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WEBSITE PRIVACY NOTICE

1. Introduction

ApotheCom is part of the Huntsworth plc group of companies (the Huntsworth Group). This Privacy Notice explains how we use any personal data (also referred to as ‘information’) we collect about you. It describes:

what information we collect about you;
how we use your information;
who we share your information with;
your rights regarding our use of your information;
how long we keep your information; and
how to contact us.

2. What information do we collect about you?

We collect information about you:

when you register with us to make a career enquiry;
if you make an enquiry about our services;
when you voluntarily complete customer surveys, provide feedback and participate in competitions or agree to be on our contact lists in relation to our client communications;
when we use cookies to collect information about your use of our website. For more information about how we use cookies please see our cookie policy at http://apothecom.com/?privacy-notice and
when we use a third-party service (e.g. Google Analytics) to collect information about how visitors to our website use the site, including collecting information about what country you logged on from, which pages you visited and how long you were on our site.

3. How do we use your information?

We use your information to:

process your request for news items about our company and, if you agree, to email you about other services we think may be of interest to you;
if you make an employment enquiry we will pass your details to other relevant companies within the Huntsworth Group;
if you make an enquiry about our services we will pass your details to the relevant other companies within the Huntsworth Group to ensure that your enquiry is adequately dealt with;
email you about similar goods and services to those you’ve purchased from us which you may be interested in; and
enter and perform a contract with you or to perform any steps you require from us before entering into the contract. If you do not provide information required by us to enter into a contract with you, we will not be able to enter into that agreement with you or provide you the services you require.

We will rely on one of the following legal grounds (as appropriate) to process your personal data:

to enter and perform a contract with you or to perform any steps you require from us before entering into a contract;
to pursue our legitimate business interests in providing and marketing our products and services;
your specific consent to us using your information, which you can withdraw at any time;
to comply with our legal obligations and establish, exercise or defend our legal rights; and
those other purposes that you have agreed with us.

4. Who do we share your information with?

We share information with the following third parties:

data processors, who are our suppliers who provide us services;
if you become an employee or freelancer your information will be passed on to and stored with our processing partners in relation to payroll, healthcare and invoice payments. The use of this personal data is restricted to the extent necessary for the performance of the contract between us;
other Huntsworth Group companies listed in the appendix to Huntsworth plc’s latest Interim or Annual Report which can be found at http://www.huntsworth.com/investor-relations/;
persons connected with any sale, merger, acquisition, disposal, reorganisation or similar change of our business (or of the business of any company in the Huntsworth Group including any potential or actual purchaser of that business and that purchaser’s advisors);
local and foreign regulators, governments, law enforcement authorities, advisors, courts, tribunals and arbitrators; and
other third parties, with your consent.

Some of these third parties are based outside the European Economic Area (EEA) in, amongst others, the following countries: the United States of America, China, Hong Kong, Singapore, the United Arab Emirates, Qatar, Kenya and Russia.

If we do transfer your information from the EEA to a jurisdiction outside the EEA, we will take appropriate steps to protect that information which includes: (i) entering into an agreement with the third party which includes clauses that the EU Commission has determined offers adequate protection for your information, a template copy of which is available at https://ec.europa.eu/info/law/law-topic/data-protection/data-transfers-outside-eu/model-contracts-transfer-personal-data-third-countries_en; or (ii) otherwise ensuring that information would only be transferred to third parties in jurisdictions that the EU Commission has determined offers adequate protection for your personal information.

5. What are your rights in relation to our use of your information?

You have rights under data protection law in relation to our use of your personal data, including to:

request access to your information by submitting a request to compliance@huntsworth.com;
update or amend your information if it is inaccurate or incomplete;
object to certain uses of your personal data including direct marketing and processing based on legitimate interests and processing for purposes of scientific or historical research and statistics on grounds relating to your particular situation;
request the deletion of your information, or restrict its use, in certain circumstances (for example, subject to lawful exceptions applying, you can request that we erase your information where the information is no longer necessary for the purpose for which it was collected;
to withdraw any consents you have provided in respect of our use of your information;
to request a copy of the information you have provided to us, to use for your own purposes (often called your right to data portability); and
to lodge a complaint with the relevant data protection supervisory authority in your jurisdiction.

