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PRIVACY POLICY


GLOBAL PRIVACY POLICY

Santa Fe Group Limited and our affiliates and associated companies (“Santa Fe
Group” and/or “We“) are committed to protecting and respecting your privacy.

This Global Privacy Policy, together with our Terms of Use, Terms and
Conditions, our Personal Data Consent Letter (if applicable) and any other
documents referred to in any of the aforementioned (together the “Policy”)
describes the types of personal data we collect, how we use that data, with whom
we share it, how you can exercise your rights on your personal data and the
choices you can make about our use of the personal data.  We also describe the
measures we take to protect the security of the personal data and how you can
contact us about our privacy practices.

The legal basis for processing your personal data is consent.  As such, we may
ask you to sign a separate form of letter (“Personal Data Consent Letter”) to
indicate your explicit consent to our processing of your personal data for the
purposes set out in the Policy.  However, please note that the absence of (i)
such a request, or (ii) a Personal Data Consent Letter signed by you, is not
intended to be conclusive of this issue and we shall be entitled to conclude
that, by visiting us at any of our approved web sites; applications; or Portals,
or using our other digital assets or agreeing to receive Services from us, you
are accepting and consenting to the practices described in the Policy.
 Notwithstanding this, you have the right to contact us to object to, or make
certain requests in relation to, the processing of your personal data (as
explained further in the Your Rights section of this policy).

Our privacy practices may vary among the countries in which we operate to
reflect local practices and legal requirements (“Applicable Data Protection
Laws”).  In most cases this will be the law of the country in which you are
located.

According to Applicable Data Protection Laws, you may be entitled to know the
identity of your “Data Controller” i.e. the legal entity which determines why
and how your personal data is processed.  This will generally be the case when
are you located within the European Economic Area.

Your relevant Data Controller may vary, depending on how you are receiving
services from us. For example:

 1. Corporate Clients: If you are being relocated as part of your employment,
    your relevant Data Controller may be your relevant employer who has engaged
    us to provide services to you. In such case, this Policy may not apply to
    you and please refer, instead, to your employer’s privacy policy or employee
    handbook for further information as to how your personal data may be
    handled.  Even if this Policy does not directly apply to you, Santa Fe
    Group, as a “Data Processor” within the meaning of Applicable Data
    Protection Laws, will process the personal data under the Data Controller’s
    sole instructions, and will take all steps necessary to preserve the
    security and confidentiality of the personal data, and prevent their
    alteration, damage, or access by unauthorized persons.

 

 2. Direct Consumers / Individuals: If you are engaging the Santa Fe Group
    directly to provide services for you, then your relevant Data Controller is
    likely to be that particular Santa Fe entity which is providing those
    services to you, and this will typically be that Santa Fe entity which is
    based in your current location and which processes your personal data and
    which is named in any relevant correspondence with you. By way of example,
    if you are engaging us directly from within the UK, your relevant data
    controller (for the purposes of the UK Data Protection Act 2018 (the “UK DP
    Act”)) is likely to be Santa Fe Relocation Services (UK) Limited of 15
    Central Way, London NW10 7XW. A full, up-to-date list of our companies
    around the world can be found here.

 3. Referred / Partners: If you normally deal with one of our business partners,
    but have been referred to us to receive specific services at the bequest of
    that business partner, then that business partner may be your relevant Data
    Controller. In such case, this Policy may not apply to you and please refer,
    instead, to that business partner’s privacy policy. Even if this Policy does
    not directly apply to you, Santa Fe Group, as a Data Processor, will process
    the personal data under the Data Controller’s sole instructions, and will
    take all steps necessary to preserve the security and the confidentiality of
    the personal data, and prevent their alteration, damage, or access by
    unauthorised persons.

 

If you have any questions in regard to the above, please contact us at
dataprotection@santaferelo.com  or using the details set out in the How to
Contact Us section below.

