Privacy Policy

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This Privacy Notice regulates the use and protection by Turnkey Signal Sighting Ltd of “personal data” you provide to Turnkey Signal Sighting either when using this Website or otherwise in relation to any processing by Turnkey Signal Sighting of personal data you provide to Turnkey Signal Sighting for the purposes set out below unless an alternative separate privacy notice applies to such processing. Personal data is information which identifies (or which could, with other information that we hold or are likely to hold, identify) a living individual.

Turnkey Signal Sighting Ltd is a “controller” under the Data Protection Act 2018 and processes personal data in accordance with the Data Protection Act 2018 and the General Data Protection Regulation (EU 2016/679) (“Data Protection Laws”). For queries on data protection, please contact Turnkey Signal Sighting Ltd’s Data Protection Officer at Turnkey Signal Sighting Ltd, 71-75 Shelton Street, Camden, London. WC2H 9JQ or info@turnkeysignalsighting.com.

Personal Data: We will not collect any personal data about you or individuals accessing this Website or otherwise communicating or interacting with Turnkey Signal Sighting, except where: it is specifically and knowingly provided, where it is necessary for Turnkey Signal Sighting to process or hold for the purposes of the goods or services it provides and where there is a valid legal basis for doing so or an alternative separate privacy notice applies to such processing. Examples of personal data that you may provide to us when accessing this Website or when otherwise communicating or interacting with Turnkey Signal Sighting, and which we may collect and process, are:

• personal details such as: your name, address, email address , telephone number and occupation;
• employment details such as: specific employment information held such as length of service or employment history/ curriculum vitae where provided by you in relation to any application for a role made by you via this Website where you have applied for a role via the ‘Join Us’ section      on this Website and provided explicit consent via a separate consent form referencing this privacy notice;
• employee referrer name and email address details and name and email address contact details of prospective referral applicants for job applicant referrals where individuals being referred have provided explicit consent via a separate consent form referencing this privacy notice;
• details in relation to you or personal of Turnkey Signal Sighting, its clients, customers, suppliers, subcontractors, business partners or joint venture partners or members of the public in respect of whistleblowing reports, reported concerns or non-compliance with Turnkey      Signal Sighting’s Code of Conduct in accordance with our 
• details in relation to you or third parties in connection with insurance claims being pursued by Turnkey Signal Sighting or its insurers or being brought against Turnkey Signal Sighting by third party claimants including: name, home address, banking/payment details, claim and/or      insurance details, vehicle registration details etc.

Turnkey Signal Sighting will also collect information about your computer, including where available and subject to your chosen cookie and privacy settings as made available on the Website your IP address, operating system and browser type and we may share non-personal aggregated statistics about our website visitors’ traffic patterns with authorised partners with a need to know namely, Google Analytics or Site Improve analytics or our authorised nominated web developer suppliers. However, we will not collect, sell or share any information about individual users.

Where we store your personal data:

All personal data you provide to us via the use of this Website is stored on systems with appropriate technical and organisational security measures and controls located within the European Economic Area, which are sufficient to comply with the requirements under the Data Protection Laws. We will only store your personal data for as long as necessary for Turnkey Signal Sighting to process such personal data for the purposes set out in this Privacy Notice and in accordance with Turnkey Signal Sighting’s internal retention policies and procedures (available on request). The accuracy of the information that we hold about you is important to us. If any of the personal information we hold about you becomes inaccurate or out of date (e.g. a contact/contact information changes), or you object to or wish to restrict us processing it, please inform us as soon as possible using the contact details below, so we can update our records. 

Where we have given you (or where you have chosen) a password which enables you to access certain parts of our Website, you are responsible for keeping this password confidential. We ask you not to share a password with anyone.

Uses made of the Personal Data:

We use personal data held about you for the following purposes:

• To send news updates to our Website subscribers. This may include press release announcements, financial results and other important news or alerts;
• To carry out our obligations arising from any agreement that we have with, or concerning, you and to provide you with the information, benefits and services that you request from us;
• To ensure that content from our Website is presented in the most effective manner for users;
• To allow you to participate in interactive features on or via our Website;
• To contact you in order to send you information that you have asked us to provide such as newsletters or information on Turnkey Signal Sighting projects or initiatives either by email, telephone or via our ‘Contact’ page or which we think may be useful to you or to send marketing information to you only where you have explicitly consented to this via a separate consent form referencing this privacy notice;
• To notify you about our services and any changes to those services;
• To enable you to access information or to submit applications regarding potential roles at Turnkey Signal Sighting or career opportunities via the ‘Join Us’ page accessible via this website and to enable us to review and respond to such applications where you have subscribed to such features via the Website and provided explicit consent via a separate consent form      referencing this privacy notice;
• To enable you to set and access job alert preferences regarding potential careers opportunities via the Website where you have subscribed to such features and subject to explicit consent to such processing via a separate consent form referencing this privacy notice;
• To enable you to nominate job applicant referrals and enable us to process requests for job application from referred candidates subject to explicit consent to such processing via a separate consent form referencing this privacy notice;
• To collect information such, as subject to your chosen cookie and privacy settings as made available on the Website, your IP address, operating system and browser type for the purposes of website analytics and sharing of non-personal aggregated statistics about our website visitors’ traffic patterns with authorised partners with a need to know namely, Google Analytics or Site Improve analytics or our authorised nominated web developer suppliers.
• Complying with our legal obligations, any relevant industry or professional rules and regulations or any applicable voluntary codes;
• Complying with demands or requests made by any relevant regulators, government departments and law enforcement authorities or in connection with any disputes or litigation;
• In connection with any sale, merger, acquisition, disposal, reorganisation or similar change of entity managing website's business;
• Investigate whistleblowing reports, reported concerns or non-compliance with Turnkey Signal Sighting’s Code of Conduct in accordance with our whistleblowing policy and separate privacy policy sent out upon request, and
• Manage, respond to and/or process insurance claims being pursued by Turnkey Signal Sighting or its insurers or being brought against Turnkey Signal Sighting by third party claimants.

