Privacy Policy

last modified 03/12/2018

1. Introduction

This Privacy Policy (together with our Terms & Conditions and Terms of Website Use) describes the type of information that we collect from you (“you/your”) through the use of our Services, or the use of our website www.mynannies.co.uk (“Website”), how that information may be used or disclosed by us and the safeguards we use to protect it.

Our Website and Services may contain links to third party websites that are not covered by this Privacy Policy. We therefore ask you to review the privacy statements of other websites and applications to understand their information practices.

We have drafted this Privacy Policy to be as clear and concise as possible. Please read it carefully to understand our policies regarding your information and how we will treat it. By using or accessing our Website or the Services, you agree to the collection, use and disclosure of information in accordance with this Privacy Policy. This Privacy Policy may change from time to time and your continued use of the Website or the Services is deemed to be acceptance of such changes, so please check periodically for updates.

This Privacy Policy was last updated on 3 December 2018 to add new provisions to the policy applicable regarding GDPR. Please check back regularly to keep informed of updates to this Privacy Policy. Please read this Privacy Policy carefully and ensure that you understand it. Your acceptance of our Privacy Policy is deemed to occur upon your first use of our Website. If you do not accept and agree with this Privacy Policy, you must stop using our Website immediately.

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. 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.

If you have any comments on this Privacy Policy, please email them to support@mynannies.co.uk.

2. Who We Are

2.1 Here are the details that the Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 on the protection of natural persons with regards to the processing of personal data and on the free movement of such data, known as General Data Protection Regulation (GDPR) says we have to give you as a ‘data controller’:

  • Our Website address is www.mynannies.co.uk
  • Our company name is My Nannies Ltd
  • Our registered address is International House, 24 Holborn Viaduct, London EC1A 2BN
  • Our nominated representative or Data Protection Officer is Sarah Hollenthoner and they can be contacted at sarah@mynannies.co.uk

2.2 We respect your right to privacy and will only process personal information about you in accordance with the Data Protection Legislation which for the purposes of this Privacy Policy shall mean: (i) unless and until the GDPR is no longer directly applicable in the UK, the General Data Protection Regulation ((EU) 2016/679) and any national implementing laws, regulations and secondary legislation, as amended or updated from time to time, in the UK and then (ii) any successor legislation to the GDPR or the Data Protection Act 1998 and other applicable privacy laws.

3. What we may collect

3.1 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 collect personal and sensitive data such as listed below.

Personal and sensitive personal data of a Candidate or Potential Candidate we may collect:

  • Full name
  • Gender
  • Title
  • Date of birth
  • Contact details (such as phone number, email address and postal address)
  • Personal identification (such as passport, ID, visa if applicable)
  • DBS and/or criminal background check
  • Information about criminal convictions
  • Driving license if applicable
  • First aid certificate and/or other relevant certificates
  • Professional experience (e.g. copy of a CV)
  • Education details
  • Referee contact details
  • Job preferences (including but not limited to salary expectations)
  • Medical conditions (including but not limited to allergies)
  • Any relevant information provided to the Agency during an interview or otherwise (e.g. preferences for job location, availability, smoking habits, language skills, or any other information that may be relevant for fulfilling our Services)

 Personal and sensitive personal data of a Client or Potential Client we may collect:

  • Profile data (such as username and any other information provided in the profile)
  • Full name
  • Contact details (such as phone number, email address and postal address)
  • Details provided in the Instructions such as age of the children, allergies or certain medical conditions of the children, languages spoken, schedule, pets at home, etc.
  • Transaction data includes details about payments and other details of our Services you have purchased from us.
  • In the case of any remittance (e.g. cancellation or refund) of the applicable fee the required bank details will also be transmitted to My Nannies

3.2 Where we do collect 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) and it is necessary to do so for our business, we will obtain your specific consent, unless we have another lawful basis to do so.

