GDPR Policy

1.1 Important information and who we are

Welcome to My Seagull Limited’s Privacy and Data Protection Policy (“Privacy Policy”).

At My Seagull Limited (“we”, “us”, or “our”) we are committed to protecting and respecting your privacy and Personal Data in compliance with the United Kingdom General Data Protection Regulation (“GDPR”), the Data Protection Act 2018 and all other mandatory laws and regulations of the United Kingdom.

This Privacy Policy explains how we collect, process and keep your data safe. The Privacy Policy will tell you about your privacy rights, how the law protects you, and inform our employees and staff members of all their obligations and protocols when processing data.

We may collect and utilize data from a variety of individuals, including:

• Corporate Customers: This encompasses companies, recruiters, and recruiting agencies.
• Educational Entities: Such as universities, colleges, schools, and training institutions.
• Career Aspirants: Including students, job seekers, and working professionals.
• Affiliates of Our Customers: This refers to third parties associated with our clientele.
• Automated Interactions: Through engagement with our website and services, technical, profile, and usage information regarding your devices, browsing activities, and patterns will be collected automatically.
• External Parties and Public Sources: We may also obtain personal information about you from diverse third parties and publicly accessible resources.

Additionally, this Privacy Policy extends to any other individuals with whom our organization maintains a relationship or may need to communicate with.

The policy is binding for all our employees, staff members, and encompasses all Personal Data managed by us at any point in time.

1.2 Your Data Controller and Data Protection Officer

My Seagull Limited is your Data Controller and responsible for your Personal Data.

We have appointed a Data Protection Officer (“DPO”) who is responsible for overseeing questions in relation to this Privacy Policy. If you have any questions about this Privacy Policy, including any requests to exercise your legal rights surrounding your Personal Data please contact the DPO using the details set out below:

• Name: Animesh Deharia
• Email: animesh@myseagull.ai
• Postal address: 124 City Road, London, EC1V 2NX, United Kingdom

You have the right to make a complaint at any time to the Information Commissioner’s Office (ICO), the UK supervisory authority for data protection issues (www.ico.org.uk). We would, however, appreciate the chance to deal with your concerns before you approach the ICO so please contact us in the first instance.

1.3 Processing data on behalf of a Controller and processors’ responsibility to you

In discharging our responsibilities as a Data Controller we have employees who will deal with your data on our behalf (known as “Processors”). The responsibilities below may be assigned to an individual or may be taken to apply to the organisation as a whole. The Data Controller and our Processors have the following responsibilities:

• Ensure that all processing of Personal Data is governed by one of the legal bases laid out in the GDPR (see 2.2 below for more information);
• Ensure that Processors authorised to process Personal Data have committed themselves to confidentiality or are under an appropriate statutory obligation of confidentiality;
• Implement appropriate technical and organisational measures to ensure a level of security appropriate to the risk associated with the processing of Personal Data;
• Obtain the prior specific or general authorisation of the Controller before engaging another Processor;
• Assist the Controller in the fulfilment of the Controller's obligation to respond to requests for exercising the data subject's rights;
• Make available to the Controller all information necessary to demonstrate compliance with the obligations laid down in the GDPR and allow for and contribute to audits, including inspections, conducted by the Controller or another auditor mandated by the Controller;
• Maintain a record of all categories of processing activities carried out on behalf of a Controller;
• Cooperate, on request, with the supervisory authority in the performance of its tasks;
• Designate a data protection officer where required by the GDPR, publish their details and communicate them to the supervisory authority;
• Support the data protection officer in performing their tasks by providing resources necessary to carry out those tasks and access to Personal Data and processing operations and to maintain their expert knowledge;
• Ensure that any person acting under the authority of the Processor who has access to Personal Data does not process Personal Data except on instructions from the Controller; and
• Notify the Controller without undue delay after becoming aware of a Personal Data Breach.

2.1 Types of data / Privacy policy scope

“Personal Data” means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymous data).

We may collect, use, store and transfer different kinds of Personal Data about you which we have grouped together below. Not all of the following types of data will necessarily be collected from you but this is the full scope of data that we collect and when we collect it from you:

• Profile/Identity Data: This is data relating to your first name, last name, gender, and date of birth.
• Contact Data: This is data relating to your phone number, addresses, email addresses, and phone numbers.
• Marketing and Communications Data: This is your preference in receiving marketing information and other information from us.
• Billing Data: This is information relating to your debit and credit card information such as the name attached to your payment details and your billing address.
• Transactional Data: This is information of details and records of all payments you have made for our services or products.
• Technical Data: This is your IP address, browser type and version, time zone setting and location, operating system and platform, and other technology on the devices you use to engage with us.
• Customer Support Data: This includes feedback and survey responses.
• Usage Data: Information about how you use our website, products and services.
• Location Data: Information about your geographical location derived from IP addresses and other location-based technologies.
• Behavioural Data: Data on how you interact with our services, such as click behaviour, navigation paths, and session durations.
• Employment Data: Information related to your job applications, CVs, employment history, and references.
• Device Data: Information about the devices you use to access our services, including device type, operating system, and mobile network information.
• Consent Data: Records of consents you have given, including what you have consented to, the date and time, and the method of consent.
• Health Data: Information related to health and wellness, if relevant to the services provided.
• Preferences Data: Information about your preferences and interests, which can help tailor services and communications.

