Privacy Policy
Introduction
EdgeWay Commodities Ltd (“EdgeWay”, “we”, “our” or “us”) takes the protection of personal data seriously.
This Privacy Policy explains how we collect, use, store and share personal data in connection with our website and our recruitment and executive search services.
We process personal data in accordance with applicable data protection legislation, including the UK General Data Protection Regulation (UK GDPR) and the Data Protection Act 2018, as applicable.
Who We Are
EdgeWay Commodities Ltd
Company Number: 17146059
Registered in England and Wales
Registered Office:
4th Floor Charles House
108–110 Finchley Road
London
NW3 5JJ
United Kingdom
For the purposes of applicable data protection law, EdgeWay will generally act as a data controller, meaning that we determine the purposes and means of processing personal data.
Where we process personal data on behalf of a client under the client's instructions, the relevant contractual and data protection arrangements will determine the respective responsibilities of EdgeWay and that client.
What Information We Collect
Depending on our relationship with you, we may collect and process:
- name and contact details, including email address, telephone number and address;
- CVs, employment history and professional experience;
- education, qualifications and professional certifications;
- interview notes and assessment information;
- professional profiles and information available through professional networking platforms and other publicly available sources;
- current and previous employers and roles;
- compensation information, including salary, benefits and salary expectations, where relevant to recruitment services;
- information provided by referees;
- information relating to recruitment processes and communications;
- client and business contact information;
- information contained in correspondence or enquiries submitted to us; and
- information necessary to manage and maintain our business relationships.
We seek to collect only information that is relevant and reasonably necessary for the purposes described in this Privacy Policy.
How We Collect Your Data
We may collect personal data:
- directly from you, including when you contact us, submit your CV, apply for a role or communicate with us;
- from clients or other business contacts;
- from referees or other professional contacts, where appropriate and lawful;
- from publicly available sources, including company websites and professional networking platforms such as LinkedIn;
- through our website and website forms;
- through email, telephone and SMS communications; and
- through technology and service providers that support our recruitment and business operations.
Where we obtain personal data from another source rather than directly from you, we will provide the privacy information required by applicable law, subject to any applicable exceptions.
How We Use Your Data
We may use personal data to:
- identify and contact potential candidates;
- identify suitable candidates for specific recruitment assignments;
- assess candidates' skills, experience and suitability for opportunities;
- communicate with candidates, clients and other professional contacts;
- arrange interviews and coordinate recruitment processes;
- introduce candidates to clients where appropriate;
- maintain our recruitment database and business records;
- manage client and candidate relationships;
- conduct market mapping, talent research and industry analysis;
- analyse recruitment trends, compensation information and skills demand;
- provide aggregated or anonymised market insights;
- administer and improve our website and services;
- protect the security and integrity of our systems;
- comply with legal and regulatory obligations; and
- establish, exercise or defend legal claims.
Where possible, market analysis and insights will be aggregated or anonymised so that individuals are not identifiable.
.
Legal Basis for Processing
We rely on one or more of the following lawful bases, depending on the circumstances:
Legitimate Interests
- We may process personal data where this is necessary for our legitimate interests, provided those interests are not overridden by your interests, rights or freedoms.
- Our legitimate interests may include:
- operating and developing our recruitment and executive search business;
- identifying and communicating with potential candidates;
- matching candidates with relevant opportunities;
- maintaining professional relationships with clients and candidates;
- conducting market mapping and talent research;
- maintaining accurate business and recruitment records; and
- improving our services.
Contract
We may process personal data where necessary to enter into or perform a contract with you, or to take steps at your request before entering into a contract.
Consent
We may rely on your consent where required or where we choose to seek consent for a particular processing activity.
Where processing is based on consent, you may withdraw that consent at any time. Withdrawal does not affect the lawfulness of processing carried out before withdrawal.
Legal Obligation
We may process personal data where necessary to comply with a legal or regulatory obligation.
