Privacy Policy

Please read this Privacy Policy carefully as it describes Partner Together Limited’s collection, use, disclosure, retention and protection of your personal information.

Partner Together Limited (we or us) is committed to protecting and respecting your privacy.

1. About this Policy

Partner Together Limited takes the privacy of its customers very seriously and is committed to protecting personal information. This Privacy Policy sets out the way in which any personal information you may provide to us is used and kept secure by Partner Together Limited. It applies whenever we collect your personal data (including when you use our website), so please read it carefully.

This policy does not apply to employees of Partner Together Limited for whom there is a separate Privacy Policy.

2. Definitions


Means information or data (including critical business information) which is stored electronically, on a computer, or authorised device (such as company provided mobile phones, tablets or in-car system), or in paper-based filing systems / locations.

Personal Data

Means any data relating to an identified or identifiable living individual who can be identified from that data (or from that data and other information in our possession). Personal data can be factual (for example, a name, address, date of birth, identification number, location data), or it can be an opinion about that person, their actions and behaviour.

Sensitive Personal Data (Special Categories of Personal Data)

Means the processing of personal data revealing racial or ethnic origin, political opinions, religious or philosophical beliefs, or trade union membership, and the processing of genetic data, biometric data for the purpose of uniquely identifying a natural person, data concerning health or data concerning a natural person's sex life or sexual orientation shall be prohibited.

Data Protection Legislation

Means the General Data Protection Regulations (EU) 2016/679 (“GDPR”), unless and until GDPR is no longer directly applicable in the UK, the GDPR and any national implementing laws, regulations and secondary legislation, as amended or updated from time to time, in the UK and then any successor legislation to the GDPR or the Data Protection Act 1998.

Data Subjects

Means all the identified or identifiable living individual to whom the personal data relates. All data subjects have legal rights in relation to their personal information.

Data Subject Rights

Means the Data Subjects rights to be informed of the data being held about them, have access to the data (known as a Subject Access Request), ability to be able to rectify the data, to be forgotten – have that data erased, to restrict processing of the data (the data can be stored but nor processed), to be able to have the data transfer easily between IT environments (portability), to be able to object to certain processing aspects (such as marketing), as well as rights relating to automated decision making and profiling.


Means any activity that involves the use the data. It includes collection, recording, structuring or storage of the data, or carrying out any operation or set of operations on the data including organising, amending, retrieving, using, disclosing, erasing or destroying it. Processing also includes transferring Personal Data to third parties.


A cookie is a small piece of data that a website asks your browser to store on your computer or mobile device. The cookie allows the website to "remember" your actions or preferences over time. Most Internet browsers support cookies; however, users can set their browsers to decline certain types of cookies or specific cookies. Further, users can delete cookies at any time.

3. About Partner Together Limited

Who we are

This Privacy Policy applies to all services offered by Partner Together Limited (a company incorporated in England with company registration number 09468938) whose registered office address is The Aspen Building, Vantage Point Business Village, Mitcheldean, Gloucestershire GL17 0DD.

This Privacy Policy also applies to all the services offered by two associated companies:
Industrial Logistical Support Services Limited – company registration number 07112290 whose registered office address is The Aspen Building, Vantage Point Business Village, Mitcheldean, Gloucestershire, GL17 0DD.
Keen Thinking Limited – company registration number 04012805 whose registered office address is The Aspen Building, Vantage Point Business Village, Mitcheldean, Gloucestershire, GL17 0DD.

If you have any questions

If you have any questions about this Privacy Policy, please contact us by email;

4. Information we collect from you and why

We collect different information depending on what your relationship with us, the services you use, or your contracts with us (e.g. Simplicity, GEMS, Recruitment Growth Network, Together, GAIN Advantage). We need to tell you what we use your information for and the legal grounds we have to use this information.

