Privacy Policy

Banen Associates Website Privacy Policy

November 2023


Welcome to the privacy notice of Banen Associates Limited (“Banen Associates”).

We highly value your privacy and are dedicated to safeguarding your personal data. This privacy notice is designed to explain how we handle your personal data when you visit our website, irrespective of your location. It also outlines your privacy rights and provides information on legal protections.

To enhance your understanding, this privacy notice is presented in a layered format. Additionally, the Glossary is available to clarify the meanings of certain terms used herein.

  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.

Article I: Important Information and Who We Are

Section 1.01: Purpose of This Privacy Notice

  1. The purpose of this privacy notice is to provide you with information regarding how Banen Associates obtains and processes your personal data when you use this website. This includes any data you may submit through the website when applying for a job, submitting your CV, requesting a callback, registering for job alerts, submitting a vacancy, or signing up for our newsletter.
  2. This website is not designed for children, and we do not intentionally obtain children’s data.
  3. Please ensure that you read this privacy notice in conjunction with any other privacy notice or fair processing notice provided on specific occasions when we collect or process your personal data. This will ensure that you have a comprehensive understanding of how and why we use your data. It’s important to note that this privacy notice serves as a supplement to other notices and is not intended to supersede them.

Section 1.02: Controller

  1. Banen Associates comprises various legal entities. This privacy notice is issued on behalf of Banen Associates. When we use terms such as “Banen Associates,” “we,” “us,” or “our” in this privacy notice, we are specifically referring to Banen Associates for the processing of your data. When you request our services, we will inform you about the specific entity acting as the controller for your data. Banen Associates is the controller and holds responsibility for this website.
  2. We are readily available to address your queries related to this privacy notice. If you have any questions regarding this privacy notice or if you wish to exercise your legal rights, please reach out to us using the contact details provided below.

Section 1.03: Contact Details

Our full details are:

    1. Full name of legal entity: Banen Associates Limited
    2. Email address: [email protected]
    3. Postal address: 166 Manchester Road East Little Hulton, Manchester, Lancashire, England, M38 9LG.
    4. Telephone number:You retain the right to lodge a complaint with the Information Commissioner’s Office (ICO), which serves as the UK supervisory authority for data protection matters ( However, we would appreciate the opportunity to address your concerns before you reach out to the ICO. Please contact us initially to allow us to handle your inquiries.

Section 1.04: Changes to The Privacy Notice and Your Duty to Inform Us of Changes

  1. This version was last updated in November 2023, and you can obtain historical versions by contacting us.
  2. Ensuring the accuracy and currency of the personal data we hold about you is crucial. Kindly keep us informed of any changes to your personal data throughout our relationship.

Section 1.05: Third-Party Links

This website may contain links to plug-ins, applications, and third-party websites. Clicking on these links or enabling such connections may enable third parties to collect or share data about you. We do not hold control over these third-party websites and are not accountable for their privacy statements. When you navigate away from our website, we advise you to review the privacy notice of each website you visit.

Article II: The Data We Collect About You

Section 2.01: Identification Data

Personal data, or personal information, refers to any information about an individual that enables the identification of that person. This definition excludes data where the identity has been removed, rendering it anonymous data.

Section 2.02: Personal Information

Banen Associates may obtain, utilise, store, and transfer various types of data about you which we have grouped together as follows:

  1. Identity Data: First name, maiden name, last name, username or similar identifier, marital status, title, date of birth, and gender.
  2. Contact Data: Email address and telephone numbers.
  3. Technical Data: 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.
  4. Profile Data: Your username and password, your interests, preferences, feedback, and survey responses.
  5. Usage Data: Information about how you use our website, products, and services.
  6. Marketing and Communications Data: Your preferences in receiving marketing from us and our third parties and your communication preferences.
  7. Aggregated Data: Statistical or demographic data for any purpose may be derived from your personal data but is not considered personal data in law as this data does not directly or indirectly reveal your identity. For instance, we might aggregate your Usage Data to determine the percentage of users accessing a particular website feature. Nevertheless, if we merge or associate Aggregated Data with your personal data in a manner that can directly or indirectly identify you, we consider the combined data as personal data. In such cases, it will be handled in accordance with this privacy notice.
  8. Special Categories: We do not collect any data that includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, health, genetic, and biometrics. Nor do we collect any information about criminal convictions and offences.

Section 2.03: If You Fail to Provide Personal Data

In situations where it is necessary to collect personal data by law or as part of a contractual agreement, and you do not provide the requested data, we may be unable to fulfill the contract we have or are attempting to enter into with you. If such a circumstance arises, and it leads to the potential cancellation of a product or service you have with us, we will inform you accordingly at that time.

Article III: How Is Your Personal Data Collected?

