Phi Partners Privacy Policy
Date created: 28 th March 2023
Introduction
Welcome to the Phi Partners International Limited privacy policy.
We are Phi Partners International Limited, a consulting firm registered in the United Kingdom, company no.

Phi Partners International Limited respects your privacy and is committed to protecting your
personal data. We believe in maximising your privacy and confidentiality, in keeping with good business
practice and the law, which for us is the General Data Protection Regulations (GDPR). 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) and tell you about your privacy rights and how the law protects you.
This privacy policy is provided in a layered format so you can click through to the specific areas set out
below. Alternatively, you can download a pdf version of the policy here: [Link]. Please also use the
Glossary to understand the meaning of some of the terms used in this privacy policy.
IMPORTANT INFORMATION AND WHO WE ARE
THE DATA WE COLLECT ABOUT YOU
HOW IS YOUR PERSONAL DATA COLLECTED?
HOW WE USE YOUR PERSONAL DATA
DISCLOSURES OF YOUR PERSONAL DATA
INTERNATIONAL TRANSFERS
DATA SECURITY
DATA RETENTION
YOUR LEGAL RIGHTS
GLOSSARY

Important information and who we are
1.1 Purpose of this privacy policy
This privacy policy aims to give you information on how Phi Partners International Limited collects
and processes your personal data through your use of this website, including any data you may
provide through this website including if you submit your CV via our website portal.
This website is not intended for children, and we do not knowingly collect data relating to children.
It is important that you read this privacy policy together with any other privacy policy or fair
processing policy we may provide on specific occasions when we are collecting or processing
personal data about you so that you are fully aware of how and why we are using your data. This
privacy policy supplements other notices and privacy policies and is not intended to override them.
1.2 Controller
Phi Partners Limited is the controller and responsible for your personal data (collectively referred to
as “Company”, “we”, “us”, or “our” in this privacy policy).
We have appointed a data privacy manager who is responsible for overseeing questions in relation
to this privacy policy. If you have any questions about this privacy policy, including any requests to
exercise your legal rights, please contact the data privacy manager using the details set out below.
1.3 Contact details
If you have any questions about this privacy policy or our privacy practices, please contact our data
privacy manager in the following ways:
Full name of legal entity: Phi Partners International Limited
Email address: legal@phipartners.com
Postal address: 110 Bishopsgate, EC2N 4AY, London, United Kingdom
Telephone number: +44 (0) 203 170 6365
You have the right to make a complaint at any time to the Information Commissioner’s Office (ICO),
the UK regulator 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.
1.4 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 28 th October
This being the first privacy policy that we have relied upon, historic versions are not available.
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. You can do this by using
the contact details on our website.
1.5 Third-party links

This website may include links to third-party websites, plug-ins and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites and are not responsible for their privacy statements. When you leave our website, we encourage you to read the privacy policy of every website you visit.

The data we collect about you
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 email addresses and telephone numbers.
– 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, your interests, preferences, feedback and
survey responses.
– Usage Data includes information about how you use our website, products and services.
– Marketing and Communications Data includes your preferences in receiving marketing from
us and our third parties and your communication preferences.
We may also collect, use and share Aggregated Data, such as statistical or demographic data, for
any purpose. Aggregated Data could be derived from your personal data but is not considered
personal data in law as this data will 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.
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). Nor do we
collect any information about criminal convictions and offences.
2.1 If you fail to provide personal data
Where we need to collect personal data by law or under the terms of a contract we have with you,
and you fail to provide that data when requested, we may not be able to perform the contract we
have or are trying to enter into with you (for example, to provide you with goods or services). In this
case, we may have to cancel a product or service you have with us, but we will notify you if this is
the case at the time.

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:
– apply to work for us or any third party
– apply for our products or services;
– create an account on our website;
– subscribe to our service or publications;
– request marketing to be sent to you;
– enter any competition, promotion or survey; or
– give us feedback or contact us.
–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, server logs and other similar technologies. We may
also receive Technical Data about you if you visit other websites employing our cookies. Please
see our cookie policy [add link] for further details.
– Third parties or publicly available sources. We will receive personal data about you from
various third parties and public sources as set out below:
Technical Data from the following parties:
(a) analytics providers such as Google based outside the UK;
(b) advertising networks such as LinkedIn based inside and/or outside the UK; and
(c) search information providers such as Google based outside the UK.
– Identity and Contact Data from data brokers or aggregators such as Hotjar or based outside the
UK.
– Identity and Contact Data from publicly available sources such as Companies House and the
Electoral Register based inside the UK.
How we use your personal data
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 obligation to find out more about the types of lawful basis that we will rely on to process your
personal data.

