1. Introduction

1.1 Deploi Technologies Ltd Ltd is committed to ensuring that your privacy is protected, and we comply with the General Data Protection Regulation as it forms part of UK law (“UK GDPR”) and other applicable data protection rules (including the Data Protection Act 2018 and marketing and cookies laws, together with associated guidance) (the "Data Protection Laws").

1.2 This policy explains how we use, store and share the information we collect about you, how you can exercise your rights in respect of that information and the procedures that we have in place to safeguard your privacy. This policy supplements any other fair processing or privacy notice that may be provided to you from time to time.

1.3 The Deploi mobile app (the "App") is run by Deploi Technologies Ltd Ltd (company no. 15530150 with registered office at Deploi, Embankment East Tower, 100 Cathedral Approach, Salford, Manchester M3 7FB ("we" and "us"). For the purposes of the Data Protection Laws, we are the controller of your personal data processed for the purposes set out below in connection with your use of the App or any Services provided in connection with the App.

1.4 This privacy notice sets out how we handle the personal data of our business clients (“Company”), suppliers, end users and other third parties for the purposes of our business.

1.5 A Company may ask you to download our App and use our Services for us to assist them in carrying out background screening checks, reference and documentation checks, checks to identify you and verify your employment references, qualifications and certifications (“Background Check(s)”) for employment or other purposes, as further detailed below.

1.6 You will be asked to provide us with specific information dependant on the Background Check that the Company wants us to carry out. This information will be shared with third party data sources (as detailed below) (“Data Sources”) who will verify the information you provide.

1.7 The outcome of the results of the Background Checks will then be used to form a report detailing our findings from the background checks and verification that will be provided to our business customers (the “Report”). After we have sent our Report to the Company, we will retain your Report to enable us to undertake any new Background Checks that you, or your prospective employer(s) require us to undertake in the future, in accordance with Section 5 below.

1.8 Any changes to this policy in the future will be posted on this page and, where appropriate, notified to you by email. Please check back frequently to see any updates or changes to this policy.

1.9 Please contact us by email at info@deploi.uk. If you have any questions, comments or concerns about this policy or how we handle your personal data, or if such information changes at any time.

2. What personal data we collect and why we collect it

1.1 Under the Data Protection Laws, we are required to explain what information we collect from you, how and why we use your personal data (the "Processing activity").

We are also required to have a "lawful basis" on which to process your personal data. You may request a copy of our expanded policy to review this.

A legitimate interest is when we have a business or commercial reasons to use your information (for example, to enhance our services or to carry out direct marketing). However, this legitimate interest must not unfairly go against what is right for you. We will therefore ensure that any collection and processing of your personal data:

● is not overly intrusive to you;

● is proportionate in order to meet our legitimate interests; and

● will always be kept to a minimum.

We consider that it is reasonable for us to process your information for the purposes of our legitimate interests outlined above as: (a) we process your information only so far as is necessary for such purpose; and (b) it can be reasonably expected for us to process your information in this way.

1.2 Sensitive Data

Certain personal data we collect warrants additional protection as it is treated as special category or relates to criminal convictions and offences (together “Sensitive Data”) to which additional protections apply under Data Protection Laws. We have indicated the purpose or purposes for which we are processing or will process your Sensitive Data in the table above in section 2.1 in connection with your use of the App or our Services, which includes the following categories of Sensitive Data:

● race and ethnicity

● religion

● political membership or opinions

● trade union membership

● genetics

● biometrics, e.g. fingerprints

● health and medical conditions

● sexual history or orientation

● any sickness absences

● any accidents connected with work

● criminal record history, including DBS checks.

We only process Sensitive Data where we are permitted to do so under Data Protection Laws, e.g.:

● we have your explicit consent;

● the processing is necessary to protect your (or someone else’s) vital interests where you are physically or legally incapable of giving consent;

● the processing is necessary to establish, exercise or defend legal claims;

● the processing is necessary for the prevention or detection of crimes and unlawful acts; or

● the processing is necessary for regulatory requirements applicable to us or our business customers.

