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Privacy Policy

Eximius Group takes the privacy of its customers very seriously. This privacy policy explains how we
use any personal information that we collect about you, when you use this website
www.eximius.com and all associated Eximius micro-sites linked to this website (collectively “Our
website”). We also comply fully with the Data Protection Act 2018 (the “Act”) and the General Data
Protection Regulation (the “GDPR”).


For the purposes of the Act and the GDPR, the GDPR sponsor is Nick Harrington, 50 Mark Lane,
London, EC3R 7QR in the United Kingdom. Eximius is registered under the Data Protection Act 2018,
Registration No. Z2623868.
This policy applies to all data, in whatever form, relating to Eximius Group business activities
worldwide, and to all data handled by Eximius Group relating to other organisations with whom it
deals.

Personal information we may collect from you:

  • We Eximius collect the minimum amount of information about you that is commensurate with
    providing you with a satisfactory service. This policy indicates the type of processes that may result
    in data being collected about you.
    We may collect and process the following data about the:
  • Information that you provide if you register on our website or place an order for data or
    data services together with the details necessary to administer your account, including any
    necessary compliance checks.
  • Information that you provide by filling in forms on our website and subscribing to the
    services available on our website.
  • Information that you provide to us when you write to us (including by email and fax) or
    when we speak to you by telephone.
  • Information that you provide to us by completing surveys or participating in competitions.
  • Details of your visits to our website and the resources you access to enable us to monitor
    and improve our service and to know which parts of our website are of most interest to our
    customers and visitors to our website.

How we will use information about you:

  • We may collect any or all of the information that you give us depending on the type of transaction
    you enter into, including your name, address, telephone number and email address, together with
    data about your use of the website. We process data differently depending on the category you fall
    under our services – Candidate Data, Client Data or Supplier Data.
    We may use information about you in the following ways:
  • Registration details and customer information will be used to administer your account, to
    keep a record of which services you have subscribed to and to deliver the services you have
    requested.
  • To provide you with information about Eximius offers and services that you request from us
    or which we believe may be of interest to you, where you have consented to be contacted
    for such purposes. You have the right to ask us not to process your personal information for
    marketing purposes and if at any time you wish to opt out of such use then you may contact
    [email protected].
  • To ensure that content from our website is presented in the most effective manner.
  • To carry out our obligations and enforce our rights arising from any contracts entered into
    between you and us.
  • From time to time we may also permit selected third parties to use your data to provide you
    with information about goods and services which may be of interest to you, provided that
    you have consented to third parties contacting you in this way.
  • You have the right to ask us not to process your personal information for marketing purposes and if at any time you wish
    to opt out of such use then you may contact [email protected].
    We do not sell or rent out personal information to any other organisations.

We do not disclose information about identifiable individuals to our advertisers, but we may provide
them with aggregate information about visitors to our website. For example, we may provide our
advertisers with an anonymous summary of the demographics of visitors to our website or with
statistics relating to site usage.

If you do not want us to use your personal information in one or more of the ways mentioned
above, please contact [email protected].

Where we store and process your personal information:

Eximius is responsible for the processing of your personal information.

Our technology services providers or other contracted service providers may also have access or
store data for us, but solely for use on behalf of Eximius in accordance with our instructions and
under our control.

Secure credit card and payment authorisation is handled by our payment
providers who also agree to these terms.

By submitting your personal information, you agree to this transfer, storing and/or processing. We
will take all steps reasonably necessary to ensure that your information is treated securely and in
accordance with this privacy policy.

Your information will not be transferred abroad, but you may be able to access your own
registration details over the Internet from locations abroad. This privacy policy covers just processing
by Eximius and does not cover any processing which may be carried out by your Internet service
provider.

Disclosure of your information

We may disclose your personal information to third parties:
 If we are under a duty to disclose or share your personal information in order to comply with
any legal obligation, or in order to enforce or apply our terms of business and/or other
agreements; or to protect the rights, property, or safety of us, our customers, or others. This
includes exchanging information with other companies and organisations, such as credit
reference agencies and fraud prevention agencies, for the purposes of fraud protection and
prevention, credit risk reduction and to pursue debtors in any other manner mentioned
elsewhere in this policy.

Cookies

Your Internet browser has the in-built facility for storing small files- “cookies” – that hold information
which allows a website to recognise your account. Our website takes advantage of this facility to
enhance your experience to store preferences. You have the ability to prevent your computer from
accepting cookies but, if you do, certain functionality on the website may be impaired. For more
details of our cookie policy, please visit www.eximius.com/cookie-policy/.
Changes to This Policy

Any changes to our Privacy Policy will be placed here and will supersede this version of our Policy.
We will take reasonable steps to draw your attention to any changes in our Policy if you are on our
mailing list. However, to be on the safe side, you should read this document each time you use the
website to ensure that it still meets with your approval.

Who Are We?
Eximius is an international specialist search and selection firm who operate in the UK and Hong
Kong. Our recruiting services are within the Financial Services, Law, IT, Secretarial and our vacancies
are on a permanent, temporary and contractual basis.