Sharing Your Data
Depending on the circumstances, we may share relevant personal data with:
- clients and prospective clients for recruitment and executive search purposes;
- candidates and professional contacts where necessary to facilitate recruitment processes;
- referees or other professional contacts where appropriate;
- technology, CRM, communications, hosting and other service providers supporting our business;
- professional advisers, including accountants, lawyers and insurers;
- regulators, government bodies or law enforcement authorities where required or permitted by law; and
- other parties where necessary to establish, exercise or defend legal claims.
We do not sell personal data to third parties.
We require relevant service providers to process personal data in accordance with applicable data protection requirements and our contractual arrangements with them.
International Transfers
Because EdgeWay works internationally, personal data may be processed or transferred outside the United Kingdom.
Where a transfer constitutes a restricted transfer under applicable UK data protection law, we will ensure that an appropriate transfer mechanism or safeguard is in place, as required by law.
This may include an adequacy regulation or appropriate contractual safeguards such as the applicable UK International Data Transfer Agreement or Addendum.
Recruitment Database and Retention
We maintain a recruitment database and may retain candidate and client information to support current and future recruitment activities.
We retain personal data only for as long as reasonably necessary for the purposes for which it was collected, taking into account the nature of the information, our legitimate business requirements and applicable legal or regulatory obligations.
As a general policy, we intend to review candidate information periodically and may retain relevant candidate information for up to three years from our last meaningful interaction, unless:
- a shorter retention period is appropriate;
- you request deletion and there is no overriding lawful reason to retain the information;
- you have consented to a longer retention period where consent is the relevant lawful basis;
- the information remains necessary for an ongoing recruitment or business relationship; or
- we are required or permitted by law to retain it for longer.
We may contact candidates periodically to ensure that their information remains accurate and relevant.
Where personal data is no longer required, we will take reasonable steps to securely delete, anonymise or otherwise dispose of it.
SMS Communications
Where you provide your telephone number, we may use it to contact you by telephone or SMS in connection with recruitment opportunities, interview coordination, business enquiries or related services.
Where applicable law requires consent for a particular type of SMS or marketing communication, we will obtain the appropriate consent before sending those communications.
Message frequency may vary depending on your interactions with us and recruitment activity. Message and data rates may apply.
Where SMS communications are sent on a consent basis, you may opt out by replying STOP. For assistance, reply HELP or contact us directly.
We do not sell mobile telephone numbers or share mobile/cell phone information with third parties or affiliates for their own marketing or promotional purposes
Cookies and Similar Technologies
Our website may use cookies and similar technologies to operate the website, remember preferences, understand website usage and, where applicable, measure or improve our services.
Where consent is required for non-essential cookies or similar technologies, we will seek that consent before using them.
Your Data Protections Rights
Depending on the circumstances and subject to applicable legal exemptions, you may have the right to:
- request access to personal data we hold about you;
- request correction of inaccurate or incomplete personal data;
- request deletion of your personal data;
- request restriction of processing;
- object to processing based on legitimate interests;
- object to certain direct marketing;
- request portability of certain personal data; and
- withdraw consent where we rely on consent as our lawful basis.
You also have the right to complain about how we process your personal data.
We aim to respond to valid data protection requests within one month, subject to any applicable legal extensions or exemptions.
Data Security
We take appropriate technical and organisational measures to protect personal data against unauthorised access, accidental loss, destruction, alteration or disclosure.
However, no electronic transmission or storage system can be guaranteed to be completely secure.
Complaints
If you are not satisfied with how we handle your data, you have the right to complain to the Information Commissioner's Office.
Contact Us
If you have any questions about this Privacy Policy or how we handle your data, please contact us at:
Email: info@edgewaycommodities.com
Website: edgewaycommodities.com
Business Name: EdgeWay Commodities Ltd
Business address: 15 Canfield Place, London, NW6 3BT, United Kingdom
Company Number: 17146059
Updates to This Policy
We may update this Privacy Policy from time to time to reflect changes in our business, services, technology or applicable legal requirements.
The latest version will be published on this website and will include the applicable effective date.