3.3. We may also collect data from any visitors to our Website which includes Candidates, Clients and Potential Candidates or Potential Clients. We collect technical, usage, marketing, and communications data such as listed below:

  • 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
  • Profile data includes your username and password, appointments made and interviews conducted or attended by you, your interests, preferences, feedback and survey responses
  • Usage data includes information about how you use our Website and Services
  • Marketing and communications data includes your preferences in receiving marketing from us and our third parties and your communication preferences
  • Analytics includes third-party analytics services (such as Google Analytics) to evaluate your use of the Website, compile reports on activity, collect demographic data, analyse performance metrics, and collect and evaluate other information relating to our Website and internet usage. These third parties use Cookies and other technologies to help analyse and provide us the data. By accessing and using the Website, you consent to the processing of data about you by these analytics providers in the manner and for the purposes set out in this Privacy Policy.
  • Third parties and Information we receive from other sources. We may receive information about you if you use any of the other websites we operate or through the Services we provide. In this case we will have informed you when we collected that data that it may be shared internally and combined with data collected on our Website. We are also working closely with third parties (including, for example, business partners, suppliers, sub-contractors, advertising networks, analytics providers, and search information providers) and may receive information about you from them.

3.4 We also collect, use and share aggregated data such as statistical or demographic data for any purpose. Aggregated data may be derived from your personal data but is not considered personal data in law as this data does not directly or indirectly reveal your identity. For example, we may aggregate your usage data to calculate the percentage of users accessing a specific website feature. However, if we combine or connect aggregated data with your personal data so that it can directly or indirectly identify you, we treat the combined data as personal data which will be used in accordance with this Privacy Policy.

3.5 Under GDPR we will ensure that your personal data is processed lawfully, fairly, and transparently, without adversely affecting your rights. We will only process your personal data if at least one of the following basis applies:

  • You have given consent to the processing of your personal data for one or more specific purposes;
  • processing is necessary for the performance of a contract to which you are a party or in order to take steps at the request of you prior to entering into a contract;
  • processing is necessary for compliance with a legal obligation to which we are subject;
  • processing is necessary to protect the vital interests of you or of another natural person;
  • processing is necessary for the performance of a task carried out in the public interest or in the exercise of official authority vested in the controller; and/or
  • processing is necessary for the purposes of the legitimate interests pursued by us or by a third party such as our financial payments, except where such interests are overridden by the fundamental rights and freedoms of the data subject, in particular where the data subject is a child

3.6 If we receive personal information in the course of providing our Services to you from another data subject, we expect you to have complete responsibility for ensuring that the contents of this Privacy Policy are brought to their attention and you have obtained their consent in the process.

3.7 In some instances, it may be appropriate for us to combine your information with other information that we may be holding about you, such as combining your name with your geographic location or your browsing and profile usage history.

4. Use of Cookies

Our Website uses its own Cookies to improve user-friendliness (“Cookies” are records sent by the web server to the user’s browser that are saved there for later retrieval). Our personal Cookies do not store any personal data. The Cookies generated by My Nannies have an expiry date as set out in the table below. You can edit your browser setting so that you are informed about the use of Cookies and can decide on a case by case basis to accept them or to generally deny acceptance of Cookies. In case Cookies are not accepted the functions of our Website can be limited. Under “help” in your web browser you will find instructions on how to change the settings of the current browser accordingly and how to accept or decline Cookies.

Cookies processed by My Nannies and its sub domains:

Name Function
PHPSESSID

Session cookie (session). Expiration: session end

nannyCookie[ct-cookieaccepted]

Hide cookie hint (Popup). Expiration: 1 year

nannyCookie[ct-seller]

Hide promoter popup (Popup). Expiration: 24 hours

nannyCookie[ct-survey]

Hide survey popup (Popup). Expiration: 1 year

nannyCookie[firstReferer]

Domain of first visit – in case a widget was loaded on an external website, this url will be saved. Expiration: 30 hours

