Privacy Policy

(Last updated: 24 May 2017) 

Introduction

  1. We recognise and value the importance of protecting the privacy of Users of our Website.  We are committed to ensuring that we manage your personal data professionally and in compliance  

with all applicable data protection laws. Part of this commitment is to ensure that there is transparency  about how we process personal data in connection with the services that we provide and with the  operation of our website, which is located at cavalryfreelancing.com (the ‘Website’).. This policy  includes an explanation of:

1.1. what data we are processing;  

1.2. why we are processing it and what we do with it;  

1.3. whether we will share it with anyone else;  

1.4. whether we will transfer it outside of the United Kingdom;  

1.5. how we keep your data safe; and  

1.6. your rights.  

  1. We hope that you find this Privacy Policy helpful. If you have any questions, please don’t hesitate  to contact us. 

About Us

3.Our company name is &Friends Payroll UK Ltd and our registered company number is 13873404.  We are located at 103 Gaunt street, London, SE1 6DP, and our registered office is at Monometer  House, Rectory Grove, Leigh-On-Sea, SS9 2HL In this policy we have referred to &Friends Payroll  UK Ltd as ‘Cavalry’, ‘us’ or ‘we’.

4.For any queries concerning your data, please contact us at the above address or by email  at [contact@cavalryfreelancing.com] 

your personal DATA

5.Subject to the Cavalry Website Terms, any person may be able to access or use certain sections of  this Website via the internet without registering with or disclosing any personally identifying  information to Cavalry (an ‘Unregistered User’).

6.To make full use of the functionality of this Website, you will need to register with Cavalry. There are  two different types of registration (collectively referred to as ‘Registered Users’);  

6.1 freelancers who are seeking to be engaged by third parties to perform freelancing services  (‘Freelancers’); and  

6.2 companies who are seeking to engage Freelancers to perform services for them (‘Clients’).  In limited circumstances a Freelancer may also be a Client (and vice versa).

Why do we need to collect your personal information?

7.The Website is more complicated than a traditional market place, because we offer a talent  management system that streamlines the way Clients and Freelancers find each other and work  together. Our system is designed to handle freelance engagements from end-to-end, including  allowing Clients to undertake searches for freelancing talent, to view and organise rosters, facilitate  interaction between Freelancers and Clients and to allow for the booking and invoicing of freelancing  services. As such, we need to collect, store, use and disclose personal data as part of the normal  operation and functioning of our Website. 

How will we collect your personal information?

8.We will always interact with you in an open and transparent manner, including by informing you: 

when we collect your personal information; and  

how we will manage your personal information. 

When do we collect personal information?

9. Visitors to our Website choose to interact with us in ways that require us to gather personal data.  The amount and type of information that we gather depends on the nature of the interaction.  

10. We collect personal data in a number of ways, including:  

  • when you visit and interact with our Website and related software (including any mobile  applications);  
  • when you sign up for a client account, submit form on our Website or sign up for our  newsletter;  
  • when you engage in transactions with us;  
  • when you submit your application to join as a Freelancer;  
  • Through cookies and other technologies that allow us to give you a better experience on our  Website; and 
  • When you contact us independently of the Website, such as by email, phone or in person. 

What personal information will we collect?

  1. 11. In order to operate the Website, we need to collect a sufficient amount of your personal data to  allow us to undertake our functions, and to allow any transactions between us to take place efficiently  and securely. 

12. You may be able to browse certain pages of our Website anonymously. However, in order to  engage in the freelance process using our Website, you will need to create an account with us and it 

is not practical for you to transact with us anonymously or using a pseudonym. When creating an  account, we will request that you provide us with personal information. This may include, but is not  necessarily limited to: 

  • your full name and prefix (e.g. Mr or Mrs), so that we can identify you;  
  • your photograph/s;  
  • your primary telephone number, so that we can contact you if there is a problem;  your postal address (business and/or home);  
  • your email address, so that we can correspond with you electronically and administer your  account (e.g. password resets);  
  • credit card and account details; and  details of the company you represent (eg company name, address and contact details) and  the title of your position at that company. 
  1. If your personal details change, it is your responsibility to update your account with those  changes, so that we can keep our records complete, accurate and up to date.  
  2. We will never collect ‘sensitive’ information about you and you must not disclose sensitive  information to us. Sensitive information includes certain kinds of information about you, such as your  political opinions or your racial or ethnic origin.  
  3. You must not provide us with the personal information about another person unless you have first  obtained that person’s prior consent to do so and you have told them their personal information will be  handed in accordance with this Privacy Policy (including where they find it). 

How we use your personal data and our applicable lawful basis?

16.We will use your personal information for a number of purposes associated with the operation of  the Website or as otherwise required or authorised by law.  

