicited marketing. Please note, however, that these services will not prevent you from receiving marketing communications that you have consented to receiving.

  5. Can I Withhold Information? You may access certain areas of Our Site without providing any personal data at all. However, to use all features and functions available on Our Site you may be required to submit or allow for the collection of certain data. You may restrict our use of Cookies. For more information, see Part 14 and our Cookie Policy http://dbdmedia.co.uk/privacy-policy/.

  6. How Can I Access My Personal Data? If you want to know what personal data we have about you, you can ask us for details 8 of that personal data and for a copy of it (where any such personal data is held). This is known as a “subject access request”. All subject access requests should be made in writing and sent to the email or postal addresses shown in Part 15. To make this as easy as possible for you, a Subject Access Request Form is available for you to use. You do not have to use this form, but it is the easiest way to tell us everything we need to know to respond to your request as quickly as possible. There is not normally any charge for a subject access request. If your request is ‘manifestly unfounded or excessive’ (for example, if you make repetitive requests) a fee may be charged to cover our administrative costs in responding. We will respond to your subject access request within 30 days and, in any case, not more than one month of receiving it. Normally, we aim to provide a complete response, including a copy of your personal data within that time. In some cases, however, particularly if your request is more complex, more time may be required up to a maximum of three months from the date we receive your request. You will be kept fully informed of our progress.

  7. How Do You Use Cookies?
    Our Site may place and access certain first-party Cookies on your computer or device.
    First-party Cookies are those placed directly by us and are used only by us. We use
    Cookies to facilitate and improve your experience of Our Site and to provide and
    improve our products and services. We have carefully chosen these Cookies and have
    taken steps to ensure that your privacy and personal data is protected and respected
    at all times.
    By using Our Site, you may also receive certain third-party Cookies on your computer
    or device. Third-party Cookies are those placed by websites, services, and/or parties
    other than us. Third-party Cookies are used on Our Site to help us and our advertisers
    see which advertisements you click on and interact with. Each individual advertiser
    uses its own tracking cookies and the data taken is not confidential or interchangeable..
    For more details, please refer to the table below. These Cookies are not integral to the
    functioning of Our Site and your use and experience of Our Site will not be impaired by
    refusing consent to them.
    All Cookies used by and on Our Site are used in accordance with current Cookie Law.
    Before Cookies are placed on your computer or device, you will be shown a pop up
    requesting your consent to set those Cookies. By giving your consent to the placing of
    Cookies you are enabling us to provide the best possible experience and service to
    you. You may, if you wish, deny consent to the placing of Cookies; however certain
    features of Our Site may not function fully or as intended. You will be given the
    opportunity to allow only first-party Cookies and block third-party Cookies.
    Certain features of Our Site depend on Cookies to function. Cookie Law deems these
    Cookies to be “strictly necessary”. These Cookies are shown in the table below. Your
    consent will not be sought to place these Cookies, but it is still important that you are
    aware of them. You may still block these Cookies by changing your internet browser’s
    settings as detailed below, but please be aware that Our Site may not work properly if
    you do so. We have taken great care to ensure that your privacy is not at risk by allowing
    them.
    The following first-party Cookies may be placed on your computer or device:
    9
    Name of Cookie Purpose Strictly Necessary
    _ga, _gid, _gat These cookies are dropped by our partner Google Analytics for traffic and user behaviour analytics. no Our Site uses analytics services provided by Google Analytics and Hotjar. Website analytics refers to a set of tools used to collect and analyse anonymous usage information, enabling us to better understand how Our Site is used. This, in turn, enables us to improve Our Site and the products and services offered through it. The analytics service(s) used by Our Site use(s) Cookies to gather the required information. You do not have to allow us to use these Cookies, however whilst our use of them does not pose any risk to your privacy or your safe use of Our Site, it does enable us to continually improve Our Site, making it a better and more useful experience for you. In addition to the controls that we provide, you can choose to enable or disable Cookies in your internet browser. Most internet browsers also enable you to choose whether you wish to disable all Cookies or only third-party Cookies. By default, most internet browsers accept Cookies, but this can be changed. For further details, please consult the help menu in your internet browser or the documentation that came with your device. You can choose to delete Cookies on your computer or device at any time, however you may lose any information that enables you to access Our Site more quickly and efficiently including, but not limited to, login and personalisation settings. It is recommended that you keep your internet browser and operating system up-todate and that you consult the help and guidance provided by the developer of your internet browser and manufacturer of your computer or device if you are unsure about adjusting your privacy settings.
  8. How Do I Contact You? To contact us about anything to do with your personal data and data protection, including to make a subject access request, please use the following details [(for the attention of Nil Bhatt): Email address: nil@verbbrands.com. Telephone number: +44 (0) 20 8977 2994. Postal Address: 78 Chamber Street, London, United Kingdom, Post code: E1 8BL.
  9. Changes to this Privacy Policy We may change this Privacy Notice from time to time. This may be necessary, for example, if the law changes, or if we change our business in a way that affects personal data protection. Any changes will be immediately posted on Our Site and you will be deemed to have accepted the terms of the Privacy Policy on your first use of Our Site following the 10 alterations. We recommend that you check this page regularly to keep up-to-date. This Privacy Policy was last updated on 05/03/2019.