Our GDPR Sponsor and GDPR Lead representatives can be contacted directly here for all our office
location:

GDPR Lead – Anna Krecisz
Email [email protected]
Phone – 0207 648 6991

GDPR Sponsor – Nick Harrington
Email [email protected]
Phone – 0207 648 6950

Or alternatively at [email protected]

The Personal Data We Would Like To Collect From You and Process On Are:
Candidate Data:
Depending on the relevant circumstances and applicable local laws and requirements, we may
collect some or all of the information listed below to enable us to offer you our recruitment services
which are tailored to you and your interests:
 Full Name
 Contact details;
 Age/date of birth;
 Gender;
 Photograph;
 Marital status;
 Education details;
 Employment history;
 Professional Qualifications;

 Emergency contacts and details of any dependants;
 Referee details;
 Immigration status (whether you need a work permit);
 Nationality/citizenship/place of birth;
 A copy of your driving licence and/or passport/identity card;
 Financial information (where we need to carry out financial background checks);
 Social security number (or equivalent in your country) and any other tax-related
information;
 Information for Vetting checks;
 Diversity details including racial or ethnic origin, religious or other similar beliefs, and
physical or mental health, including disability-related information;
 Details of any criminal convictions;
 Details about your current remuneration;
 Information on your interests and needs regarding future employment, both collected
directly and inferred, for example from jobs viewed or articles read on our website;
 Extra information that your referees chooses to tell us about you;
 Extra information that our Clients may tell us about you, or that we find from other third
party sources such as job boards;
 The dates, times and frequency with which you access our services;
 CCTV footage if you attend our premises; and
 Any additional information you choose to tell us.

Client Data:
We process client data but actually store relatively limited amount of information. The necessary
details we store are names, telephone numbers and email addresses. We intend to hold only the
minimum amount of data needed with our clients to foster a successful relationship.

Supplier Data:
We process our supplier data but actually store relatively limited amount of information. The
necessary details we store are names, telephone numbers, email addresses and the relative
payment details that we might need to pay you. We intend to hold only the minimum amount of
data needed with our suppliers to foster a successful relationship.

The Personal Data We Collect Will Be Used For The Following Purposes:
 Recruitment Activities
 Marketing Activities
 Legal Claims
Candidate Data:
Recruitment Activities
Our main services at Eximius are recruitment as we try and fill vacancies with candidates that are
presented to us by our clients. The purposes for the use of your personal information are in the list
below:
 Collecting your data from you and sources, eg LinkedIn, Telephone, Email.
 Processing and storing your data on our database so we can contact you in relation to a
relevant role.
 Comparing data about you to vacancies that might be a suitable option for you.
 Sending your data to our clients in relation to a job application or eligibility.
 Your data will be processed from any contract entered between you and us.
 Your data will be processed from any contract entered between Eximius and third parties in
relation to your recruitment process.
 Processing our payroll and invoices operations.
 Using your data to enable us to send you targeted marketing materials or other
communications that we think will be relevant to you.
Marketing Activities
We may send you information for purposes that we think might be of interest to you, in aid of
connecting candidates to job roles, such as:
 To market our recruitment services to you.
 To send you detailed reports on market conditions, promotional offers, client’s events and
emergency roles.
 Promote marketing offers that we may have on for a period of time (consent given).
Certain marketing activities will require consent to be given if some of these activities do not fall
under a legitimate interest and depending on the scenario we will ask for you to opt-in for our
marketing purposes by subscribing to our email send outs.
There is also a ‘soft opt in’ option where we might send you information via previously-obtained
details, due to the fact that you have been affiliated with us in the past. Our marketing activities will only be similar to that of the past and we will offer you a clear and simple [email protected]
option upon receiving.
Our marketing activities are based on what our candidates and clients would be interested in. If this
is not of interest to you then you can withdraw your consent and also opt out of our marketing
interests.

Legal Claims
In certain situations we may use your data to prepare or exercise legal claims against us.

Client Data:
Recruitment Activities
Our main services at Eximius are recruitment through administering candidates to you on a
permanent basis or contractually through us. Some of the purposes of using your data are below:
 Storing your details and data on our database so we can contact you in regards to
candidates that we feel may be of interest to you.
 Keeping records of our conversations on our databases so we can record and offer a
bespoke service to you.
 Processing your data for our targeted marketing campaigns.
We possibly may use your data if it is deemed to be necessary for our legitimate interests, stated
below. If this is not something you would like to have, you have the right to object.
Marketing activities
We will not seek your consent when sending you marketing content to a corporate post address or
email address. If you wish to no longer receive our marketing information then please find out more
and opt out of our marketing communications by emailing [email protected].

Legal Claims
In certain situations we may use your data to prepare or exercise legal claims against us.
Supplier Data:

We only use your data for the following activities, for our suppliers and those who are operating
with Eximius:

 To store your data on our database so we can contact you regarding our current contract,
agreement or relating to a past issue.
 To retain or gain support from you in our services.
 Help us to offer a tailored marketing approach
 In certain situations we may use your data to prepare or exercise legal claims against us.
We may use your data if it is deemed to be necessary for our legitimate interests.
In any event, we are committed to ensuring that the information we collect and use is appropriate
and accurate for this purpose, and does not constitute an invasion of your privacy.
In terms of being contacted for marketing purposes Eximius would contact you for additional
consent. We will not seek your consent when sending you marketing content to a corporate post
address or email address. If this is not something you would like to have, you have the right to
object.