17.We may also process your information to allow us to pursue our legitimate interests including:  provide you with functional access to the Website, including the ability to participate in various  stages of the freelance search process with a view to engaging a Freelancer if you are a  Client or propose to provide freelancing services to a Client if you are a Freelancer; 

  • to put Freelancers in communication with Clients (and vice versa);  
  • identify you and authenticate your identity; 
  • contact you in respect of the Website, and the freelance process;  
  • ensure that Cavalry Freelancing receives payment of any fees due to it;  
  • facilitate payment by Clients to Freelancers;  
  • send you service or promotional communications, including surveys and information about  security updates;  
  • create or distribute marketing material that is relevant to you;  
  • permit content on the Website (such as postings or third party advertisements) to be targeted,  on an aggregate basis, to the users for whom it is most likely to be relevant;  
  • undertake quality assurance and training;  
  • conduct research;  
  • develop new Website features;  
  • customise the content on the Website and any advertising on the Website;  develop relationships with affiliate service providers;  
  • for statistical reporting purposes, on an anonymised and aggregated basis;  investigate, prevent or take action regarding any breach or suspected breach by you of the  Terms of Use or any law;  
  • act in a way that is required or authorised by or under law  
  • undertake any other uses identified at the time of collection of your personal data.

18.If you are a Freelancer, certain of your personal data included in your professional profile to may  be visible to Clients, depending on the extent to which you have opted in to share your personal data  via your account settings.  

19. We may also offer a profile feature that allows portions of a Freelancer’s profile to be published to  the Internet. If you are a Freelancer, certain portions of your public profile may be indexed and  displayed through public search engines such as Google when someone searches for your name,  and allow them to click through to your Cavalry profile. You may opt out of this feature entirely in your  account settings. [However, you should be aware that third-party search engines may not  automatically update their caches, which may contain old public profile information.]  

20.Our lawful basis for keeping you updated about our products and services is usually our legitimate  interests (namely, to grow our business). The secondary purpose for which we will use your personal information is to allow us to send you  direct marketing in relation to our respective goods and services [or the respective goods and  services of trusted third parties]. If you do not agree to us using your personal information for this  secondary purpose, you should just notify us of this at the time you create a user account. You can  also change your mind at a later date by notifying us. You can opt-out of receiving direct marketing  materials or ‘unsubscribe’ at any time in a number of ways. Firstly, you can log on to your user  account at the Website and change your preferences and settings. Secondly, you can in many cases  unsubscribe via the marketing materials themselves. For example, any direct marketing emails we  send to you will contain a functional ‘unsubscribe’ feature which will always be valid for at least 30  days from the date of the communication. Finally, you can always change your marketing preferences  by contacting us using the contact details provided.  

21.Where relevant you consent to Cavalry posting and using any photographs, content and/or  personal information you might upload on our website or have otherwise provided consent to publish  on our website, blog, in our marketing collateral or social media channels, which we may use in order  to provide our services, the marketing of our services or for the purpose of our functions and/or  activities.  

Who will we disclose your personal information to?

  1. We may disclose your personal data:  

for the purposes for which it is collected and for any related purposes, including:  

  1. to any person where necessary or desirable in connection with the provision of the Website,  and the services to you;  
  2. to any person where necessary or desirable in connection with the management of our  relationship with you; and  
  • to our external advisors, service providers, subcontractors and suppliers, so that they can  provide professional, financial, technical, administrative or other advice and services in  connection with the operation of our business;  
  • if you are a Freelancer, to Clients or, if you are a Client, to Freelancers;  
  • to our affiliated entities for the purpose of such affiliated entities contacting you about their  products and services [or the products and services of trusted third parties]; 
  • to any person who acquires or expresses an interest in acquiring all or any part of our  business;  
  • to facilitate payments in relation to the freelancing process;  
  • to any person where necessary or desirable in connection with us investigating, preventing or  taking action regarding any breach or suspected breach by you of the Website Terms or any  law; and  
  • to any person as required or authorised by or under law, and to any other person to which you  subsequently consent from time to time.  

23.When you use the Website to participate in the freelance search process or otherwise  communicate in a public forum on the Website, your user ID and all or some of the material you post  may be visible to other users on the Website and may be publicly available to other internet users. We  therefore suggest that you use discretion and caution when posting information to the Website. We do  not in any way control, and do not accept any responsibility or liability whatsoever for, the disclosure  or use of personal information which is voluntarily posted by you in any publicly accessible area of the  Website.  

24.We will never sell your personal information.  

25. We will never use or disclose your personal data for the purpose of sending you spam, that is,  unsolicited commercial messages which offer or advertise goods or services. 

Transferring your data outside of the United Kingdom ('UK')

26. The information that you send to us may be transferred to countries outside the UK. By way of  example, this may happen if any of our servers or those of our third-party service providers are  located in a country outside of the UK. These countries may not have similar data protection laws to  the UK. 