Information we collect from you

We may collect personal information (including personally identifiable data and,
special category personal data for visa applications (where required to be
provided under law) within the meaning of Applicable Data Protection Law) about
you and/or your family (“Your Data”) in the following ways:

 * Information you give us. This is information that you and/or your family give
   us by filling in forms on our websites or other digital assets or by
   corresponding with us by phone, e-mail or otherwise. This includes when you
   use our websites or other digital assets or inquire about, or use, any of our
   immigration, moving, relocation and/or assignment services (the “Services”). 
   The personal data may include without limitation your and /or your family’s
   name, address, e-mail address, phone number or other contact details, marital
   status, age, occupation, role/title/area of responsibilities, financial and
   credit card information, personal description and photograph and other
   information (including as required by laws and regulations addressing
   insurance and related matters or as required to provide the Services). 
   Special category personal data may include, for example, data about criminal
   convictions, physical health and medical records, sexual orientation, racial
   or ethnic origin and religious beliefs for visa applications (where required
   to be provided under law).

Of course, you are not required to supply any of the personal data that we may
request, notably special category personal data, although this might limit the
Services we are able to offer you.  While we make every effort to ensure that
Your Data is accurate, complete and up to date, you can help us considerably in
this by promptly notifying us if there are any changes to Your Data (please see
the How to Contact Us section below).

 * Information we collect about you. We, our service providers and other
   business partners collect certain information by using automated means, such
   as cookies, when you interact with our advertisements, mobile applications,
   or visit our websites, pages or other digital assets. This information may
   include your IP address, browser type, operating system, the full URLs,
   referring URLs and information on actions taken or interaction with our
   digital assets.

We may use third-party web analytics services on our websites and other digital
assets, to help us analyse how visitors use our websites and other digital
assets.

We, our service providers and our business partners may also collect information
about your activities on our websites and other digital assets for use in
providing you with content and advertising tailored to your individual
interests.  The information collected for these purposes may include details
about things like the particular pages or advertisements you view on our
websites and the actions you take on our websites and or other digital assets.
For more details please see our Cookie Policy.

 * Information we may receive from other sources. We are working closely with
   third parties (including, for example, your employer, business partners and
   sub-contractors (including in technical, payment and delivery services,
   advertising networks, analytics providers, search information providers,
   credit reference agencies, financial institutions, financial advisers,
   external medical bodies, disclosure and criminal check services, police
   forces and courts) and may receive information about you from them). These
   third parties may be based outside of the EEA (see the Storage and transfer
   of Your Data section for more information).


COOKIES

Our website uses cookies.  A cookie is information that a web site stores on
your computer so that it can remember something about you at a later time.
 Cookies are commonly used on the Internet and do not harm your computer.  This
helps us to provide you with a good experience when you browse our website and
also allows us to improve our site.  The cookies used on our web sites do not
collect any personal data that others could read and understand about you, such
as your name; however, we may link information contained in a cookie to personal
information you may provide us with other means (e.g. web site registration).

All of our web sites currently use cookies for the purpose of collating general,
non- personal management information that is used to plan enhancements to our
web site.  For example, cookies help us to understand the popular paths that
users take through our web site and how often they visit. For more detailed
information on the cookies we use and the purpose for which we use them see our
Cookies Policy.

If you do not want us to use cookies when you visit our websites, you can
configure your browser not to accept them.  Disabling the use of cookies should
not adversely affect your use of the website.  To find out how to disable the
use of cookies, please refer to your browsers help facility or the manufacturers
instruction manual, or to our Cookies Policy.


USE OF YOUR DATA

We may use Your Data in the following ways:

 * to provide you and/or your family and/or or accompany dependents with the
   Services (as applicable);
 * to administer, operate, facilitate and manage your and/or your family’s
   and/or or accompany dependent’s relationship and/or account with us, and to
   otherwise, including contacting you or, if applicable, your designated
   representative(s) by post, telephone, email etc.;
 * to provide you, or permit selected third parties to provide you, with
   information (such as relocation research), recommendations or advice
   concerning our offers, promotions, products and services, including those
   products and services which you request from us. If you are an existing
   customer (and save for where this is permitted under Applicable Data
   Protection Laws or where you have provided your consent to further marketing)
   we will only contact you by electronic means (email) with information about
   goods and services similar to those which were the subject of a previous sale
   or negotiation of a sale to you. If you are a new customer, and where we
   permit selected third parties to use Your Data, we (or they) will contact you
   by electronic means only if you have consented to this, save for where this
   is otherwise permitted under Applicable Data Protection Laws. If you do not
   want us to use Your Data in this way, or to pass your details on to third
   parties for marketing purposes, then please indicate your preference on the
   form on which we collect Your Data;
 * to notify you about changes to the Services;
 * to operate, evaluate and improve our business (including developing new
   products and services, troubleshooting, data analysis, testing and research
   and statistical and survey purposes); managing our communications;
   determining the effectiveness of and optimizing our advertising; analysing
   our products, services, websites, mobile applications and any other digital
   assets; facilitating the functionality of our websites, mobile applications
   and any other digital assets; to ensure the content of our site is presented
   in the most effective manner for you and for your computer; and performing
   accounting, auditing, billing, reconciliation and collection activities;
 * as may be required by applicable laws and regulations or requested by any
   relevant judicial process or governmental agency; and
 * to comply with industry standards and our policies.