We also collect, use and share Aggregated Data such as statistical or demographic data for any purpose. Aggregated Data could be derived from your personal data but is not considered personal data in law as this data will not directly or indirectly reveal your identity. For example, we may aggregate your Usage Data to calculate the percentage of users accessing a specific website feature. However, if we combine or connect Aggregated Data with your personal data so that it can directly or indirectly identify you, we treat the combined data as personal data which will be used in accordance with this privacy policy. Aggregated Data could be derived from your Personal Data but is not considered Personal Data in law as this data will not directly or indirectly reveal your identity. However, if we combine or connect Aggregated Data with your Personal Data so that it can directly or indirectly identify you, we treat the combined data as Personal Data which will be used in accordance with this Privacy Policy.

We may also aggregate data to enable research or analysis so that we can better understand and serve you and others. For example, we may conduct research on your demographics and usage. Although this aggregated data may be based in part on Personal Data, it does not identify you personally. We may share this type of anonymous data with others, including service providers, our affiliates, agents and current and prospective business partners.

For the purposes of our business we also collect what is known under the GDPR as special categories of Personal Data. We collect the following types of special Personal Data:

• Political Data: Information about race, or ethnicity, religious beliefs, sexual orientation.

In order to collect this special kind of data we need enhanced legal justifications beyond the ordinary legal justifications under the GDPR. We explain which justifications we rely on in paragraph 2.2 below.

2.2 The Legal Basis for Collecting That Data

There are a number of justifiable reasons under the GDPR that allow collection and processing of Personal Data. The main avenues we rely on are:

• “Consent”: Certain situations allow us to collect your Personal Data, such as when you tick a box that confirms you are happy to receive email newsletters from us, or ‘opt in’ to a service.
• “Contractual Obligations”: We may require certain information from you in order to fulfil our contractual obligations and provide you with the promised service.
• “Legal Compliance”: We’re required by law to collect and process certain types of data, such as fraudulent activity or other illegal actions.
• “Legitimate Interest”: We might need to collect certain information from you to be able to meet our legitimate interests - this covers aspects that can be reasonably expected as part of running our business, that will not have a material impact on your rights, freedom or interests. Examples could be your address, so that we know where to deliver something to, or your name, so that we have a record of who to contact moving forwards.

For the special categories of data that we collect, the enhanced legal justification we rely on is:

• (a) The data subject has given explicit consent to the processing of such Personal Data for one or more specified purposes (“Explicit Consent”).


• (b) Processing relates to Personal Data which are manifestly made public by the data subject (“Already Public”).

3.1 Our data uses

We will only use your Personal Data when the law allows us to.

Set out below is a table containing the different types of Personal Data we collect and the lawful basis for processing that data. Please refer to section 2.2 for more information on the lawful basis listed in the table below.

Examples provided in the table below are indicative in nature and the purposes for which we use your data may be broader than described but we will never process your data without a legal basis for doing so and it is for a related purpose. For further inquiries please contact our Data Protection Officer.

Universities & Corporates

Activity	Type of Data	Legal Justification	Lawful Basis for Processing Data
Customer Support	Profile/Identity Data, Contact Data, Customer Support Data, Usage Data	Legitimate Interest	We process Profile/Identity and Contact Data based on Legitimate Interest to provide efficient customer support. This allows us to address inquiries and resolve issues effectively, ensuring customer satisfaction and maintaining the quality of our services.
Personalized Marketing	Profile/Identity Data, Contact Data, Billing Data, Usage Data	Consent, Legitimate Interest	We need to process this data for personalized marketing efforts to provide targeted promotions and updates. We use this data to offer personalized services and communications, enhancing the user experience.
Website Monitoring	Technical Data, Usage Data	Consent	We need to process this data to monitor website performance and usage analytics to enhance user experience.

