Effective Date: 25/02/2025
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1. Introduction

‍1.1 RequiDex Limited ("we," "us," or "our") is committed to safeguarding the privacy of our Platform Users, including Clients, Suppliers, and Workers. This policy explains how we will handle your personal data when using the RequiDex Platform.

1.2 By using the RequiDex Platform and agreeing to this policy, you consent to our use of cookies in accordance with the terms of this policy.

1.3 Our Platform incorporates privacy controls that affect how we will process your personal data. You can change privacy settings by contacting us at support@requidex.com or through your account settings on the Platform.

‍2. Changes to the Privacy Policy and Your Duty to Inform Us of Changes

‍2.1 We keep our privacy policy under regular review. This version was last updated on 25/02/2025. Changes to this policy will be posted on this page, and you may be required to read and accept the changes to continue using the Platform.

2.2 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.

‍3. How We Use Your Personal Data

‍3.1 In this Section, we have set out:
- (a) The general categories of personal data that we may process;
- (b) In the case of personal data that we did not obtain directly from you, the source and specific categories of that data;
- (c) The purposes for which we may process personal data; and
- (d) The legal bases of the processing.

3.2 Usage DataWe may process data about your use of the RequiDex Platform (“Usage Data”). The Usage Data may include your IP address, geographical location, browser type and version, operating system, referral source, length of visit, page views, Platform navigation paths, as well as information about the timing, frequency and pattern of your Platform usage.

Source of Usage Data: The source of the Usage Data is our analytics tracking system.

Purpose of Processing: This data may be processed for the purposes of analysing the use of the Platform, enhancing user experience, ensuring security, and improving the Platform's functionality and performance.

Legal Basis for Processing: The legal basis for this processing is our legitimate interests, namely monitoring, securing, and improving our Platform.

3.3 Account Data

We may process your account data (“Account Data”). The Account Data may include your name, email address, job title, organisation, and any other information necessary to provide access to and use of the Platform.

Source of Account Data: The source of the Account Data may be directly from you or provided by your employer, agency, or organisation with which you have a relationship.

Purpose of Processing: The Account Data may be processed for the purposes of operating our Platform, providing Platform services, ensuring the security of the Platform, maintaining back-ups of our databases, communicating with you, and administering your account.

Legal Basis for Processing: Where you have provided us with this information, the legal basis for this processing is the performance of a contract between you and us and/or taking steps, at your request, to enter into such a contract. Where a third party has provided us with your Account Data, the legal basis is our legitimate interests, namely the proper administration of our Platform and business.

3.4 Profile Data

We may process your information included in your personal profile on the Platform (“Profile Data”). The Profile Data may include your name, address, telephone number, email address, identity pictures, gender, date of birth, educational and employment details, qualifications, compliance documentation, and work history.

Source of Profile Data: The source of the Profile Data may be you or any employment agency, contractor, intermediary, or employer with whom you have a relationship.

Purpose of Processing: The Profile Data may be processed for the purposes of enabling and monitoring your use of the Platform, facilitating workforce management, verifying identity and compliance, and ensuring that you meet the qualifications and requirements for work assignments.

Legal Basis for Processing: Where you have provided us with this information, the legal basis for this processing is the performance of a contract between you and us and/or taking steps, at your request, to enter into such a contract. Where a third party has provided us with your Profile Data, the legal basis is our legitimate interests, namely the proper administration of our Platform, business, and workforce management services.

3.5 Service Data

We may process your personal data that are provided in the course of the use of the Platform (“Service Data”). The Service Data may include any information necessary for you to be placed in work assignments and/or any information necessary for the correct processing of payments, including compliance verification, qualifications, work history, time and attendance records, payroll data, and statutory reporting.

Source of Service Data: The source of the Service Data may be you or any employment agency, contractor, intermediary, or employer with whom you have a relationship.

Purpose of Processing: The Service Data may be processed for the purposes of operating our Platform, providing our workforce management services, ensuring compliance with statutory requirements, processing payments, maintaining back-ups of our databases, and communicating with you.

Legal Basis for Processing: Where you have provided us with this information, the legal basis for this processing is the performance of a contract between you and us and/or taking steps, at your request, to enter into such a contract. Where a third party has provided us with your Service Data, the legal basis is our legitimate interests, namely the proper administration of our Platform, business, and workforce management services.

