"At the end of the day, the goals are simple: safety and security."
-Jodi Rell

Legend Corp–GDPR Privacy Notice for service providers

What is the purpose of this document?

Legend Corp is committed to protecting the privacy and security of your personal information. This privacy notice describes how we collect and use personal information about you during and after your working relationship with us, in accordance with the General Data Protection Regulation (GDPR). It applies to all service-providers (including individual freelancers and corporate or other organisations).

Legend Corp is a "data controller". This means that we are responsible for deciding how we hold and use personal information about you. We are required under data protection legislation to notify you of the information contained in this privacy notice.

This notice applies to current and former service-providers. This notice does not form part of any contract to provide services. We may update this notice at any time but if we do so, we will provide you with an updated copy of this notice as soon as reasonably practical.

It is important that you read and retain this notice, together with any other privacy notice we may provide on specific occasions when we are collecting or processing personal information about you, so that you are aware of how and why we are using such information and what your rights are under the data protection legislation.

Data protection principles

We will comply with data protection law. This says that the personal information we hold about you must be:

  • 1. Used lawfully, fairly and in a transparent way.
  • 2. Collected only for valid purposes that we have clearly explained to you and not used in any way that is incompatible with those purposes.
  • 3. Relevant to the purposes we have told you about and limited only to those purposes.
  • 4. Accurate and kept up to date.
  • 5. Kept only as long as necessary for the purposes we have told you about
  • 6. Kept securely.

The kind of information we hold 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 will collect, store, and use the following categories of personal information about you:

  • • Personal contact details such as an individual’s name, title and gender (if individual is a freelancer or equivalent or as part of an organisation).
  • • Bank account details (if individual is a freelancer or equivalent)
  • • Start date (and end date) of services (if individual is a freelancer or equivalent or as part of an organisation)
  • • Location where work is provided (if individual is a freelancer or equivalent or as part of an organisation)
  • • Performance information in relation to the provision of services (if individual is a freelancer or equivalent or as part of an organisation).

How is your personal information collected?

We collect personal information about service providers (including individual freelancers and individuals within corporate or other organisations) through recommendations from third parties, pitches, and information gathered from the service provider’s business platforms.

How we will use information about you

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

  • 1. Where we need to perform the contract we have entered into with you
  • 2. Where we need to comply with a legal obligation.
  • 3. Where it is necessary for legitimate interests pursued by us or a third party and your interests and fundamental rights do not override those interests.

We may also use your personal information in the following situations, which are likely to be rare:

  • 1. Where we need to protect your interests (or someone else's interests).
  • 2. Where it is needed in the public interest or for official purposes.

Situations in which we will use your personal information

We need all the categories of information in the list above primarily to (1) allow us to perform our contract with you; and (2) to enable us to comply with legal obligations. In some cases, we may use your personal information to (3) pursue legitimate interests, provided your interests and fundamental rights do not override those interests.

The situations in which we will process your personal information are listed below. We have indicated by a corresponding number (1, 2 or 3) the purpose or purposes for which we are processing or will process your personal information, as well as indicating which categories of data are involved. Where a legitimate interest is involved, we state what the legitimate interest is.

  • • Making a decision about your engagement as a service provider (3). The legitimate interest is to assess your suitability to perform the services.
  • • Determining the terms on which you provide services (3). The legitimate interest is to ensure the company has appropriate terms with service providers for sound and responsible business planning.
  • • Paying you (1)
  • • Administering the contract we have entered into with you (1).
  • • Conducting service providers contract reviews (3). The legitimate interest is to drive business productivity and performance.
  • • Assessing qualifications for particular provisions of services (2) and (3). The legitimate interest is to ensure that individuals are carrying out work competently and appropriate to the standards required and prescribed for the provision of services.
  • • Making decisions about your continued engagement as a service provider (1) and (3). The legitimate interest is to protect and improve the business and its functions.
  • • Making arrangements for the termination of the working arrangement (1).
  • • Dealing with legal disputes involving you, or other service providers (1), (2) and (3). The legitimate interest is to protect and defend the organisation.
  • • To monitor your use of our information and communication systems to ensure compliance with our IT policies (3). The legitimate interest is to ensure confidentiality of proprietary and commercially sensitive data, to minimise threats and damage to business IT systems and mitigate reputational damage.
  • • To ensure network and information security, including preventing unauthorised access to our computer and electronic communications systems and preventing malicious software distribution (3). The legitimate interest is to minimise unauthorised access to confidential and commercially sensitive data and to mitigate threats to business systems.