Our Legal Basis for Processing your Personal Data:
Legitimate Interests
Article 6(1)(f) gives you a lawful basis for processing where “processing is necessary for the purposes
of the legitimate interests pursued by the controller or by a third party except where such interests
are overridden by the interests or fundamental rights and freedoms of the data subject which
require protection of personal data, in particular where the data subject is a child.”

Candidate Data:
We believe that if you are under contract with us, in the process of starting a contract with us
(contract placements) or have been placed with one of our clients (permanent placements), then it
is necessary for us to acquire your personal data through purposes of legitimate interest. We
normally would like to check the information you have provided to us or to confirm references,
qualifications and any criminal checks to the extent that it is appropriate with local laws.
To carrying on providing our services, to you our candidates, we need to process your data for
internal administrative duties, for example payroll or invoicing. As a result this falls under the
purposes of legitimate interests, as you the candidate, are under a contract (contractors) with us or
our respective clients (permanent).
If we believe that you are looking for employment or we have received your personal data from a
job board where you have uploaded your personal data, and you match some of the vacancies we have from our clients, then if we contacted you, this would fall under the purpose of legitimate
interest for processing your personal data.
We also want to offer detailed job recommendations that are tailored to you, to aid your job search.
As a result we believe it is appropriate for us to process your data to make sure you receive the most
tailored content which in turn falls under the purpose of legitimate interests for processing your
data.
If certain specific obligations fall on us, then by law, we have a legitimate interest to share your data
with certain crime detection, tax collection or any litigation purposes.

Client Data:
To ensure we foster a well working relationship with our clients, we store your personal data/or the
personal data of individual contacts, for each specific client of ours on a CRM database. This is also
used to store records of our conversations, meetings, vacancies and placements with you. As a result
we deem your data to be necessary in our relationship with you, which falls under our legitimate
interests as we provide our executive search and recruitment services to you.
Supplier Data:
We store data from individuals from our suppliers in order to warrant the services that you offer to
us as our suppliers. We will also hold your financial data because we will need to reimburse you for
your services. As a result we deem it to be within the scope of legitimate interest as a legal basis for
processing your personal data as we are a beneficiary of your services.

Your Consent
By consenting to this privacy notice you are giving us permission to process your personal data
specifically for the purposes identified.
Consent is required for Eximius to process both types of personal data, but it must be explicitly
given. Where we are asking for your sensitive personal data we will always tell you why and how the
information will be used.
You may withdraw consent to process your personal data for certain activities or for consent in our
marketing activities at any time by emailing [email protected] or in writing to us at 50 Mark
Lane, London, EC3M 7QR.

Disclosure of Your Information
Eximius Group collects and processes information from our clients, candidates and other third
parties with whom we do business with. Primarily we also share your data with prospective clients
to increase your chances of matching to a relevant vacancy listed. We may also share your data with
third parties, our service providers, to provide you with the best possible service from us.

Retention Period
Eximius processes personal data for a period of 3 years and will store personal data on our systems
for that period of time unless the law or any other regulation requires us to keep that data (for
example, any obligations with the tax authorities or in any connection to possible litigation).

Your Rights as A Data Subject
At any point while we are in possession of or processing your personal data, you, the data subject,
have the following rights:
● Right of access – you have the right to request a copy of the information that we hold about
you.
● Right of rectification – you have a right to correct data that we hold about you that is
inaccurate or incomplete.
● Right to be forgotten – in certain circumstances you can ask for the data we hold about you
to be erased from our records.
● Right to restriction of processing – where certain conditions apply to have a right to restrict
the processing.
● Right of portability – you have the right to have the data we hold about you transferred to
another organisation.
● Right to object – you have the right to object to certain types of processing such as direct
marketing.
● Right to object to automated processing, including profiling – you also have the right to be
subject to the legal effects of automated processing or profiling.

● Right to judicial review: in the event that Eximius refuses your request under rights of
access, we will provide you with a reason as to why. You have the right to complain as
outlined below.
All of the above requests will be forwarded on should there be a third party involved (as stated
above) in the processing of your personal data.
Please download the Subject Access Request form and send it to us in writing if you would like to
understand what data we hold on you.

Complaints
In the event that you wish to make a complaint about how your personal data is being processed by
Eximius (or third parties as described above), or how your complaint has been handled, you have the
right to lodge a complaint directly with the supervisory authority of Eximius’ data protection
representatives reachable at [email protected].

The details for individual contacts are:
GDPR Lead – Anna Krecisz
Email [email protected]
Phone – 0207 648 6991
GDPR Sponsor – Nick Harrington
Email [email protected]
Phone – 0207 648 6950
Or alternatively at [email protected]