Website
Privacy Policy

BACKGROUND:
Garrison Technology Limited (“we” or “us”, and “our” shall be construed accordingly) understands that your privacy is
important to you and that you care about how your personal data is used. We respect and value the privacy of everyone
who visits this website, www.garrison.com (“Our Site”) and will only collect and
use personal data in ways that are described here, and in a way that is consistent with our obligations and your rights
under the law.

Please read this Website Privacy Policy (“this Policy”) carefully and ensure that you understand it.
Your acceptance of this Policy is deemed to occur upon your first use of Our Site. If you do not accept and agree with
this Policy, you must stop using Our Site immediately.

  1. Definitions and Interpretation
    1. In this Policy the following terms shall have the following meanings:
      Account means an account required to access and/or use certain areas and features of Our Site;
      Adequate Third Countries   means those countries outside the UK whose legal framework has been
      assessed as providing ‘adequate’ protection for individuals’ rights and freedoms for their personal data under the UK “adequacy regulations”, as amended from time to time. Currently, the list of “adequate” countries include the EEA (which consists of all EU member states, plus Norway, Iceland, and Liechtenstein), Switzerland, Gibraltar and all countries, territories and international organisations covered by European Commission “adequacy decisions” valid as at 31 December 2020;
      Cookie means a small text file placed on your computer or device by Our Site
      when you visit certain parts of Our Site and/or when you use certain features of Our Site; and
      Cookie Law means the relevant parts of the Privacy and Electronic Communications (EC Directive) Regulations 2003;
      ICO means the Information Commissioner’s Office that acts as the UK regulatory authority in relation to data protection and privacy;
      PECR means Privacy and Electronic Communications (EC Directive) Regulations 2003;
      Data Protection Legislation means the Retained Regulation (EU) 2016/679 (‘UK GDPR’) and the Data Protection Act 2018;
      European Economic Area or “EEA” means all European Union member states, plus Norway, Iceland, and Liechtenstein;
      Standard

      Contractual

      Clauses or “SCCs”