Career Aspirants & Learners

Activity	Type of Data	Legal Justification	Lawful Basis for Processing Data
Data Insights and Promotions	Profile/Identity Data, Contact Data	Legitimate Interest	We process this data to provide career insights, recommendations, and promotions relevant to career aspirants and learners.
System Architecture/Connectivity	Technical Data	Legitimate Interest	We need to process this data for system connectivity and data archiving, ensuring seamless service delivery.
Disclosing Details to Employers	Profile/Identity Data, Contact Data	Contractual Obligations	We need to process this data to share relevant details with potential employers as part of job application processes.
Focused Promotional Campaigns	Profile/Identity Data, Contact Data, Usage Data	Legitimate Interest	We process this data to deliver targeted promotional campaigns to career aspirants and learners.

Website Users

Activity	Type of Data	Legal Justification	Lawful Basis for Processing Data
Targeted Advertising	Profile/Identity Data, Contact Data, Marketing and Communications Data, Usage Data	Legitimate Interest	We process this data to provide targeted advertising to website users based on their interactions and preferences.
Website Hosting	Contact Data, Technical Data	Legitimate Interest	We need to process this data for website hosting and maintenance, ensuring reliable service delivery to users.
Website Tracking	Technical Data, Usage Data	Consent	We process this data to track website and web application usage for performance monitoring and user experience enhancement. Consent is obtained through a cookie policy banner on the first visit to the site.

Affiliates and Partners

Activity	Type of Data	Legal Justification	Lawful Basis for Processing Data
Partnership Management	Profile/Identity Data, Contact Data	Contractual Obligations	We process this data to manage relationships with affiliates and partners, ensuring contractual compliance and collaboration.
Marketing Collaborations	Profile/Identity Data, Contact Data, Marketing and Communications Data	Legitimate Interest	We process this data to collaborate on joint marketing campaigns and initiatives.
Data Sharing for Services	Profile/Identity Data, Contact Data, Technical Data	Contractual Obligations	We share necessary data with partners to deliver joint services and products.

Prospective Clients

Activity	Type of Data	Legal Justification	Lawful Basis for Processing Data
Targeted Advertising	Activity and Behavioural Data, Contact Data, Personal Characteristics	Legitimate Interest	We process this data to provide targeted advertising and promotional content to prospective clients based on their interests and interactions.
Website Tracking	Activity and Behavioural Data, Technical Identifiers	Consent	We process this data to track website and web application usage for performance monitoring and user experience enhancement.

3.2 Marketing and content updates

You will receive marketing and new content communications from us if you have created an account and chosen to opt into receiving those communications. From time to time we may make suggestions and recommendations to you about goods or services that may be of interest to you.

3.3 Change of purpose

We will only use your Personal Data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If you wish to get an explanation as to how the processing for the new purpose is compatible with the original purpose, please contact our Data Protection Officer.

If we need to use your Personal Data for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so.

Please note that we may process your Personal Data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.

4.1 Your legal rights

Under certain circumstances, you have the following rights under data protection laws in relation to your personal data:

• Right to be informed. You have a right to be informed about our purposes for processing your personal data, how long we store it for, and who it will be shared with. We have provided this information to you in this policy.


• Right of access. This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it (also known as a "data subject access request"). See section 4.5 below for more details on how you can make a data subject access request.


• Right to rectification. You have a right to request correction of the personal data that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.


• Right to erasure. You have the right to ask us to delete or remove personal data where there is no good reason for us continuing to process it, where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your personal data to comply with local law. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.


• Right to object. You can object to the processing of personal data we hold about you. This effectively allows you to stop or prevent us from processing your personal data. Note that this is not an absolute right and it only applies in certain circumstances, for example:


• (i) Where we are processing your personal data for direct marketing purposes.


• (ii) Where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms.


• (iii) In some cases, we may continue processing your data if we can demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms.


• Right to restrict processing. You have the right to request the restriction or suppression of their personal data. Note that this is not an absolute right and it only applies in certain circumstances:


• (i) If you want us to establish the data's accuracy.


• (ii) Where our use of the data is unlawful but you do not want us to erase it.


• (iii) Where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims.


• (iv) You have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.


• Right to data portability. You have the right to request the transfer of your personal data to you or to a third party. If you make such a request, we will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.

If you wish to make a request under any of these rights, please contact us at animesh@myseagull.ai.

4.2 Your control over My Seagull Limited’s use of your Personal Data

Your account information will be protected by a password for your privacy and security. You need to prevent unauthorized access to your account and personal information by selecting and protecting your password appropriately and limiting access to your computer or device and by signing off after you have finished accessing your account.

You will need to contact us if you would like to delete your account.

California Privacy Rights: Under California Civil Code sections 1798.83-1798.84, California residents are entitled to ask us for a notice identifying the categories of personal customer information which we share with our affiliates and/or third parties for marketing purposes, and providing contact information for such affiliates and/or third parties. If you are a California resident and would like a copy of this notice, please submit a written request to animesh@myseagull.ai.

