Welcome to the Ceuta Holding’s privacy statement.

Summary

We respect your privacy and we are committed to protecting your personal data. This privacy statement will inform you how we use and look after your personal data when you are a customer or you:

• Visit our website: www.ceutagroup.com (regardless of where you visit it from);
• Visit our social media pages, including:
  • LinkedIn: linkedin.com/company/ceuta-group;
  • Twitter: twitter.com/ceutagroup; and
  • Facebook: facebook.com/CeutaGroup
• Call us, write to us, or communicate with us in any way.

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.

This statement does not apply to you if you work for us or are applying to work for us, in which case you will be provided with separate privacy statements setting out that relationship with you. For example, if you use our job application forms via the links on our site.

This statement also tells you about your privacy rights and how the law protects you.

When we say “we”, “us”, or “Ceuta Holdings” that means the company Ceuta Holdings Limited. The Ceuta Group of Companies is made up of different companies, details of which can be found here: [https://www.ceutagroup.com/about/our-companies/]. This privacy statement is issued on behalf of Ceuta Holdings. If your communications with us relate to other Ceuta Group companies then we will pass your personal data to them so they can handle your enquiry. Their privacy statement will also apply to how they process your data.

Where we collect information about you, if that information is about you, or can be used by us or organisations with which we work, to find out about you, it is known as “personal data”.

The law says that we have to tell you what types of personal data we have about you, what we use it for, why we are allowed to use it in that way, and what your legal rights are. That is what this document – called a “privacy statement” – is for. We also have to tell you some other things – those are all covered in this statement.

The rules about personal data are detailed and can be difficult to understand. If you need help understanding anything in this policy, please contact us at dataprotection@ceutagroup.com

The simple version is this:

• • We collect information about you, including contact details (like your email address), when you give us that information on our website, when you call us, or communicate with us,
  • We treat all information we have about you very carefully. We do our best to make sure that information about you does not go to the wrong people or to people who might not look after that information properly.
  • If you ask us to do certain things with information about you, we usually have to do what you ask and you do not usually have to pay for this. Those things include:
    • Give you a copy of information about you
    • Put right any mistakes in the information we have about you
    • Stop using or delete information about you

If you want to ask us to do any of these things, or you have any questions or worries, you can contact us at dataprotection@ceutagroup.com You can also contact the organisation in charge of making sure we do the right things with your personal data – the Information Commissioner’s Office – by clicking here.

BACKGROUND

This policy is addressed to individuals who visit the websites or pages on social media platforms operated by Ceuta Holdings Limited (Ceuta Holdings, we, our or us) or our customers, and other individuals that may deal with us, including individuals at our suppliers. In this policy we collectively refer to these categories of individuals as “you”.

If you are applying for a job or you are one of our staff members or workers a different policy will apply, which will be provided to you.

Our privacy statement is provided in a layered format so you can click through the links below to take you to the specific sections set out below. Alternatively, you can contact us to ask for a copy.

Please also use the Glossary to understand the meaning of some of the terms used in this privacy statement.

1. IMPORTANT INFORMATION AND WHO WE ARE
2. THE DATA WE COLLECT ABOUT YOU
3. HOW IS YOUR PERSONAL DATA COLLECTED?
4. HOW WE USE YOUR PERSONAL DATA
5. DISCLOSURES OF YOUR PERSONAL DATA
6. INTERNATIONAL TRANSFERS
7. DATA SECURITY
8. DATA RETENTION
9. YOUR LEGAL RIGHTS
10. GLOSSARY

1. IMPORTANT INFORMATION AND WHO WE ARE

Purpose of this privacy statement

This privacy statement aims to give you information on how Ceuta Holdings collects and processes your personal data when you are a customer or you:

• • Visit our website: https://www.ceutagroup.com (regardless of where you visit it from);
  • Visit our social media pages, including:
    • LinkedIn: https://www.linkedin.com/company/ceuta-group;
    • Twitter: https://twitter.com/ceutagroup; and
    • Facebook: https://www.facebook.com/CeutaGroup/;
  • Call us, write to us, or communicate with us in any way.

It does not apply to you if you work for us or are applying to work for us, in which case you will be provided with separate privacy statements setting out that relationship with you. For example, if you use our job application forms via the links on our site.

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 statement together with any other data protection or privacy statement that 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 statement supplements other notices and privacy policies and is not intended to override them.