We do not use automated decision making.


DISCLOSURE OF YOUR DATA

We may share Your Data with:

 * Any member of our group, which means our subsidiaries, our ultimate holding
   company and its subsidiaries, as defined in section 1159 of the UK Companies
   Act 2006, subject to the terms of this Global Privacy Policy.
 * Selected third parties including:
   * business partners, suppliers and sub-contractors for the performance of the
     Services (as applicable) or any other contract we enter into with them or
     you;
   * credit reference agencies for the purpose of assessing your credit score
     where this is a condition of us providing the Services to you and/or your
     family and where authorized under Applicable Data Protection Law; and
   * your employer, external medical bodies, disclosure and criminal check
     services, police forces and courts and relevant immigration authorities for
     the purpose of preparing and processing your visa application.

We may also disclose Your Data to third parties:

 * In the event that we sell or buy any business or assets, in which case we may
   disclose Your Data to the prospective seller or buyer of such business or
   assets.
 * If Santa Fe Group Limited or substantially all of its assets are acquired by
   a third party, in which case Your Data may be one of the transferred assets.
 * If we are under a duty to disclose or share Your Data in order to comply with
   any legal obligation, or in order to enforce or apply our Terms of Use or
   Terms and Conditions and other agreements; or to protect the rights,
   property, or safety of our group, our customers, or others.  This includes
   exchanging information with other companies and organisations for the
   purposes of fraud protection and risk reduction.

As the case may be, one or more of the above may be located outside of the
European Economic Area.

Storage and transfer of Your Data

Santa Fe is a global business.  To offer and perform our services, we may need
to transfer your personal information among several countries.  The personal
information that we collect from you may be transferred to, and stored at, a
destination outside the European Economic Area (“EEA”) or Switzerland, including
the United States of America.  Those countries may not have the same data
protection laws as the country in which you initially provided the information. 
It may also be processed by staff operating outside the EEA who work for us or
for one of our business partners or sub-contractors. This includes staff engaged
in, among other things, providing you and/or your family with the Services (as
applicable), the processing of your payment details and the provision of support
services.  We will take all steps reasonably necessary to ensure that Your Data
is processed and treated securely and in accordance with this Global Privacy
Policy and with the Applicable Data Protection Law which may include using the
EU model clauses.

The security of Your Data is important to us.  We are committed to protecting
the information we collect.  We maintain administrative, technical and physical
safeguards designed to protect the personal information you provide or we
collect against accidental, unlawful or unauthorized destruction, loss,
alteration, access, disclosure or use.  All information you provide to us is
stored on our secure servers.  We use SSL encryption on our websites from which
we transfer certain personal information.

We store Your Data only for as long as it is necessary to fulfil the purpose for
which it was collected, unless otherwise required or authorized by Applicable
Data Protection Law.  We take measures to destroy or permanently de-identify
Your Data if required by law or if Your Data is no longer required for the
purpose for which we collected it.

Where we have given you (or where you have chosen) a password which enables you
to access certain parts of our websites or other digital assets, you are
responsible for keeping this password confidential.  We ask you not to share a
password with anyone.

Unfortunately, the transmission of information via the internet is not
completely secure. Although we will do our best to protect Your Data, we cannot
guarantee the security of Your Data transmitted to our websites or other digital
assets that are in the public domain; any transmission is at your own risk.
 Once we have received your information, we will use strict procedures and
security features to try to prevent unauthorised access.


