Sumitomo 0–1 Challenge 202-

0-1 CHALLENGE – PRIVACY NOTICE

This is the privacy notice for “0-1 CHALLENGE” (the Programme).

The Programme is organised by L Marks Limited (the Administrator of the Programme), in conjunction with Sumitomo Corporation Europe Limited (the Employer). Any reference to we, us or our in this notice is a reference to the Administrator and the Employer unless otherwise stated.

We are committed to respecting the privacy of those applying to and participating in the Programme. The following statement explains how we may use the personal information we collect from you in connection with the application process and your participation in the Programme.

The Administrator is registered in England and Wales with company number 7756651. The Administrator’s registered office address is 20 Broad Lane, Hale, Altrincham, Cheshire, WA15 0DF.

The Employer is registered in England and Wales with company number 01885117. The Employer’s registered office address is Vintners Place, 68 Upper Thames Street, London, Greater London, United Kingdom, EC4V 3BJ.

APPLICABILITY OF THIS NOTICE
1. This notice applies to any person submitting an application to participate in the Programme. It also describes how we will treat your personal data in connection with your participation in the Programme (if your application is successful).
2. The Administrator and the Employer are separate entities, and each is separately responsible for how it deals with your personal information.
3. This notice supplements the Employer’s standard privacy notice which is available here. You should read that privacy notice in addition to this notice.
4. Where you submit an application or participate in the Programme, this privacy notice applies in addition to the Programme Terms (https://sc01challenge.com/program-terms/). The submission of an application and acceptance to the Programme is conditional upon you agreeing to the terms of this privacy notice.
5. Applications are made through the L Marks application portal, the Bridge. The Bridge has its own Privacy Policy which describes how the Bridge may use your personal information. You should read the Bridge privacy notice in addition to this notice.
PERSONAL INFORMATION
1. During the application process and overall participation in the Programme you may provide us with personal information about you such as your name, address, date of birth, telephone numbers (including mobile number) and email address (personal information).
2. We may also obtain personal information about you from other sources, for example from other team members or from publicly available information sources such as LinkedIn.
3. We are committed to protecting your privacy, and will only use your personal information in accordance with applicable data protection legislation, including the General Data Protection Regulation (as supplemented by the Data Protection Act 2018).
4. To properly complete the application form we require you to provide some basic data about yourself. This is information that we consider necessary or desirable so that we can properly consider your application. If you do not agree to us or the Employer holding this information about you, please do not complete an application.
5. In completing the application form or participating in the Programme, you may choose to provide further information about yourself, team members or other associated people. It is entirely your decision as to whether you provide this type of information to us and you should only provide this information if you are comfortable with us storing it and using it to process your application and use it in connection with the Programme.
6. You are entitled by law to ask for a copy of your personal information at any time. Please contact us using the details in paragraph 1.1. You are entitled to ask us to correct or update your personal information at any time by contacting us at the address above.
PERSONAL INFORMATION RELATING TO OTHER PEOPLE
1. It is possible that during the application process, for example whilst completing the application form or participating in pitch day, you may provide us with personal information relating to other individuals, such as your team member colleagues.
2. Where you do provide us with personal information relating to other people, it is essential that you:
  1. inform those people that you will be providing their personal information to us;
  2. provide them with a copy of this notice so that they are aware of how their personal information may be used and their rights in respect of it; and
  3. obtain their written consent (for example by way of email) to you providing the information to us.
USES MADE OF THE INFORMATION
1. We (and our representatives) may use your personal information as follows:
  1. to perform our obligations in respect of the handling of your application, including:
    (a) registering you on our database;
    (b) considering your application to participate in the Programme; and
    (c) making arrangements with you to attend and participate in pitch day;
  2. where you have expressly consented to us doing so, including responding to any enquiry that you submit to us (whether via our Website enquiry form or otherwise);
  3. where it is necessary for compliance with legal obligations, including for record keeping and regulatory compliance purposes; and
  4. where we otherwise have a legitimate interest in doing so, including promoting the Programme, to increase awareness of the Programme and our products, services and brands.
