Welcome to Kompetenza’s privacy policy.

kompetenza.com respects your privacy and is committed to protecting your personal data. This privacy policy will inform you as to how we look after your personal data when you visit our website (regardless of where you visit it from) or when you chose us for your service requirements.

Additionally, this privacy policy tells you about your privacy rights and how the law protects you.

 

IMPORTANT INFORMATION AND WHO WE ARE

 

PURPOSE OF THIS PRIVACY POLICY

This privacy policy aims to give you information on how kompetenza.com collects and processes your personal data through your use of our website and through the use of the services we may supply to you or your interaction with us when you seek to upload information for career consideration purposes. It is important that you read this privacy so that you are fully aware of how and why we are using your data. This privacy policy supplements other notices, privacy policies and data protection clauses and is not intended to override them.

CONTACT DETAILS

If you have any questions about this privacy policy or our privacy practices, please contact us by following this link: info@kompetenza.com We aim to respond to you within 5 working days.
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 (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.

CHANGES TO THE PRIVACY POLICY AND YOUR DUTY TO INFORM US OF CHANGES

We keep our privacy policy under regular review. This version was last updated on 01/04/2021. It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during your relationship with us.

THE DATA WE COLLECT ABOUT YOU

The data which we collect about you varies based on the relationship we share.

Visitors of our website: On its most basic level, a mere visitor to our website submits to allow us access to certain forms of technical data as detailed below. However, certain features within our website allow you to contact us and submit CV/Resumes for our consideration, should this be the case, then greater levels of information may be gathered, including, identity data, contact data, work history and educational history.

Clients and Service Users: Clients and other users of our services will provide us with far greater levels personal data and information, this will generally include identity data, contact data, financial data, transaction data, usage data and technical data. 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).
We may collect, use, store and transfer different kinds of personal data about you which we have grouped together as follows:

- Identity Data includes first name, maiden name, last name, username or similar identifier, marital status, title, date of birth and gender.

- Contact Data includes billing address, email address and telephone numbers.

- Financial Data includes bank account and payment card details.

- Transaction Data includes details about payments to and from you and other details of products and services you have purchased from us.

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

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

We do not collect any Special Categories of Personal Data about you (this includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health, and genetic and biometric data).

HOW IS YOUR PERSONAL DATA COLLECTED?

We use different methods to collect data from and about you including through:
Direct interactions. You may give us your Identity, Contact and Financial Data by filling in forms or by corresponding with us by post, phone, email or otherwise. This includes personal data you provide when you:

- subscribe to our service;

- request marketing to be sent to you;

- Voluntary upload of your CV/Resume;

Automated technologies or interactions. As you interact with our website, we will automatically collect Technical Data about your equipment, browsing actions and patterns. We collect this personal data by using cookies and other similar technologies.

HOW WE USE YOUR PERSONAL DATA

We use Personal Information to do some or all of the following:

- Communicate with you as part of our business;

- Send you information regarding changes to our policies, other terms and conditions;

- Provide improved quality, training and security and manage other commercial risks;

- Carry out market research and analysis, including satisfaction surveys;

- Provide marketing information to you (including information about other products and services offered by selected third-party partners) in accordance with preferences you have expressed;

- Personalise your experience by presenting tailored information, advertisements and opportunities to you;

- Facilitate social media sharing functionality;

- Resolve complaints, and handle requests for data access or correction;

- Comply with applicable laws and regulatory obligations (including laws outside your country of residence), such as those relating to anti-money laundering and anti-terrorism; comply with legal process; and respond to requests from public and governmental authorities (including those outside your country of residence);

- Establish and defend legal rights; protect our operations or those of any of our group companies or insurance business partners, our rights, privacy, safety or property, and/or that of our group companies, you or others; and pursue available remedies or limit our damages.

PURPOSES FOR WHICH WE WILL USE YOUR PERSONAL DATA

We have set out below, in a table format, a description of all the ways we plan to use your personal data, and which of the legal bases we rely on to do so. We have also identified what our legitimate interests are where appropriate.
Note that we may process your personal data for more than one lawful ground depending on the specific purpose for which we are using your data. Please contact us if you need details about the specific legal ground we are relying on to process your personal data where more than one ground has been set out in the table below.

