Policy on privacy, data, cookies and marketing communications

Date of Last Revision: 20 March 2016

This Policy sets out how Grad DNA Ltd (“we” / “our”) may obtain and use certain personal and non-personal information which we may acquire when you download and interact with the Grad DNA app or our website (together, the “Service”). You should carefully review this policy prior to downloading and/or using the Service.

  1. About Us

    1. Grad DNA Ltd is a company registered in England, with our registered office address at 2nd Floor, 130 Shaftsbury Avenue, London, United Kingdom, W1D 5EU. Our company number is 09799423. Our VAT number is 223513445. For the purposes of the Data Protection Act 1998, we are the data controller in respect of any personal data which you may submit to us.
  2. Data

    1. We may ask you for and / or you may submit certain personal and non-personal information and / or data to us through the Service (such as your name, email address, password, contact details, anonymous unique device identifier number, CV, qualifications, and work history, responses to assessment exercises, and other information supplied by you pursuant to exhibiting an interest in job opportunities made available to you via the Service) and information concerning your use of the Service when you use the Service.
    2. We may also record which parts of the Service and its related features and services you are interested in and your usage patterns.
    3. This information will be kept secure by us in accordance with the Data Protection Act 1998 and may be used to:
      1. process and make available the Service;
      2. enable your use of the Service and associated services;
      3. to transmit test results and other information to prospective employers, in which case the Service will provide a brief summary of the information to be sent and to whom, and will ask you to confirm that you are happy for it to be shared;
      4. open and run your user account and provide you with an up to date, efficient and reliable service;
      5. monitor the use of the Service;
      6. keep you updated on the Service news and developments and related services;
      7. to generate anonymous and aggregate data reports to highlight the use of the Service; and
      8. to comply with any Apple iTunes Store or Google Play policy or law enforcement request.
    4. We may associate any category of information with any other category of information and will treat the combined information as personal data in accordance with this policy for as long as it is combined.
    5. By submitting your data and using the Service you agree to our use and disclosure of your personal information as described in this privacy policy.
    6. We will only use information collected about you in accordance with the data protection act 1998.
    7. We will never collect sensitive information about you without your explicit consent, which includes circumstances where you decide to supply sensitive information to us through the Service, for example as part of describing your suitability for a job opportunity.
    8. If you believe we have information about you that you do not want us to have or that is incorrect please contact us as described below and we shall correct or remove the data as you request as soon as is reasonably practicable and/or provide details to you of how you can update the data. If you would like to receive a copy of the information we have about you, please note that an administrative fee of £10 may be applicable.
    9. When you use your Facebook ID and/or Twitter ID and/or Linkedin to login into the Service, please note that you will be sharing additional information with us from your Facebook and/or Twitter profile and/or Linkedin. We shall set out the information you will share with us when you use those login methods, and such personal data shall be used in accordance with the Facebook, Twitter and Linkedin policies and this privacy policy.
    10. We may use servers outside the European Economic Area to store any data which we acquire from your use of the Service, and where we do so, we shall ensure that our data processors agree to handle the data in accordance with the Data Protection Act 1998.
    11. We use reasonable efforts to protect your personal data. However, the Internet is an insecure medium and any transmission of personal data to us via our Service is at your own risk. Once we have received your information, we will use strict procedures and security features to try to prevent unauthorised access.
    12. In the event that we are subject to a purchase or all or some of our assets are acquired by a third party, then the personal data we hold shall be deemed an asset which may be transferred to the third party.
    13. Please note that if you are below the age of 16 you should not provide any personal data to us. If you are older than 16 years of age, but below 18 years of age you should obtain the consent of your parent or guardian before you submit personal data to us.
  3. Marketing Communications

    1. We shall give you a choice of whether or not you want us or other reputable companies chosen by us to contact you about future offers, events and new services or related activities that we believe you may find useful.
    2. We will not sell or trade personal information to other companies except as described in this privacy policy (including by sharing your information with prospective employers when you confirm that you are happy for us to do so) but we would like to keep you informed of the developments on the Service and we would like to share data with other reputable companies who may have interesting offers and information for you (inside or outside the EU).
    3. We will not send you any marketing emails or pass your information on to third parties unless you give your consent or you have given it already.
  4. Cookies

    1. We may use cookies or other similar tools within the Service, and by downloading and/or using the Service you consent to this use.
    2. A cookie is a text file placed onto your device when you access our Service. We use cookies and other online tracking devices such as web beacons, local storage, and flash object storage to deliver, improve and monitor our Service, including in the following ways:


      To log you into our Service and keep you logged in.


      To remember information about you such as your preferred language and configuration.


      To help us understand how you use our Service, and how often, so we can improve it to deliver a better experience for our users.

      To carry out research and statistical analysis to help improve our content, products and services.

    3. The information we obtain from our use of cookies will not usually contain your personal data. Although we may obtain information about your device such as your IP address, your browser and/or other internet log information, this will not usually identify you personally.
    4. Our Service may display a notice alerting you to our use of cookies and other similar technologies and linking to this privacy policy. If you use our Service after reading this privacy policy or after this notice has been displayed to you we will assume that you consent to our use of cookies or similar technologies for the purposes described in this privacy policy.
    5. Please note that, if you choose to disable cookies or similar technologies on your device, you may be unable to make full use of our Service.
    6. We work with third parties who may also set cookies through our Service, for example Google Analytics, Facebook, Twitter, and Linkedin, which we use to display content, enable social networking functionality and sharing, and to monitor how visitors use our Service. These third party suppliers are responsible for the cookies they set on your device. For further information please visit the website of the relevant third party.
  5. Privacy

    1. If you have any other concerns over privacy, this privacy policy or the Service please contact us by email to legal@grad-dna.com. We will endeavour to respond to any query or questions within 48 hours.

Grad DNA Ltd
Registered Office: 2nd Floor, 130 Shaftesbury Avenue, London W1D 5EU, United Kingdom | Registered in England and Wales | Registration No: 09799423