__zlcmid

Activate support chat & helpdesk. Expiration: 1 year

__zlcprivacy

Activate support chat & helpdesk. Expiration: 1 year

_gat

Google-Analytics cookie, used to throttle request rate. Expiration: 10 minutes

_ga Google-Analytics Cookie, used to distinguish users. Expiration: 2 years
_gid Google-Analytics Cookie, used to distinguish users. Expiration: 24 hours
__ar_v4 Google-Adwords Cookie, associated with the DoubleClick advertising service from Google. Helps with tracking conversion rates for ads. Expiration: no date set
__utma Google-Analytics Cookie, used to distinguish users and sessions. The cookie is created when the javascript library executes and no existing __utma cookies exists. The cookie is updated
every time data is sent to Google Analytics. Expiration: no date set
__utmb Google-Analytics Cookie, used to determine new sessions/visits. The cookie is created when the javascript library executes and no existing __utmb cookies exists. The cookie is updated
every time data is sent to Google Analytics. Expiration: end of sessions
__utmc Google-Analytics Cookie, not used in ga.js. Set for interoperability with urchin.js. Historically, this
cookie operated in conjunction with the __utmb cookie to determine whether the user was in a new session/visit. Expiration: 30 minutes
__utmk Google-Analytics Cookie, overall Google Analytics UTM-Cookies hash value. Expiration: no date set
__utmz Google-Analytics Cookie, stores the traffic source or campaign that explains how the user reached your site. The cookie is created when the javascript library executes and is updated
every time data is sent to Google Analytics. Expiration: 6 months

4.2. All Cookies used by and on our Website are used in accordance with current English and EU Cookie Law.

5. How we may collect your data

  • Information and documents provided by the Candidate or Potential Candidate. By filling in forms, surveys, profile information and information provided during the interview with Clients or us whether orally, in writing or electronically (e.g. via the Platform)
  • Information provided by referees (such as assess of performance and sickness reports) for Candidates
  • DBS checks for Candidates
  • Information from various third party suppliers (such as Facebook, LinkedIn, Instagram)
  • Information provided by the Client to the Agency by filling in forms or surveys (e.g. via our Website) or corresponding with us by phone, email or otherwise

6. How we may use your data

6.1 In addition to the above, we may use the information in the following ways:

  • To assess Candidate’s skills and suitability for a position
  • To perform background checks
  • To ensure equal opportunities during the recruitment process
  • To provide appropriate adjustments during the recruitment process
  • To Introduce Candidates to Clients which subsequently may lead to an Engagement
  • To fulfil the Agency’s Services
  • To personalise your Website experience and to allow us to deliver the type of content and Candidates or Client vacancies in which you are most interested
  • To administer a contest, promotion, survey or other site feature
  • Present Website content effectively to you
  • Provide information, and Services that you request, or (with your consent) which we think may interest you

6.2 The  Client agrees that the Instructions given to the Agency being made available on the Website and Platform for the purposes of marketing and in order to find suitable Candidates for the Client. The Agency will only share the Client’s full name, address and contact details with a Candidate once the Client requested (orally, in writing or electronically) to interview this Candidate..

6.3 If you are already our registered Client or Candidate, we will only contact you electronically about Services similar to what we provided for you in the past.

6.4 If you are a new Client, you will only be contacted if you agree to it.

6.5 We may keep a record of those links which are used the most to enable us to provide the most helpful information but we agree to keep such information confidential and you will not be identified from this information.

6.6  In addition, if you don’t want us to use your personal data for any of the other reasons set out in this section in 6, you can let us know at any time by contacting us at support@mynannies.co.uk, and we will delete your data from our systems. However, you acknowledge this will limit our ability to provide the best possible Service.

6.7 In some cases, the collection of personal data may be a statutory or contractual requirement, and we will be limited in the Services we can provide you if you don’t provide your personal data in these cases.

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

  • Where we need to perform the contract we are about to enter into or have entered into with you
  • Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests
  • Where we need to comply with a legal or regulatory obligation

6.9 Generally we do not rely on consent as a legal basis for processing your personal data other than in relation to our marketing communications or sending third party direct marketing communications to you via email or text message. You have the right to withdraw consent to marketing at any time by contacting us at support@mynannies.co.uk, and we will either delete your data from our systems or move your data to our “unsubscribe list”. However, you acknowledge this will limit our ability to provide the best possible services to you.

6.10 As already indicated above, with your permission and/or where permitted by law, we may also use your data for marketing purposes which may lead to us contacting you by email and/or telephone with information, news and offers on our Services. We agree that we will not do anything that we have not agreed to under this Privacy Policy, and we will not send you any unsolicited marketing or spam. We will take all reasonable steps to ensure that we fully protect your rights and comply with our obligations under the GDPR and the Privacy and Electronic Communications (EC Directive) Regulations 2003, as amended in 2004, 2011 and 2015.

7. Where we store your data and security

7.1 We may transfer your collected data to storage outside the European Economic Area (EEA). If we do store or transfer data outside the EEA, we will take all reasonable steps to ensure that your data is treated as safely and securely as it would be within the EEA and under the GDPR. Such steps may include, but not be limited to, the use of legally binding contractual terms between us and any third parties we engage with and the use of the EU-approved model contractual arrangements. Your acceptance of this Privacy Policy shall be your consent permitting us to store or transfer data outside the EEA if it is necessary for us to do so.

