1.0Who are we?

We are Refeasy Limited. We own and operate this website. Our contact details are on the website. Please contact us if you have any questions or feedback about this policy.

We are registered with the Information Commissioner’s Register of Data Controllers under number ZA225630.

2.0What’s the point of this policy?

This policy tells you how we deal with your “personal data” (i.e. technical term for information about any identified or identifiable living person). Please read on to find out what kinds of personal data we collect, how we use and protect it, to whom we disclose it and how you can access and rectify it.

Please do not use our website unless you are completely happy with this policy. If you do use our website, we will assume that you do accept it.

3.0Might the policy change?

It may well do without giving you prior notice and so you should check it whenever you visit our website. Revision versions of this policy will be posted on our websites at least 14 days before the effective date. Where appropriate, such policy changes may be communicated with you via your registered e-mail address. We will assume you agree to the revised policy if you use our website after the effective date shown at the top of the policy.

4.0What personal or other data do we collect?

We collect and store the information which you give us via forms on our website - such as your title, name, username, address, e-mail address, phone number, role, answer to security question, subscription details, marketing preferences; your referee name, address, e-mail address and phone number; your recruiter, educational institution, address, e-mail address and phone number and so on - or when communicating with us by e - mail or in some other way.

We may receive and store certain information automatically when you interact with us. Examples include the internet protocol (IP) address used to connect your computer to the internet, connection information such as browser type and version, information about your mobile or other device including device-type and device identifier, operating system and platform, a unique reference number linked to the data you enter on our system, login details, clickstream data, details of your activity on our websites with date / time stamps including the pages you visited, searches you made and services purchased.

We may collect personal information about you from third parties, for example in information contained in references or recommendation letters uploaded to our site by referees and also where users supply referee / recruiter name and contact details to enable requests for and forwarding of references or recommendation letters. This also includes personal information uploaded on reference and recommendation letter templates by recruiters.

5.0What about cookies?

We and/or third parties use cookies and other tracking technologies on our website. A cookie is an identifier (a small file of letters and numbers) that is sent to your computer. Our website’s functionality will be limited if you configure your browser to reject cookies.

Cookies are widely used to make websites work, or work more efficiently, as well as to provide information to the website owner or others. Session cookies are temporary cookies that remain in the cookie file of your browser only until your browser is closed. They allow websites to link your actions during a browser session. Persistent cookies stay in the cookie file of your browser for longer (though how long will depend on the lifetime of the specific cookie). For further information on cookies, including how to use your browser to block them and how to delete cookies already stored on your device, visit: www.allaboutcookies.org.

Cookies are used on this website for the following purposes:

• Session cookies: We use session cookies to enable the website to keep track of your movement from page to page and store your selections so you do not get asked repeatedly for the same information. These cookies allow you to proceed through many pages of the website quickly and easily without having to authenticate or reprocess each new area you visit. For example, the session cookie remembers your shopping cart selection so will have the items you selected when you are ready to check out.


• Log-in cookies: We use persistent cookies to remember the date and time when users log in and out of service. These cookies are for security purposes and essential to our service.


• Third party advertising cookies: As do many other sites, we may use third party advertisers and/or internet advertising companies working for them to fill ad space on our website. These third parties may use persistent cookies and other similar technologies (known as action tags, single pixel gifs and web beacons) to assess information about your visits to this and other sites. This is so they can track the effectiveness of their campaigns (including whether these advertisements are clicked on or viewed by users and later purchases by such users), avoid showing you the same advertisement repeatedly and display advertisements on this and other sites tailored to your preferences. We do not have any access to or control over these third party technologies. If you would like more information about these practices and to know your choices about not having this information used by certain of these companies, please visit www.youronlinechoices.com and www.networkadvertising.org/choices. Please contact the third parties directly for more information about their privacy practices.


• Google cookies: Persistent cookies (up to four years we believe) may be set in connection with the following Google services on our site and these cookies may involve certain non-personally identifying information being sent to Google:


• Google Analytics (“GA”): We use cookies to recognise and count the number of website visitors as well as providing other information about the visit such as duration, route through the website and what sites the visitor came from. This information helps us to improve the way our website works, for example by making sure users find what they need easily.
  


• More information and opt out: Click here for Google’s privacy policy and here for more information about the kinds of cookies placed by Google. Click here for information about how Google uses data from its partners’ sites or apps as well as how to opt out of Google cookies.


• Advertising cookies: We may use these persistent cookies to track your country to enable us to provide country-specific content, avoid showing you the same advertisement repeatedly and to display advertisements or other content tailored to your preferences.