      		 standard data protection clauses in the form recognised or issued in
      accordance with Data Protection Legislation, as amended from time to time.
  2. Information About Us
    1. Our Site, www.garrison.com, is owned and operated by Garrison Technology Limited, a limited company registered in England under 09286531, whose registered address is 117 Waterloo Road, London, SE1 8UL. Our Data Protection Officer can be contacted by email at dpo@garrison.com.
  3. What Does This Policy Cover?
    1. This Privacy Policy applies only to your use of Our Site. Our Site may contain links to other websites. Please note that we have no control over how your data is collected, stored, or used by other websites and we advise you to check the privacy policies of any such websites before providing any data to them.
  4. What Is Personal Data?
    1. Personal data is defined by the Data Protection Legislation as ‘any information relating to an identifiable person who can be directly or indirectly identified in particular by reference to an identifier’.
    2. Personal data is, in simpler terms, any information about you that enables you to be identified. Personal data covers obvious information such as your name and contact details, but it also covers less obvious information such as identification numbers, electronic location data, and other online identifiers.
  5. What Are My Rights?
    1. Under the Data Protection Legislation, you have the following rights, which we will always work to uphold:
      1. The right to be informed about our collection and use of your personal data. This Privacy Policy should tell you everything you need to know, but you can always contact us to find out more or to ask any questions using the details in Section 15.
      2. The right to access the personal data we hold about you. Section 13 will tell you how to do this.
      3. The right to have your personal data rectified if any of your personal data held by us is inaccurate or incomplete. Please contact us using the details in Section 15 to find out more.
      4. The right to be forgotten, i.e., the right to ask us to delete or otherwise dispose of any of your personal data that we hold.Please contact us using the details in Section 15 to find out more.
      5. The right to restrict (i.e., prevent) the processing of your personal data.
      6. The right to object to us using your personal data for a particular purpose or purposes.
      7. The right to withdraw consent. This means that, if we are relying on your consent as the legal basis for using your personal data, you are free to withdraw that consent at any time.
      8. The right to data portability. This means that, if you have provided personal data to us directly, we are using it with your consent or for the performance of a contract, and that data is processed using automated means, you can ask us for a copy of that personal data to re-use with another service or business in many cases.
    2. Rights relating to automated decision-making and profiling. We do not use your personal data in this way.
    3. For more information about our use of your personal data or exercising your rights as outlined above, please contact us using the details provided in Section 15.
    4. It is important that your personal data is kept accurate and up to date. If any of the personal data we hold about you changes, please keep us informed as long as we have that data.
    5. Further information about your rights can also be obtained from the Information Commissioner’s Office or your local Citizens Advice Bureau.
    6. If you have any cause for complaint about our use of your personal data, you have the right to lodge a complaint with the Information Commissioner’s Office. We would welcome the opportunity to resolve your concerns ourselves; if so, please contact us first using the details in Section 15.
  6. What Data Do You Collect and How?
    1. Depending upon your use of Our Site, we may collect and hold some or all of the personal and non-personal data set out in the table below, using the methods also set out in the table. Please also see Section 14 for more information about our use of Cookies and similar technologies and our Cookie Policy https://www.garrison.com/cookie-policy/. We do not collect any ‘special category’ and/or ‘sensitive’ personal data and/or personal data relating tocchildren and/or data relating to criminal convictions and/or offences.
      Data Collected How We Collect the Data
      Basic personal & business information (for example, name, organisation,
      job) and Contact information (for example, email address and phone numbers)      		 Via webforms on Our Site.
      Technical information including e.g., IP address, browser type and version,
      operating system.      		 Via Google Analytics.
  7. How Do You Use My Personal Data?
    1. Under the Data Protection Legislation, we must always have a lawful basis for using personal data. The following table describes how we may use your personal data, and our lawful bases for doing so:
      What We May Do What Data We Use Our Lawful Basis
      Communicating with you. Basic personal & business information, and Contact information provided
      by you when filling webforms on Our Site.      		 Through our web forms you express a desire for contact, or further information. We will use your data to respond to you.
    2. With your permission and/or where permitted by law, we may also use your personal data for marketing purposes, which may include contacting you by email and/or telephone with information, news, and offers on our products and/or services. You will not be sent any unlawful marketing or spam. We will always work to fully protect your rights and comply with our obligations under the Data Protection Legislation and the PECR, and you will always have the opportunity to opt-out. We will always obtain your express opt-in consent before sharing your personal data with third parties for marketing purposes and you will be able to opt-out at any time.
    3. Third Parties (including, for example, Workable) whose content appears on Our Site may use third-party Cookies, as detailed below in Section 14. Please refer to Section 14 for more information on controlling cookies. Please note that we do not control the activities of such third parties, nor the data that they collect and use themselves, and we advise you to check the privacy policies of any such third parties.
    4. We will only use your personal data for the purpose(s) for which it was originally collected unless we reasonably believe that another purpose is compatible with that or those original purpose(s) and need to use your personal data for that purpose. If we do use your personal data in this way and you wish us to explain how the new purpose is compatible with the original, please contact us using the details in Section 15.
    5. If we need to use your personal data for a purpose that is unrelated to, or incompatible with, the purpose(s) for which it was originally collected, we will inform you and explain the legal basis which allows us to do so.
    6. In some circumstances, where permitted or required by law, we may process your personal data without your knowledge or consent. This will only be done within the bounds of the Data Protection Legislationvand your legal rights.