7.2 Where we use providers based in the US, we may transfer data to them if they are part of the privacy shield which requires them to provide similar protection to personal data shared between the Europe and the US. For further details, see the European Commission: EU-US privacy shield.

The following data is transferred to countries outside the EU as part of data processing:

Country Application Type of Data
USA Google Google Analytics: anonymised
IP address, website, browser data, information about website usage
USA Google Google Adwords: IP
address, website, browser data, information about website usage
USA Zendesk Support & Helpdesk: ticket
data, website title, browser data
USA Facebook Facebook pixel: IP
address, website, browser data, information about website usage
USA Mixpanel IP address, website, browser
data, information about website usage
USA HubSpot IP address, website, browser
data, information about website usage
USA Amazon AWS communication, data
handling, general server log files

7.3 Data security is of great importance to us, and to protect your data we have put in place suitable physical, electronic and managerial procedures to safeguard and secure data collected through our Website. 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.

7.4 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.

7.5 By giving us your personal data, you agree to this arrangement. We will do what we reasonably can to keep your data secure.

7.6 All personal data transmitted via the internet is encrypted using SSL procedures. We secure our website and other systems by technical and organisational measures against loss, destruction, access, modification or distribution of your data via unauthorised persons.

7.7 Notwithstanding the security measures that we take, it is important to remember that the transmission of data via the internet may not be completely secure and that you are advised to take suitable precautions when transmitting to us data via the internet and you take the risk that any sending of that data turns out to be not secure despite our efforts.

7.8 If we give you a password upon registration on our Website or Platform, you must keep it confidential. Please don’t share it.

8. Data Sources (if not provided by the user)

These are the third party data sources that we use to enable us to carry out our Services

External Recipients of Data Transfer of Electronic Identification Data to Responsible Parties
Payment Services:
Wirecard CEE, Reininghausstraße 13a, 8020 Graz, AUSTRIA
IP address, payment data
Payment Services: SIX Payment Services (Europe) S.A., 10, rue Gabriel Lippmann, L-5365 Munsbach, LUXEMBURG IP address, payment data
Payment Services: Revolut Limited, 4th Floor, 7 Westferry Circus, E14 4HD London, UK payment data
Video embedding:
YouTube LLC, 901 Cherry Ave.
San Bruno, CA 94066, USA
IP address, browser data
Support, helpdesk:
Zendesk, Inc, 1019 Market St
San Francisco, CA 94103, USA
IP address, browser data
Analytics, ad network,
APIs: Google Inc., 1600 Amphitheatre Parkway Mountain View, CA 94043, USA
IP address, browser data
Analytics: Mixpanel Inc,
405 Howard Street, Floor 2, San Francisco, CA 94105, USA
IP address, browser data
Pixel, social plug-in:
Facebook Inc., 1 Hacker Way, 94025 Menlo Park, USA
IP address, browser data
Cloud services: Amazon
Web Services, Inc., 410 Terry Avenue North, Seattle, WA 98910, USA (location:
IRELAND)
Communication, data handling, general server log files
Newsletter registration: HubSpot, Inc., 25 First Street, 2nd Floor, Cambridge, MA 02141, USA Email address, gender, firstname, lastname
   

9. Data Retention Period

9.1 Non-registered users: on the grounds of the legal basis mentioned above the data of registered users will be processed by My Nannies for 40 months after the contract has ended (=36 months of possible contractual claims + maximum of 4 months delivery time of these claims) and is subsequently deleted (in any case the personal reference). In any case, the license agreement ends after a period of 40 months of being inactive and leads to an immediate deletion. Data related to your booking will remain saved in our systems until the statute of limitations for all claims arising from the contract passes. Data from payment transactions must be stored until the expiry of the statutory limitation period.

9.2 Registered users: registered users can access their stored data any time via login. On the grounds of the legal basis mentioned above the data of registered users will be processed by My Nannies for 40 months after the contract has ended (=36 months of possible contractual claims + maximum of 4 months delivery time of these claims) and is subsequently deleted (in any case the personal reference). In any case, the license agreement ends after a period of 40 months of being inactive and leads to an immediate deletion. Data related to your booking will remain saved in our systems until the statute of limitations for all claims arising from the contract passes. Data from payment transactions must be stored until the expiry of the statutory limitation period.