3. Marketing and Promotional material

We may use your personal data to provide you with marketing and promotional materials (as stated above). You may opt-out of receiving marketing and promotional materials from us at any time by emailing us at info@deploi.uk, using the ‘unsubscribe’ link in the marketing or promotional email or message. You may also update your preferences to receive marketing or promotional materials by visiting our App.

4. Sharing your personal data AND BACKGROUND REPORT

1.3 Data Sources

For us to carry out Services and in connection with your use of the App, we use various third party sources to obtain your information, including the following:

• from publicly accessible sources, e.g., Companies House or HM Land Registry; • directly from a third party, e.g. sanctions screening providers, global watchlists and fraud databases; credit reference agencies; customer due diligence providers; referees (previous employers, etc.); public authority records; DBS criminal records checks; global watchlists and fraud databases; social media.

You may request a full list of the different checks which will be performed specifically for you in connection with our App or the Services. You may also contact our business customer who requires you to have a background check at any time if you have any questions about the specific information that will be collected about you. We will always use appropriate and reliable sources in providing our Services.

1.4 Recipients

We will only disclose your personal data to:

● Our business customers, such as your prospective employer(s) to be able to provide the service and App to you;

● companies within our group;

● our professional advisors (including without limitation tax, legal or other corporate advisors who provide professional services to us);

● third party Data Sources listed above, who provide us with your Vetting Data;

● other third party suppliers, business partners and sub-contractors for business administration, support, processing, services, or IT purposes;

● web hosting providers;

● analytics or search engines, that enable us to optimise and improve your App experience; ● other third party suppliers for marketing purposes;

● third parties we use to help deliver our App and the related Services to you, e.g. payment service providers, warehouses and delivery companies;

● third parties that you approve (including without limitation, social media sites and third party payment providers);

● our regulators, law enforcement or fraud prevention agencies, as well as our legal advisers, courts, the police and any other authorised bodies, for the purposes of investigating any actual or suspected criminal activity or other regulatory or legal matters; and

● HMRC or other tax bodies or agencies to comply with our legal and regulatory obligations.

We will disclose your personal data to third parties in the following circumstances:

● in the event that we consider selling or buying any business or assets, in which case we will disclose your personal data to any prospective sellers or buyers of such business or assets;

● external auditors, in which case the recipient of the information will be bound by confidentiality obligations;

● in the event we are the subject of any insolvency situation (e.g., the administration or liquidation);

● if we, or substantially all of our assets, are acquired by a third party, in which case personal data held by us about our customers will be one of the transferred assets;

● in order to enforce or apply our terms and conditions;

● to protect our rights, property, or safety, or that of our customers, or others. This includes exchanging information with other companies and organisations (including without limitation HMRC, the local police or other local law enforcement agencies) for the purposes customer safety, crime prevention, fraud protection and credit risk reduction; and

● if we are under a duty to disclose or share your personal data in order to comply with any legal obligation or regulatory requirements, or otherwise for the prevention or detection of fraud or crime.

5. Retention Periods

Different retention periods apply for different types of personal data. Further details on this are available. When we have carried out a Background Check on you, we will retain the results for our legitimate business purposes.

We have adopted retention guidelines for all the personal data which we retain, a copy of which can be obtained from info@deploi.uk.

6. International Transfers

We may transfer personal data to countries other than the country in which the data was originally collected (for example, outside the UK/EEA) to provide you with our Services.

These countries may not have the same data protection laws as the country in which you initially provided the information and may not provide the same level of protection.

If we transfer personal data to countries outside of the UK/EEA, we may rely on a decision from the UK government or European Commission determining that the country provides an adequate level of protection to the Data Protection Laws. Alternatively, we may rely on appropriate safeguards and supplementary measures to protect your personal data in accordance with this policy.

For example, if we were to transfer personal data from the UK to a third party located in a country outside of the UK European Economic Area such as the United States, we would implement an appropriate data export solution such as the European Commission’s or UK’s Standard Contractual Clauses and take such other supplementary measures required to ensure that your personal data has an adequate level of data protection as determined by Data Protection Laws.