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Privacy policy
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Your Arctic Shores Privacy Notice
Last updated 22 March 2024

Who we are:                  Hello! We are Arctic Shores Limited. For the purposes of the UK
                             GDPR, where you are a Candidate, we are a Data Processor.

                             If you are a User, Website Visitor or Prospective Client we will
                             process your personal data in our capacity as a Data Controller.

What we do:                  We are on a mission to provide next generation task-based
                             assessment tools for companies.

Why is privacy notice        You are here because we may process some of your personal
relevant to you:             information either because:
                                 ● You have been invited by one of the companies we work
                                   with to undertake a task-based assessment (we will refer
                                   to you as a “Candidate” in this privacy notice), or
                                 ● You are a business partner who uses our UNA or Data
                                   Hub platform on behalf of the company to set up, manage
                                   and administer the task-based assessments for that
                                   company (and we will refer to you as a “User” in this
                                   privacy notice).
                                 ● You are visiting our website (and we will refer to you as a
                                   “Website Visitor” in this privacy notice)
                                 ● You have attended one of our events or contacted us to
                                   collaborate with us in some way (we will refer to you as
                                   an “Prospective Client”
                                   Please take the time to read this privacy notice together
                                   with the privacy notice of the company that introduced
                                   you to us.

How to contact us:           We're here to help!

                             Questions regarding this privacy notice and how we may
                             process your data are welcomed and should be addressed to
                             privacy@arcticshores.com or by mail to:

                             Arctic Shores Limited
                             Attn: Data Protection Queries
                             17 Marble Street
                             Manchester, M2 3AW
                             England

                             Regarding Your Queries:
                          If you are a Candidate, please be aware that we are a Data
                          Processor. This means that we process your personal data solely on
                          behalf of the business that introduced you to us, as they are the
                          Data Controller, so we may refer your query to them. The Data
                          Controller is responsible for deciding how your information is used
                          and we process it based on their instructions. If we need to pass
                          your query to them, we'll let you know. Rest assured, we'll also
                          work together with them, you, and the regulator to ensure you
                          receive the necessary information and support.

Personal Information We Collect about You
If you are a Candidate:   We always collect:

                             ●   Psychometric Data: This is the responses you input
                                 during the assessment process.
                             ●   Technical Data: Your IP (internet protocol) address used
                                 to connect your computer to the internet, device
                                 identifier, browser type and version, time zone setting,
                                 browser plug in types and versions, operating system and
                                 platform.

                          We will may also collect:

                             ●   Identity and Email Address Data: Your first name, last
                                 name, candidate ID, username and email address.
                             ●   Contact Data: your telephone number or address - if you
                                 contact us for any reason and would like us to contact
                                 you back.
                             ●   Interaction Data: Any emails or letters you might write to
                                 us or support tickets (if you raise a technical support
                                 query).
                             ●   Demographic data: such as your ethnicity, age, gender,
                                 health and socioeconomic background - but only if you
                                 wish to provide this to us after you have used our
                                 assessment tools. This is always completely optional.
                             ●   Special category data, such as health information, which
                                 will be collected if you request a reasonable adjustment
                                 for the assessment.

If you are a User:        We collect:

                             ●   Identity Data: Your first name, last name.
                             ●   Contact Data: Your email address and phone number.
                             ●   Interaction Data: The data you provide when you are
                                 logged-into and use our UNA or DataHub Platform and in
                                  any emails or other correspondence (such as tech
                                  support tickets).
                              ●   Technical Data: Your IP (internet protocol) address.

If you are a Prospective   We collect:
Client:
                              ●   Identity Data: Your first name, last name and company
                                  you work for.
                              ●   Contact Data: Your email address and phone number.

If you are a Website       We collect:
Visitor:
                              ●   Technical Data: Your IP (internet protocol) address
                              ●   Information about how you are using our website (please
                                  see Cookies section below.