Some of the above grounds for processing will overlap and there may be several grounds which justify our use of your personal information.

If you fail to provide personal information

If you fail to provide certain information when requested, we may not be able to perform the contract we have entered into with you (such as paying you), or we may be prevented from complying with our legal obligations.

Change of purpose

We will only use your personal information 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 we need to use your personal information 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 information without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.

How we use particularly sensitive personal information

"Special categories" of particularly sensitive personal information require higher levels of protection. We need to have further justification for collecting, storing and using this type of personal information. We have in place an appropriate policy document and safeguards which we are required by law to maintain when processing such data. We may process special categories of personal information in the following circumstances:

  • 1. In limited circumstances, with your explicit written consent.

Less commonly, we may process this type of information where it is needed in relation to legal claims or where it is needed to protect your interests (or someone else's interests) and you are not capable of giving your consent, or where you have already made the information public.

Our obligations

We do not envisage using any particularly sensitive personal information.

Do we need your consent?

We do not need your consent if we use special categories of your personal information in accordance with our written policy to carry out our legal obligations. In limited circumstances, we may approach you for your written consent to allow us to process certain particularly sensitive data. If we do so, we will provide you with full details of the information that we would like and the reason we need it, so that you can carefully consider whether you wish to consent. You should be aware that it is not a condition of your contract with us that you agree to any request for consent from us.

Information about criminal convictions

We may only use information relating to criminal convictions where the law allows us to do so. This will usually be where such processing is necessary to carry out our obligations and provided we do so in line with our data protection policy.

Less commonly, we may use information relating to criminal convictions where it is necessary in relation to legal claims, where it is necessary to protect your interests (or someone else's interests) and you are not capable of giving your consent, or where you have already made the information public.

We do not envisage that we will hold information about criminal convictions.

Automated decision-making

Automated decision-making takes place when an electronic system uses personal information to make a decision without human intervention. We are allowed to use automated decision-making in the following circumstances:

  • 1. Where we have notified you of the decision and given you 21 days to request a reconsideration.
  • 2. Where it is necessary to perform the contract with you and appropriate measures are in place to safeguard your rights.
  • 3. In limited circumstances, with your explicit written consent and where appropriate measures are in place to safeguard your rights.

If we make an automated decision on the basis of any particularly sensitive personal information, we must have either your explicit written consent or it must be justified in the public interest, and we must also put in place appropriate measures to safeguard your rights.

You will not be subject to decisions that will have a significant impact on you based solely on automated decision-making, unless we have a lawful basis for doing so and we have notified you. We do not envisage that any decisions will be taken about you using automated means, however we will notify you in writing if this position changes.

Data sharing

We may have to share your data with third parties, including third-party service providers and other entities in the group.

We require third parties to respect the security of your data and to treat it in accordance with the law.

We may transfer your personal information outside the EU.

If we do, you can expect a similar degree of protection in respect of your personal information.

Why might you share my personal information with third parties?

We will share your personal information with third parties where required by law, where it is necessary to administer the working relationship with you or where we have another legitimate interest in doing so.

Which third-party service providers process my personal information?

"Third parties" includes third-party service providers (including contractors and designated agents) and other entities within our group, such as IT and payment administration providers.

How secure is my information with third-party service providers and other entities in our group?

All our third-party service providers are required to take appropriate security measures to protect your personal information in line with our policies. We do not allow our third-party service providers to use your personal data for their own purposes. We only permit them to process your personal data for specified purposes and in accordance with our instructions.

What about other third parties?

We may share your personal information with other third parties, for example in the context of the possible sale or restructuring of the business. In this situation we will, so far as possible, share anonymised data with the other parties before the transaction completes. Once the transaction is completed, we will share your personal data with the other parties if and to the extent required under the terms of the transaction.

We may also need to share your personal information with a regulator or to otherwise comply with the law.

Transferring information outside the EU

We may transfer the personal information we collect about you to countries outside the EU in order to perform our contract with you such as online service providers and online tools. There may not be an adequacy decision by the European Commission in respect of those countries. This means that the countries to which we transfer your data may or may not be deemed to provide an adequate level of protection for your personal information.

