About this notice

Prime GTM ("we", "us", "our") is committed to protecting and respecting your privacy. Prime GTM is a trading name of This Is Prime Limited.

This notice explains how we collect, use and protect any personal data we collect from you, or that you provide to us. Please read it carefully to understand our views and practices regarding your personal data.

Our Group means our subsidiaries, our ultimate holding company and its subsidiaries, and our associated companies as defined in section 1159 of the UK Companies Act 2006.

Data controller

For the purposes of the UK General Data Protection Regulation (UK GDPR) and the Data Protection Act 2018, the data controller is:

This Is Prime Limited, trading as Prime GTM 31 Princess Street Manchester M2 4EW

Our nominated Data Protection Officer is Neil Clough, who can be contacted at the above address or by email at connect@thisisprimegtm.com.

Who we are and what we do

Prime GTM is a specialist go-to-market (GTM) recruitment business. We connect companies with talent across sales, marketing, customer success, revenue operations and commercial leadership. We are a recruitment agency and recruitment business as defined in the Conduct of Employment Agencies and Employment Businesses Regulations 2003. We also provide related training and consultancy services.

We collect the personal data of the following people so that we can run our business:

• Prospective and placed candidates for permanent, interim and contract GTM roles
• Prospective and current client contacts
• Supplier contacts who support our services
• Our employees, consultants and freelance workers

Information we collect about you

Information you give us

This is information you give us by filling in forms on our website or by corresponding with us by phone, email, video call or otherwise. It includes information you provide when you register on our site, join our talent network, subscribe to our services, attend our events or training, take part in social media features, enter a competition, promotion or survey, or report a problem with our site.

It may include your name, address, personal and work email address and phone number, financial information, compliance documentation and references verifying your qualifications, experience and right to work in the United Kingdom, your CV and photograph, details of your current and previous GTM roles (such as targets, performance and remuneration), and links to your professional profiles in the public domain, such as LinkedIn or a corporate website.

Information we collect when you visit our website

Each time you visit our site, we automatically collect technical information. This includes your IP address, login information, browser type and version, operating system and platform. It also includes information about your visit, such as the URLs you click through, pages viewed or searched for, page response times, download errors, length of visits, page interaction (such as scrolling, clicks and mouse-overs), and how you leave the page.

Information we obtain from other sources

We may obtain information about you from other sources, such as LinkedIn, corporate websites, job boards, online CV libraries, business cards and personal recommendations. Where we do, we will send you this privacy notice within 30 days of collecting your data. We will tell you that we hold your data, where it came from, and the purposes for which we intend to use it.

We also work with third parties, including companies within our Group, business partners, sub-contractors in technical, professional, payment and other services, analytics providers, search information providers, credit reference agencies and professional advisers. We may receive information about you from them for the purposes of our recruitment and related support services.

How we use your information and our lawful basis

Our core service is introducing GTM candidates to our clients for permanent, interim or contract roles. Beyond that, we support individuals throughout their commercial careers and help businesses build and scale their go-to-market teams.

We use the information we hold about you to:

• Carry out our obligations under any contract we have entered into, or intend to enter into, with you
• Provide you with the information and services you request, or that we think will interest you because they are relevant to your career or your organisation
• Tell you about other services we offer that are similar to those you have already used or enquired about

Our main lawful basis for processing personal data is our legitimate business interests, described below. We also rely on contract, legal obligation and consent for specific uses of data.

• Contract: where we are negotiating or have entered into a placement agreement, or any other contract to provide services to you or receive services from you or your organisation.
• Legal obligation: where the law requires us to hold information about you.
• Consent: for particular uses of your data, where legally required. For example, we will ask your permission before introducing you to a client if you are a candidate.

Our legitimate business interests

As a recruitment business, we introduce candidates to clients for permanent employment, interim and contract placements. Exchanging the personal data of our candidates and client contacts is a fundamental part of this.

To support our candidates' career goals and our clients' hiring needs, we keep a database of candidate and client personal data. It holds historical information as well as current hiring requirements. To maintain, expand and develop our business, we also need to record the personal data of prospective candidates and client contacts.

Consent

Where we rely on consent, we will ask for it orally, by email or through an online process for the specific activity, and record your response on our system. You can withdraw your consent to that processing at any time by emailing connect@thisisprimegtm.com.

Other uses of your data

We also use your information to notify you about changes to our services, and to make sure our website content is presented in the most effective way for you and your device. Specifically, we use it to:

• Administer our site and for internal operations, including troubleshooting, data analysis, testing, research, statistical and survey purposes
• Improve our site so content is presented in the most effective way
• Let you take part in interactive features of our service, when you choose to
• Keep our site safe and secure
• Measure and understand the effectiveness of our advertising, and deliver relevant advertising to you
• Make suggestions and recommendations about services that may interest you

Automated decision-making

We do not carry out automated decision-making or profiling. We use our systems to search for and identify personal data using parameters set by a person, and a person is always involved in any decision.