How We Get Your Personal Information
                           We will normally receive your personal data directly from you
                           and any devices you use when accessing our website or using
                           our platform.

                           If you are a Candidate we may receive your name and E-Mail
                           address directly from the company who introduced you to us.

Our Legal Basis to Use     Under the UK General Data Protection Regulation, the lawful
Your Personal              basis we rely on for processing your personal information is
Information:               contractual necessity. This means that we use your data to
                           deliver our service under contracts we have in place with Users
                           of our platforms, and who introduced Candidates to us.

                           In very limited circumstances we may also process your personal
                           information to comply with a legal or regulatory obligation or for
                           our legitimate interests. We will describe some examples for
                           situations when this may occur below.

                           Where you may be sharing special category data with us (for
                           example health information), this will be on the basis of consent.
                           It is the responsibility of the company who introduced you to us
                           (the Data Controller,) to ensure that they are obtaining your
                           explicit consent for us to process this data.

                           For further information, we encourage you to also read the
                           privacy notice of the company that introduced you to us or to
                           reach out to them directly.

What We Do With Your Personal Information:
If you are a Candidate:   We use your personal information in the following ways to
                          perform our contract with the business that introduced you to
                          us:

                             ●   Provide a task-based assessment to you on the
                                 instructions of the company that introduced you to us.
                             ●   Using a standardised scoring mechanism, your
                                 assessment results will be compared against appropriate
                                 norm groups to assess your responses against the
                                 characteristics required by the company introducing you,
                                 as part of their job profile.
                             ●   Report the results of that assessment to the Company.
                                 Once generated, your results are automatically sent to
                                 the company who introduced you to us.
                             ●   Provide you with your own summary of your assessment
                                 results. This report will provide you with a summary of
                                 your assessments results and how you scored against the
                                 criteria set by the company. These results are based on a
                                 standardised marking system and feedback framework.
                             ●   Manage any support queries you may raise (such as
                                 technical issues you may be having), including queries
                                 about your personal data.

                          If you provide us with any optional demographic data either:

                             ●   When we ask you before you start your assessment
                                 whether you have any disabilities (such learning
                                 difficulties), we will provide that personal information to
                                 the company who introduced you so it can decide
                                 whether it wishes to make any adjustments to the
                                 assessment based on the information you provide.
                             ●   When we ask you after you have completed the
                                 task-based assessment for information about your
                                 ethnicity, health, socio-economic background, disabilities
                                 and education, we use that personal information for equal
                                 opportunity monitoring and reporting. While the company
                                 that introduced you may receive a summary report
                                 containing aggregated data we receive from these
                                 responses, the data is anonymised and they will not
                                 receive your specific responses to those questions.

                          We may also use your Personal Data:

                             ●   To improve our product or the services we provide.
                                 However, if we do this, we will anonymise your personal
                                 information first (meaning that any data we use will not
                                 be able to identify you).
                             ●   On the rare occasion:
                                     ○   for our legitimate interests of investigating or
                                         preventing fraudulent, harmful, unauthorised or
                                         illegal activity on our platform.
                                     ○   to comply with any legal requirement such as
                                         being required by a court or regulatory body such
                                         as the Information Commissioner’s Officer to
                                         process your personal information in a specific
                                         way.

If you are a User:         We use your personal information to perform our contract with
                           the business that introduced you to us. This includes to:

                              ●   Provide the services set out in our contract with the
                                  business that introduced you to us and to administer that
                                  contract (such as processing orders, payment of invoices
                                  and ongoing relationship management).
                              ●   Provide any reports and insights to you.
                              ●   Process any support tickets (such as technical support or
                                  service level issues).
                              ●   Improve our product or the services we provide.

