We are committed to safeguarding your privacy.

Please read the following policy to understand how your personal data will be treated when you provide information via our system.

This policy (together with our User Terms and any other documents referred to in it) sets out the basis on which any personal data we collect from you, that you provide to us, or that we collect from other sources about you, will be processed by us.

This policy applies where you use our websites (our site), our mobile applications (our app), or communicate with us in relation to our site, our app or our services. In this policy we call our site, our app and our services collectively our “Service”.

The Service is used for a range of purposes by LaunchPad’s customers, which our customer will make clear to you when you use the Service. For example, for recruitment, recruitment agency services, internal staff engagement and surveys. We refer to our customer in this policy as the “employer”.

It is important that you read this policy together with any other policy or fair processing notice 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 personal data. This policy supplements the other notices and is not intended to override them.

Privacy Policy Sections:

Responsibility for personal data
Contact Details
Personal data we collect
If you fail to provide personal data
Cookies
How your personal data is collected (where we process your data as either a processor or a controller)
How your employer uses your personal data
How we use personal data (as a controller for our own purposes)
Communications
Change of purpose
Sharing your information
Where we store your personal data and our security
How long will you store my personal data for?
Your rights
Changes to our privacy policy and your duty to inform us of changes
IP addresses and cookies

Responsibility for personal data

Your employer

Our system is a platform which an employer can use to manage their processes including recruitment and employee engagement processes. The system allows you to provide various information to the employer, such as your contact details, your CV, video and audio interviews, assessment answers as well as general communication.

Your employer may also use our system to automate some of their decision making process. If you would like to know more about this, please see here.

LaunchPad Recruits act as a processor (rather than a controller) in relation to personal data which you provide via our Services – which means we act on behalf of your employer for the purposes of using our services. That means that your employer, will be responsible for deciding what information to collect from you, how that personal data is used, when it is updated or deleted. The employer has its own obligations as a controller under the applicable data protection legislation. For example, they must comply with the data protection principles as set out in the EU’s General Data Protection Regulation and the UK’s Data Protection Act 2018, which you can find out more about here www.ico.org.uk. In particular, any information which you provide for the purposes of the employer’s process must be handled and stored securely, and not disclosed without authorisation.

We have a contract in place with each employer which uses our system, which sets out in detail how we are required to process your personal data.

You should read any privacy information that your employer has provided to you. It will set out how your personal data will be handled by them in more detail.

LaunchPad Recruits

In limited circumstances, we also process some personal data that you provide as a controller – when we do so, it means that we are primarily responsible for that data, and make decisions about how that data is used. Most importantly, this type of personal data is not shared with your employer, and is not used as part of your process.

We act as a controller in relation to your personal data for the following purposes:

- our internal research and development. For example, our information scientists and occupational psychologists use computer algorithms which analyse video content to make better judgements about candidates. We use your video content to test and improve our algorithms and our services to achieve goals such as improving decision making, and removing decision bias.

- Analysis about how you use our service at a technical level, and for our own statistical analysis to help improve the Service. For example, we may collect information about your browser, and computer operating system to allow us to provide an efficient browsing experience.

We have set out how we process this type of personal data in more detail below.

Contact Details

Our registered company name is LaunchPad Recruits Ltd. Our registered office at Fleet House, 8-12 New Bridge Street, London, EC4V 6AL.

We have appointed a Compliance Committee who is responsible for overseeing questions in relation to this policy. If you have any questions about this policy, including any requests to exercise your legal rights, please contact us by email to support@outmatch.com.

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). If you are based in a different country you may have different rights to those reflected in this policy. We would, however, appreciate the chance to address your concerns before you approach the ICO so please contact us in the first instance.

Personal data we collect

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 collect personal data in two broad categories (1) where we process personal data on behalf of an employer (where we act as a processor) and (2) where we use that personal data for our own purposes (where we act as a controller).

Information we may collect where we process personal data on behalf of your employer (where we act as a processor) which is shared with your employer

- Application data which you provide via our Service. We will receive information about you where you or your employer provide information via our Services, for the purposes of your process. We call this "Application Data", which may include:

contact data which includes name, address, email address and telephone numbers.
video and audio content.
question responses.
your demographic information.
details about your experience such as your past work experience.
records of correspondence between you, us and your employer regarding your application process.
any surveys that you chose to complete where we have told you that the survey is for the employer as part of your application process. For example, the employer may ask you to provide feedback on your experience.
details of your use of the Services in relation to a specific employer, including traffic data (such as from which site you linked to our Service and pages of the Service that you visit), location data, logs used to support your use of the Service.
some of the information that you provide via the Service may include sensitive types of data, which may include special categories of personal data. This may include information which reveals information about your ethnicity, religious or philosophical beliefs, sexual orientation, trade union membership, and information about any criminal convictions and offences (including data about criminal allegations, proceedings or convictions) or linked to related security measures. Such information should only be requested by your employer where they are legally permitted to do so (for example, where they are required to confirm suitability to perform a role, perform a DBS check, or they wish to collect diversity monitoring information). You are advised to only share sensitive information if you are happy to disclose it to us and your employer as part of your application.