YOUR RIGHTS

Under Applicable Data Protection Law, you may have certain rights regarding the
personal data we maintain about you.  We also offer you certain choices about
what personal data we collect from you, how we use that personal data, and how
we communicate with you.

You can choose not to provide personal data to us.  You also may refrain from
submitting personal data directly to us.  However, if you do not provide Your
Data when requested, or if you exercise your rights you and/or your family may
not be able to benefit from the Services (as applicable), and we may not be able
to provide you with information about our products, services and promotions.

To the extent provided by Applicable Data Protection Law, you may withdraw any
consent you previously provided to us, or object at any time to the processing
of Your Data.  We will apply your preferences going forward.  In some
circumstances, withdrawing your consent to our use or disclosure of Your Data
will mean that you cannot take advantage of certain Services.

In addition you may have the right to: obtain confirmation that we hold personal
data about you, request access to and receive information about the personal
data we maintain about you, receive copies of the personal data we maintain
about you, update and correct inaccuracies in your personal data, object to the
processing of your personal data, and have the personal data blocked, anonymized
or deleted, as appropriate.  The right to access personal data may be limited in
some circumstances by local law requirements including Applicable Data
Protection Law. To exercise these rights, please contact
dataprotection@santaferelo.com.

You have the right to ask us not to process Your Data for marketing purposes.
 We will inform you (before collecting Your Data) and obtain your prior consent
where required by the Applicable Data Protection Law if we intend to use Your
Data for such purposes or if we intend to disclose Your Data to any third party
for such purposes.  You can exercise your right to prevent such processing by
advising us of your preferences before we collect Your Data, including on the
form that is used to collect Your Data.  You can also exercise the right at any
time by contacting us at marketing@santaferelo.com.

The rights above are likely to apply to you if you are based in Europe.

Our websites or other digital assets may, from time to time, contain links to
and from the websites of our partner networks, advertisers and affiliates.  If
you follow a link to any of these websites, please note that these websites have
their own privacy policies and that we do not accept any responsibility or
liability for these policies.  Please check these policies before you submit any
personal data to these websites.

If you provide us with any information or material relating to another
individual, you should make sure that the sharing with us and our further use as
described to you from time to time is in line with applicable laws, so for
example you should duly inform that individual on the processing of her/his
personal data and obtain her/his consent, as may be necessary under Applicable
Data Protection Laws.


ACCESS TO INFORMATION

Applicable Data Protection Law may give you the right to access personal data
held about you.  This will usually be the case where you are based in Europe.
 Any request should be made in writing, and the best way for you to do so is to
contact us at the addresses stated below.  As we must be able to identify the
person making the request, we request that you confirm any request made by you
via different means by contacting us at the address stated below.  Due to
technological constraints and/or information security considerations, it may be
inappropriate to use social media to supply information in response to any
request by you for access to personal data, and so please provide an alternative
delivery address for our response.  We may reject requests and/or charge a fee
where we are entitled to do so under Applicable Data Protection Laws, which may
include where the request is manifestly unreasonable, in particular due to its
repetitive or systematic nature, require disproportionate effort and/or risks
the privacy or confidentiality of others.


DATA SECURITY AND INTEGRITY

The security, integrity and confidentiality of Your Data is very important to
us. We have implemented controls to protect Your Data from unauthorised access,
modification, disclosure and misuse.  We encrypt our data in transit and
constantly review new technologies to protect Your Data.  Please bear in mind
that despite our best efforts to safe guard Your Data, no security measures are
perfect or impenetrable.


CHANGES TO OUR GLOBAL PRIVACY POLICY

Any changes we make to our Global Privacy Policy in the future will be posted on
this page and, where appropriate, notified to you by e-mail.  Please check back
frequently to see any updates or changes to our Global Privacy Policy.


HOW TO CONTACT US

If you have any questions or comments about this Global Privacy Policy, our
privacy practices or if you would like us to update personal data or preferences
you provided to us, please click here.  You also may e-mail us at:
dataprotection@santaferelo.com or write to us at:

 

Data Protection Officer
Santa Fe Group Limited
1 Lyric Square
London, W6 0BN
United Kingdom

 

Issue date: 01/11/2021

Owner: Legal / Compliance



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