Privacy policy

This privacy policy gives you information about how Modern Citizens collects and uses your personal data through your use of this website, including any data you may provide when you use our website to apply for jobs or to use the contact us functionality.

This website is not intended for children, and we do not knowingly collect or retain data relating to children. If you are concerned that your child may have entered personal data on our website, please contact us at Andrew.roberts@moderncitizens.com and we will delete such data within a reasonable timeframe.

1. Who we are

Modern Citizens is a trading name of Positive Digital Limited (registration number 05350547) and Creature London Limited (registration number 07121993) both with registered offices at 12 Macklin Street, London, England, WC2B 5NF who are subsidiaries of Candid Platform Ltd.

When we mention Modern Citizens, “we”, “us” or “our” in this privacy policy, we are referring to the relevant company responsible for processing your data, either Positive Digital Limited or Creature London Limited. Candid Platform Ltd (registration number 13688758 and registered office at The Market Exchange, 8-14 Macklin Street, London, England WC2B 5NF) is the controller and responsible for this website.

If you have any questions about this privacy policy, including any requests to exercise your legal rights (paragraph 9), please contact us at Andrew.roberts@moderncitizens.com. 

2. The types of personal data we collect about you

Personal data means any information about an individual from which that person can be identified.

We may collect, use, store and transfer different kinds of personal data about you which we have grouped together as follows:

• Identity Data includes first name, last name, any previous names, username or similar identifier, marital status, title, date of birth and gender.
• Contact Data includes address, email address and telephone numbers.
• Technical Data includes internet protocol (IP) address, your login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform, device ID and other technology on the devices you use to access this website.
• Profile Data includes your username and password, applications made by you, your employment history (usually in the form of a CV), your interests, preferences, feedback and survey responses.  
• Usage Data includes information about how you interact with and use our website, products and services.
• Marketing and Communications Data includes your preferences in receiving marketing from us and our third parties and your communication preferences.

We also collect, use and share aggregated data such as statistical or demographic data which is not personal data as it does not directly (or indirectly) reveal your identity. For example, we may aggregate individuals' Usage Data to calculate the percentage of users accessing a specific website feature to analyse general trends in how users are interacting with our website to help improve the website and our service offering.

3. How is your personal data collected?

We use different methods to collect data from and about you including through:

Your interactions with us. You may give us your personal data by filling in online forms or by corresponding with us by post, phone, email or otherwise. This includes personal data you provide when you:

apply for a position advertised on our website;

request marketing to be sent to you; or

contact us.

Automated technologies or interactions. As you interact with our website, we will automatically collect Technical Data about your equipment, browsing actions and patterns. We collect this personal data by using cookies and other similar technologies. Please see our cookie policy https://www.positive.co.uk/cookies for further details.

How we use your personal data

Legal basis

The law requires us to have a legal basis for collecting and using your personal data. We collect and use your personal data on the following legal bases:

1. Consent: your active agreement for us to use your personal data for a specified purpose, for example if you have applied to Modern Citizens.
2. Legitimate interests: where it is necessary to conduct our business and pursue our legitimate interests, for example to enable us to give you the best experience on our website.

In using our website and submitting your application, you agree for us to use your personal data in the following ways:

Third-party marketing 

We will not share your personal data with any third party for their own direct marketing purposes without your consent.

Opting out 

You can ask to stop sending you marketing communications at any time by following the opt-out links within any marketing communication sent to you or by contacting us Andrew.roberts@moderncitizens.com.

You may still receive communications that are essential for administrative or service purposes for example relating to applications, interview reminders, updates to our Terms and Conditions, checking that your contact details are correct.

Cookies

For more information about the cookies we use and how to change your cookie preferences, please see https://www.positive.co.uk/cookies.

5. Disclosures of your personal data

We may periodically share your personal data where necessary with the digital marketing agent set out below to conduct marketing activity on our behalf:

• Prospect Global Ltd (trading as Sopro) Reg. UK Co. 09648733. You can contact Sopro and view their privacy policy here: http://sopro.io. Sopro are registered with the ICO Reg: ZA346877 their Data Protection Officer can be emailed at: dpo@sopro.io.

We require all third parties to respect the security of your personal data and to treat it in accordance with the law. We do not allow our third-party service providers to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our instructions.

6. International transfers

We do not transfer your personal data outside of the European Economic Area.

7. Data security

We have put in place appropriate technical and organisational security measures (including encryption) to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we review those measures frequently and limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know through a combination of physical and IT security controls. They will only process your personal data on our instructions, and they are subject to a duty of confidentiality.

We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.

8. Data retention

How long will you use my personal data for?

We will only retain your personal data for as long as reasonably necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, regulatory, or reporting requirements. We may retain your personal data for a longer period in the event of a complaint.

Following an application, we keep your information in case any other opportunities become available; however, we will only keep your information for a limited time and your details will be purged after 24 months of inactivity.

9. Your legal rights

Data protection laws allow you to:

• Request a copy of the personal data we hold about you (commonly known as a "subject access request") and to check that we are lawfully processing it.
• 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.
• Ask us to delete or remove your personal data where there is no good reason for us continuing to process it. You may also request that we restrict our usage of your data (for example if your preferences change).
• Object to processing of your personal data where we are relying on a legitimate interest as the legal basis for such processing.
• Object any time to the processing of your personal data for direct marketing purposes.
• Ask us to provide to you, or a third party where technically feasible, your personal data in a structured, commonly used, machine-readable format.
• Withdraw consent at any time where we are processing your personal data based on your consent.

If you wish to exercise any of the rights set out above, please contact Andrew.roberts@moderncitizens.com. 

No fee usually required

You will not have to pay a fee to access your personal data (or to exercise any of the other rights), unless your request is clearly unfounded, repetitive or excessive. 

What we may need from you

We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). 

Time limit to respond

We try to respond to all legitimate requests within one month. Occasionally it could take longer if your request is particularly complex, or you have made a number of requests.

10. Contact details

If you have any questions about this privacy policy or about the use of your personal data or want to exercise your privacy rights, please contact us at Andrew.roberts@moderncitizens.com.

11. Complaints

In the event you are unable to resolve your concerns, you have the right to make a complaint at any time to the Information Commissioner’s Office (ICO), the UK regulator for data protection issues (www.ico.org.uk).

12. Changes to the privacy policy and your duty to inform us of changes  

We keep our privacy policy under regular review. This version was last updated on 16 October 2024.

It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during your relationship with us, for example a new address or email address.

13. Third-party links  

This website may include links to third-party websites, plug-ins and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites and are not responsible for their privacy statements or how they may collect and use your personal data. When you leave our website, we encourage you to read the privacy policy of every website you visit to ensure you are comfortable with how your personal data is collected and used.