Controller

Ceuta Holdings Limited (registered company number 08528478) with its registered head offices at Hill House, 41 Richmond Hill, Bournemouth, Dorset, BH2 6HS is the controller and responsible for your personal data (referred to as “Ceuta Holdings”, “we”, “us” or “our” in this privacy statement).

The Ceuta Group of Companies is made up of different companies, details of which can be found here. This privacy statement is issued on behalf of Ceuta Holdings. If your communications with us relate to other Ceuta Group companies then we will pass your personal data to them so they can handle your enquiry. Their privacy statement will apply to how they process your personal data.

If you have any questions about this privacy statement, including any requests to exercise your legal rights, please contact the Data Privacy Manager using our contact details below.

Contact details

If you have any questions about this privacy statement or our privacy practices, please contact our Data Privacy Manager in the following ways:

Full name of legal entity: Ceuta Holdings Limited

Email address: dataprotection@ceutagroup.com

Postal address: 41 Richmond Hill, BH2 6HS, Bournemouth, UK

Telephone number: 01202 449781

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 we would encourage you to contact us in the first instance to discuss these.

Changes to the privacy statement and your duty to inform us of changes

Any changes that we make to this policy in the future will be posted on this page and, where appropriate, notified to you by email. Please check back frequently to see any updates or changes to our privacy policy.

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.

Third-party links

This website, and information that we may post on our website or via the pages on social media platforms which we operate (our sites) may include links to third-party websites, plug-ins and applications, for your convenience and information. Clicking on those links or enabling those connections means you may leave our sites and may allow third parties to collect or share data about you.

We do not control these third-party websites, the social media platforms themselves, or third party, social media accounts or apps and are not responsible, or liable, for how they process your personal data or for their privacy statements. For example, they may send their own cookies to users, collect data or solicit personal data from you. When you leave our sites, we encourage you to read the privacy statement of every website, app and social media account that you use or visit.

If you are applying for a job with us, you may be asked to complete an online application form. This form is provided by a recruitment software provider. All personal data that you provide via that form is stored on our systems, and is not accessed or otherwise processed by that provider.

2. THE DATA WE COLLECT ABOUT YOU

When you contact us through our sites, or communicate with us, or visit our premises, you may provide us with personal data about you.

Personal data 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, last name, title, company name and email address].
• Contact Data includes [email address 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].
• Usage Data includes information about how you use this website, and our products and services.
• Social Media Data includes Communications Data via the relevant social media channel and limited Identity Data where you engage with our social media accounts.
• Communications Data includes personal data included in your communications with us.
• CCTV Data includes images and video recordings which may contain personal data collected by our CCTV systems at our premises.

We 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 statement.

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, or we are processing your personal data to fulfil a request you have made, 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) or we may not be able to otherwise comply with your request. In this case, we may have to cancel a product or service you have with us but we will use reasonable efforts to notify you if this is the case at the time.

3. 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 Data, Contact Data, and Correspondence Data, Social Media Data by filling in forms or by corresponding with us by post, phone, email, social media, website or otherwise. This includes personal data you provide when you:
  • enquire about our products or services;
  • give us feedback or contact us.
• CCTV Systems. Where our Group Company Ceuta Healthcare operates and manages CCTV on our behalf at our premises.
• Automated technologies or interactions. As you interact with our sites, 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. Please see our cookie plicy for further details.
• Third parties or publicly available sources. We will receive personal data about you from various third parties as set out below:
  • Technical Data from the following parties:
    • analytics providers such as Google
  • Marketing data. We collect your Contact Data if you make an enquiry via one of our Ceuta Group companies, and that enquiry is dealt with by or we need to pass you to another Ceuta Group company.
  • Social Media Data: When you use social media platforms such as Facebook, Linked In and Twitter to communicate with us or engage with us via that platform or share content with us.
    • Those platforms may provide us with information about you, such as where you send us a message, or like or comment on us or our content.
    • When contacting us through a social media platform, we suggest you also familiarise yourself with the privacy information provided by the relevant platform, which is not controlled by us.
    • If you wish to contact us via a social media platform, we suggest you use direct messaging rather than public messaging if you wish to share any personal data with us. Any personal data shared in public on social platforms is shared at your own risk.

4. HOW WE USE YOUR PERSONAL DATA

We will only use your personal data when the law allows us to do so. 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, refer to the Glossary at the end of this document.

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.

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.