- Technical data, including the Internet protocol (IP) address used to connect your computer to the internet, your login information, browser type and version, time zone setting, browser plug-in types and versions, operating system and platform and other technology on the devices you use to access our system.

- Usage data, which includes information about your use of the system, including the full Uniform Resource Locators (URL) clickstream to, through and from our Service (including date and time page response times, download errors, length of visits to certain pages, page interaction information (such as scrolling, clicks, and mouse-overs); frequency and number of views of particular profiles; application logs detailing who has added, edited or amended content and when; methods used to browse away from the page and any phone number used to call our customer service number.

- Information we receive from other sources. We may receive information about you from third party processors which analyse your application data to derive information to support our Service.

Information we collect where we use that personal data for our own purposes (where we act as a controller)

We may collect, use, store and transfer different kinds of personal data about you for our own purposes, which we have grouped together follows:

- Information we collect about you. With regard to each of your visits to our Service we may automatically collect the following information:

Application data (as defined above).
LaunchPad survey responses where we have told you that the survey is for our purposes not the employer’s. For example, we may ask you to provide feedback on your experience. We do not share this with your employer, or use it for making any decisions about your application process.
Records of correspondence between you, and us which do not relate to your application process.
Technical data (as defined above).
Usage data (as defined above)
Identity data which includes username and password.
Contact data which includes address, email address and telephone numbers where you correspond with us outside your application process.
We also collect, use and share aggregated data such as statistical or demographic data for any purpose. This aggregated data may be derived from your personal data but it is anonymised as this data does not directly or indirectly reveal your identity and therefore it is not considered personal data in law. For example, we may aggregate your usage data to show how many views a job description has had. We may aggregate your contact data to show the number of applicants are from particular areas of the country. 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 policy.
We do not collect any special categories of personal data or information about criminal convictions and offences, except to the extent that such data is included in your Application data or as part of a LaunchPad survey. For example, if your video or audio recording reveals information about your health or religious beliefs where you have volunteered that information, or it is obvious from your appearance. See below for further details.

- Information about other people. If you provide information to us about any person other than yourself, such as your referees, or personnel at your previous employer, your clients, or your suppliers, you must ensure that they understand how their information will be used and that they have given their permission for you to disclose it to us and for you to allow us to use it.

- Information from Clients 18 and Under. If you are aged 18 or under, you must obtain your parent or guardian’s permission beforehand to use our system. Users without this consent are not allowed to provide us with personal data.

- Information we receive from other sources. We may receive information about you from other systems used by the employer such as applicant tracking systems or assessment tools. We may also receive information from 3rd party processors who derive information from

If you fail to provide personal data

Where an employer requires specific information about you to complete your application process and make a decision about you, where we or your employer need to collect personal data by law, and you fail to provide that data when requested, we may not be able to provide our services (for example, to provide you with access to our system). In this case, we may have to reject or cancel your account and deny you access to our system.

Cookies

Our Service uses cookies to distinguish you from other users of our Service. This helps us to provide you with a good experience when you use our Service and also allows us to improve our Service. For detailed information on the cookies we use and the purposes for which we use them see our Cookie policy.

How your personal data is collected (where we process your data as either a processor or a controller)

We only collect personal data where:

- Direct interactions. Where you or your employer provide that data to us. you register your identity or contact details by filling in forms on the Service or by corresponding with us via our system or by answering questions or submitting information using the Service. This includes personal data you provide when reporting a problem with our system, request support, or give us some feedback in relation to the system or in relation to your application process.

- Automated technologies or interactions.

Third party tools, which analyse your application data to derive information to support our Service.
As you interact with our Service, we may automatically collect technical data and usage data about your equipment, browsing actions and patterns. We collect this data by using cookies, server logs and other similar technologies. Please see our Cookie policy for further details.
An employer may provide information through integrations with their own systems (such as HR management systems, and applicant tracking systems).

- Third parties or publicly available sources. We may receive personal data about you from various third parties and public sources as set out below:

Other providers which you interact with as part of an application or other process you perform using the Service (such as psychometric tests).
Data from third parties, including: analytics providers such as Google based outside the EU, job boards or job advertising services which may be based outside the EU.
Data from public sources such as geographic location of IP addresses.

How your employer uses your personal data

Your employer will use your personal data for the purposes of the process they are conducting such as completing your application process, and assessing your suitability for the relevant role. They are responsible for your personal data, when used for that purpose, and therefore their privacy policy will provide you with further detail about how they process your personal data.