Purpose/Activity	Type of data	Lawful basis for processing including basis of legitimate interest
Respond to Queries posed via our ‘Contact Us’ website feature	(a) Identity (b) Contact	(a) Necessary for our legitimate interests (to respond to queries about our business/impart greater levels of information to you)
To process and deliver our services to you: (a) Manage payments, fees and charges	(a) Identity (b) Contact (c) Financial (d) Transaction (e) Marketing and Communications	(a) Performance of a contract with you (b) Necessary for our legitimate interests
To manage our relationship with you which will include: (a) Notifying you about changes to our terms or privacy policy (b) Asking you to leave a review or take a survey	(a) Identity (b) Contact (c) Profile (d) Marketing and Communications	(a) Performance of a contract with you (b) Necessary to comply with a legal obligation (c) Necessary for our legitimate interests (to keep our records updated and to study how customers use our products/services)
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 reorganisation or group restructuring exercise) (b) Necessary to comply with a legal obligation
To deliver relevant website content and advertisements to you and measure or understand the effectiveness of the advertising we serve to you	(a) Identity (b) Contact (c) Profile (d) Usage (e) Marketing and Communications (f) 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	(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 and to inform our marketing strategy)
To make suggestions and recommendations to services, job roles or candidates that may be of interest to you	(a) Identity (b) Contact (c) Technical (d) Usage (e) Profile (f) Marketing and Communications	Necessary for our legitimate interests (to develop our products/services and grow our business)

MARKETING

We strive to provide you with choices regarding certain personal data uses, particularly around marketing and advertising.

PROMOTIONAL OFFERS FROM US

We may use your Identity, Contact, Technical, Usage and Profile Data to form a view on what we think you may want or need, or what may be of interest to you. This is how we decide which products, services and offers may be relevant for you (we call this marketing).
You will receive marketing communications from us if you have requested information from us or purchased services from us and you have not opted out of receiving that marketing.

THIRD-PARTY MARKETING

We will get your express opt-in consent before we share your personal data with any third party for marketing purposes.

OPTING OUT

You can ask us or third parties to stop sending you marketing messages at any time by contacting us or them at any time.
Where you opt out of receiving these marketing messages, this will not apply to personal data provided to us as a result of a product/service purchase, warranty registration, product/service experience or other transactions.

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.

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.

DISCLOSURES OF YOUR PERSONAL DATA

We may share your personal data with third parties for the purpose of fulfilling the role required of us.
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.

INTERNATIONAL TRANSFERS

Due to the nature of our global business and the technologies required, your Personal Information may be transferred globally, in countries where there may be a lower legal level of data protection.
Whenever we transfer your personal data, we ensure a similar degree of protection is afforded to it (in line with the expectations of the General Data Protection Regulations (GDPR)) by ensuring, we transfer the minimum amount of data necessary, anonymise it where possible and enter legal contracts to aim to ensure these third parties handle your Personal Information in accordance with this Privacy Policy and the European levels of data protection.
Please contact us if you want further information on the specific mechanism used by us when transferring your personal data.

DATA SECURITY

We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised 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.

DATA RETENTION

HOW LONG WILL YOU USE MY PERSONAL DATA FOR?

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

YOUR LEGAL RIGHTS

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

- 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.

- 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 could 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 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.

1. 1. POLICY STATEMENT
2. 1.1. It is our policy to conduct all of our business in an honest and ethical manner. We take a zero-tolerance approach to bribery and corruption and are committed to acting professionally, fairly and with integrity in all our business dealings and relationships wherever we operate and implementing and enforcing effective systems to counter bribery and corruption.
3. 1.2. We will uphold all laws relevant to countering bribery and corruption in all the jurisdictions in which we operate.
4. 2. ABOUT THIS POLICY
5. 2.1. The purpose of this policy is to:
6. a) set out our responsibilities, and of those working for us, in observing and upholding our position on bribery and corruption; and
7. b) provide information and guidance to those working for us on how to recognise and deal with bribery and corruption issues.
8. 2.2. It is a criminal offence to offer, promise, give, request, or accept a bribe. Individuals found guilty can be punished by up to ten years’ imprisonment and/or a fine. As an employer if we fail to prevent bribery we can face an unlimited fine, exclusion from tendering for public contracts, and damage to our reputation. We therefore take our legal responsibilities very seriously.
9. 2.3. In this policy, third party means any individual or organisation you come into contact with during the course of your work for us, and includes actual and potential clients, customers, suppliers, distributors, business contacts, agents, advisers, and government and public bodies, including their advisors, representatives and officials, politicians and political parties.
10. 2.4. This policy does not form part of any employee’s contract of employment and we may amend it at any time.
11. 3. WHO MUST COMPLY WITH THIS POLICY?
12. 3.1. This policy applies to all persons working for us [or any Group Company] or on our behalf in any capacity, including employees at all levels, directors, officers, agency workers, seconded workers, volunteers, interns, agents, contractors, external consultants, third-party representatives and business partners, sponsors, or any other person associated with us, wherever located.
13. 4. WHO IS RESPONSIBLE FOR THE POLICY?
14. 4.1. The board of directors has overall responsibility for ensuring this policy complies with our legal and ethical obligations, and that all those under our control comply with it.
15. 4.2. All members of management have day-to-day responsibility for implementing this policy, monitoring its use and effectiveness, dealing with any queries about it, and auditing internal control systems and procedures to ensure they are effective in countering bribery and corruption.
16. 4.3. A member of senior-management will filter down throughout the management teams guidance on this policy. Points of Contact are detailed within Annex A of this Code of Conduct.
17. 4.4. Management at all levels are responsible for ensuring those reporting to them understand and comply with this policy and are given adequate and regular training on it.
18. 4.5. You are invited to comment on this policy and suggest ways in which it might be improved. Comments, suggestions and queries should be addressed to a manager.
19. 5. WHAT IS BRIBERY AND CORRUPTION?
20. 5.1. BRIBERY is offering, promising, giving or accepting any financial or other advantage, to induce the recipient or any other person to act improperly in the performance of their functions, or to reward them for acting improperly, or where the recipient would act improperly by accepting the advantage.
21. 5.2. An advantage includes money, gifts, loans, fees, hospitality, services, discounts, the award of a contract or anything else of value.
22. 5.3. A person acts improperly where they act illegally, unethically, or contrary to an expectation of good faith or impartiality, or where they abuse a position of trust. The improper acts may be in relation to any business or professional activities, public functions, acts during employment, or other activities by or on behalf of any organisation of any kind.
23. 5.4. CORRUPTION is the abuse of entrusted power or position for private gain.

