This privacy Notice (the “Notice”) relates to information that we (Value Retail Management Limited, jointly with our associated companies, see ‘Who we are’ below) collect and use about you in connection with your use of the Brand Recruitment Site. We operate the Brand Recruitment Site in order to allow you to explore and ask to be considered for recruitment opportunities within the retail outlets in Value Retail Villages (referred to in this Notice as “Brand Partners”) and in accordance with the Recruitment Site Terms of Use available here.

You should read through the Notice to fully understand the basis upon which we and Brand Partners will use your information including the information we collect about you, how the information is used, where the information is stored and to whom the information is disclosed.

For information on the rights you have in relation to the information we process about you, please see ‘Your Rights’ below. This Notice only applies to your use of the Brand Recruitment Site and applies in addition to our individual privacy policies which relate to our use of information about you other than in connection with the Brand Recruitment Site.

Our Brand Recruitment Site is hosted by iCIMS, Inc (“iCIMS”), a third party service provider. For information about iCIMS’ use of cookies and how iCIMS secures your personal information, you should also review the iCIMS privacy policy which is available here.

By providing us with your personal information through the Brand Recruitment Site you acknowledge this Notice applies to your use of it and that we and the Brand Partners may process information about you in the manner and for the purposes set out in this Notice.

Commitment to Privacy

We are committed to protecting your privacy. We will use your personal information provided through the Brand Recruitment Site as set out in this Notice. We will keep your personal information safe and comply with applicable data protection laws. Who we are

Please click here to see who we are. The entities listed are the administrator of the Brand Recruitment Service provided via the Brand Recruitment Site or are the owners and operators of The Bicester Village Shopping Collection. References in this Agreement to “we” or “us” are to all the entities listed. We are “controllers” of the personal information which we collect about you through your use of the Brand Recruitment Site, which we jointly administer.

We administer the Brand Recruitment Service provided via the Brand Recruitment Site but will not be directly involved in the recruitment process of the Brand Partners unless you become a member of the Store Manager Talent Pool in which case we may collect and use additional information about you as detailed in this Notice.

If you apply for or are accepted into membership of the Store Manager Talent Pool, we and our Brand Partners will each be separate and independent controllers of your data. We and our Brand Partners use your data to asses your suitability for particular store manager roles.

For further information on who the Brand Partners are and how they will use your information, please see ‘Who do we share your information with?’ below.

What information do we collect about you?

The Brand Recruitment Site is made available to the Brand Partners to support their recruitment process. The personal information you submit to the Brand Recruitment Site to create your profile and submit applications will include the personal details you need to provide to us in order to create an account such as your name, gender, residential address, email address, contact telephone numbers, and the positions which you are interested in applying for. You may also choose to provide some or all of this information by joining the Brand Recruitment Site’s Talent Network.
You can choose to complete the data required yourself, or by logging in through Facebook, Google+ or LinkedIn If you log in through such a social media account, any information you provide using it will only be used by us to complete basic details on the Brand Recruitment Site - we will not collect any other information from your social media or other online accounts.

You may also choose to provide a copy of your curriculum vitae as part of your profile, or as part of joining the Talent Network, or as part of your application for membership of the Store Manager Talent Pool, which may include:

a) Details about your previous employment such as your, work history (including whether you have been employed by us or a Brand Partner before) and any further information about your employment history you have chosen to include;

b) Details about your suitability for roles such as your skills, qualifications, education, the languages you speak and your proficiency, your eligibility to work in a particular country (e.g. your citizenship or visa details), your experience in particular areas and industries including any management experience and the size of any teams you have managed; and

c) Details about your preferences such as positions you may be interested in, information about when you may be available to interview, start work (i.e. your current notice period) or work on an ongoing basis (e.g. full or part time or on weekends).

Please note that the Brand Recruitment Process allows you to include any other information you think relevant to your application. Please be aware that although we do not require you to provide such information, you may provide additional personal information, and we will hold and process any information, including any personal information that you provide as part of your application.

If you apply for membership of the Store Manager Talent Pool we will contact you in order to ask you to undertake questionnaires and other assessments. We will collect and process the information you provide in your responses to and the results of any questionnaires or other assessments you provide or undertake in connection with your application.

Who do we share your information with?

Your information will be shared with and made available to Brand Partners who use the Brand Recruitment Site from time to time. The Brand Partners are the legal entities that are the operators of the boutiques within Value Retail Villages who will change from time to time. You are able to choose which of the Brand Partners will have access to your information.

The Brand Partners who access and process your personal information through the Brand Recruitment Site will also be data controllers within the meaning of data protection laws applicable in the UK, EU and EEA. Where this is the case, the Brand Partner’s own privacy notice (which is usually available via their website) will set out how they will treat your information.

You can control which Brand Partners your information is shared with by either making specific applications Brand Partners you select (whereby only that Brand Partner will be able to view your information), or by making your information available to all Brand Partners (called a “general application”). You can also select which Brand Partners will see your information from the settings in your profile on the Brand Recruitment Site.

If you become a member of the Store Manager Talent Pool we may share your data with Brand Partners who are seeking to recruit a store manager. We will always contact you before we do so to ensure that you are interested in any such role before sharing your data.