If you have subscribed to us or agreed to be on a contact list to receive information from us, you can ask to be removed at any time by using the unsubscribe link included in any e-communications or by emailing compliance@huntsworth.com.

If you have any questions about these rights, or you would like to exercise any of them, please contact us by submitting a request to compliance@huntsworth.com – additional details of how to get in touch are set out in section 7 below.

6. How long do we keep your information?

Personal data of employees and freelancers will be kept for no longer than is necessary, and that period of time will be determined with reference to applicable statutory limitation periods in your jurisdiction.

Our policy is to destroy employment applications 1 (one) year after their submission if they have not led to an offer of employment, unless during the submission process you agreed to a longer retention period on the basis of being considered for future work opportunities we may have.

Any other information obtained as set out in section 2 above will be kept for no longer than is necessary and will be determined with reference to applicable statutory limitation periods in your jurisdiction, or otherwise as agreed between us.

We will keep our retention policies under review to ensure that your data is not stored for longer than is strictly necessary.

7. How to contact us?

If you have any questions about this Privacy Notice or the information we hold about you, you can contact us:

by email: compliance@huntsworth.com
by post: Company Secretary, Huntsworth plc, 8th floor Holborn Gate, 26 Southampton Buildings, London, WC2A 1AN

Enquiries from outside of the European Union can still be made via the above email or postal route.

8. Changes to this Privacy Notice

We keep this Privacy Notice under regular review and we will place any updates on this webpage.

This Privacy Notice was last updated on 3 May 2018.

PRIVACY

We will not collect any personally identifiable information about individuals, except as set out in the Cookies section below or where it is specifically and knowingly provided by them.

COOKIES

When you visit our Web site, we use the cookies that are set out below. A cookie is a small file of letters and numbers that we put on your computer if you agree.

The information that is collected by cookies on our Web site is used to analyze the use of our Web site to help guide improvements and to improve functionality of our Web site.

The Cookies we use on our Web site do not collect or store any personally identifiable information.

By using our Web site, you agree that we can place these types of cookies on your device.

HOW TO DISABLE COOKIES

You can disable the use of cookies, see www.investis.com/info/disabling-cookies.html. You may also wish to visit www.aboutcookies.org which contains further general information about cookies together with comprehensive information about how to restrict or block cookies using your browser and how to delete cookies from your computer. However, if you disable the use of cookies the Web site may lose some useful functionality.

The following cookies are used on our site:

Cookie Name	Purpose
Google Analytics: _utma _utmb _utmc _utmz	Collects information about how visitors use our site. We use the information to compile reports and to help us improve the site. The cookies collect information in an anonymous form, including the number of visitors to the site, from whence visitors have come to the site, and the pages they visited.

GOOGLE ANALYTICS

This Web site uses Google Analytics, a Web analytics service provided by Google, Inc. ("Google"). Google Analytics uses cookies to help the Web site operators (us) analyze how users use our site. The anonymous information generated by the cookie about your use of the Web site (including your IP address) will be transmitted to and stored by Google on servers in the United States. Google will use this anonymous information for the purpose of evaluating your use of the Web site, compiling reports on Web site activity, including the number of visitors to the Web site, from whence they have come to the Web site, the pages they visit, and the length of time they have spent on the Web site, for ourselves and other Web site operators and providing other services relating to Web site activity and Internet usage. We use these reports to improve the way our Web site works. Google may also transfer the information collected by the Google Analytics cookie to third parties where required to do so by law, or where such third parties process the information on Google's behalf. Google will not associate your IP address with any other data held by Google.

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