                           We may also use your Personal Data:

                              ●   for our legitimate interests of investigating or preventing
                                  fraudulent, harmful, unauthorised or illegal activity on our
                                  platform.
                              ●   for our legitimate interests of sending you marketing
                                  communications related to our product or services (and
                                  you will always have an opportunity to opt out of this).
                              ●   to comply with any legal requirement such as being
                                  required by a court or regulatory body such as the
                                  Information Commissioner’s Officer to process your
                                  personal information in a specific way.

If you are a Prospective   We will use your Personal Data to keep you informed of our
Customer:                  products and services we feel may be of interest to you. We will
                           do so on the basis of legitimate interest unless consent is
                           required, in which case it will be obtained as appropriate
                           beforehand.

Who We Share Your Personal Information With:
                           We will share your personal information with the company who
                           introduced you to us in accordance with this Privacy Notice
                           because they are the data controller of your personal
                           information and we process your personal information for them.
                        In order to provide our services to the company who introduced
                        you to us, we also share your personal information with other
                        third party data sub-processors. You can find out who these
                        sub-processors are available on request.

International Data Transfers
                        When we share personal information, it may be transferred to,
                        and processed in, countries other than the country you live in –
                        such as to the United States, where our customer management
                        software is located. These countries may have laws different to
                        what you’re used to - but rest assured, where we disclose
                        personal data to a third party in another country, we put
                        safeguards in place to ensure your personal data remains
                        protected.

                        Where your personal data is transferred outside the United
                        Kingdom or the European Economic Area, it will only be
                        transferred to countries that have been identified as providing
                        adequate protection (like New Zealand), or to a third party
                        where we have approved transfer mechanisms in place to
                        protect your personal data, for example, by entering into and
                        International Data Transfer Agreement. For further information,
                        please contact us using the details set out in the Contact us
                        section below.

How Long We Hold Your   If you are a Candidate, we will retain your information for 12
Personal Information    months after your last activity with us. This period is counted
For:                    from the latest of these events: (i) when a record of you is
                        created in our Platform by the company that introduced you to
                        us, (ii) when you receive an invitation to take the assessment,
                        (iii) when you open the assessment, or (iv) when you complete
                        the assessment. If the company that introduced you to us asks
                        you to take another assessment within this 12 months period
                        (perhaps because you have applied for another role at that
                        company), this retention period starts again.

                        If you are a User, we will retain your information for the duration
                        of the Agreement and for a reasonable period after that to either
                        return your personal data to the company or delete Your
                        Personal Data.

                        We may erase your personal information sooner than that if the
                        company who introduced you to us asks us to do that - either on
                        their own behalf or following a request from you to erase your
                        personal information. If you want to exercise those rights, you
                         need to contact the company that introduced you to us. You can
                         find the relevant contact details in their privacy notice.

Special Category Data:   Special category data includes information about criminal
                         convictions, race or ethnic origin, political or religious beliefs,
                         health, genetic or biometric data, sex life and sexual orientation,
                         trade union membership and philosophical beliefs of an
                         individual.

                         We will not routinely collect special category data. However, if
                         you request a Reasonable Adjustment to complete the
                         Candidate Assessment, or if you choose to participate in our
                         post-assessment candidate survey, we may collect data about
                         your health and ethnic origin. This is always completely optional
                         and will not be shared with the company that introduced you to
                         us.

                         If you provide us with health information prior to taking the
                         assessment, we will share this information with the company
                         that introduced you, so they can determine whether any
                         reasonable adjustments need to be made to the assessment
                         before you take it.

How Do We Keep Your Personal Information Secure:
                         Safe and sound, that's our promise!

                         We have put in place appropriate security measures to prevent
                         your Personal Data from being accidentally lost, used or
                         accessed in an unauthorised way, altered or disclosed. The
                         efficacy of these security measures is evidenced by the fact that
                         we are proudly ISO 27001 certified. This is a global standard for
                         keeping personal information safe and secure. We also apply the
                         technical and organisational measures across our company to
                         prevent unauthorised processing of your personal information or
                         loss, damage or destruction to it. All our employees are also
                         subject to a contractual duty of confidentiality and training,
                         along with other protective measures.