1. 6. WHAT YOU MUST NOT DO
2. 6.1. It is not acceptable for you (or someone on your behalf) to:
3. a) give, promise to give, or offer, a payment, gift or hospitality with the expectation or hope that a business advantage will be received, or to reward a business advantage already given;
4. b) give or accept a gift or hospitality during any commercial negotiations or tender process, if this could be perceived as intended or likely to influence the outcome;
5. c) accept a payment, gift or hospitality from a third party that you know, or suspect is offered with the expectation that it we will provide a business advantage for them or anyone else in return;
6. d) accept hospitality from a third party that is unduly lavish or extravagant under the circumstances.
7. e) offer or accept a gift to or from government officials or representatives, or politicians or political parties, without the prior approval of your manager;
8. f) threaten or retaliate against another individual who has refused to commit a bribery offence or who has raised concerns under this policy;
9. g) engage in any other activity that might lead to a breach of this policy.
10. 7. FACILITATION PAYMENTS AND KICKBACKS
11. 7.1. We do not make, and will not accept, facilitation payments or “kickbacks” of any kind.
12. 7.2. Facilitation payments, also known as “back-handers” or “grease payments”, are typically small, unofficial payments made to secure or expedite a routine or necessary action (for example by a government official). They are not common in the UK but are common in some other jurisdictions in which we operate.
13. 7.3. Kickbacks are typically payments made in return for a business favour or advantage.
14. 7.4. You must avoid any activity that might lead to a facilitation payment or kickback being made or accepted by us or on our behalf, or that might suggest that such a payment will be made or accepted. If you are asked to make a payment on our behalf, you should always be mindful of what the payment is for and whether the amount requested is proportionate to the goods or services provided. You should always ask for a receipt which details the reason for the payment. If you have any suspicions, concerns or queries regarding a payment, you should raise these with a manager.
15. 8. GIFTS, HOSPITALITY AND EXPENSES
16. 8.1. This policy allows reasonable and appropriate hospitality or entertainment given to or received from third parties, for the purposes of:
17. a) establishing or maintaining good business relationships;
18. b) improving or maintaining our image or reputation; or
19. c) marketing or presenting our products and/or services effectively.
20. 8.2. You are prohibited from accepting a gift from or giving a gift to a third party
21. 8.3. Promotional gifts of low value such as branded stationery to or from existing customers, suppliers and business partners will usually be acceptable.
22. 8.4. Reimbursing a third party’s expenses or accepting an offer to reimburse our expenses (for example, the costs of attending a business meeting) would not usually amount to bribery. However, a payment in excess of genuine and reasonable business expenses (such as the cost of an extended hotel stay) is not acceptable.
23. 8.5. We appreciate that practice varies between countries and regions and what may be normal and acceptable in one region may not be in another. The test to be applied is whether in all the circumstances the gift, hospitality or payment is reasonable and justifiable. The intention behind it should always be considered.
24. 9. DONATIONS
25. 9.1. We do not make contributions to political parties.
26. 9.2. We only make charitable donations that are legal and ethical under local laws and practices. No donation must be offered or made without the prior approval of the head of compliance. Any donation that is made will be done so in a transparent and open fashion and open to scrutiny and discussion between the concerned parties.
27. 10. RECORD-KEEPING
28. 10.1. We must keep financial records and have appropriate internal controls in place which will evidence the business reason for making payments to third parties.
29. 10.2. You must declare and keep a written record of all hospitality or gifts given or received, which will be subject to managerial review.
30. 10.3. You must submit all expenses claims relating to hospitality, gifts or payments to third parties in accordance with our expenses policy and record the reason for expenditure.
31. 10.4. All accounts, invoices, and other records relating to dealings with third parties including suppliers and customers should be prepared with strict accuracy and completeness. Accounts must not be kept “off-book” to facilitate or conceal improper payments.
32. 11. YOUR RESPONSIBILITIES
33. 11.1. You must ensure that you read, understand and comply with this policy.
34. 11.2. The prevention, detection and reporting of bribery and other forms of corruption are the responsibility of all those working for us or under our control. You are required to avoid any activity that might lead to, or suggest, a breach of this policy.