2. Non-personal information that you submit may also be used for analytical or reporting purposes and anonymised reports may be published or otherwise provided to third parties.
3. Please be aware that any part of the Programme, including the pitch day and interviews, may be recorded and a copy of any recordings we make may be publicised and circulated as we consider appropriate. If you take part in any relevant events and would prefer not to be recorded please let us know and we’ll ensure you are not included in any content.
4. Where our processing of your personal data is based on consent, you have the right to withdraw this consent at any time, which you may do by contacting us as described in paragraph 11.1. Please note however that the withdrawal of your consent will not affect any use of the data made before you withdrew your consent.
DISCLOSURE OF YOUR INFORMATION
1. We (and our representatives) may disclose your personal information to third parties:
  1. for completing due diligence on you and your business idea (and, where appropriate, on your team);
  2. in publicity material, as described in the Programme terms;
  3. to the provider of our e-learning services;
  4. to external/internal support members who are involved in the Programme;
  5. to suppliers involved in the operation of the Programme, for example a creative agency involved in publicising the Programme;
  6. if we are under a duty to disclose or share your personal data in order to comply with any legal obligation, or in order to enforce or apply such other terms as apply to our relationship, or to protect the rights, property, or safety of our customers, ourselves or others. This includes exchanging information with other companies and organisations for the purposes of fraud protection and credit risk reduction; and
  7. if we determine that such disclosure is necessary in connection with any investigation or complaint regarding your use of the Website or your application.
2. The Administrator and the Employer may also share your personal information between them and with other companies in the Employer’s group for the purposes of assessing and processing your application and arranging your participation in pitch day.
TRANSFERRING YOUR PERSONAL INFORMATION INTERNATIONALLY
1. 1. In certain cases the sharing of your personal information to a third party as described above may involve your personal information being transferred outside of the United Kingdom. This may be to:
  2. a country in the European Economic Area or that is otherwise considered to have data protection rules that are equivalent to those in the United Kingdom; or
  3. a country outside of the European Economic Area which is not considered to have the same standards of protection for personal data as those in the United Kingdom, in which case we will take all steps required by law to ensure sufficient protections are in place to safeguard your personal information, including where appropriate putting in place contractual terms approved by the relevant regulatory authorities.
  1. Participation in this Programme is available to employees based outside the European Economic Area. As part of their participation in the Programme, they may access information about the Programme, including about other participants, from their home country. By applying to participate in this Programme you acknowledge that:
  2. your personal data may be transferred to participants located outside the European Economic Area, including countries which are not considered to have the same standards of protection for personal data as those in the United Kingdom;
  3. those participants may be employed by other companies within the Employer’s group which are not directly subject to the General Data Protection Regulation (or equivalent law);
  4. these transfers may not be subject to the type of approved safeguards described in paragraph 6.1.2 and the personal data which is transferred may therefore not enjoy the same level of protection as would be offered within the United Kingdom or European Economic Area; and
  5. the transfer of your personal data to other participants (including those based outside the European Economic Area) is essential to the operation of the Programme,
    and you consent to your personal data being transferred to other participants in this manner.
INCOMPLETE APPLICATIONS
1. The Bridge website offers you the opportunity to save incomplete applications prior to submission. It is important to be aware that where you save an incomplete application we can access that application and the information within it, even if you have not submitted it. It is therefore important that you do not save any information in the application form that you would not be comfortable with us seeing.
2. If your application remains unsubmitted after the closing date we may nonetheless access your application and consider admitting it to the application process even though it was not submitted. By starting an application you agree to us doing this. If we do decide that we are prepared to consider accepting your application we will let you know, and you will then be able to decide whether you want to proceed with it.
RETENTION, UPDATING AND REMOVAL OF YOUR PERSONAL INFORMATION
1. Where you provide us with personal information in the application form or during the course of the Programme, we may retain this information for future use, including:
  1. for record keeping and compliance purposes; and/or