                         We require our sub-processors to protect your personal data as
                         we do in this notice, and they may not use your personal
                         information for any other purpose.

                         We have also put in place procedures to deal with any actual or
                         suspected personal data breach. In the event of any such
                         breach, we have systems in place to work with the company
                         who introduced you to us and the applicable regulators.
Your Rights:   You're in control

               The GDPR gives you certain rights regarding the processing of
               your personal information. The rights that may apply will depend
               on the purpose for which your data is being processed. The
               company which introduced you to us (who is the Data Controller)
               will be able to provide you with full details of your applicable
               rights. You should refer to their Privacy Notice, or contact them
               directly. These rights may include the following:

               Your right of access. You have the right to ask us for copies of
               your personal information.

               The right to be informed. You have the right to be told what
               personal data is collected about you, why, who is collecting the
               data, how long it will be held, how you can file a complaint and
               with whom your data will be shared.

               Your right to rectification. You have the right to ask us to rectify
               personal information you think is inaccurate. You also have the
               right to ask us to complete information you think is incomplete.

               Your right to erasure. You have the right to ask us to erase your
               personal information in certain circumstances.

               Your right to restriction of processing. You have the right to ask
               us to restrict the processing of your personal information in
               certain circumstances.

               Your right to object to processing. You have the right to object
               to the processing of your personal information in certain
               circumstances.

               Your right to data portability. You have the right to ask that we
               transfer the personal information you gave us to another
               organisation, or to you, in certain circumstances.

               Rights in relation to automated decision making and profiling.
               You have particular rights in relation to automated decision
               making and profiling to reduce the risk that a potentially
               damaging decision is taken without human intervention. You can
               object to your personal data being used for profiling, direct
               marketing or research purposes.

               You will usually not be charged for exercising any of these rights.
               However, we may charge a reasonable fee if your request is
               clearly unfounded, repetitive or excessive, or, we may simply
               refuse to comply with your request in these circumstances.

               We or the company that introduced you to us will try to respond
               to all requests within one month. Should we require more time,
               we will let you know within 30 days of your request and will
               always respond within 90 days of the date of your request.
                    To exercise any of these rights, we recommend that you contact
                    the company that introduced you to us - as they are responsible
                    for determining the scope of these rights and how they are
                    administered. You can also contact us by using the contact
                    details at the start of this notice and we will pass your request
                    on to that company if you would prefer to do that.

Changes to this notice
                    We regularly review our privacy notice and we will post any
                    modifications or changes to this privacy notice on this page,
                    unless we specifically notify you otherwise.

Need to Complain?   Let's sort it out.

                    If you're concerned about how we handle your data, please
                    reach out to us using the contact details we provided in this
                    notice or contact the company that introduced you to us.

                    Not satisfied? You can also contact the ICO:

                    Address: Information Commissioner’s Office, Wycliffe House,
                    Water Lane, Wilmslow, Cheshire, SK9 5AF
                    Helpline: 0303 123 1113
                    Website: https://www.ico.org.uk

How We Use Cookies and Similar Technologies:
                    Cookies are small text files that are placed on your computer by
                    websites that you visit. They are widely used in order to make
                    websites work, or work more efficiently, as well as to provide
                    information to the owners of the site. The table below explains
                    the cookies we use and why.

                    You can set your browser to refuse all or some of those cookies
                    but if you disable or refuse these cookies, some parts of this
                    assessment may become inaccessible or not function properly.

                    Cookie ID            Purpose and User Type                       Expiry

                    token                This cookie is for Candidates and UNA          30
                                         Users and is a strictly necessary cookie.    minutes

                                         This is a token session cookie.
                                         Whenever you complete an action, this
                   cookie tells our system that so it can
                   remember what page you are currently
                   on.