Section 3.01: We use different methods to collect data from and about you including through

Direct Interactions: You may provide us with your Identity and Contact Data through various means, such as filling in forms or corresponding with us via post, phone, email, or other channels. This encompasses personal data submitted when you:

  • Express interest in or apply for job vacancies.
  • Create an account on our website.
  • Register for job alerts or a call back.
  • Submit a vacancy to us.
  • Subscribe to our service or publications.
  • Request marketing materials to be sent to you.
  • Enter a competition, promotion, or survey.Provide us with feedback.

Automated Technologies or Interactions:During your interaction with our website, we may automatically gather Technical Data regarding your equipment, browsing actions, and patterns. This collection of personal data is achieved through the use of cookies, server logs, and similar technologies. Additionally, we may receive Technical Data about you when you visit other websites utilizing our cookies. For additional information, please refer to our Cookie Policy.

Third Parties or Publicly Available Sources: We may obtain personal data about you from various third parties and public sources, as outlined below:

Technical Data from the following parties:

  • Analytics providers such as Google, located outside the EU.
  • Advertising networks situated inside or outside the EU.
  • Search information providers, based inside or outside the EU.

Contact, Financial and Transaction Data: from providers of technical, payment and delivery services based inside or outside the EU.

Identity and Contact Data: from publicly availably sources such as Companies House and the Electoral Register based inside the EU.

Article IV: How We Use Your Personal Data

Section 4.01: Lawful Basis

We will only process your personal data when permitted by law. The primary circumstances under which we typically use your personal data include:

  1. To fulfill the contract we are about to enter into or have entered into with you.
  2. When it is necessary for our legitimate interests (or those of a third party), and your interests and fundamental rights do not override those interests.
  3. Where we need to comply with a legal or regulatory obligation.

Section 4.02: Consent

In general, our legal basis for processing your personal data does not rely on consent, except in the context of sending third-party direct marketing communications to you via email or text message. You retain the right to withdraw consent for marketing activities at any time by reaching out to us.

Section 4.03: Purposes for Which We Will Use Your Personal Data

  1. We have provided a table below outlining the various ways we intend to use your personal data, along with the corresponding legal bases we rely on for each purpose. Where applicable, we have also identified our legitimate interests.
  2. It’s important to note that we may process your personal data on more than one lawful ground, depending on the specific purpose for which we are utilizing your data. If you require details about the specific legal ground on which we are relying to process your personal data when more than one ground has been outlined in the table below, please feel free to contact us.
Purpose/Activity Type of data Lawful basis for processing including basis of legitimate interest
To register you as a new customer (a) Identity
(b) Contact
Performance of a contract with you
To process and deliver your order including:
(a) Manage payments, fees and charges
(b) Collect and recover money owed to us
(a) Identity
(b) Contact
(c) Financial
(d) Transaction
(e) Marketing and Communications
(a) Performance of a contract with you
(b) Necessary for our legitimate interests (to recover debts due to us)
To manage our relationship with you which will include:
(a) Notifying you about changes to our terms or privacy policy
(b) Asking you to leave a review or take a survey
(a) Identity
(b) Contact
(c) Profile
(d) Marketing and Communications
(a) Performance of a contract with you
(b) Necessary to comply with a legal obligation
(c) Necessary for our legitimate interests (to keep our records updated and to study how customers use our products/services)
To enable you to partake in a prize draw, competition or complete a survey (a) Identity
(b) Contact
(c) Profile
(d) Usage
(e) Marketing and Communications
(a) Performance of a contract with you
(b) Necessary for our legitimate interests (to study how customers use our products/services, to develop them and grow our business)
To administer and protect our business and this website (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data) (a) Identity
(b) Contact
(c) Technical
(a) Necessary for our legitimate interests (for running our business, provision of administration and IT services, network security, to prevent fraud and in the context of a business reorganisation or group restructuring exercise)
(b) Necessary to comply with a legal obligation
To deliver relevant website content and advertisements to you and measure or understand the effectiveness of the advertising we serve to you. (a) Identity
(b) Contact
(c) Profile
(d) Usage
(e) Marketing and Communications
(f) Technical
Necessary for our legitimate interests (to study how customers use our products/services, to develop them, to grow our business and to inform our marketing strategy).
To use data analytics to improve our website, products/services, marketing, customer relationships and experiences (a) Technical
(b) Usage
Necessary for our legitimate interests (to define types of customers for our products and services, to keep our website updated and relevant, to develop our business and to inform our marketing strategy)
To make suggestions and recommendations to you about goods or services that may be of interest to you (a) Identity
(b) Contact
(c) Technical
(d) Usage
(e) Profile
Necessary for our legitimate interests (to develop our products/services and grow our business)

Section 4.04: Marketing

We strive to provide you with choices regarding certain personal data uses, particularly around marketing and advertising. We have established a preference center where you can view and make certain decisions about your personal data use. This link along with an unsubscribe link can be found at the bottom of every marketing email you previously subscribed to.