Automated decision making including profiling

Our system can be used by employers to make automated decisions. The tool applies algorithms and machine learning techniques to review your video and audio recordings and any other data collected via our Service (excluding any special categories of personal data or criminal offence data), to produce indicative scores for the employer to consider when making their decision about your application. We have set out more information here which explains the logic of the tool, and the significance of the decisions it allows an employer to make, and the safeguards in place to make sure the tool functions correctly and fairly.

The tool does not use any special categories of personal data, or criminal offence data, to inform any decision made about you.

How we use personal data (as a controller for our own purposes)

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 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 perform the contract we are about to enter into with you or have entered into with you.

- Where we have consent from you to do so.

- Where we need to comply with a legal or regulatory obligation.

Click here to find out more about the types of legal basis that we will rely on to process your personal data.

Where we rely on consent as a legal basis for processing your personal data you have the right to withdraw consent by contacting us using support@outmatch.com. Most importantly, if you do not give your consent or later withdraw your consent, that fact will not be passed to your employer or considered as part of your application process.

We have set out below 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 using support@outmatch.com 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	Retention period for personal data (see further below)
To conduct internal research and development to test and improve our algorithms and services.	Application Data LaunchPad Survey Responses Records of Correspondence Technical Data Usage Data	(a) Our legitimate interests and of our customers (in relation to your personal data which is not special category data or criminal offence data) to test and improve our algorithm and services (b) Consent in relation to your personal data which is special category data or criminal offence data (c) Where you have made special categories of personal data or criminal offence data manifestly public.	Up to 3 years following the date provided to us
To manage our relationship with you which will include: (a) To administer your user account (b) To process requests for support or information outside your application process. (c) To notify you about changes to our services. (d) Notifying you about changes to our User Terms or privacy policy (e) Asking you to take a survey (f) To comply with our legal obligations	Application Data LaunchPad Survey Responses Records of Correspondence Technical Data Usage Data Identity Data Contact Data	(a) Necessary for our legitimate interests (to keep our services up to date, to keep our records updated and to study how customers use our products/services) (b) Performance of a contract with you (c) Necessary to comply with a legal obligation (such as responding to subject access requests) (d) To the extent that we have contacted you to review or take a survey we process that data on the basis of consent.	Up to 3 years following the date provided to us
To optimise the presentation of this our site and our app for your browser or operating system.	Technical Usage	(a) Necessary for our legitimate interests and of your employer (as our customer) to ensure users have easy access to our system.	Up to 3 years following the date provided to us
To administer and protect our business and our system (including troubleshooting, testing, system maintenance, support, reporting and hosting of data)	Records of Correspondence Technical Data Usage Data	(a) Necessary for our legitimate interests (for running our business, provision of administration and IT services, network security, to prevent fraud, identity verification (where required). (b) Necessary to comply with a legal obligation	Up to 3 years following the date provided to us
To use data analytics to improve our system, customer relationships and experiences	Application Data LaunchPad Survey Responses Records of Correspondence Technical Data Usage Data	(a) Necessary for our legitimate interests (for running our business, provision of administration and IT services, network security, to prevent fraud, identity verification (where required).	Up to 3 years following the date provided to us
To use data analytics to improve our system, customer relationships and experiences	Application Data LaunchPad Survey Responses Records of Correspondence Technical Data Usage Data	(a) Necessary for our legitimate interests (to define types of customers for our products and services, to keep our system updated and relevant, to develop our business and to inform our marketing strategy)	Up to 3 years following the date provided to us
In the context of a business reorganisation or group restructuring exercise, including a business or asset sale.	Application Data LaunchPad Survey Responses Records of Correspondence Technical Data Usage Data Identity Data Contact Data	(a) Necessary for our legitimate interests to manage our business.	Up to 3 years following the date provided to us

Communications

LaunchPad Recruits may contact registered users on occasion to keep you updated about your application process (such as interview dates, deadlines and status of your process), and to inform you about system changes including material changes to our User Terms or this policy.

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 using support@outmatch.com.

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.

Sharing your information

We may have to share your personal data with the parties set out below:

- to the employer as part of your application process

- to our contractors to enable us to provide and develop the Service. This includes:

Email hosting, and messaging system providers
Data storage providers
IT support and service management providers
Other assessment providers. For example, psychometric test providers who your employer wishes to use to perform assessments
Project management providers
Voice transcription providers
Video recording and processing providers
Scheduling tool providers
Background check providers.

- to an acquirer if we 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.

- to our group companies, where they provide us with services which support our system.

