1. Dragonfly Holidings Ltd, Piccadilly Group Ltd, Piccadilly Labs Ltd, and Piccadilly Labs SL (hereafter, “we” or “Dragonfly”), complies with the UK Data Protection Act 1998, EU Directive 95/46/EC and the forthcoming EU Regulation 2016/679 (“GDPR”).

2. Our “services” include consultancy and professional services.

3. Your “personal data” applies to information relating to you as an identifiable natural person.

4. This Privacy Policy applies to the personal data that you provide to us, or we obtain through your use of the services, your participation or potential participation in the provision of services, your relationship or potential relationship with Dragonfly as an employer, or when you otherwise interact with us.

5. By registering for the services you consent to your personal data being collected, transferred, controlled, processed and destroyed as outlined in this policy.

Changes to this Policy

6. We may change this Privacy Policy from time to time. If we make any changes, we will notify you by revising the "Effective Starting" date at the top of this Privacy Policy. If we make any material changes, we will provide you with additional notice (such as by email).

7. If you disagree with any changes to this Privacy Policy, please let us know by sending an email to operations@piccadillygroup.com


Information We Process

8. Information you provide.  We store a limited amount of personal data that you directly provide us through our websites, software services, and interactions with us.

9. We do not collect collect or process information relating to racial or ethnic origin, political opinions, religious or philosophical beliefs, trade union membership, genetics, or biometrics.  In the event this data is given to us incidentally as it is present on copies of documents used to identify you, it will be used solely for identification purposes.

10. Call Recording.  Where appropriate, we may record audio or video conversations with for training and quality purposes.  You will be advised of this prior to the commencement of recording.

11. Other data submitted by you.  We collect other data that you submit to our websites or services as you participate in any interactive features of the services, participate in a survey, contest, promotion, sweepstakes, activity or event, apply for a job, request customer support, communicate with us via third party social media sites or otherwise communicate with us.

12. Computer Logs.  As is true with most websites and services delivered over the Internet, we gather certain information and store it in log files when you interact with our services.  This information includes internet protocol (IP) addresses as well as browser type, internet service provider, URLs of referring/exit pages, operating system, date/time stamp, information you search for, locale and language preferences, identifcation numbers, associated with your Devices, your mobile carrier, and system configuration information. Occasionally, we connect Personal Data to information gathered in our log files as necessary to improve the services for individual customers.  In such a case, we would treat the combined information in accordance with this privacy policy.

13. Cookies and Other Tracking Technologies.  We use various technologies to collect information, such as cookies and web beacons. Cookies are small data files stored on your hard drive or in device memory. We use cookies to improve and customize the services and your experience; to allow you to access and use the services without re-entering your username or password; and to count visits and understand which areas and features of the services are most popular. You can instruct your browser, by changing its options, to stop accepting cookies or to prompt you before accepting a cookie from websites you visit. If you do not accept cookies, however, you may not be able to use all aspects of the services.  We also use javascript, e-tags, " ash cookies", and HTML5 local storage to collect information about your online activities over time and across different websites or online services.

How we use the Personal Data we collect

14. We use the information we collect about you to:

a)        Provide, operate, maintain and promote our services;

b)        Identify you and enable you to use the services;

c)        To personalise the services to you;

d)        Send you messages, including responding to your comments, questions, and requests; providing service and support; and sending you technical notices;

e)        Send promotional communications, such as providing you with information about services, features, surveys, newsletters, offers, promotions, contests, events and providing other news or information about us and our select partners. You have the ability to opt out of receiving any of these communications as described below under "Your Choices"; or

f)         Monitor and analyse trends, usage, and activities in connection with the services.

How Long We Keep Your Data

15. Any data you provide will be deleted after 12 months

Information Disclosure

16. We are the controller and processor of the personal data provided and other than to provide the services you use, we will not share your personal data with a third party except:

a)        where required to do so by law;

b)        with your express consent;

c)        where data has been compiled into “Aggregated Data” and no longer identifies any natural person or corporate entity;

d)        where we nominate a third party processor subject to and in compliance with UK and EU legislation, or codes of conduct as defined in Article 40 of GDPR1.

Data Security

17. All data will be stored within the UK or the EU, except where the county has been permitted by Article 45 of GDPR, or alternative adequate safeguards are determined in line with Article 46 of GDPR.

18. The servers on which Personal Data is stored are kept in a secure environment. While we take reasonable efforts to guard your Personal Data, no security system is impenetrable and due to the inherent nature of the Internet as an open global communications vehicle, we cannot guarantee that information during transmission through the Internet or while stored on our systems or otherwise in our care, will be absolutely safe from intrusion by others, such as hackers.

19. Where data is transmitted over the internet it will always be encrypted using industry standard SSL (HTTPS).

Your Choices

20. You can opt out of receiving marketing materials or promotional communications by using the unsubscribe link within each email, or by emailing us at operations@piccadillygroup.com.  You can still use the services after opting out of this.

21. You have the right to see the information we hold about you.  Copies can be requested by sending a request to operations@piccadillygroup.com.

22. Information stored about you can be destroyed on your request.  Please send any such requests to operations@piccadillygroup.com.