1.
Introduction

Welcome to the iCAN Apply privacy policy.
iCAN Apply is an online job board (referred to in this policy as the Job
Board) run by the Insurance Cultural Awareness Network (iCAN), which is an
unincorporated association under English law.

ICANAPPLY respects your privacy and is
committed to protecting your personal data. This privacy policy will inform
you as to how we look after your personal data when you visit our website
(regardless of where you visit it from) and tell you about your privacy
rights and how the law protects you.

This privacy policy is provided in a
layered format so you can click through to the specific areas set out
below. Please also use the Glossary to understand the meaning of some of
the terms used in this privacy policy.

1.IMPORTANT
INFORMATION AND WHO WE ARE

2.THE
DATA WE COLLECT ABOUT YOU

3.HOW
IS YOUR PERSONAL DATA COLLECTED?

4.HOW
WE USE YOUR PERSONAL DATA

5.DISCLOSURES
OF YOUR PERSONAL DATA

6.INTERNATIONAL
TRANSFERS

7.DATA
SECURITY

8.DATA
RETENTION

9.YOUR
LEGAL RIGHTS

10.GLOSSARY

1.
Important information and who we are

Purpose of this privacy policy

This privacy policy aims to give you
information on how iCAN Apply collects and processes your personal data
through your use of this website, including any data you may provide
through this website when you submit your CV to our job board.

For certain processing, ICANAPPLY can be a processor of your application
materials submitted through the website. These data are controlled by the
employer to whom you are applying. As a processor, we retain data until the
controller tells us to delete it.

This website is not intended for children
and we do not knowingly collect data relating to children.

It is important that you read this privacy
policy together with any other privacy policy or fair processing policy we
may provide on specific occasions when we are collecting or processing
personal data about you so that you are fully aware of how and why we are
using your data. This privacy policy supplements other notices and privacy
policies and is not intended to override them.

Controller

iCAN is the controller and responsible for
your personal data (referred to as "iCAN", "we", "us" or "our" in this
privacy policy).

We have appointed a data privacy manager
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, please contact the data privacy
manager using the details set out below.

Contact details

If you have any questions about this
privacy policy or our privacy practices, please contact our data privacy
manager in the following ways:

Full name of legal entity: Insurance
Cultural Awareness Network - iCAN

Email address: icanlondonnetwork@gmail.com

Postal address: Flat 50 Terrace
Apartments, 40 Drayton Park, London, N5 1PW.


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). We would, however, appreciate the chance to deal with
your concerns before you approach the ICO so please contact us in the first
instance.

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 21 June
2023.

[1]


[2]


[3]

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.

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. When you leave our website, we
encourage you to read the privacy policy of every website you visit.

2. The
data we collect about you

Personal data, or personal information,
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
as follows:

● Identity Data includes first name, maiden name, last
name, username or similar identifier, marital status, title, date of birth
and gender.

● Contact Data includes email address and telephone
number.

● Location (city)

● 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, and
other technology on the devices you use to access this website.

● Profile Data includes your username and password, your
curriculum vitae, your preferences, feedback and survey responses.

● Usage Data includes information about how you use our
website, products and services.

● Marketing and Communications Data includes your
preferences in receiving marketing from us and your communication
preferences.

We may 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.

We do not collect any Special Categories of Personal Data
about you (this includes details about your race or ethnicity, religious or
philosophical beliefs, sex life, sexual orientation, political opinions,
trade union membership, information about your health, and genetic and
biometric data). If you fail to provide
personal data

Where we need to collect personal data by law, or under the terms of a
contract we have with you (in particular to make your information available
to prospective employers), and you fail to provide that data when
requested, we may not be able to perform the contract we have or are trying
to enter into with you (for example, to provide you with goods or
services). In this case, we may have to cancel a product or service you
have with us but we will notify you if this is the case at the time.

3. How is
your personal data collected?

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

● Direct interactions. You may give us your Identity and
Contact Data by filling in forms or by corresponding with us by post,
phone, email or otherwise. This includes personal data you provide when you
:

● Register on the iCAN Apply job board

● Submit your CV through the iCAN Apply website

● apply for our products or services;

● subscribe to our service or publications;

● request marketing to be sent to you;

● enter a competition, promotion or survey; or

● give us feedback or contact us.

