Privacy Policy
Who we are
Gradient Edge Ltd, The Ormeau Baths, 18 Ormeau Avenue, Belfast, BT2 8HS. Registered in Northern Ireland, company number NI653279. Registered with the Information Commissioner's Office, reference ZB046253.
We are the data controller for the personal data described below. We have not appointed a Data Protection Officer, as we are not required to; responsibility for data protection sits with our Chief Technology Officer.
Contact us about anything in this policy at privacy@gradientedge.com.
What this policy covers
This policy covers personal data we decide what to do with - data about people who contact us, visit this website, apply for a job with us, or supply services to us.
It does not cover personal data we process on behalf of our clients. When we build and maintain software for a client, that client decides what is processed and why, and we act on their instructions under a written contract. If you are a customer of one of our clients, their privacy policy applies and they are the right people to ask.
What we collect, why, and on what basis
| Data | Why | Lawful basis |
|---|---|---|
| Name, employer, job title, email, phone and anything you put in your message | To respond to your enquiry and discuss potential work | Legitimate interests - responding to a business enquiry addressed to us |
| Business contact details of people at client and supplier organisations | To deliver our services and manage the relationship | Contract, or legitimate interests in managing a business relationship |
| Contact details and preferences for marketing | To send you material you have asked for | Consent |
| IP address, device and browser type, pages visited | To operate and secure this website, and to see how it is used | Legitimate interests for security and operation; consent for non-essential analytics |
| Recruitment data - CV, application, work history, right-to-work evidence, references | To assess your application | Steps prior to a contract; legal obligation for right-to-work checks |
| Equality monitoring data for applicants and staff in Northern Ireland | To meet fair employment monitoring duties and report to the Equality Commission | Legal obligation, and Article 9(2)(g) UK GDPR - substantial public interest |
We may also collect business contact details from public professional sources where we have a genuine reason to get in touch about work.
You cannot apply for a job through this website. If you apply for a role with us, we receive your application either directly at jobs@gradientedge.com or from a recruitment agency acting on your behalf - in which case the agency is the source of your data, and its own privacy policy covers what it does with it.
You do not have to give us any of this data, but if you do not we may be unable to respond to your enquiry, provide our services, or consider your application.
No automated decision-making or profiling takes place.
Cookies
We use two kinds of cookie on this website.
Strictly necessary cookies keep the site working and record your cookie choice. These are set without consent, because the site cannot function without them.
Analytics cookies are set by Google Analytics, which we use to understand how the site is used so we can improve it. These are set only if you agree. If you decline, Google Analytics does not run and no analytics cookies are set. Google Analytics sets a small number of cookies that distinguish one visitor from another and keep track of a visit; they expire after up to two years.
Google Analytics is provided by Google, which acts as our processor and transfers data to the United States - see the next section. Google does not store your full IP address in Google Analytics; it is used to estimate your general location and then discarded.
You can change or withdraw your choice at any time using the cookie settings link in the footer, or by clearing cookies in your browser.
Who we share it with, and where it is held
We share personal data with the technology providers who host our systems, with our professional advisers and insurers, and with regulators or law enforcement where the law requires it. We do not sell personal data or share it for anyone else's marketing.
We store data in the UK by default, and in the European Economic Area where a UK region is not available. Some data is transferred to the United States - including Google Analytics data, if you have accepted analytics cookies. For those transfers we rely on the UK Extension to the EU-US Data Privacy Framework, or on the UK International Data Transfer Agreement or Addendum. Ask us and we will tell you which applies to a particular service.
How we protect it
We hold Cyber Essentials Plus certification, independently audited and renewed annually, and we encrypt personal data in transit and at rest.
How long we keep it
| Enquiries that do not lead to a relationship | 12 months from last contact |
|---|---|
| Client and supplier records, and project data | Duration of the relationship, then 6 years |
| Employee records | Duration of employment, then 6 years |
| Unsuccessful job applications | 6 months, or 3 years in Northern Ireland |
| Equality monitoring data | 3 years for unsuccessful applicants; employment plus 6 years for those appointed |
| Financial records | 7 years |
| Marketing consents | Until you withdraw consent |
We may keep data longer where we need it for a legal claim or the law requires it. After that it is securely deleted or anonymised.
Your rights
You have the right to be informed about how we use your data, and to ask us to give you a copy of it, correct it, delete it, restrict how we use it, or provide it in a portable format. You can object to our use of your data where we rely on legitimate interests, and you can object to direct marketing at any time. Where we rely on consent, you can withdraw it at any time without affecting what we did beforehand.
Email privacy@gradientedge.com. We will respond within one month, free of charge. If a request is complex we may extend that by two months and will tell you why. Some rights do not apply in every situation; if we cannot do what you ask, we will explain why.
Complaints and changes
If you are unhappy with how we have handled your data, please tell us first at privacy@gradientedge.com. You can also complain to the Information Commissioner's Office at any time - ico.org.uk, helpline 0303 123 1113.
We review this policy at least annually and will post any updates here.