In broad terms, the information we use and the purposes for which we use it are:

  • To administer and provide products and services for our customers, our customers and to provide potential customers with information about products and services they have expressed an interest in
  • To perform services that we are contracted to deliver
  • For fraud screening and prevention purposes
  • For record keeping purposes e.g. financial records
  • To track your activity on our websites or portals
  • Where you have given us permission to do so i.e. you have opted in, for marketing purposes

Cookies and websites

Our site uses cookies to distinguish you from other users of our sites. This helps us to provide you with a good experience when you browse our sites, and also allows us to improve our sites. For detailed information on the cookies we use and the purposes for which we use them, please see our Cookie Policy.

Our sites may, from time to time, contain links to and from the websites of our partner networks, advertisers and affiliates. If you follow a link to any of these websites, please note that these websites have their own privacy policies, and that we do not accept any responsibility or liability for these policies. Please check these policies before you submit any personal data to these websites.

5. Uses made of the information

We use information held about you in the following ways:

Information you give to us.

This is information about you that you give us by filling in forms on our site, or by corresponding with us by phone, email or otherwise. It includes information you provide when you register to use our site, subscribe to our service, use our service, enter a competition, promotion or survey (where available), and when you report a problem with our site. The information you give us may include your name, address, email address and phone number, and financial and credit card information (where relevant).

We will use this information:

to carry out our obligations arising from any contracts entered into between you and us and to provide you with the information and services that you request from us;

to notify you about changes to our service;

to ensure that content from our site is presented in the most effective manner for you and for your computer.

Information we collect about you.

We will use this information:

to administer our sites and for internal operations, including troubleshooting, data analysis, testing, research, statistical and survey purposes;

to improve our sites to ensure that content is presented in the most effective manner for you and for your computer;

to allow you to participate in interactive features of our service, when you choose to do so;

as part of our efforts to keep our sites safe and secure;

to measure or understand the effectiveness of advertising we serve to you and others, and to deliver relevant advertising to you;

to share this information where we are required to do so e.g. HM Revenue & Customs, regulators, law enforcement agencies.

to make suggestions and recommendations to you and other users of our site about goods or services that may interest you or them.

Information we receive from other sources.

We will combine this information with information you give to us and information we collect about you. We will use this information and the combined information for the purposes set out above (depending on the types of information we receive).

Information we receive from other sources includes information we receive about you if you use any of the other websites we operate, or the other services we provide (if relevant). In this case we will have informed you when we collected that data if we intend to share those data internally and combine it with data collected on this site. We will also have told you for what purpose we will share and combine your data. We are working closely with third parties (including, for example, business partners, sub-contractors in technical, payment and delivery services, advertising networks, analytics providers, search information providers, credit reference agencies). We will notify you when we receive information about you from them and the purposes for which we intend to use that information.

We receive technical information, including the Internet protocol (IP) address used to connect your computer to the Internet, your login information, browser type and version, time zone setting, browser plug-in types and versions, operating system and platform;

We also receive information about your visit, including the full Uniform Resource Locators (URL), clickstream to, through and from our site (including date and time), products, services or businesses you viewed or searched for, page response times, download errors, length of visits to certain pages, page interaction information (such as scrolling, clicks, and mouse-overs), methods used to browse away from the page, and any phone number used to call our customer service number.

Detailed below are the different categories of contact we hold information for. In each case we specify what is collected, what use it is put to and on what basis we are processing the data:

Prospective Customers

What information is collected?

  • We purchase data of companies that are known or believed to be forming a Limited Company for the purpose of starting a recruitment agency
  • We enhance that data with information we can desk research from published
  • Personal contact details
  • The sector and nature of contract you will be recruiting for i.e. permanent or temporary
  • Stage that you are in setting up your business

What is it used for

  • To send you information that we think will be useful in setting up and growing your recruitment business.

What is the legal basis for collecting/use this information?

  • Legitimate Interest. We are sending you information that we believe will be of interest and use to you, as you start and look to grow your recruitment business. We will hold this information for a period of no more than 6 months (unless you have opted in). It is also in the legitimate interests of a person or organisation enquiring that we are able to contact them to provide them with the information necessary to satisfy their enquiry.
  • Performance of a Contract. To allow us to complete the performance of our contract with you, we require you to provide the stated information (or access to the information). We will also send you information that we feel will be beneficial to your business and of interest.
  • Marketing Consent. Where you, the prospective customer opts into marketing we will send you marketing information in accordance with the wording of the opt in statement that we believe will be of interest to you. The opt in period will be three years from the date that you opt in and we will contact you towards the end of this to see if you want to opt in to continue to receive marketing.