27. If we transfer your information outside of the UK in this way, we will take steps to ensure that  appropriate security measures are taken with the aim of ensuring that your privacy rights continue to  be protected. These measures include imposing contractual obligations on the recipient of your  personal information or ensuring that the recipients are subscribed to ‘international frameworks’ that  aim to ensure adequate protection. Please contact us if you would like more information about the  protections that we have put in place.

Data security and how will we hold your personal information

28.We are committed to storing your personal information as securely as possible. 

29.We will take all reasonable to steps to protect your personal data from misuse, loss, interference  and unauthorised access, modification or disclosure.  

30. We have adopted appropriate technical and organisational measures to protect the personal data  we collect and use having regard to the state of the art, the nature of the data stored and the risks to  which the data is exposed to human action or the physical or natural environment. However, as  effective as our security measures are, no security system is impenetrable. We cannot guarantee the  security of our database.  

31. The transmission of information via the internet is not completely secure. Although we will do our  best to protect your personal data, we cannot guarantee the security of your data transmitted to our  website; any transmission is at your own risk. Once we have received your information, we will use  procedures and security features to try to prevent unauthorised access.  

32. 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.  

33. We will only retain your personal data for as long as necessary to fulfil the purposes we have  collected it for, including for the purposes of satisfying any legal, accounting, or reporting  requirements.  

Why do we use cookies?

  1. Cookies are small text files that many websites place on your computer or device. Some cookies  are deleted when you close down your browser. These are known as session cookies. Others remain  on your device until they expire or you delete them from your cache. These are known as persistent  cookies and enable us to remember things about you as a returning visitor.  

To find out more about cookies, including how to see what cookies have been set and how to manage  and delete them, visit www.allaboutcookies.org.  

35. We also use cookies to, for example, allow you to remain permanently signed into the Website  and to save information in forms to be filled out on the Website, for you to come back to later. Cookies  may also be used to allow Freelancers to save a property to a list of favourites to come back to later.  

36.Most browsers are automatically set up to accept cookies. The storage of cookies can be  deactivated or the browser can be configured in such a way that it sends a notification when cookies 

are sent. You are always free to decline our cookies, however doing so may significantly interfere with  your use of the Website.  

37.We use the following third party cookies on our Website: 

Sentry 

Analytics cookies  

Application performance monitoring and error logging  

Facebook  

Advertising cookies  

Tracking ad spend and attribution  

Google Analytics  

Analytics cookies  

User flows and monitoring  

Google Ads  

Advertising cookies  

Tracking ad spend and attribution  

Amplitude  

Analytics cookies  

User and behavioural tracking analytics  

Fullstory 

Analytics cookies  

User and behavioural tracking analytics  

ActiveCampaign 

Functional cookies  

Support live chat  

ActiveCampaign #2 

Analytics cookies  

User flows and lifecycle event tracking

YOUR rights to access data

  1. We always aim to be as open as we can and allow people access to their personal information.  Where we hold your personal data, you can make a ‘subject access request’ to us and we will provide  you with:  

38.1. a description of it;  

38.2. an explanation of why we are holding it;  

38.3. information about who it could be disclosed to; and  

38.4. a copy of the information in an intelligible form – unless an exception to the disclosure  requirements is applicable. 

39. If you would like to make a ‘subject access request’ please make it in writing to our contact email  address noted above and mark it clearly as ‘Subject Access Request’.  

40. If you agree, we will try to deal with your request informally, for example by providing you with the  specific information you need over the telephone.  

41.Unless you agree a different time, we will complete your subject access request within one month. 

What if your personal information is wrong?

42.We will take reasonable steps to ensure that the personal information we hold, use and disclose is  accurate, up to date and complete. However, we will not take any administrative steps to verify the  accuracy or completeness of the information you provide to us at the time of collection (for example, if  you make a mistake when typing in your details).  

43.If you suspect or believe that the personal information we have is not accurate, complete or up to  date, please either (a) log in to the Website and update your personal information as appropriate, or  (b) contact us at the details below and we will respond to your request within a reasonable period.  When responding, we will take reasonable steps to correct that information and to ensure that it  remains accurate, complete and up to date in the future. If for some reason we are unable to correct  your personal information, we will provide you with our reasons in writing and your further options for  complaint. We will not ordinarily charge you for requesting the correction of your personal information.

right to be forgotten

44. If we hold personal data about you, but it is no longer necessary for the purposes that it was  collected and cannot otherwise be justified – you have the right to request that we delete the data.  

right to complain

45. You always have the right to complain to the personal data regulator, the ICO. You may also be  entitled to seek compensation if there has been a breach of data protection laws.

changes to this policy

46.From time to time, we may amend this Privacy Policy and will publish the amended version on our  Website. 

Policy Updates

47.This policy was last updated on 14 December 2021.

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