3.6 Identity Verification and Compliance Data

We may process documentation provided for identity verification and compliance purposes, including but not limited to Right to Work checks, proof of competency, and other regulatory compliance requirements.

Source of Identity Verification and Compliance Data: The source of this data may be you or your employer, agency, or organisation.

Purpose of Processing: The data is processed to validate worker documentation for compliance, identity verification, and regulatory requirements. We use Chat AI to assist in validating this documentation.

Legal Basis for Processing: The legal basis for this processing is compliance with legal obligations and our legitimate interests, namely ensuring regulatory compliance and maintaining the integrity and security of the Platform.

Data Security Note: The Chat AI used for this purpose does not store any personal data, and all information is securely maintained within the RequiDex Platform.

3.7 Enquiry Data

We may process information contained in any enquiry you submit to us (“Enquiry Data”) for the purposes of providing you with information about our Platform now or in the future and/or services provided by third parties which may be of interest to you.

Source of Enquiry Data: The source of this data is directly from you when you submit an enquiry on the Platform or contact us.

Purpose of Processing: The Enquiry Data may be processed for the purposes of communicating with you, providing requested information, and following up on your enquiries.

Legal Basis for Processing: The legal basis for this processing is your consent, which you provide when submitting the enquiry. You have the right to withdraw consent at any time by contacting us at support@requidex.com.

3.8 Communication and Correspondence Data

We may process information contained in or relating to any communication that you send to us (“Correspondence Data”). This may include the communication content, metadata, and logs associated with the communication.

Source of Correspondence Data: Our Platform generates metadata associated with communications made using the Platform contact forms or support requests.

Purpose of Processing: The Correspondence Data may be processed for the purposes of communicating with you, providing support, record-keeping, and resolving disputes.

Legal Basis for Processing: The legal basis for this processing is our legitimate interests, namely the proper administration of our Platform, business, and communications with users.

3.9 General Legal Basis and Purpose for Processing

We may process any of your personal data identified in the other provisions of this policy where necessary for:
- (a) Compliance with a legal obligation to which we are subject;
- (b) Protecting your vital interests or the vital interests of another natural person;
- (c) Establishing, exercising, or defending legal claims, whether in court proceedings or in an administrative or out-of-court procedure.

3.10 Restriction on Third-Party Data

Please do not supply any other person’s personal data to us unless we prompt you to do so, for example, where you have the other person’s authority to do so for the purposes of a work assignment or referral.

‍4. Providing Your Personal Data to Others

‍4.1 Disclosure to Insurers and Professional Advisers
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We may disclose your personal data to our insurers and/or professional advisers, including legal and financial consultants, insofar as reasonably necessary for the purposes of obtaining and maintaining insurance coverage, managing risks, obtaining professional advice, handling claims, and managing legal disputes.

4.2 Disclosure to Suppliers, Subcontractors, and Clients
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We may disclose your personal data to our suppliers, subcontractors, and clients where reasonably necessary for the performance of a contract between you and us and/or taking steps, at your request, to enter into such a contract. This may include:
- Verifying identity and compliance documents,
- Facilitating work assignments,
- Managing workforce assignments,
- Coordinating payments and billing, and
- Ensuring regulatory and statutory compliance.

4.3 Disclosure for Financial Transactions
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Financial transactions relating to our Platform are handled by our payment services providers. We will share transaction data with our payment services providers only to the extent necessary for processing your payments, dealing with complaints and queries relating to such payments, and complying with financial and statutory reporting obligations.

4.4 Disclosure to Service Providers and Partners
We may share your personal data with our service providers and partners who assist us in delivering the Platform services, including:
- Cloud storage and hosting providers,
- Security and IT support services,
- Application communication services,
- Document and identity verification services,
- Customer support and helpdesk solutions,
- Backup and data recovery services, and
- Data analytics and business intelligence services.

Data Protection Assurance:
All third-party service providers are engaged under written contracts that require them to safeguard your personal data in compliance with applicable data protection laws. We ensure that they provide adequate technical and organisational measures to protect your data.

4.5 Disclosure for Legal Compliance and Vital Interests
In addition to the specific disclosures set out in this Section, we may also disclose your personal data where such disclosure is:

- Necessary for compliance with a legal obligation to which we are subject, including responding to lawful requests by public authorities, such as to meet national security or law enforcement requirements;
- Necessary to protect your vital interests or the vital interests of another natural person, including safeguarding public health and safety or protecting against imminent harm.