What information is collected?

  • Your personal details (and those of your employees), company details and financial information.
  • Details of your Prospective Clients, Clients and their personal details
  • Personal details of candidates, both permanent and temporary.
  • For permanent jobs, details of the vacancies e.g. salary etc and temporary jobs details of the role.

What is it used for

  • To allow you to access our services to help you run your business and where applicable provide you with finance

What is the legal basis for collecting this information?

  • Performance of a Contract. To allow us to complete the performance of our contract with you, we require you to provide the stated information (or access to the information). We will also send you information that we feel will be beneficial to your business and of interest.
  • Marketing Consent. Where you, the customer opts into marketing we will send you marketing information in accordance with the wording of the opt in statement that we believe will be of interest to you. The opt in period will be three years from the date that you opt in and we will contact you towards the end of this to see if you want to opt in to continue to receive marketing.


What information is collected?

  • Supplier contacts
  • Invoicing details
  • Estimates
  • Service level agreements and capabilities.

What is it used for?

  • To be able to place work with and direct work to the supplier, to meet its contractual obligations with customers and provide the best possible service.
  • To be able to pay for services delivered by the supplier.

What is it used for?

What is the legal basis for collecting this information?

  • Performance of a Contract. To allow us to complete the performance of our contract with our customer we require the supplier to provide the stated information (or access to the information).

6. Disclosure of your information

To provide our services to you or to otherwise fulfil contractual arrangements that we have with you, we may need to appoint other organisations to carry out some of the data processing activities on our behalf.

Any member of our group, which means our subsidiaries, our ultimate holding company and its subsidiaries, as defined in section 1159 of the UK Companies Act 2006.

Selected third parties including:

associated companies – Industrial Logistical Support Services Limited and Keen Thinking Limited

business partners, suppliers and sub-contractors for the performance of any contract we enter into with them or you;

If you are an authorised user of our sites, we may share your information with employers, prospective employers and recruitment agencies for the performance of any contract we enter into with them or you.

Advertisers and advertising networks that require the data to select and serve relevant adverts to you and others. We do not disclose information about identifiable individuals to our advertisers, but we will provide them with aggregate information about our users (for example, we may inform them that 500 men aged under 30 have clicked on their advertisement on any given day). We may also use such aggregate information to help advertisers reach the kind of audience they want to target (for example, women in SW1). We may make use of the personal data we have collected from you to enable us to comply with our advertisers' wishes by displaying their advertisement to that target audience;

analytics and search engine providers that assist us in the improvement and optimisation of our site;

credit reference agencies for the purpose of assessing your credit score where this is a condition of us entering into a contract with you.

In some circumstances, we may also have to disclose your personal information by law, because a court or the police or other law enforcement agency has requested it.

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 our website terms of use Website Terms of Use, platform use agreement End User License Agreement or end user licence agreement End User License Agreement and other agreements; or to protect the rights, property, or safety of Partner Together Limited, our customers, or others. This includes exchanging information with other companies and organisations for the purposes of fraud protection and credit risk reduction.

Where you opt-in to receive Marketing information from us we will not share this information with third parties (other than our associated companies), except where they are integral to the process of creating or sending the marketing material.

In the event that we sell or buy any business or assets, in which case we will disclose your personal data to the prospective seller or buyer of such business or assets.

If Partner Together Limited or substantially all of its assets are acquired by a third party, in which case personal data held by it about its customers will be one of the transferred assets.

We only give third parties the information that they need. We always keep control of your data and our suppliers must act in accordance with our instructions.