We will also share your information with other Value Retail entities which need to access your information in order to administer the Brand Recruitment Site and iCIMS, the third party provider of the Brand Recruitment Site. From time to time, we may also need to share your information with other third party service providers (such as our third party IT providers) that process information on our behalf for the purposes of administering and providing the Brand Recruitment Site.

In addition, in limited circumstances, we may disclose your personal data:

a) If we are under a duty to disclose or share your information in order to comply with any legal obligation (such as providing your information to government authorities or regulators); b) In order to protect the rights, property or safety of our business, our customers or others. This includes, in specific cases, exchanging information with other companies and organisations for the purposes of fraud protection; and c) To successors in title or replacement operators of all or part of our respective businesses.

How we use your information

If you choose to use the Brand Recruitment Site, the information you provide or which we collect from third parties in connection with your use of the Brand Recruitment Site will be used for the following reasons:

• We use the information held about you to administer the Brand Recruitment Site, including by sending you notifications of changes to the site and may also contact you periodically to update your personal information and, if you have provided your consent, to send general email communications about recruitment events and job opportunities with Brand Partners. When new jobs are added to the Brand Recruitment Site which align with your stated interests, we will send you email job alerts when you have consented to receive such notifications. You may withdraw your consent to receiving these notifications at any time. We will also use your information for analysis of how effective the Brand Recruitment Site is and for deciding whether to make any improvements.

• The Brand Partners will use your information in order to consider you for recruitment opportunities at Value Retail Villages. The Brands may communicate with you about these opportunities and if your application is successful, the information will be used to process your employment with them. They will not always notify you if your application is unsuccessful. Your information will be stored in the Brand Recruitment Site and you will be able to log into the system and track how an application is progressing.

If you select to only make the information available in connection with a specific role with a Brand Partner (a “specific application”), then the information that is collected through the Brand Recruitment Site will only be available to that Brand Partner, who will be able to view your information on the Brand Recruitment Site and to transfer your information to their own systems.

If you have provided information as part of a general application or if you select to make it available for consideration by all Brand Partners, then the information that is collected through the Brand Recruitment Site will be available to all current and future Brand Partners each of whom will be able to view your information on the Brand Recruitment Site and to transfer your information to their own systems. If you are being considered for a role with a Brand Partner then you can choose whether your information will also be available to be viewed by other Brand Partners at the same time or whether to restrict your information to just the Brand Partner which is considering you for that role.

In either a specific application or a general application, once a Brand Partner accesses your information, they will be a controller of that information using it for their own purposes and will be responsible for keeping such information safe and complying with applicable data protection laws.

• When you apply for membership of the Store Manager Talent Pool, we will use the information you provide in your responses to and the results of any questionnaires or other assessments you undertake to determine your suitability to join the Talent Pool. If you become a member of the Talent Pool, we and any relevant Brand Partner will use that information to decide if you may be suitable for a particular store manager role with a Brand Partner.

• We or our Brand Partners may use information you provide to contact you by post, telephone, SMS text message or by email in connection with your application or use of the Brand Recruitment Site, as per your preferences.

The legal basis for us using your information

We (and any Brand Partners you choose to share your information with) have a legitimate interest in collecting and processing the personal data referred to above (see ‘What Information Do We Collect About You?’) so that we can:

a) Administer and provide you with access to the Brand Recruitment Site, and pass on any applications you make to our Brand Partners; b) Keep you informed of changes to the Brand Recruitment Site; c) Provide you with relevant training, training materials and other information if you are successful in securing a position with a Brand Recruitment Partner; d) Create and maintain a Store Manager Talent Pool; e) Ensure that our recruitment offering is effective and useful for our Brand Partners. Our Brand Partners will use your information to: a) Process any applications you make for a specific position (including via your membership of the Store Manager Talent Pool) or consider your suitability for any available positions when you make a general application; b) Communicate with you about any applications you have made; c) Conduct any pre-employment screening (that are necessary for hiring and permissible under applicable laws in your jurisdiction) or verification checks which the Brand Partner undertakes if your application is successful; and d) For any other purposes as specified in the Brand Partner’s privacy notice.

We have assessed the impact of processing your information for the reasons listed above and have balanced your interests, rights and freedoms against our interests in processing your data in this way. This assessment has been used to implement the way we process your data to ensure your rights are adequately protected. If you would like more information about this process, please see ‘Contacting Us’ below.

Additionally, sometimes we also need to process your personal information to comply with our legal obligations including in relation to handling complaints and investigations or litigation.

In certain circumstances, we process your personal data after obtaining your consent to do so for the purposes of contacting you about other employment opportunities you may be interested in. Where you have provided consent to us processing your data you have a right to withdraw this consent at any time (see Your rights below).

How long do we keep your data for?

Any information provided in connection with an application for a specific role will be retained on the Brand Recruitment Site for up to 12 months so that at any time you can choose to make it available as a general application so that it can be viewed by all Brand Partners. If you have made a general application then your information will remain available on the Brand Recruitment Site for so long as you are actively using the site. If you have not actively used the site for 12 months your information will be automatically deleted. You can also choose to delete your account with the Brand Recruitment Site at any time. Where your account on the Brand Recruitment Site is deleted (either by your or by us) your personal information may be retained by us for record keeping purposes, and as may be necessary to handle any complaints or investigations) for such period as is permissible under applicable laws.