Generally, we do not rely on consent as a legal basis for processing your personal data, although we will get your consent before 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.
4.1 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

To register you as a new customer

(a) Identity
(b) Contact

Performance of a contract with you

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 enable you to partake in a prize draw, competition or complete a survey

(a) Identity
(b) Contact
(c) Profile
(d) Usage
(e) Marketing and Communications

(a) Performance of a contract with you
(b) Necessary for our legitimate interests
(to study how customers use our products/services, to develop them and grow our business)

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

(a) Identity
(b) Contact

Necessary for our legitimate interests (to study how customers use our products/services, to develop them, to

understand the effectiveness of the advertising we serve to you

(c) Profile
(d) Usage
(e) Marketing and Communications
(f) Technical 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 you about goods or services 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) To match candidate data to candidate job opportunities after collecting your CV via our portal

(a) Identity
(b) Contact
(c) Technical
(d) Usage
(e) Profile
(f) Marketing and
Communications

We may use data ourselves and/or pass our data to our client organisations in the event we believe that you are suitable for a vacancy, but we will only do this with your permission (which may be verbal, written, or otherwise and may be specific or general in nature). If your data is passed to client organisations, then in these circumstances, we will be acting on behalf of our client, and the handling of your personal data will be governed by the client’s own privacy policy.

4.2 Processing your CV data
You will normally directly provide us with most of the CV data we collect about you if you are applying for a job with us or any third party and we will keep this CV on our file. Personal data is normally submitted by you to us via our website or email or an equivalent one-to-one messaging platform. Some of your data may be taken from public sources such as LinkedIn or company or third party websites. We also collect data via browser cookies when you visit our website, which are explained in more detail below.

Your candidate data is stored in searchable digital formats in our cloud hosting environment. We maintain a highly secure digital infrastructure with rigorous security and redundancy standards and policies. To minimise the risk of losing data, they are not held in physical form. We retain your candidate data for up to five years from first contact with us whether or not you are hired by us or any third party. This time frame is based on the expectation that interest in career opportunities are likely to remain similar, changing only in terms of seniority, over the course of roughly five years. These retention periods are subject to your data rights, including the right to request we cease processing, which are explained further below. We use your candidate data to match you with job opportunities. As a candidate, we may use and process your data ourselves in relation to our own job vacancies. We may also pass your data to our client organisations or third parties in the event we believe you are suitable for one of their vacancies, but we will only do this with your permission (which may be verbal, written, or otherwise and may be specific or general in nature). If your data is passed to our client organisation or third party, then in these circumstances we will be acting on behalf of our client or the relevant third party and the handling of your personal data will be governed by the
client’s or third party’s own privacy policy. Note that we, our client organisations and/or third parties may use and process your data in some or all of the following ways, in line with our and their privacy policies.
– Assessing your suitability for a role
– Contacting you for interview and examination requests
– Background and credit checks (which may include using third party agencies)
– Contacting your referees
4.3 Marketing
We strive to provide you with choices regarding certain personal data uses, particularly around marketing and advertising.
4.4 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).
4.5 Third-party marketing
We will get your express opt-in consent before we share your personal data with any third party for marketing purposes.
4.6 Opting out You can ask us or third parties to stop sending you marketing messages at any time by logging into the website and checking or unchecking relevant boxes to adjust your marketing preferences OR by following the opt-out links on any marketing message sent to you OR by contacting us at any time.