Section 4.05: Promotional Offers from Us

  1. We may utilise your Identity, Contact, Technical, Usage, and Profile Data to develop an understanding of your potential preferences, needs, and interests. This enables us to determine which products, services, and offers may be relevant to you, a practice we refer to as marketing.
  2. If you have requested information from us or provided your details when entering a competition or registering for a promotion, and in each case have not opted out of receiving marketing communications, you will receive such communications from us.

Section 4.06: Third-Party Marketing

We will obtain your explicit opt-in consent before sharing your personal data with any company outside the Banen Associates group for marketing purposes.

Section 4.07: Opting Out

  1. You have the option to request us or third parties to cease sending you marketing messages at any time. This can be done by following the opt-out links provided in any marketing message sent to you or by reaching out to us directly.
  2. Opting out of receiving marketing messages will not affect the processing of personal data provided to us due to a product or service purchase, product or service experience, or other transactions.

Section 4.08: Cookies

You have the option to configure your browser settings to reject all or certain browser cookies or to receive alerts when websites attempt to set or access cookies. However, it’s important to note that if you disable or refuse cookies, certain parts of this website may become inaccessible or may not function correctly. For additional details about the cookies we use, please refer to our Cookie Policy.

Section 4.09: Change of Purpose

  1. We will exclusively use your personal information for the purposes for which we initially collected it, unless we reasonably determine that there is a need to utilise it for another reason, and that reason is compatible with the original purpose. If you seek an explanation of how the processing for the new purpose aligns with the original purpose, please reach out to us.
  2. In the event that we need to use your personal data for a purpose unrelated to the original collection, we will inform you and provide an explanation of the legal basis that permits such usage.
  3. It’s important to note that we may process your personal data without your knowledge or consent, in accordance with the mentioned principles, when such processing is required or permitted by law.

Article V: Disclosures Of Your Personal Data

Section 5.01: Sharing Personal Data

Banen Associates may share your personal information with third parties mentioned below for purposes set out in the above-given table.

  1. Internal Third Parties as mentioned in the Glossary.
  2. External Third Parties as mentioned in the Glossary.
  3. Specific third parties mentioned in the table in section 4 above.
  4. Third parties who we might choose to transfer, sell, or merge our business or our assets.

Alternatively, we may explore acquiring other businesses or engage in mergers with them. In the event of a change to our business structure, the new owners may utilise your personal data in a manner consistent with the provisions outlined in this privacy notice.

Section 5.02: Personal Data Security

We mandate that all third parties uphold the security of your personal data and handle it in compliance with the law. Our third-party service providers are not permitted to use your personal data for their own purposes; they are only authorized to process your personal data for specific purposes and in accordance with our instructions.

Article VI: International Transfers

Section 6.01: International Data Sharing

We share your personal data within Banen Associates Limited, and this may entail the transfer of your data outside the European Economic Area (EEA).

Section 6.02: International Data Sharing Protection

Whenever we transfer your personal information outside the EEA, we ensure an equivalent level of protection by implementing at least one of the following safeguards:

  1. When employing specific service providers, we may utilise contracts that have been approved by the European Commission. We give personal data the same level of protection it has in Europe. For additional information, refer to the European Commission’s Model contracts for the transfer of personal data to third countries.
  2. In cases where we engage providers based in the US, we may transfer data to them if they are part of the Privacy Shield. The Privacy Shield mandates these providers to afford a level of protection for personal data that is comparable to the standards applicable to data shared between Europe and the US. For further details, consult the European Commission’s EU-US Privacy Shield.
  3. If you seek more information about the specific mechanism used by us when transferring your personal data outside the EEA, please feel free to contact us.

Article VII: Data Security

Section 7.01: Security Measures

We have implemented suitable security measures to prevent your personal data from being accidentally lost, used or accessed without authorisation, altered, or disclosed. Additionally, we restrict access to your personal data to employees, agents, contractors, and other third parties who have a legitimate business need to access it. These individuals will only process your personal data based on our instructions and are bound by a duty of confidentiality.

Section 7.02: Security Breach

We have established procedures to address any suspected personal data breaches and will notify you and any relevant regulatory authorities of a breach, as we are legally obligated to do so.

Article VIII: Data Retention

Section 8.01: How Long Will You Use My Personal Data For?