However, to ensure that your personal information does receive an adequate level of protection we have already or are putting in place the following appropriate measures to ensure that your personal information is treated by those third parties in a way that is consistent with and which respects the EU and UK laws on data protection:

  • • standard contractual clauses adopted by the European Commission
  • • approved certification mechanisms
  • • approved codes of conducts
  • • Privacy Shield compliance

Data security

We have put in place measures to protect the security of your information. Details of these measures are available upon request.

Third parties will only process your personal information on our instructions and where they have agreed to treat the information confidentially and to keep it secure.

We have put in place appropriate security measures to prevent your personal information from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your personal information to those agents, contractors and other third parties who have a business need to know. They will only process your personal information on our instructions and they are subject to a duty of confidentiality.

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


Data Retention
How long will you use my information for?

We will only retain your personal information for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements.

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 requirements.

In some circumstances we may anonymise your personal information so that it can no longer be associated with you, in which case we may use such information without further notice to you. Once you are no longer a worker or contractor of the company we will retain and securely destroy your personal information in accordance with applicable laws and regulations.


Rights of access, correction, erasure, and restriction
Your duty to inform us of changes

It is important that the personal information we hold about you is accurate and current. Please keep us informed if your personal information changes during your working relationship with us.

Your rights in connection with personal information

Under certain circumstances, by law you have the right to:

  • Request access to your personal information (commonly known as a "data subject access request"). This enables you to receive a copy of the personal information we hold about you and to check that we are lawfully processing it.
  • Request correction of the personal information that we hold about you. This enables you to have any incomplete or inaccurate information we hold about you corrected.
  • Request erasure of your personal information. This enables you to ask us to delete or remove personal information 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 information where you have exercised your right to object to processing (see below).
  • Object to processing of your personal information 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. You also have the right to object where we are processing your personal information for direct marketing purposes.
  • Request the restriction of processing of your personal information. This enables you to ask us to suspend the processing of personal information about you, for example if you want us to establish its accuracy or the reason for processing it.
  • Request the transfer of your personal information to another party.

If you want to review, verify, correct or request erasure of your personal information, object to the processing of your personal data, or request that we transfer a copy of your personal information to another party, please contact the Data Protection Team by email at . Please also note the following:

Verasafe has been appointed as Legend Corp’s representative in the European Union for data protection matters, pursuant to Article 27 of the General Data Protection Regulation of the European Union. VeraSafe can be contacted in addition to Legend Corp’s Data Protection Team only on matters related to the processing of personal data. To make such an inquiry, please contact VeraSafe at:

verasafe.com/privacy-services/contact-article-27-representative

Alternatively, VeraSafe can be contacted at:

Matthew Joseph

Zahradníčkova 1220/20A

Prague 15000

Czech Republic

VeraSafe Ireland Ltd

Unit 3D North Point House

North Point Business Park

New Mallow Road

Cork T23AT2P

Ireland

VeraSafe Netherlands BV

Keizersgracht 391 A

1016 EJ Amsterdam

Netherlands

No fee usually required

You will not have to pay a fee to access your personal information (or to exercise any of the other rights). However, we may charge a reasonable fee if your request for access is clearly unfounded or excessive. Alternatively, we may refuse to comply with the request in such 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 the information (or to exercise any of your other rights). This is another appropriate security measure to ensure that personal information is not disclosed to any person who has no right to receive it.

Right to withdraw consent

In the limited circumstances where you may have provided your consent to the collection, processing and transfer of your personal information for a specific purpose, you have the right to withdraw your consent for that specific processing at any time. To withdraw your consent, please contact the Data Protection Team. Once we have received notification that you have withdrawn your consent, we will no longer process your information for the purpose or purposes you originally agreed to, unless we have another legitimate basis for doing so in law.

Data protection officer

We have appointed a Data Protection to oversee compliance with this privacy notice. If you have any questions about this privacy notice or how we handle your personal information, please contact the Data Protection Team. You have the right to make a complaint at any time to your local supervisory authority for data protection issues.

Changes to this privacy notice

We reserve the right to update this privacy notice at any time, and we will provide you with a new privacy notice when we make any substantial updates. We may also notify you in other ways from time to time about the processing of your personal information.

If you have any questions about this privacy notice, please contact the Data Protection Team by email at