4.7 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. For more information about the cookies we use,
please see our cookie policy.
4.8 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 the parties set out below for the purposes set out in the table
Purposes for which we will use your personal data above.
– Internal Third Parties as set out in the Glossary.
– External Third Parties as set out in the Glossary.
– Specific third parties listed in the table Purposes for which we will use your personal data above
such as [SPECIFIC THIRD PARTIES].
– Third parties to whom we may choose to sell, transfer or merge parts of our business or our
assets. Alternatively, we may seek to acquire other businesses or merge with them. If a change
happens to our business, then the new owners may use your personal data in the same way as
set out in this privacy policy.
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
We share your personal data within the Phi Partners International Limited’s group of companies.
These group companies are as follows:
Phi Partners International Inc. of 1209 Orange Street, Wilmington, DE 19801,
New Castle County;
Phi Partners International GmbH of Darmstadter Landstr. 116, 60598, Frankfurt
am Main, Germany;

Phi Partners International SAS of 1 Rue Julius et Ethel Rosenberg, Stop & Work
Bezons, 95870 Bezons;
Phi Partners International Limited of Splügenstrasse 10, 8002 Zürich,
Switzerland;
Phi Partners International Limited Londra, Sucursala Bucuresti SRL of 11, Dinu
Vintila, Euro Tower, 6 th Floor, 021101 Bucharest, Romania;
Phi Partners International Limited Bulgaria Branch of Sofia, p.k. 1715, bul.
Alexander Malinov № 85, fl. 1, office 1, Bulgaria.
Phi Partners International Limited Dubai, of Meydan, Free Zone, The Meydan
Hotel, Dubai, U.A.E;
Branch of Phi Partners International LTD of Lilian Towers, Prince Sultan Road,
Jeddah, Kingdom of Saudi Arabia;
This will involve transferring your data outside the UK.
Many of our external third parties are based outside the UK so their processing of your personal
data will involve a transfer of data outside the UK.
Whenever we transfer your personal data out of the UK, we ensure a similar degree of protection is
afforded to it by ensuring at least one of the following safeguards is implemented:
– We will only transfer your personal data to countries that have been deemed to provide an
adequate level of protection for personal data; or
– We will only transfer your personal data to countries which do not have an adequate level of
protection for personal data where we make such transfers in accordance with relevant data
protection law.
Please contact us if you want further information on the specific mechanism used by us when
transferring your personal data out of the UK.
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
8.1 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. Details of retention periods for different aspects of your personal data are set out in these terms and also the table Purposes for which we will use your personal data above.

Your legal rights
Under certain circumstances, you have rights under data protection laws in relation to your personal
data. Please click on the links below to find out more about these rights:
– 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.
– Request transfer of your personal data.
– Right to withdraw consent.
If you wish to exercise any of the rights set out above, please contact us.
9.1 No fee is 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.
9.2 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.
9.3 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.
Glossary
10.1 LAWFUL BASIS

Legitimate Interest means the interest of our business in conducting and managing our business to enable us to give you the best service/product and the best and most secure experience. We make sure we consider and balance any potential impact on you (both positive and negative) and your rights before we process your personal data for our legitimate interests. We do not use your personal data for activities where our interests are overridden by the impact on you (unless we have your consent or are otherwise required or permitted to by law). You can obtain further information about how we assess our legitimate interests against any potential impact on you in respect of specific activities by contacting us. Performance of Contract means processing your data where it is necessary for the performance of a contract to which you are a party or to take steps at your request before entering into such a contract. Comply with a legal obligation means processing your personal data where it is necessary for compliance with a legal obligation that we are subject to.

10.2 THIRD PARTIES

– HM Revenue & Customs, regulators and other authorities acting as processors or joint controllers based in the United Kingdom who require reporting of processing activities in certain circumstances.

10.3 YOUR LEGAL RIGHTS
You have the right to:

Request access to your personal data (commonly known as a “data subject access request”). This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it.

Request correction of the personal data that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us. Request erasure of your personal data. This enables you to ask us to delete or remove personal data where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal data where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your personal data to comply with local law. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request. Object to processing of your personal data where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms. You also have the right to object where we are processing your personal data for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms. Request restriction of processing of your personal data. This enables you to ask us to suspend the processing of your personal data in the following scenarios:
– If you want us to establish the data’s accuracy.
– Where our use of the data is unlawful but you do not want us to erase it.
– Where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims.
– You have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.
Request the transfer of your personal data to you or to a third party. We will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine- readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you. Withdraw consent at any time where we are relying on consent to process your personal data. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain products or services to you. We will advise you if this is the case at the time you withdraw your consent.

PHI PARTNERS WEBSITE PRIVACY POLICY