4.3 How My Seagull Limited protects customers' Personal Data

We are concerned with keeping your data secure and protecting it from inappropriate disclosure. We implement a variety of security measures to ensure the security of your Personal Data on our systems, including adopting a secure protocol and encrypting our databases. Any Personal Data collected by us is only accessible by a limited number of employees who have special access rights to such systems and are bound by obligations of confidentiality. If and when we use subcontractors to store your data, we will not relinquish control of your Personal Data or expose it to security risks that would not have arisen had the data remained in our possession. However, unfortunately no transmission of data over the internet is guaranteed to be completely secure. It may be possible for third parties not under the control of My Seagull Limited to intercept or access transmissions or private communications unlawfully. While we strive to protect your Personal Data, we cannot ensure or warrant the security of any Personal Data you transmit to us. Any such transmission is done at your own risk. If you believe that your interaction with us is no longer secure, please contact us.

4.4 Opting out of marketing promotions

You can ask us to stop sending you marketing messages at any time by using the unsubscribe link on the email.

Where you opt out of receiving these marketing messages, we will continue to retain other Personal Data provided to us as a result of interactions with us not related to your marketing preferences.

4.5 How to request your data and the process for obtaining it

You will not have to pay a fee to access your Personal Data (or to exercise any of the other rights). However, if your request is clearly unfounded, we could refuse to comply with your request.

We may need to request specific information from you to help us confirm your identity and ensure you have the right to access your Personal Data (or to exercise any of your other rights). This is a security measure to ensure that Personal Data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.

5.1 Sharing your data with third parties

We may share non-Personal Data with third parties. We may share your Personal Data with subcontractors or affiliates, subject to confidentiality obligations to use it only for the purposes for which we disclose it to them and pursuant to our instructions.

We may also share Personal Data with interested parties in the event that My Seagull Limited anticipates a change in control or the acquisition of all or part of our business or assets or with interested parties in connection with the licensing of our technology.

If My Seagull Limited is sold or makes a sale or transfer, we may, in our sole discretion, transfer, sell or assign your Personal Data to a third party as part of or in connection with that transaction. Upon such transfer, the Privacy Policy of the acquiring entity may govern the further use of your Personal Data. In all other situations your data will still remain protected in accordance with this Privacy Policy (as amended from time to time).

We may share your Personal Data at any time if required for legal reasons or in order to enforce our terms or this Privacy Policy.

We will only retain your Personal Data for as long as reasonably necessary to fulfil the purposes we collected it for. We may retain your Personal Data for a longer period than usual in the event of a complaint or if we reasonably believe there is a prospect of litigation with respect to our relationship with you.

Your personal data may be transferred and processed in locations outside the UK and the European Economic Area (EEA) due to some of our external partners being based internationally. By engaging with My Seagull Limited, you agree to such international data transfers. We commit to protecting your personal data by ensuring it receives a comparable level of security when transferred outside the UK and EEA. We achieve this by either:

• Transferring personal data to countries recognized by the European Commission as having adequate data protection laws; or
• Implementing European Commission-approved contractual clauses that obligate our partners to protect your personal data to the standards enforced in the UK and EEA.

We keep our Privacy Policy under review and will place any updates here. This version is dated 20 June 2024.

By using Seagull, you consent to the collection and use of data by us as set out in this Privacy Policy. Continued access or use of Seagull will constitute your express acceptance of any modifications to this Privacy Policy.

All uses of the word "including" mean "including but not limited to" and the enumerated examples are not intended to in any way limit the term which they serve to illustrate. Any email addresses set out in this policy may be used solely for the purpose for which they are stated to be provided, and any unrelated correspondence will be ignored. Unless otherwise required by law, we reserve the right to not respond to emails, even if they relate to a legitimate subject matter for which we have provided an email address. You are more likely to get a reply if your request or question is polite, reasonable and there is no relatively obvious other way to deal with or answer your concern or question (e.g. FAQs, other areas of our website, etc.).

Our staff are not authorised to contract on behalf of My Seagull Limited, waive rights or make representations (whether contractual or otherwise). If anything contained in an email from a My Seagull Limited address contradicts anything in this policy, our terms or any official public announcement on our website, or is inconsistent with or amounts to a waiver of any My Seagull Limited rights, the email content will be read down to grant precedence to the latter. The only exception to this is genuine correspondence expressed to be from the My Seagull Limited legal department.

Please also see our Terms of Use which set out the terms, disclaimers, and limitations of liability governing your use of My Seagull Limited.