35. 11.3. You must notify your manager as soon as possible if you believe or suspect that a conflict with this policy has occurred or may occur in the future. For example, if a client or potential client offers you something to gain a business advantage with us or indicates to you that a gift or payment is required to secure their business. Further “red flags” that may indicate bribery or corruption are set out in Paragraph 16.
36. 12. HOW TO RAISE A CONCERN
37. 12.1. You are encouraged to raise concerns about any issue or suspicion of bribery or corruption at the earliest possible stage.
38. 12.2. If you are offered a bribe, or are asked to make one, or if you believe or suspect that any bribery, corruption or other breach of this policy has occurred or may occur, you must notify your manager as soon as possible.
39. 12.3. If you are unsure about whether a particular act constitutes bribery or corruption, raise it with your manager.
40. 13. PROTECTION
41. 13.1. Individuals who refuse to accept or offer a bribe, or who raise concerns or report another’s wrongdoing, are sometimes worried about possible repercussions. We aim to encourage openness and will support anyone who raises genuine concerns in good faith under this policy, even if they turn out to be mistaken.
42. 13.2. We are committed to ensuring no one suffers any detrimental treatment as a result of refusing to take part in bribery or corruption, or because of reporting in good faith their suspicion that an actual or potential bribery or other corruption offence has taken place or may take place in the future. Detrimental treatment includes dismissal, disciplinary action, threats or other unfavorable treatment connected with raising a concern. If you believe that you have suffered any such treatment, you should inform management immediately. If the matter is not remedied, and you are an employee, you should raise it formally with a senior member of management.
43. 14. TRAINING AND COMMUNICATION
44. 14.1. Training on this policy forms part of the induction process for all individuals who work for us, and regular training will be provided as necessary.
45. 14.2. Our zero-tolerance approach to bribery and corruption must be communicated to all suppliers, contractors and business partners at the outset of our business relationship with them and as appropriate thereafter.
46. 15. BREACHES OF THIS POLICY
47. 15.1. Any employee who breaches this policy will face disciplinary action, which could result in dismissal for misconduct or gross misconduct.
48. 15.2. We may terminate our relationships with other individuals and organisations working on our behalf if they breach this policy.
49. 16. POTENTIAL RISK SCENARIOS: “RED FLAGS”
50. 16.1. The following is a list of possible red flags that may arise during the course of you working for us and which may raise concerns under various anti-bribery and anti-corruption laws. The list is not intended to be exhaustive and is for illustrative purposes only.
51. 16.2. If you encounter any of these red flags while working for us, you must report them promptly to your manager:
52. a) you become aware that a third party engages in, or has been accused of engaging in improper business practices;
53. b) you learn that a third party has a reputation for paying bribes, or requiring that bribes are paid to them, or has a reputation for having a “special relationship” with foreign government officials;
54. c) a third party insists on receiving a commission or fee payment before committing to sign up to a contract with us, or carrying out a government function or process for us;
55. d) a third-party request payment in cash and/or refuses to sign a formal commission or fee agreement, or to provide an invoice or receipt for a payment made;
56. e) a third-party request that payment is made to a country or geographic location different from where the third party resides or conducts business;
57. f) a third party requests an unexpected additional fee or commission to “facilitate” a service;
58. g) a third party demands lavish entertainment or gifts before commencing or continuing contractual negotiations or provision of services;
59. h) a third-party request that a payment is made to “overlook” potential legal violations;
60. i) a third-party request that you provide employment or some other advantage to a friend or relative;
61. j) you receive an invoice from a third party that appears to be non-standard or customised;
62. k) a third party insists on the use of side letters or refuses to put terms agreed in writing;
63. l) you notice that we have been invoiced for a commission or fee payment that appears large given the service stated to have been provided;
64. m) a third party requests or requires the use of an agent, intermediary, consultant, distributor or supplier that is not typically used by or known to us;
65. n) you are offered an unusually generous gift or offered lavish hospitality by a third party;