7. Criteria for sharing your data

We only share your data with third parties if:

  • They have a need to know the information for the purposes of providing the contracted services;
  • Sharing your Personal Data complies with this Privacy Policy and, if required, the Data Subject’s consent has been obtained;
  • The third party has agreed to comply with the required data security standards, policies and procedures and put adequate security measures in place;
  • The transfer complies with any applicable cross border transfer restrictions; and
  • Where an appropriate written contract or agreement that contains data protection clauses has been agreed

8. Record Keeping

How we record the data we hold

We are required to keep full and accurate records of all our data Processing activities; including records of Data Subjects’ consents and procedures for obtaining consents.

9. We only hold Your Choices and Obligations

How long we keep your data for

We only hold your personal information for as long as is necessary to provide services to you unless there is a requirement to hold that information for a longer period – for example where we are subject to a statutory obligation to keep hold of your information e.g. financial records.

To be able to fulfil our contractual obligations with our customers we typically retain any necessary data to meet these obligations for the duration of the contract.

If there is a possibility that you may have a legal claim against us or you have made a complaint against us, then we will hold your information for the duration of any statutory limitation period associated with the claim.

Where you opt in to receive Marketing material from Partner Together Limited, this will apply for a period of three years before we are required to ask you again. You can of course ask to unsubscribe at any time. All our Marketing emails have an unsubscribe option clearly visible and you can also unsubscribe at any time by emailing us at

10. Security of your data

Partner Together Limited are committed to ensuring that your information is secure. To prevent unauthorised access or disclosure we have put in place robust physical, electronic and managerial procedures to safeguard and secure the information we collect.

If at any point you become aware of a security incident or you have reason to suspect that your data may have been compromised, please forward the communication to us or report the incident by email to

If you have been the victim of a fraudulent transaction whether or not this relates to your dealings with Partner Together Limited you should always contact the police and/or your bank in the first instance to ensure your own finances are secure.

11. Where we store your personal data

The data that we collect from you may be transferred to, and stored at, a destination outside the European Economic Area (EEA). It may also be processed by staff operating outside the EEA, who work for us or for one of our suppliers. This includes staff engaged in, among other things, the administration of your subscription, fulfilment of the services to which you have subscribed, the processing of your payment details and the provision of administration and support services. By submitting your personal data, you agree to this transfer, storing or processing. We will take all steps reasonably necessary to ensure that your data is treated securely and in accordance with this privacy policy.

All information you provide to us is stored on our secure servers. Any payment transactions will be encrypted using SSL technology. Where we have given you (or where you have chosen) a password which enables you to access certain parts of our site, you are responsible for keeping this password confidential. We ask you not to share a password with anyone.

Unfortunately, the transmission of information via the internet is not completely secure. Although we will do our best to protect your personal data, we cannot guarantee the security of your data transmitted to our site; any transmission 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. More about your information - your rights

Right of rectification.

You may request a correction or update your personal information at any time by emailing

Please include your name, address and email address when you contact us as this helps us to ensure that we accept amendments only from the correct person and can contact you to verify your identity should this be necessary. We encourage you to promptly update your personal information if it changes and we will action these as quickly as we reasonably can.

Right of erasure.

We will securely retain your information as described in this policy and in accordance with law applicable at the time. If you wish to submit a request that your data be deleted, please email us using

Subject Access Request.

You have the right to receive a copy of the personal information that we hold about you. Please email us using you wish to exercise this right.

Opting out.

If you have opted in to receive marketing from Partner Together Limited or we are marketing to you on the basis of legitimate interest, you can unsubscribe by contacting us using the email address above at any time (there will also be an unsubscribe option on every marketing email we send you).

13. Complaints

Complaints to the Regulator

If you do not think that we have processed your data in accordance with this notice, please contact us by email at

If you are not satisfied with our response, you can refer the matter to the Information Commissioner's Office. Information about how to do this is available on their website at

14. Changes to this Policy

Notification of Changes

Partner Together Limited reserve the right to change this policy at any time. Where appropriate, Partner Together Limited will notify Data Subjects of those changes in writing (letter or email). Please check back frequently to see any updates or changes to our privacy policy.

15. Contact

Questions, comments and requests regarding this privacy policy are welcomed and should be addressed to