- If we are under a duty to disclose or share your personal data in order to comply with any legal obligation, or in order to enforce or apply our terms of service and other agreements; or to protect the rights, property, or safety of LaunchPad Recruits Limited, our customers, candidates, or others.

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.

We will not export your personal data from the EEA, except where:

- We have your approval.

- To our support team, based outside the EEA (which are our employees and are required to comply with our data protection policies)

- To our data processors acting under our instructions (where we have appropriate safeguards in place).

- If you are using the Service and are located in the EEA with a employer located outside the EEA, to the employer.

Where we store your personal data and our 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. For more information about our security measures, please see here) or contact us using support@outmatch.com.

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 strictly limit access to your personal data to those that require it for the purposes set out in this policy.

Where you have a password which enables you to access to our system, you are responsible for keeping that password confidential. We ask you not to share a password with anyone.

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.

Unfortunately, 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 via our system; any transmission is at your own risk.

How long will you store my personal data for?

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

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 requirements.

Details of retention periods for different aspects of your personal data where we act as a controller, are in the table above.

Where we process your personal data as a processor, we retain that information as agreed with the relevant employer (which they will make clear to you).

In some circumstances you can ask us to delete your data: see Request erasure below for further information.

In some circumstances we may anonymise your personal data (so that it can no longer be associated with you) for research or statistical purposes, in which case we may use this information indefinitely without further notice to you.

Your rights

Our system may, from time to time, contain links to and from the websites of our employer clients, partner networks, advertisers and affiliates. If you follow a link to any of these websites, please note that these websites have their own privacy policies and that we do not accept any responsibility or liability for these policies. Please check these policies before you submit any personal data to these websites.

Under certain circumstances, and depending on our relationship with you as a controller or processor, you have rights under data protection laws in relation to your personal data:

- 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 held about you and to check that it is being lawfully processed.

- Request correction of your personal data that is held about you. This enables you to have any incomplete or inaccurate data held about you corrected, though the accuracy of the new data you provide may need to be verified.

- Request erasure of your personal data. You can ask for your personal data to be deleted or removed 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. 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 your personal data. This enables you to ask that processing of your personal data to be suspended in the following scenarios: (a) if you want us to establish the data’s accuracy; (b) where use of the data is unlawful but you do not want it to be erased; (c) where you need the data to be held even if we no longer require it as you need it to establish, exercise or defend legal claims; or (d) you have objected to the use of your data but we need to verify whether we have overriding legitimate grounds to use it.

- Request transfer of your personal data to you or to a third party. You can ask to be provided with, or that a third party you have chosen is provided with, 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.

- Right to withdraw consent 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.

If you wish to exercise any of the rights set out above, please Contact us using support@outmatch.com.

No fee 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 may refuse to comply with your request in these circumstances.

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.

Time limit to respond - We try to respond to all legitimate requests. Occasionally it may 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.

Changes to our privacy policy and your duty to inform us of changes

This version was last updated on 25 May 2018 and historic versions can be obtained by contacting us.

Any changes we may make to our privacy policy in the future will be posted on this page and, where appropriate, you will be notified via an announcement to your registered email address.

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.

IP addresses and cookies

When you visit our website our server will record your IP address together with the date, time and duration of your visit and we set cookies. An IP address is an assigned number, similar to a telephone number, which allows your computer to communicate over the Internet. It enables us to identify which organisations have visited this website. The cookie similarly tracks your usage of the site. A cookie is a small file that can be placed on your computer's hard disk or on a website server.

It does not retrieve information about you stored on your hard drive and will not corrupt or damage your computer or computer files. You are not obliged to accept the cookie and you can modify your browser so that it will not accept cookies (see www.allaboutcookies.org).

The table below explains the cookies we use and why.

Cookie	Name	Purpose	More Information
Search Filters	stat e e m p p	When users access our search pages we set cookies to remember the filters they set. We do this to improve the user experience.
Remember Me	remember_user_token	This cookie is set if you select the "Remember me" option when logging in. It allows users to stay logged in when they return to the site.
Request Form	request_form_info	This cookie is set so that the website remembers the entries you entered when you fill up the Request a Callback form. Your personal information is not stored in the cookie itself.
Google Analytics	_utma _utmb _utmc _utmz	These cookies are used to collect information about how visitors use our site. We use the information to compile reports and to help us improve the site. The cookies collect information in an anonymous form, including the number of visitors to the site, where visitors have come to the site from and the pages they visited.	Click here for an overview of privacy at Google
Hubspot		Hubspot is an online marketing subscription service that uses cookies to collect information on how visitors use our site and deliver content about our company based on the visitors preferences. Hubspot cookies collect information about visits to web pages such as your IP address, geographical location, browser and device type, referral source, length of visit and pages viewed.	Please visit Hubspot's privacy page for more information.
Login Language	Locale	Stores language preference on Login screen