Any information which you make available to a Brand Partner will be retained in accordance with the data retention policy of that Brand Partner.

Where we store or process your information

In order for us to provide the Brand Recruitment Site, the information you provide via the Brand Recruitment Site or which we collect from third parties will be transferred to, stored at, or accessed from, destinations outside the EU and EEA, including by iCIMS in Canada and the United States of America in connection with hosting and the administration of the Brand Recruitment Site.

We have obligations to ensure that your personal data processed by us or by our suppliers or processors operating outside the EEA is treated securely and is protected against unauthorised access, loss or destruction, unlawful processing and any processing which is inconsistent with the purposes set out in this Notice. For further detail concerning the safeguards that we use to protect your information when it is transferred outside of the EEA, and the means to obtain a copy of them or where they have been made available, please see Contacting Us below.

Brand Partners may also transfer your information from the Brand Recruitment Site to their systems hosted outside the EU and EEA. Where they do so, the Brand Partners will be responsible for ensuring that such transfers are made in accordance with applicable data protection laws.

While we strive to protect your personal information, we cannot guarantee the security of information that you submit online, and you do so at your own risk. We urge you to keep your username, password and any other log-in details in a safe place as you are responsible, together with the Brand Partners for maintaining the confidentiality of the information that you submit to us.

Your rights

By law, you have a number of rights when it comes to your personal data. We have set these rights out below, and if you need any further information or wish to exercise any of these rights, please let us know (see Contacting Us below). Alternatively, further information and advice about your rights can be obtained from the data protection regulator in your country.

Rights What Does this mean?
1. The right to be informed You have the right to be provided with clear, transparent and easily understandable information about how we use your information and your rights. This is why we’re providing you with the information in this Notice.
2. The right of access You have the right to obtain access to your information (if we’re processing it), and certain other information (similar to that provided in this Notice).
This is so you’re aware and can check.
3. The right to rectification You are entitled to have your information corrected if it’s inaccurate or incomplete.
4. The right to erasure This is also known as ‘the right to be forgotten’ and, in simple terms, enables you to request the deletion or removal of your information where there’s no compelling reason for us to keep using it. This is not a general right to erasure; there are exceptions and we make decision whether to erase data on a case by case basis when we receive a request to exercise this right.
5. The right to restrict processing You have rights to ‘block’ or suppress further use of your information. When processing is restricted, we can still store your information, but may not use it further. We keep lists of people who have asked for further use of their information to be ‘blocked’ to make sure the restriction is respected in future.
6. The right to data portability You may have the right to obtain information you have provided to us in a structured, commonly used and machine readable format.
7. The right to lodge a complaint You have the right to lodge a complaint about the way we handle or process your personal data with your national data protection regulator, in particular in the country where you live, work or where an alleged infringement of data protection law occurred.
8. The right to withdraw consent If you have given your consent to anything we do with your personal data, you have the right to withdraw your consent at any time (although if you do so, it does not mean that anything we have done with your personal data with your consent up to that point is unlawful).
9. The right to object to processing You have the right to object to any processing which is carried out for our legitimate interests. If we can show compelling legitimate grounds for processing your personal information which override your interests, rights and freedoms, or we need your personal information to establish, exercise or defend legal claims, we can continue to process it.

We usually act on requests and provide information free of charge, but we may charge a reasonable fee to cover our administrative costs of providing the information for:

a) baseless or excessive/repeated requests, or b) further copies of the same information.

Alternatively, we may be entitled to refuse to act on the request. Please consider your request responsibly before submitting it. We will respond as soon as we can and in the event that we decide to charge you a reasonable fee, we will notify you. Generally we will respond to you within one month from when we receive your request but, if the request is going to take longer to deal with, we’ll come back to you and let you know.

Where your request relates to information which is being separately processed by a Brand Partner, the Brand Partner will be the sole controller of that information using it for their own purposes and will be responsible responding to data protection requests directly. You are also able to exercise the above rights against any of our Brand Partners who are processing your personal data. In order to do so, you will need to contact the Brand Partners directly.

Where we have shared your data with a Brand Partner resulting from your membership of the Store Manager Talent Pool, and your request relates (wholly or partly) to information which is being processed by that Brand Partner, we may not be able to respond directly to your request (or that part of your request). We will notify the relevant Brand Partner that you have made a request to exercise your rights which relates to information within their possession and the Brand Partner will be responsible for responding to you in connection with your request directly.

Contacting Us

If you need to contact us for any reason (including to exercise any of your rights in relation to data protection as set out above) please contact us at villagecareers@kildarevillage.com or at the address below.

Village Careers Administrator

Kildare Village Nurney Road, Kildare Town, Co. Kildare, Ireland Eircode: R51 R265

We may make minor changes to this Privacy Notice. When we make these changes we will publish the updated notice on the Brand Recruitment Site. If we make any significant changes we will take additional steps to inform you of them.