  2. for exercising our rights set out in the Programme terms.
2. The duration for which we retain your personal information will differ depending on the type of information and the reason why it was submitted. However, in some cases personal information may be retained on a long term basis: for example, personal information that we need to retain for legal purposes will normally be retained for at least six years in accordance with usual commercial practice and regulatory requirements.
3. You are responsible for ensuring that the personal information that we hold about you is accurate and up-to-date, and you should check it on a regular basis. For the application process, you will be able to update information via the application form on the Bridge website until the closing date. Following closure of the application process, or if you are otherwise unable to do this, to update your personal information you can contact us using the details in paragraph 11.1 below.
4. If you want to withdraw your application or withdraw from the Programme at any time please contact us. Your withdrawal will result in the deletion of some of the personal information that we hold about you, but we may still retain some personal information, for example for record keeping purposes. Please note that if you would like to close your account on the Bridge, you should confirm this in your request to us.
5. You may in certain circumstances be entitled to request the erasure of personal information that we hold on you. To make a request of this nature, please contact us, providing full details of the personal information you want to be erased and the reason(s) for your request. We will consider all requests upon receipt and confirm to you whether we are able to agree to your request.
6. Please be aware that the erasure of personal information that we hold about you may affect your ability to participate in the Programme. In some cases our acceptance of an erasure request may require us to cease considering your application.
ISSUES AND COMPLAINTS
1. In the unlikely event that you have any concerns about how your personal information is being used, please contact us as described in paragraph 11.1 This includes situations where you want to request the rectification or erasure of your personal information, restrictions to be placed around how we use your personal information, or to object to a particular use.
2. If you make a complaint about our handling of your personal information, it will be dealt with in accordance with our complaints handling procedure.
3. In the first instance your complaint will be reviewed by an employee of the Administrator or Sponsor (depending on which of us you make your complaint to) within 28 days.
4. If you are dissatisfied with the response to our initial review you may request that your complaint be escalated, in which case it will be passed to a senior person within the relevant business who will review your complaint and the initial response and provide a further response within 28 days of your request to escalate the matter.
5. We will endeavour to provide a full response within the relevant review period. However, in some cases further investigation may be necessary (for example, you may submit a complaint to the Administrator but it may have to discuss certain aspects of your complaint with the Employer or vice versa).
6. If we cannot provide a final response within the relevant review period then we will provide an initial response acknowledging your complaint, explaining the reason for the delay and giving an estimate as to when a full response can be provided, and will aim to provide that full response as soon as we reasonably can following the expiry of the relevant review period.
7. If we are unable to resolve your complaint after you have escalated it to a senior person as described in paragraph 11.1 you may make a complaint to the Information Commissioner’s Office. Please see https://ico.org.uk/your-data-matters/ for more information.
CHANGES TO THE PRIVACY NOTICE
1. We reserve the right to alter this privacy notice at any time. Where we do this, we will also send you a copy of the updated notice using the details you have provided to us.
2. It is important that you read any alterations as and when they are posted on the Website by us and should you object to any alteration, please contact us as described in paragraph 14.
CONTACTING US
1. If you have a general query about this notice or the handling of your personal information, or if you have an issue regarding the use or retention of your personal information by the Administrator, please contact the Administrator’s Data Protection Officer at Daniel Saunders at 72 Acton St, London WC1X 9NB or by email at daniel@lmarks.com.
2. If you have an issue regarding the use or retention of your personal information by the Employer, please contact the Employer as described in the Employer’s privacy notice.
FURTHER INFORMATION
1. We hope that the contents of this privacy notice address any queries that you may have about the personal information we may hold about you and how we may use it. However, if you do have any further queries, comments or requests, please contact us as described in paragraph 11.1 above.
2. Whilst this privacy notice sets out a general summary of your legal rights in respect of personal information, this is a very complex area of law. More information about your legal rights can be found on the Information Commissioner’s website at https://ico.org.uk/for-the-public/.