Apt.uid            This cookie is for Candidates and UNA         30
Apt.sid            Users and is an optional cookie.            minutes
(for Candidates)
A random uid is    This is a unique id used to track what
generated          you are doing (such as what you are
(for Una Users)
                   clicking on). The purpose is to track
                   usage of the software so our product
                   team can improve the product and user
                   experience

amplify-signin-w   This cookie is for UNA Users and is a         30
ith-hostedUI       strictly necessary cookie.                  minutes

                   This is an AWS cookie for tracking
                   signing in and sign out. When you sign
                   in, an identifier is set and your
                   credentials (such as name, email and
                   user ID and user type are recalled via a
                   JSON feed.

2fa_session        This cookie is for DataHub Users and       24 hours
                   Candidates and is a strictly necessary     DataHub
                                                              Users
                   cookie.

                   This is a session cookie for user login.   30 days
                                                              Candidates
                   The server checks the session ID in the
                   cookie against the stored session data
                   to authenticate the user. Example:
                   546d31c62aa24ed4a5f39dd27576aea4:
                   1rd4V3:uA7wubNBxA6zkAghIMsSY3LM
                   SdY

__cf_bm            This cookie is for DataHub Users and is       30
                   an a strictly necessary cookie.             minutes

                   This cookie contains information related
                   to the calculation of Cloudflare's
                   proprietary bot score and, when
                   Anomaly Detection is enabled on Bot
                   Management, a session identifier.

csrftoken          This cookie is for DataHub Users and is    As long as
                   an a strictly necessary cookie                 the
                                                               session
                   A CSRF token is a unique, secret, and
                   unpredictable value that is generated by
                   the server-side application and shared
                   with the company we work with.

ID: sessionid      This cookie is for DataHub Users and is    Once you
                   an a strictly necessary cookie.            log off or
                                                              close the
                   This is a server-specific cookie that       browser
                   cannot be passed to any machine other
                   than the one that generated the cookie.
                   The server creates a “session ID” which
                   is a randomly generated number that
                   temporarily stores the session cookie.

ID: _ga            This functional cookie is for Website        2 years
                   Visitors and is an optional cookie.

                   Used to distinguish users.

ID: _gcl_au        This analytics cookie is for Website         2 months
                   Visitors and is an optional cookie.

                   This cookie is used by Google Analytics
                   to understand user interaction with the
                   website.

ID: _gid           This analytics cookie is for Website         24 hours
                   Visitors and is an optional cookie.

                   The cookie is used to store information
                   of how visitors use a website and helps
                   in creating an analytics report of how
                   the website is doing. The data collected
                   including the number of visitors, the
                   source where they have come from, and
                   the pages visited in an anonymous form.

_hjAbsoluteSessi   This functional cookie is for Website        30 mins
onInProgress       Visitors and is an optional cookie.

                   This cookie is used to detect the first
                   pageview session of a user. This is a
                   True/False flag set by the cookie.

ID: _hjFirstSee    This functional cookie is for Website        Session
                   Visitors and is an optional cookie.           only

                   This is set to identify a new user’s first
                   session. It stores a true/false value,
                   indicating whether this was the first time
                   Hotjar saw this user. It is used by
                   Recording filters to identify new user
                   sessions.

_hjTLDTest         This functional cookie is for Website        Session
                   Visitors and is an optional cookie.

                   When the Hotjar script executes we try
                   to determine the most generic cookie
                   path we should use, instead of the page
                   hostname. This is done so that cookies
                   can be shared across subdomains
                   (where applicable). To determine this,
                   we try to store the _hjTLDTest cookie for
                   different URL substring alternatives until
                   it fails. After this check, the cookie is
                   removed.
_hjid               This functional cookie is for Website         1 year
                    Visitors and is an optional cookie.

                    Hotjar cookie that is set when the
                    customer first lands on a page with the
                    Hotjar script. It is used to persist the
                    Hotjar User ID, unique to that site on the
                    browser. This ensures that behavior in
                    subsequent visits to the same site will
                    be attributed to the same user ID.