Unless otherwise agreed with you, we will not use any of your personal data for automated decision-making or profiling.

Disclosure of your Information:

We will share your information within Turnkey Signal Sighting, where relevant, tour professional advisers.  Where required by law or regulatory requirement, or where necessary to fulfil our contract with you, we may also share your information with:

1. other companies who provide goods/services to us;

2. our professional advisers and auditors;

3. regulators, government departments, law enforcement authorities, and insurance companies;

4. any relevant ombudsman, dispute resolution body or the courts; and

5. persons in connection with any sale, merger, acquisition, disposal, reorganisation or similar change in the Turnkey Signal Sighting business.

Personal data shall not be transferred to or stored at a destination outside the European Economic Area (“EEA”) unless required for the purposes of transfers by Turnkey Signal Sighting to its service providers who may be located outside of the EEA in which cases such transfers shall be subject to appropriate safeguards such as EC model clause data transfer agreements, US-EU Privacy Shield certification, an EC adequacy decision in relation to the country location or consent from you or other alternative safeguards in accordance with the Data Protection Laws.

The transmission of information via email or the internet is not completely secure. We cannot guarantee the security of your data transmitted to our site; and any transmission is at your own risk.

Legal Basis for Processing: Data Protection Laws require that we meet certain conditions before we are allowed to use your personal data as described in this Privacy Notice. For personal data which is not ‘sensitive personal data’ or ‘special categories of personal data’ under Data Protection Laws, unless otherwise notified, we rely on a condition known as "legitimate interests" in order to process your personal data for the above specified purposes. For example, it is in our legitimate interests to process your personal data in relation to your business contact names, and contact details where it is required by us in order to for us to:

• ensure that content from our Website is presented in the most effective manner for users;
• allow you to participate in interactive features on or via our Website;
• administer and respond to inquiries from you in connection with your use of the Website or our products or services;
• procure goods and services for you as a supplier where applicable;
• meet legal obligations under the GDPR and applicable data protection laws to hold necessary information as part of our GDPR compliance programme record-keeping obligations;
• comply with legal and regulatory requirements and to ensure that employees or third parties adhere to Turnkey Signal Sighting’s Code of Conduct and ethical standards by investigating whistle-blowing and anti-bribery reports or concerns;
• appropriately respond to and/or manage or initiate insurance claims/ proceedings in the interests of Turnkey Signal Sighting;
• help verify job applicant referrals;
• verify integrity and suitability of employees and/or prospective employee or contractor candidates to comply with client requirements and/or to ensure the safety of our workforce.

We will ensure that the collection and processing of your personal data:

• is kept to a minimum with regards to the amount of data collected and the extent of any processing;
• will not be overly intrusive to you; and
• will be proportionate in order to meet our legitimate interests, as above.

If applicable, we will only process ‘sensitive personal data’ or ‘special categories of personal data’ provided by you where you have provided your explicit consent to do so via a separate consent form referencing this privacy notice or where there is an alternative legal basis for such processing under Data Protection Laws.

Your rights in relation to your personal data: Under Data Protection Laws you have the following rights in relation to your personal data:

• right to access your personal data by subject access request;
• right to have your personal data rectified if inaccurate/incomplete;
• right to object to direct marketing;
• in certain circumstances, the right:
  • to have your data erased or removed, and where the personal data has been made public, that other controllers processing the personal data also erase links to, or copy or replication of, such personal data;
  • to restrict the processing of your data;
  • of data portability, namely to obtain and reuse your data for your own purposes across different services;
  • to not be subjected to automated decision making (including profiling) where it produces a legal effect or a similarly significant effect on you; and
  • the right to bring a civil action if there is a breach of the Data Protection Laws.
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Contact and Complaints:  You may contact us in relation to the above rights by contacting Turnkey Signal Sighting’s Data Protection Officer at: info@turnkeysignalsighting.com. Requests for subject access to personal data will be administered free of charge unless such requests are manifestly unfounded or excessive in which case we reserve the rights to charge a reasonable fee for administrative costs.

If you are not happy with the way in which your personal data is held or processed by us, or if you are not satisfied with our handling of any request by you in relation to your rights, we would request that you raise a complaint with our Data Protection Officer at the contact details set out above in the first instance, however, you always have the right to complain re: data protection matters to the Information Commissioner Office (ICO). The ICO is the UK's independent body set up to uphold information rights. You can find out more about the ICO on its website.

Links to Other Website: This Privacy Notice only applies to this Website and does not apply to any links within the site linking to other websites. We ask you to read the privacy notices on other websites you visit.

Changes to this Privacy Notice: This Privacy Notice is correct as at 05 September 2023, however we keep this Privacy Notice under regular review, and we reserve the right to change it at any time on notice to you.  

We will email you to notify you of these changes where:

• we are making substantial changes, or
• where we are doing something with your personal data, which youmight not expect based on what we have told you in this Privacy Notice.

Otherwise, any updates to this Privacy Notice will be notified to you by a clearly highlighted banner on the homepage of this Website.