4.6 Disclosure for Business Transactions
In the event of a business transaction, such as a merger, acquisition, restructuring, sale of assets, or other significant corporate event, we may share or transfer your personal data to the relevant third party involved in the transaction.

4.7 Data Protection Assurance
In such circumstances, we will ensure that the third party is bound by confidentiality obligations and that the personal data continues to be processed in a manner consistent with this Privacy Policy.

‍5. International Transfers

‍5.1 We do not transfer your data outside of the European Economic Area (EEA).

5.2 If data transfers outside the EEA become necessary, we will ensure an adequate level of protection in compliance with data protection laws.

‍6. Data Security and Retention

‍6.1 We have implemented security measures to prevent unauthorised access, use, or disclosure of your personal data. Access is restricted to employees, agents, and third parties who require it for business purposes.

6.2 We will retain your personal data only as long as necessary to fulfil the purposes for which it was collected, including legal and regulatory compliance.

6.3 Personal data related to work assignments will be retained for 7 years from the date of input.

‍7. Your Rights

‍7.1 In this Section 7, we provide a summary of your rights under data protection law. Some of these rights are complex, and not all details are included in our summaries. Accordingly, you should review the relevant laws and guidance from regulatory authorities for a full explanation of these rights.

7.2 Your principal rights under data protection law are:
- (a) The Right to Access – You have the right to request copies of your personal data, along with information on how we process it.
-(b) The Right to Rectification – You have the right to request correction of inaccurate or incomplete personal data.
-(c) The Right to Erasure – You have the right to request the deletion of your personal data under certain circumstances.
-(d) The Right to Restrict Processing – You have the right to request that we limit the processing of your personal data under certain circumstances.
-(e) The Right to Object to Processing – You have the right to object to our processing of your personal data where we rely on legitimate interests as the legal basis for processing.
-(f) The Right to Data Portability – You have the right to request that we provide your personal data to you or another service provider in a structured, commonly used, and machine-readable format.
-(g) The Right to Complain to a Supervisory Authority – You have the right to lodge a complaint with the Information Commissioner's Office (ICO) or another competent supervisory authority.
-(h) The Right to Withdraw Consent – Where we rely on your consent to process your personal data, you have the right to withdraw that consent at any time.

7.3 You have the right to confirmation as to whether or not we process your personal data and, where we do, access to that personal data together with certain additional information. This includes:
- Details of the purposes of processing,
- Categories of personal data being processed, and
- Recipients or categories of recipients to whom the personal data has been disclosed.

Providing the rights and freedoms of others are not affected, we will supply to you a copy of your personal data. The first copy will be provided free of charge, but additional copies may be subject to a reasonable fee. You can access your personal data by submitting a request to support@requidex.com.

7.4 You have the right to have any inaccurate personal data about you rectified and, taking into account the purposes of the processing, to have any incomplete personal data about you completed. You can request updates or corrections by contacting support@requidex.com.

7.5 In some circumstances, you have the right to the erasure of your personal data without undue delay. These circumstances include:
- The personal data is no longer necessary in relation to the purposes for which it was collected or otherwise processed;You withdraw consent to consent-based processing;
- The processing is for direct marketing purposes; and
- The personal data has been unlawfully processed.

However, there are certain general exclusions of the right to erasure, including where processing is necessary:
- For exercising the right of freedom of expression and information;
- For compliance with a legal obligation; orFor the establishment, exercise, or defence of legal claims.

7.6 In certain circumstances, you have the right to restrict the processing of your personal data. Those circumstances include:

- You contest the accuracy of the personal data;
- Processing is unlawful but you oppose erasure;
- We no longer need the personal data for the purposes of processing, but you require the personal data for the establishment, exercise, or defence of legal claims; and
- You have objected to processing, pending the verification of that objection.

Where processing has been restricted on this basis, we may continue to store your personal data. However, we will only otherwise process it:
- With your consent;
- For the establishment, exercise, or defence of legal claims;
- For the protection of the rights of another natural or legal person; or
- For reasons of important public interest.

7.7 You have the right to object to our processing of your personal data on grounds relating to your particular situation, but only to the extent that the legal basis for the processing is:
- The performance of a task carried out in the public interest or in the exercise of any official authority vested in us; or
- The purposes of legitimate interests pursued by us or by a third party.