10. Disclosing your information

10.1 We are allowed to disclose your information in the following cases:

  • If we want to sell our business, or our company, we can disclose it to the potential buyer
  • We can disclose it to other businesses in our group
  • We can disclose it if we have a legal obligation to do so, or in order to protect other people’s property, safety or rights
  • We can exchange information with others to protect against fraud or credit risks
  • We may contract with third parties to supply services to you on our behalf. These may include payment processing, search engine facilities, advertising and marketing. In most cases we will only share anonymised data but in some cases, the third parties may require access to some or all of your data. These are the third parties that could have access to your information:

PAYE for Nannies Ltd (Macclesfield House, 8A Saxon Way, Norfolk, PE31 6LY, UK), Courseticket GmbH (Siebenbrunnengasse 17, Top 7  1050 Vienna, Austria), HubSpot, Inc. (25 First Street, 2nd Floor, Cambridge, MA 02141, USA , Wirecard CEE (Reininghausstraße 13a, 8020 Graz, Austria), SIX Payment Services (Europe) S.A. (10, rue Gabriel Lippmann, L-5365 Munsbach, Luxemburg), Morton Michel Ltd (9 St Michaels Road, Croydon, CR9 3DD, UK), PIB Group Ltd (Rossington’s Business Park, West Carr Road, Retford, DN22 7SW), Covéa Insurance Plc (2 Norman Place, Reading, RG1 8DA, UK), ARAG Plc (9 Whiteladies Road, Clifton, Bristol, BS8 1NN, UK)

10.2 Where any of your data is required for such a purpose, we will take all reasonable steps to ensure that your data will be handled safely, securely, and in accordance with your rights, our obligations, and the obligations of the third party under GDPR and the law.

11. Your rights

11.1 When you submit information via our Website, you may be given options to restrict our use of your data. We aim to give you strong controls on our use of your data (including the ability to opt-out of receiving emails from us which you may do by unsubscribing using the links provided above in this Privacy Policy).

11.2 Under the GDPR, you have the right to:

  • request access to, deletion of or correction of, your personal data held by us at no cost to you;
  • request that your personal data be transferred to another person (data portability);
  • be informed of what data processing is taking place;
  • restrict processing;
  • to object to processing of your personal data; and
  • complain to a supervisory authority.

11.3 You also have rights with respect to automated decision-making and profiling as set out in section 14 below.

11.4 You have the right to ask us not to process your personal data for marketing purposes. We will usually inform you (before collecting your data) if we intend to use your data for such purposes or if we intend to disclose your information to any third party for such purposes.

11.5 To enforce any of the foregoing rights or if you have any other questions about our Website or this Privacy Policy, please contact us at support@mynannies.co.uk.

12. Links to other sites

12.1 Please note that our Terms & Conditions and our policies will not apply to other websites that you get to via a link from our Website. 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.

13. Changes

13.1 If we change our Privacy Policy, we will post the changes on this page. If we decide to, we may also email you.

14. Automated decision-making and profiling

14.1 In the event that we use personal data for the purposes of automated decision-making and those decisions have a legal (or similarly significant effect) on you, you have the right to challenge to such decisions under GDPR, requesting human intervention, expressing their own point of view, and obtaining an explanation of the decision from us.

14.2 The right described in section 14.1 does not apply in the following circumstances:

  • the decision is necessary for the entry into, or performance of, a contract between the you and us;
  • the decision is authorised by law; or
  • you have given you explicit consent
  • where we use your personal data for profiling purposes, the following shall apply:
  • clear information explaining the profiling will be provided, including its significance and the likely consequences;
  • appropriate mathematical or statistical procedures will be used;
  • technical and organisational measures necessary to minimise the risk of errors and to enable such errors to be easily corrected shall be implemented; and
  • all personal data processed for profiling purposes shall be secured in order to prevent discriminatory effects arising out of profiling.

15. Terms & Conditions and Terms of Website Use

15.1 Please also visit our Terms & Conditions section and our Terms of Website Use establishing the use, disclaimers, and limitations of liability governing the use of our Website.

16. Your Consent

16.1 By using our Website and by way of acknowledgment, you consent to our Privacy Policy.