• Social media cookies: We may use various social media and other third party features on our website including like button from Facebook, follow button from Twitter), Plus +1 button from Google, Pin It button from Pinterest, share / follow button from LinkedIn, embed button from YouTube, These features may involve the relevant companies using cookies or linking your visit with cookies previously placed by them on your computer in order for them to collect information relating to your visit to our website or your interaction with their services or otherwise. Click the links shown above for further information about the specific features and those companies’ cookie / privacy practices generally as well as to opt out where this is possible.


• Cookie-warning cookie: This cookie takes note of whether you are happy to accept cookies on this website based on your response to the message which appeared when you first visited the website. This persistent cookie will remember your preference for as long as necessary until you opt out.

By continuing to use our website, having seen our cookie notice, we assume that you consent to use of the cookies outlined above.

6.0How do we use your personal data?

We use your personal data to provide our services, e.g. send service messages, process payments and/or fulfil orders.

If you are a referee / recruiter, we may use your contact details to enable the user to send you requests for references or recommendation letters. Please contact us immediately by email to support@refeasy.com if you don’t wish your information to be used in this way or if you want us to delete your details.

We use your personal data to help us communicate with you effectively should you try to contact us via our website.

If you have given permission on our website, we may use your personal data to send you emails (or other communications such as mail, phone or SMS) with details of our or third party goods or services which may be of interest to you including information about special offers or promotions.

We may use personal data to recognize you when you visit or return to our website to track anonymised traffic and usage patterns, to prevent or detect fraud or abuses or to help us improve our website. We may use cookies to do this. See above.

We retain personal data from closed accounts in order to comply with legal obligations, enforce our terms and conditions, prevent fraud, collect any fees owed, resolve disputes, troubleshoot problems, assist with any investigations and take other actions as permitted by law.

We may access, remove, alter, store or otherwise use any personal data if we have reason to believe that it breaches our terms and conditions, or that such steps are necessary to protect us or others, or that a criminal act has been committed, or if we are required to do so by law or appropriate authority.

7.0How do we protect personal data?

Security is a high priority for us. We take appropriate precautions to protect personal data.

E-mail and other electronic communications are not secure if they have not been encrypted. Your communications will pass through a number of network nodes before they reach us. So we do not accept responsibility for any unauthorised access to or loss of personal data that stems from a cause beyond our control. Nor can we be held responsible for the actions or omissions of other users or third parties who may misuse your personal data which they collect from the website.

8.0To whom do we disclose personal data?

Your date and time of last log-in may be shown to other users, for example so that they can see if and when you uploaded or accessed a reference or recommendation letter.

If you are a candidate, your contact details may be provided to referees to enable them to contact you with any queries relating to your request for a reference or recommendation letter.

If you are a referee, your contact details may be provided to recruiters to enable them to contact you with any queries relating to the reference or recommendation letter you have given.

If you are a recruiter, your contact details may be provided to referees relating to provided reference or recommendation letters shared with you by the candidate.

Payment details including credit card numbers are supplied direct to our payment partner mentioned on our website. We do not receive such information. To ensure your details are not being used without consent, your personal data may be supplied by our payment partners to relevant third parties including credit reference and fraud prevention agencies, who may keep a record of that information.

We may allow access to your personal data by third parties who supply us with a service. Examples include e-commerce platform providers, website hosts, content delivery networks and businesses which assist us in undertaking communications or monitoring our website.

We may disclose personal data so far as reasonably necessary:

• if we have reason to believe that it breaches our terms and conditions, or that such steps are necessary to protect us or others, or that a criminal act has been committed, or if there has been a complaint about content posted by you, or if we are required to do so by law or appropriate authority; or
• in the case of an actual or proposed (including negotiations for a) sale or merger or business combination involving all or the relevant part of our business.

We may store or transfer personal data outside the European Economic Area (EEA) for the purposes stated in this policy. If so, we will of course comply with the applicable laws relating to data transfer outside the EEA.

Except as otherwise specifically included in this policy, this document addresses only the use and disclosure of information we collect from you. If you disclose your information to third parties, whether they are suppliers of services on our website (e.g. payment providers) or other websites, different rules will apply to their use or disclosure of your information. Please check their privacy policies carefully.

9.0How can you access and rectify personal data?

You have the opportunity to access, modify, delete or request changes to the personal information processed via our Website, Apps, Services, third party websites or where applicable by law. We may charge an administration fee in line with data protection laws and we may also require appropriate evidence of identity. Note that you may be able to rectify certain aspects of your personal data within your account on our service (if applicable).

For information about your rights under UK data protection laws, see the website of the UK Information Commissioner.