  8. How Long Will You Keep My Personal Data?
    1. We will not keep your personal data for any longer than is necessary in light of the reason(s) for which it was first collected. Your personal data will therefore be kept for the following periods (or, where there is no fixed period, the following factors will be used to determine how long it is kept):
      Type of Data How Long We Keep It
      Basic personal & business information (for example, name, organisation, job) and Contact information (for example, email address and phone numbers) you provide to us via our webforms For up to 18 months or until they are clearly out of date or there is no current business or no potential for future business with the customer, whichever is earlier.
      Technical information including e.g. IP address, browser type and version, operating system. Information collected via Google Analytics will be retained for a maximum period of 14 months.
  9. How and Where Do You Store or Transfer My Personal Data?
    1. We may store or transfer some or all of your personal data in countries outside the UK. These are known as “third countries” and may not have data protection laws that are as strong as those in the UK. This means that we will take additional steps in order to ensure that your personal data is treated just as safely and securely as it would be within the UK and under the Data Protection Legislation as follows:
    2. We share your data within the group of companies of which we are a part, some of which are outside
      the UK. More information.
    3. We may share your data with external third parties, that are based outside of the UK.
    4. In either case where the receiving company is outside the UK, we will only transfer your personal data to Adequate Third Countries and require the receiving company to enter into SCCs. More information is available from the ICO.
    5. Where we transfer your data to a third country that is not an Adequate Third Country we will adopt “appropriate safeguards” to protect the rights of individuals whose personal data is transferred. More information is available from the ICO.
    6. Please contact us using the details in Section 15 for further information about the particular data protection mechanisms used by us when transferring your personal data to a third country.
    7. The security of your personal data is essential to us, and to protect your data, we take a number of important measures, including the following:
      1. limiting access to your personal data to those employees, agents, contractors, and other third parties with a legitimate need to know and ensuring that they are subject to duties of confidentiality;
      2. procedures for dealing with data breaches (the accidental or unlawful destruction, loss, alteration, unauthorised disclosure of, or access to, your personal data) including notifying you and/or the Information Commissioner’s Office where we are legally required to do so.
  10. Do You Share My Personal Data?
    1. We will not share any of your personal data with any third parties for any purposes, subject to the following exceptions:
      1. If we sell, transfer, or merge parts of our business or assets, your personal data may be transferred to a the party. Any new owner of our business may continue to use your personal data in the same way(s) that we have used it, as specified in this Policy.
      2. In some limited circumstances, we may be legally required to share certain personal data, which might include yours, if we are involved in legal proceedings or complying with legal obligations, a court order, or the instructions of a government authority.
  11. How Can I Control My Personal Data?
    1. In addition to your rights under the Data Protection Legislation, set out in Section 5, when you submit personal data via Our Site, you may be given options to restrict our use of your personal data. In particular, we aim to give strong controls on our use of your data for direct marketing purposes (including the ability to opt-out of receiving emails from us which you may do by unsubscribing using the links provided in our emails.
  12. Can I Withhold Information?
    1. You may access certain areas of Our Site without providing any personal data at all.
    2. You may restrict our use of Cookies. For more information, see Section 14 and Cookie Policy https://www.garrison.com/cookie-policy/.
  13. How Can I Access My Personal Data?
    1. If you want to know what personal data we have about you, you can ask us for details of that personal data and for a copy of it (where any such personal data is held). This is known as a “subject access request”.
    2. All subject access requests should be made in writing and sent to the email or postal addresses shown in Section 15.
    3. There is not normally any charge for a subject access request. If your request is ‘manifestly unfounded or excessive’ (for example, if you make repetitive requests) a fee may be charged to cover our administrative costs in responding.
    4. We will respond to your subject access request within 28 days and, in any case, not more than one month of receiving it. Normally, we aim to provide a complete response, including a copy of your personal data within that time. In some cases, however, particularly if your request is more complex, more time may be required up to a maximum of three months from the date we receive your request. You will be kept fully informed of our progress.
  14. How Do You Use Cookies?
    1. Our Site may place and access certain first-party Cookies on your computer or device. First-party Cookies are those placed directly by us and are used only by us. We use Cookies to facilitate and improve your experience of Our Site and to provide and improve our products and/or services. By using Our Site you may also receive certain third-party Cookies on your computer or device.
    2. Third-party Cookies are those placed by websites, services, and/or parties other than us. Third-party Cookies are used on Our Site in conjunction with our recruitment software to publish the latest jobs roles we have available. In addition, Our Site uses analytics services provided by Google Analytics, which also use Cookies. Website analytics refers to a set of tools used to collect and analyse usage statistics, enabling us to better understand how people use Our Site. For more details, please refer to our Cookie Policy https://www.garrison.com/cookie-policy/.
    3. Our Site includes an Instagram feed plugin. This does not use any cookies. For full details regarding how data is processed please refer to https://smashballoon.com/doc/instagram-feed-gdpr-compliance/.
  15. How Do I Contact You?
    1. To contact us about anything to do with your personal data and data protection, including to make a
      subject access request, please send an email to dpo@garrison.com.
  16. Changes to this Privacy Policy
    1. We may change this Privacy Notice from time to time. This may be necessary, for example, if the law changes, or if we change our business in a way that affects personal data protection.
    2. Any changes will be immediately posted on Our Site and you will be deemed to have accepted the terms of the Privacy Policy on your first use of Our Site following the alterations. We recommend that you check this page regularly to keep up-to-date.