This privacy notice applies if you are applying for employment with East Alpha Ltd.

East Alpha is registered in the UK and our registered address is at 4th Floor, Tea Auction House, Hay’s Galleria, SE1 2HD and our company registration number is OC431086.

East Alpha is responsible for ensuring that it uses your personal data in compliance with data protection law. For the purposes of data protection law, the data controller in respect of your personal data is:

East Alpha Limited, 4th Floor, Tea Auction House, Hay’s Galleria, SE1 2HD (Company No.: 10782681).

The purpose of this notice is to explain what personal data East Alpha collects and how East Alpha uses it. Please take the time to read and understand this privacy notice.

“East Alpha”, “we or “us” means East Alpha Limited, East X LLP and any other companies or firms in the East X organisation (“Firm ”), details of which can be found on our website. Where we use the terms “East Alpha”, “we”, “us” and “our” in this notice, we are referring to the relevant East Alpha entity with whom you are applying for a job.

Where we use the term your “Application” in this notice, we are referring to your application to work at the Firm.

Personal data collected by East Alpha

East Alpha will collect and process (e.g. obtain, record, use, share or hold etc.) the following personal data about you:

Information that you provide to East Alpha

This includes information that you submit to us when you make your initial application and includes:

o   personal details such as, but not limited to, your full name, email address, contact details, employment history and qualifications (both academic and professional); and

o   any other details you provide in support of your Application, including (but not limited to) information contained in your CV and/or covering email and your reasons for applying to East Alpha.

Information we, or other members of the Firm, otherwise collect about you. This includes information that is collected in connection with your Application and is likely to include:

    • personal data that we collect through your communication and correspondence with us (including but not limited to the content, date and time of your email correspondence); and

    • information obtained through any interviews and assessments with you.

Information we obtain from other sources.

This may include:

o   personal data that we collect from screening, background and/or reference checks we may perform on you as part of the Application or recruitment process, which may include your address history, your credit history, your qualifications (both academic and professional), your previously held directorships (if any); and

o   a criminal records check.

Uses of your personal data

Your personal data may be stored and processed by East Alpha in the following ways and for the following purposes:

·           to consider your Application including, in some cases, verifying your qualifications and references with third parties for the purpose of undertaking background checks;

·           to meet our legal and regulatory obligations;

·           to maintain consistent practices and procedures with respect to the collection, use, disclosure, transfer and processing of personal data across all East X companies worldwide. These practices and procedures include the effective recording, management and administration of personal data;

·           to maintain consistent practices and procedures with respect to the recruitment of personnel across the Firm, including the performance of human resources and other functions of the East X organisation;

·           for equal opportunities monitoring purposes; and

·           to maintain contact with you in the future and notify you of relevant job vacancies with a member of the Firm that you might be interested in. Please note that if you do not want us to retain your information, or want us to update it at any stage, please contact us in accordance with the “Contacting us” section.

We are entitled to use your personal data in these ways because:

·           we need to in order to take steps in preparation for entering into a contract with you, in particular to consider you for a position at East Alpha;

·           we have legal and regulatory obligations that we have to discharge;

·           we may need to in order to establish, exercise or defend our legal rights or for the purpose of legal proceedings; and/or

·           the use of your personal data as described is necessary for our legitimate business interests (or the legitimate interests of another East X company), such as:

    • allowing us to effectively assess your skills, qualifications and/or the strength and merits of your Application and your suitability for the role applied for;

    • allowing us to effectively verify your information;

    • allowing us to effectively and efficiently administer and manage the operation of our business;

    • ensuring a consistent approach to the recruitment of East X personnel worldwide; or

    • being able to contact you in relation to your Application and the recruitment process.

Please note, if your Application is successful and you are subsequently offered and accept employment at East Alpha, the information we collect during the application and recruitment process will become part of your employment record.

Special categories of personal data

“Special categories personal data” are subject to specific protection or restriction by law in certain territories, including the UK. For these purposes, “special categories of personal data” relate to: racial or ethnic origin; political opinions; religious or philosophical beliefs; trade union membership; genetic data; biometric data; data concerning health; or data concerning sexual preferences, sex life or sexual orientation. There are also special rules surrounding data relating to criminal convictions or offences. We will only process special categories of personal data or data relating to your criminal records if permitted by law and only if one of the following conditions is met:

·           the processing is necessary for carrying out obligations and specific rights of East X in the field of employment law, social security or social protection law (including obligations in relation to public health, health and safety and disability discrimination, the legality of personnel working in a particular jurisdiction, which will involve processing data in relation to nationality, work permits and visas, monitoring equality of racial or ethnic opportunity or treatment, and vetting (where necessary));

·           the processing is necessary to protect the vital interests of you or another person where you are physically or legally incapable of giving consent;

·           the data in question has been made public by you;

·           the processing is necessary for the purpose of, or in connection with, any actual or prospective legal proceedings, for the purpose of obtaining legal advice or otherwise for the purposes of establishing, exercising or defending legal rights subject to applicable local legislation or where courts are acting in their judicial capacity;

·           the processing is necessary for reasons of substantial public interest on the basis of local law which is proportionate to the aim pursued and which contains appropriate safeguarding measures;

·           the processing is necessary for archiving purposes in the public interest or scientific and historical research purposes or statistical purposes; or

·           as otherwise permitted by law; and

In each case we will meet any additional local legal requirements and enforce any applicable duties of confidentiality effectively, for example in relation to access to health records.