If you make such an objection, we will cease to process your personal data unless we can demonstrate compelling legitimate grounds for the processing which override your interests, rights, and freedoms, or the processing is for the establishment, exercise, or defence of legal claims.

7.8 You have the right to object to our processing of your personal data for direct marketing purposes, including profiling for direct marketing purposes. If you make such an objection, we will cease to process your personal data for this purpose. You can opt-out by following the unsubscribe links in our marketing emails or by contacting us at support@requidex.com.

7.9 To the extent that the legal basis for our processing of your personal data is consent or performance of a contract, and such processing is carried out by automated means, you have the right to receive your personal data from us in a structured, commonly used, and machine-readable format. However, this right does not apply where it would adversely affect the rights and freedoms of others.

7.10 If you consider that our processing of your personal data infringes data protection laws, you have a legal right to lodge a complaint with a supervisory authority responsible for data protection. You may do so in the UK with the Information Commissioner's Office (ICO) or in the EU member state of your habitual residence, place of work, or the place of the alleged infringement.

7.11 To the extent that the legal basis for our processing of your personal data is consent, you have the right to withdraw that consent at any time. Withdrawal will not affect the lawfulness of processing before the withdrawal. You can withdraw your consent by contacting us at support@requidex.com.

7.12 You may exercise any of your rights in relation to your personal data by contacting us at:
Email: support@requidex.com
Postal Address:
RequiDex Limited,
Hafod Wen,
Llanddona,
Beaumaris, LL58 8UU,
United Kingdom.

We will respond to your request within one month of receipt. This period may be extended by two further months where necessary, considering the complexity and number of requests. We will inform you of any such extension within one month of receiving your request, together with the reasons for the delay.

‍8. Cookies and Tracking Technologies

‍8.1 We use cookies and similar tracking technologies to monitor Platform usage and improve user experience.

8.2 For more information, please see our Cookie Policy.

‍9. Use of Chat AI

‍9.1 RequiDex uses Chat AI to assist in the validation of worker documents, including but not limited to Right to Work and proof of competency documents. Chat AI is employed to enhance the accuracy and efficiency of compliance checks by verifying the validity of submitted documents.

9.2 The use of Chat AI involves the processing of personal data contained within worker documents. This may include sensitive personal information such as identity details, qualification certificates, and other compliance-related documents.
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RequiDex ensures that all data processed by Chat AI is secured using industry-standard encryption and security measures to prevent unauthorized access, alteration, or disclosure.

9.3 Chat AI does not store any personal data. All personal data used for document validation is processed in real-time and is not retained within the AI system. Once the validation process is complete, the data is recorded and securely stored within the RequiDex Platform in accordance with our data retention policy.

9.4 The legal basis for processing personal data through Chat AI for document validation is as follows:
- Performance of a Contract – Ensuring compliance with legal and contractual requirements for worker verification.
- Legitimate Interests – Enhancing the efficiency, accuracy, and security of document validation processes.
- Legal Obligation – Complying with regulatory requirements for verifying worker documentation.

9.5 User Consent and Rights

- By using the RequiDex Platform, you consent to the use of Chat AI for document validation purposes as described in this clause.
- You have the right to object to this processing or request manual verification by contacting support@requidex.com.
- All other rights, including the right to access, rectification, erasure, and data portability, as outlined in Clause 7, apply to data processed through Chat AI.

9.6 Third-Party Involvement and Data Sharing

Chat AI is provided by a third-party service provider. RequiDex ensures that this provider complies with all relevant data protection regulations and adequate safeguards are in place to protect personal data.No personal data is shared with any other third parties outside of the document validation process.

9.7 Any updates or changes to the use of Chat AI for document validation will be communicated to you via the RequiDex Platform or by email. You may be required to read and accept the updated Privacy Policy to continue using the Platform.

‍10. Changes to this Privacy Policy
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‍10.1 We may update this Privacy Policy from time to time. We will notify you of significant changes by email or via Platform notifications.

‍11. Contact Details

‍If you have any questions or concerns regarding this Privacy Policy or your personal data, please contact us at:
RequiDex Limited
Hafod Wen, Llanddona,
Beaumaris LL58 8UU, United Kingdom
Email: support@requidex.com

‍12. Complaints

‍12.1 Whilst 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, if you have any concerns about our use of your personal data, we would appreciate the opportunity to address them before you approach the ICO. Please contact us in the first instance at support@requidex.com.