● Automated technologies or interactions. As you interact
with our website, Technical Data about your equipment, browsing actions and
patterns will be collected automatically by us or jBoard, Inc.. We collect
this personal data by using cookies, server logs and other similar
technologies. We may also receive Technical Data about you if you visit
other websites employing our cookies. Please see our cookie policy for
further details. Further information about jBoard, Inc. including their
privacy policy and cookies policy may be found at www.jboard.io.

4. How we use your personal data

We will only use your personal data when
the law allows us to. Most commonly, we will use your personal data in the
following circumstances:

● Where we need to perform the contract we are about to enter into
or have entered into with you, in particular by allowing potential
employers to view and download your CV.

● Where it is necessary for our legitimate interests (or those of a
third party) and your interests and fundamental rights do not override
those interests. Given that we hold your personal data solely for the
purposes of connecting you with potential employers, the scope of this
paragraph is likely to be very narrow.

● Where we need to comply with a legal obligation.

to find out more about the types of lawful basis that we will rely on to
process your personal data.

Generally, we do not rely on consent as a
legal basis for processing your personal data.

Purposes for which we will use your personal data

We have set out below, in a table format,
a description of all the ways we plan to use your personal data, and which
of the legal bases we rely on to do so. We have also identified what our
legitimate interests are where appropriate.

Note that we may process your personal
data for more than one lawful ground depending on the specific purpose for
which we are using your data. Please contact us if you need details about
the specific legal ground we are relying on to process your personal data
where more than one ground has been set out in the table below.

Promotional offers from us

We may use your Identity, Contact,
Technical, Usage and Profile Data to form a view on what we think you may
want or need, or what may be of interest to you. This is how we decide
which products, services and offers may be relevant for you (we call this
marketing).

You will receive marketing communications
from us if you have requested information from us or obtained services from
us and you have not opted out of receiving that marketing.

Cookies

You can set your browser to refuse all or
some browser cookies, or to alert you when websites set or access cookies.
If you disable or refuse cookies, please note that some parts of this
website may become inaccessible or not function properly. For more
information about the cookies we use, please see below.

Cookies used on the site are categorised and below you can read about each
category and allow or deny some or all of them. When categories than have
been previously allowed are disabled, all cookies assigned to that category
will be removed from your browser. Additionally you can see a list of
cookies assigned to each category and detailed information in the cookie
declaration.

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 us.

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.

5.
Disclosures of your personal data

We may share your personal data with the
parties set out below for the purposes set out in the table

Purposes for which we will use your personal data

above.

● Internal Third Parties as set out in the

Glossary

at the end of this document.

● External Third Parties as set out in the

Glossary

at the end of this document.

● Third parties to whom we may choose to sell, transfer or merge
parts of our business or our assets. Alternatively, we may seek to acquire
other businesses or merge with them. If a change happens to our business,
then the new owners may use your personal data in the same way as set out
in this privacy policy.

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 may share your personal data within the ICAN Group. This will sometimes
involve transferring your data outside the UK.

Some of our External Third Parties are based outside the UK so their
processing of your personal data will involve a transfer of data outside
the UK.

Whenever we transfer your personal data
out of the UK, we ensure a similar degree of protection is afforded to it
by ensuring at least one of the following safeguards is implemented:

● We will only transfer your personal data to countries that have
been deemed to provide an adequate level of protection for personal data.

● Where we use certain service providers, we may use specific
contracts approved for use in the UK which give personal data the same
protection it has in the UK.

● We will ensure that our terms of service for employers using the
job board provide appropriate protection for the privacy of candidates and
their personal information. Please contact
us if you want further information on the specific mechanism used by us
when transferring your personal data out of the UK.

7. Data
security

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. In addition, we limit
access to your personal data to those employees, agents, contractors and
other third parties who have a business need to know. 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, tax,
accounting or reporting requirements. We may retain your personal data for
a longer period in the event of a complaint or if we reasonably believe
there is a prospect of litigation in respect to our relationship with you.