  1. We will retain your personal data only for the duration necessary to fulfill the purposes for which we initially collected it, including meeting any legal, accounting, or reporting requirements.
  2. In determining the appropriate retention period for personal data, we take into account factors such as the quantity, nature, and sensitivity of the personal data, the potential risk of harm from unauthorized use or disclosure, the purposes for which we process the data, whether those purposes can be achieved through alternative means, and the relevant legal requirements.
  3. You can request details of retention periods for different aspects of your personal data by contacting us. We have a retention policy in place, and this information is available upon request.

Article IX: Your Legal Rights

Section 9.01: Data Protection Laws

Under specific circumstances, you are protected under the data protection laws regarding your personal data. Each of the following sections is elaborated in more detail in section 10.3:

  1. Request access to your personal data.
  2. Request correction of your personal data.
  3. Request erasure of your personal data.
  4. Object to the processing of your personal data.
  5. Request restriction of processing of your personal data.
  6. Request the transfer of your personal data.
  7. Right to withdraw consent.

Section 9.02: Exercising Data Protection Laws

Please make sure to contact Banen Associates first if you are looking to exercise the rights listed above in section 9.1. Email your query to: [email protected].

Section 9.03: No Fee Usually Required

You will not be charged a fee to access your personal data or to exercise any of the other rights mentioned. However, if your request is evidently unfounded, repetitive, or excessive, we may impose a reasonable fee. In such cases, we may also choose to decline to fulfill your request.

Section 9.04: What We May Need from You

To confirm your identity and ensure your right to access your personal data (or exercise any of your other rights), we may need to request specific information from you. This is a security measure to prevent the disclosure of personal data to individuals who are not authorized to receive it. Additionally, we may reach out to you for further information related to your request to expedite our response.

Section 9.05: Time Limit to Respond

We make every effort to respond to all legitimate requests within one month. However, if your request is especially complex or if you have submitted multiple requests, it may take us longer than a month. In such cases, we will notify you and keep you informed of the progress.

Article X: Glossary

Section 10.01 Lawful Basis

  1. Legitimate Interest refers to the interest of our business in conducting and managing our operations to provide you with the best service/product and the most secure experience. We ensure to consider and balance any potential impact on you (both positive and negative) and your rights before processing your personal data for our legitimate interests. We refrain from using your personal data for activities where our interests are outweighed by the impact on you (unless we have your consent or are otherwise required or permitted by law). Further information about how we assess our legitimate interests against potential impacts on you in specific activities can be obtained by contacting us.
  2. Performance of Contract involves processing your data when it is necessary for the performance of a contract to which you are a party or to take steps at your request before entering into such a contract.
  3. Complying with a Legal or Regulatory Obligation means processing your personal data when necessary for compliance with a legal or regulatory obligation to which we are subject.

Section 10.02: Third Parties

Internal Third Parties

Other companies within Banen Associates Limited may act as joint controllers or processors, and they are based in the UK and Hong Kong. These entities collaborate to provide services to candidates.

External Third Parties

  • Service providers acting as processors who offer IT and system administration services.
  • Professional advisers acting as processors or joint controllers, including lawyers, bankers, auditors, and insurers based in the UK or Hong Kong, providing consultancy, banking, legal, insurance, and accounting services.
  • HM Revenue & Customs, regulators, and other authorities acting as processors or joint controllers based in the United Kingdom or Hong Kong, requiring reporting of processing activities in certain circumstances.

Section 10.03 Your Legal Rights

You have the right to:

  1. Request access to your personal data (commonly known as a “data subject access request”). This allows you to receive a copy of the personal data we hold about you and verify that we are processing it lawfully.
  2. Request correction of the personal data that we hold about you. This allows you to have any inaccurate or incomplete data we have stored corrected, though we may need to verify the accuracy of the new data you provide to us.
  3. Request removal of your personal data. This allows you to ask us to delete or remove personal data where there is no good reason for us to continue processing 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 for erasure due to specific legal reasons, which will be communicated to you, if applicable, at the time of your request.
  4. Object to the 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 situation that 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 to the processing of your personal data for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which overrides your rights and freedoms.
  5. Request restriction of the processing of your personal data. This allows you to ask us to suspend the processing of your personal data in the following scenarios: (a) if you want us to establish the data’s accuracy; (b) where our use of the data is unlawful, but you do not want us to erase it; (c) 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; or (d) you have objected to our use of your data, but we need to verify whether we have overriding legitimate grounds to use it.
  6. Request the transfer of your personal data to you or to a third party. We will provide you, or a third party of your choice, with your personal data in a structured, commonly used, machine-readable format. Please note that this right only applies to automated information which you initially provided with your consent for us to use or where we used the information to draw up a contract with you.
  7. 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 process 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.

Banen Associates Limited

Banen Associates is a limited company, registered in England, with registered number 08996749. Our registered office is at 166 Manchester Road East Little Hulton, Manchester, Lancashire, England, M38 9LG.

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