Disclosure of your information to third parties

Within the Firm

East Alpha may disclose your personal data to other members of the Firm for the purposes of:

·           the management and administration of the East Alpha business, including the maintenance of the centralised databases storing personal data;

·           enabling the performance of the functions that each of the East X organisations businesses may perform relating to regional or global HR decisions within the Firm; or

·           assessing compliance with applicable laws, rules and regulations, and internal policies and procedures within the firm.

Where personal data is disclosed to other members of the Firm , we will take steps to ensure that the personal data is accessed only by those East X personnel that have a need to do so for the purposes described in this notice.

Outside the Firm

In addition to the above, East Alpha (and the other East X companies to whom your personal data is disclosed) may share your personal data outside the firm:

•       to the extent required by law, regulation or court order, for example if we are under a duty to disclose your personal data in order to comply with any legal obligation.

·           to third party agents or contractors, bound by obligations of confidentiality, in connection with the processing of your personal data for the purposes described in this notice. This may include outsourced HR service providers and consultants, IT and communications service providers, law firms, accountants and auditors (“Third Parties”); and

International transfers of personal data

Your personal data may be transferred to and stored in databases hosted and maintained outside the UK. It may be stored and processed by other East X Group companies and/or Third Parties in other countries, which may include destinations outside of the United Kingdom (“UK”). 

Where your personal data is transferred outside the UK, we will ensure that it is protected in a manner that is consistent with how your personal data will be protected by us in the UK. This can be done in a number of different ways, for instance:

·           the country that we send the data to might be approved by the UK Government; or

·         the recipient might have signed up to a contract based on “model contractual clauses” approved by the UK Government, obliging them to protect your personal data.

In other circumstances the law may permit us to otherwise transfer your personal data outside the UK. In all cases, however, we will ensure that any transfer of your personal data is compliant with applicable data protection law.

You can obtain more details about the protection given to your personal data when it is transferred outside the UK by contacting us in accordance with the “Contacting us” section.

Retention of personal data

How long we hold your personal data for will vary. The retention period will be determined by various criteria including:

·           the purpose for which we are using it – we will need to keep the data for as long as is necessary for that purpose; and

·           legal obligations – laws or regulation may set a minimum period for which we have to keep your personal data.

In some instances, we may retain your information to consider you for other roles and future opportunities at East X which may be of interest to you. If you do not want us to retain your information, or want us to update it at any stage, please contact us in accordance with the “Contacting us” section.

Your rights

You have a number of legal rights in relation to the personal data that we hold about you and you can exercise your rights by contacting our Privacy Officer at info@eastalpha.co.

These rights include:

·           the right to obtain information regarding the processing of your personal data and access to the personal data which we hold about you;

·           the right to withdraw your consent to our processing of your personal data at any time. Please note, however, that we may still be entitled to process your personal data if we have another legitimate reason (other than consent) for doing so;

·           in some circumstances, the right to receive some personal data in a structured, commonly used and machine-readable format and/or request that we transmit those data to a third party where this is technically feasible. Please note that this right only applies to personal data which you have provided to us (and not, for the avoidance of doubt, information we, or other members of the Firm , otherwise collect about you or information we obtain about you from other sources);

·           the right to request that we rectify your personal data if it is inaccurate or incomplete;

·           the right to request that we erase your personal data in certain circumstances. Please note that there may be circumstances where you ask us to erase your personal data but we are legally entitled to retain it;

·           the right to request that we restrict our processing of your personal data in certain circumstances. Again, there may be circumstances where you ask us to restrict our processing of your personal data but we are legally entitled to refuse that request;

·           the right to object to our processing of your personal data in certain circumstances. Please note that there may be circumstances where you object to our processing of your personal data but we are legally entitled to continue to process it; and

·           the right to lodge a complaint with the UK data protection regulator, the Information Commissioner’s Office (https://ico.org.uk/), if you think that any of your rights have been infringed by us.

Contacting us

If you would like further information on the collection, use, disclosure, transfer or processing of your personal data or the exercise of any of the rights listed in this notice, please contact us using the following contact information:

            Address:          4th Floor, Tea Auction House, Hay’s Galleria, SE1 2HD, United Kingdom

            Email Address:    info@eastalpha.co (Attn. Privacy Officer)

You can also contact us at Steve Wynne, Chief of Staff (sw@eastalpha.co)