_hjIncludedInPag    This analytics cookie is for Website           30
eviewSample         Visitors and is an optional cookie.          minutes

                    This cookie is set to let Hotjar know
                    whether that visitor is included in the
                    data sampling defined by your site’s
                    pageview limit.

cli_user_preferen   This cookie is for Website Visitors and      Session
ce                  is a necessary cookie.

                    The cookie is set by the GDPR Cookie
                    Consent plugin and is used to store
                    whether or not user has consented to
                    the use of cookies. It does not store any
                    personal data.

Cookielawinfo-c     This cookie is for Website Visitors and       1 year
heckbox-necess      is a necessary cookie.
ary
                    This cookie is set by GDPR Cookie
                    Consent plugin. The purpose of this
                    cookie is to check whether or not the
                    user has given the consent to the usage
                    of cookies under the category
                    ‘Necessary’.

Cookielawinfo-c     This cookie is for Website Visitors and       1 year
heckbox-non-ne      is a necessary cookie.
cessary
                    This cookie is set by GDPR Cookie
                    Consent plugin. The purpose of this
                    cookie is to check whether or not the
                    user has given their consent to the
                    usage of cookies under the category
                    ‘Non-Necessary’.

nabAlternative      This analytics cookie is for Website         3 months
                    Visitors and is an optional cookie.

                    Nelio A/B Testing: This cookie stores the
                    variant a visitor is supposed to see.
nabExperiement       This analytics cookie is for Website         3 months
sWithPageViews       Visitors and is an optional cookie.

nabParticipation     This analytics cookie is for Website         3 months
                     Visitors and is an optional cookie.

                     Nelio A/B Testing: Visitors may or may
                     not participate in your tests. This cookie
                     keeps track of that.

nabSegmentatio       This analytics cookie is for Website         3 months
n                    Visitors and is an optional cookie.

Viewed_cookie_       This cookie is for Website Visitors and       1 hour
policy               is a necessary cookie.

                     The cookie is set by the GDPR Cookie
                     Consent plugin and is used to store
                     whether or not user has consented to
                     the use of cookies. It does not store any
                     personal data.

_hs_initial_opt_in   This cookie is for Website Visitors and       1 week
                     is a necessary cookie.

                     This cookie is used by HubSpot to
                     prevent the banner from always
                     displaying when visitors are browsing in
                     strict mode.

_hs_opt_out          This cookie is for Website Visitors and      13 months
                     is a necessary cookie.

                     The cookie is set by HubSpot and is
                     used by the opt-in privacy policy to
                     remember not to ask the visitor to
                     accept cookies again.

_hssc                This analytics cookie is for Website            30
                     Visitors and is an optional cookie.           minutes

                     This cookie is set by HubSpot and is
                     used to keeps track of sessions.

_hssrc               This functional cookie is for Website         Session
                     Visitors and is an optional cookie.

                     This cookie is set by HubSpot and is
                     used whenever HubSpot changes the
                     session cookie, this cookie is also set to
                     determine if the visitor has restarted
                     their browser.
                               _hstc                  This analytics cookie is for Website        13 months
                                                      Visitors and is an optional cookie.

                                                      The cookie is set by HubSpot and is the
                                                      main cookie for tracking visitors.

                               Hubspotutk             This functional cookie is for Website       13 months
                                                      Visitors and is an optional cookie.

                                                      This cookie is set by HubSpot and is
                                                      used to keeps track of a visitor’s
                                                      identity. It is passed to HubSpot on form
                                                      submission and used when
                                                      deduplicating contacts.

Previous versions:

Privacy Notice effective up to 20 March 2024 (for website users only)
Privacy Notice effective up to 20 March 2024 (for Una users only)
Privacy Notice effective up to 20 March 2024 (for DataHub users only)