Cookies

Our website uses cookies to distinguish you from other users. This helps us give you a good experience when you browse and lets us improve our site. Non-essential cookies are only set with your consent. For details of the cookies we use and why, see our Cookie Notice.

Who we share your information with

We may share your personal information with any member of our Group, in the UK or overseas, and with selected third parties, including:

• Clients, for the purpose of introducing candidates to them
• Candidates, for the purpose of arranging interviews, training and engagements
• Clients, business partners, suppliers and sub-contractors, to perform and comply with any contract we enter into with them or you
• Sub-contractors such as email marketing specialists, event organisers, and payment and other financial service providers
• Advertisers and advertising networks. We do not disclose information about identifiable individuals to advertisers, but we may give them aggregate information about our users (for example, that 500 people clicked on their advert on a given day)
• Analytics and search engine providers that help us improve and optimise our site
• Credit reference agencies, our insurance broker, compliance partners and other sub-contractors, to assess your suitability for a role where this is a condition of our contract with you

We will also disclose your personal information to third parties:

• If we sell or buy any business or assets, in which case we may disclose your data to the prospective seller or buyer
• If This Is Prime Limited, or substantially all of its assets, are acquired by a third party, in which case personal data it holds will be one of the transferred assets
• If we are under a duty to disclose or share your data to comply with a legal obligation, to enforce our terms and agreements, or to protect the rights, property or safety of Prime GTM, our clients, candidates or others. This includes exchanging information with other organisations for fraud protection and credit risk reduction

The lawful basis for third-party processing will include:

• Their own legitimate business interests, in most cases to meet their internal hiring needs
• Fulfilling their contractual obligations to us as our data processor
• A contract that is in place or in contemplation
• Fulfilling their legal obligations

Where we store your data and how we keep it secure

Your data may be transferred to, and stored at, destinations outside the United Kingdom. This can happen when we introduce you to clients overseas, or when it is processed by staff or suppliers working outside the UK who support our recruitment and related services.

Where we transfer personal data outside the UK, we make sure it is protected. We do this by transferring only to countries the UK government has approved as providing adequate protection, or by using appropriate safeguards such as the ICO's International Data Transfer Agreement or the UK Addendum to the EU Standard Contractual Clauses.

All information you provide to us is stored on secure servers, and any payment transactions are encrypted. Where we have given you, or you have chosen, a password for parts of our site, you are responsible for keeping it confidential. Please do not share it with anyone.

No transmission of information over the internet is completely secure. We will do our best to protect your data, but we cannot guarantee the security of data sent to our site, and any transmission is at your own risk. Once we receive your information, we use strict procedures and security features to prevent unauthorised access.

How long we keep your data

We only keep personal data for as long as we need it for our legitimate business interests, and we have a legal duty to keep it accurate. We have a data retention policy and run regular routines to remove data we no longer have a legitimate reason to keep.

To keep your data accurate, we check the details we hold before making an introduction, and we stay in touch so you can tell us about any changes.

We keep different types of data for different periods. The criteria we use include:

• The nature of the personal data
• Its perceived accuracy
• Our legal obligations
• Whether an interview or placement has been arranged
• Our recruitment expertise and knowledge of the GTM market by country, sector and role

We may archive some or all of your data, or keep it only on our financial systems and delete it from our main Customer Relationship Management (CRM) system. We may pseudonymise parts of your data, particularly after a request for suppression or deletion, so that we do not re-enter your details on our database unless you ask us to. Pseudonymised data is created by replacing identifying fields in a database with artificial identifiers, or pseudonyms.

Our current retention policy is available on request.

Your rights

You have the right to ask us not to process your personal data for marketing purposes. We will usually tell you before collecting your data if we intend to use it for marketing or share it with a third party for marketing, and we will get your express consent where legally required. You can exercise this right by ticking the relevant boxes on our forms, or at any time by emailing connect@thisisprimegtm.com.

Under the UK GDPR, you also have the right to:

• Access the personal information we hold about you, free of charge in most cases
• Correct any incomplete or inaccurate information we hold about you
• Erase your personal information where there is no good reason for us to keep processing it, or where you have objected to processing
• Object to processing based on our legitimate interests (or those of a third party) where something about your situation makes you want to object, and to object to processing for direct marketing
• Restrict processing, for example while we check the accuracy of your data or our reason for processing it
• Transfer your personal information to another party in a commonly used format, where practicable
• Complain to the Information Commissioner's Office (ICO), the UK supervisory authority, at ico.org.uk/make-a-complaint. We would, however, appreciate the chance to deal with your concerns first

To make a subject access request or exercise any of these rights, email connect@thisisprimegtm.com. We will respond within one month.

Links to other websites

Our site may contain links to and from the websites of our partner networks, advertisers and affiliates. These websites have their own privacy policies, and we do not accept responsibility or liability for them. Please check their policies before submitting any personal data.

Changes to this notice

Any changes we make to this privacy notice will be posted on this page and, where appropriate, notified to you by email. Please check back regularly for updates.

Contact us

Questions, comments and requests about this privacy notice are welcome. Please email connect@thisisprimegtm.com.