To determine the appropriate retention
period for personal data, we consider the amount, nature and sensitivity of
the personal data, the potential risk of harm from unauthorised use or
disclosure of your personal data, the purposes for which we process your
personal data and whether we can achieve those purposes through other
means, and the applicable legal, regulatory, tax, accounting or other
requirements.

Where we act as processor of your personal data, we store such data until
instructed to delete it by the Controller (the employer on whose behalf we
process your data).

In some circumstances you can ask us to
delete your data: see

your legal rights

below for further information.

In some circumstances we will anonymise
your personal data (so that it can no longer be associated with you) for
research or statistical purposes, in which case we may use this information
indefinitely without further notice to you.

9. Your
legal rights

Under certain circumstances, you have
rights under data protection laws in relation to your personal data. Please
click on the links below to find out more about these rights:

●

Request access to your personal data

.

●

Request correction of your personal data

.

●

Request erasure of your personal data

.

●

Object to processing of your personal data

.

●

Request restriction of processing your personal data

.

●

Request transfer of your personal data

.

●

Right to withdraw consent

.

If you wish to exercise any of the rights
set out above, please contact us.

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). However, we
may charge a reasonable fee if your request is clearly unfounded,
repetitive or excessive. Alternatively, we could refuse to comply with your
request in these circumstances.

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).
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.

Time limit to respond

We try to respond to all legitimate
requests within one month. Occasionally it could take us longer than a
month if your request is particularly complex or you have made a number of
requests. In this case, we will notify you and keep you updated.

10.
Glossary

LAWFUL BASIS

Legitimate Interest
means the interest of our business in conducting and managing our business
to enable us to give you the best service/product and the best and most
secure experience. We make sure we consider and balance any potential
impact on you (both positive and negative) and your rights before we process
your personal data for our legitimate interests. We do not use your personal
data for activities where our interests are overridden by the impact on you
(unless we have your consent or are otherwise required or permitted to by
law). You can obtain further information about how we assess our legitimate
interests against any potential impact on you in respect of specific
activities by contacting us.

Performance of Contract
means processing your data where it is necessary for the performance of a
contract to which you are a party or to take steps at your request before
entering into such a contract.

Comply with a legal obligation

means processing your personal data where it is necessary for compliance
with a legal obligation that we are subject to.

THIRD PARTIES

Internal Third Parties

Other companies in the ICAN Group and who
are based in the UK and provide IT and system administration services and
undertake leadership reporting.

External Third Parties

● Employers seeking candidates through the Job Board.

● Service providers based in the UK who provide IT and system
administration services.

● Professional advisers including lawyers, bankers, auditors and
insurers based in the UK who provide consultancy, banking, legal, insurance
and accounting services.

● HM Revenue & Customs, regulators and other authorities acting
as processors or joint controllers based in the United Kingdom who require
reporting of processing activities in certain circumstances.

14.
YOUR LEGAL RIGHTS

You have the right to:

Request access to your
personal data (commonly known as a "data subject access request"). This
enables you to receive a copy of the personal data we hold about you and to
check that we are lawfully processing it.

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.

Request erasure of your
personal data. This enables you to ask us to delete or remove personal data
where there is no good reason for us continuing to process it. You also
have the right to ask us to delete or remove your personal data 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.

Object to processing of
your personal data 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. You also have the right to
object where we are processing your personal data for direct marketing
purposes. In some cases, we may demonstrate that we have compelling
legitimate grounds to process your information which override your rights
and freedoms.

Request restriction of processing of
your personal data. This enables you to ask us to suspend the processing of
your personal data in the following scenarios:

● If you want us to establish the data's accuracy.

● Where our use of the data is unlawful but you do not want us to
erase it.

● 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.

● You have objected to our use of your data but we need to verify
whether we have overriding legitimate grounds to use it.

Request the transfer of
your personal data to you or to a third party. 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.

Withdraw consent at any time where
we are relying on consent to process your personal data. However, this will
not affect the lawfulness of any processing carried out before you withdraw
your consent. If you withdraw your consent, we may not be able to provide
certain products or services to you. We will advise you if this is the case
at the time you withdraw your consent.