Your privacy is important. This Privacy Policy explains how we, Universal Identity Limited trading as Construct.id, handle your personal information in connection with the website, application (including a mobile application), product, or service that links to this Privacy Policy and the administration of the employment relationship with our employees and contractors (we call these our “Services”). It applies generally to the following groups:

• Customers and users (including prospective customers and users);
• Employees;
• Third party business partners; and
• Other individuals who interact with us or whose personal information we maintain.

This Privacy Policy does not apply to any website, application, product, or service that links to its own Privacy Policy or that is offered by third parties, in which clicking on third party links or enabling those connections may allow the third party to collect, use, or share data about you. We encourage you to read their respective privacy policies.

For more information on our use of cookies and other automated technologies as well as interest-based advertising, please review our Cookie Policy.

Who is Construct.id and how can we be contacted?

Construct.id is the trading name of Universal Identity Ltd, which is a private limited company registered in England and Wales under company number 14175724.

Construct.id acts as a controller of your personal information where we determine how and why personal information can be used. This Privacy Policy, however, does not apply where we act as a processor or service provider to another controller (such as our customers).

Any comments, complaints, or questions may be emailed to dpo@construct.id or posted to our Data Protection Officer: 87 Church Road, Hove, East Sussex BN3 2BB.

What personal information do we collect and process?

Generally, we collect, use, disclose and process personal information in the following categories:

Category	Examples
Name & Contact Information	Name, address, phone number, social media user ID, email address
Account Information	Account ID, User ID, account profile, settings and preferences, purchase history, subscriptions, and registrations
Security Information	User credentials (username and password) and similar security information, individual network activity in security and audit logs
Billing & Payment Information	Payment and payment card information or bank account information, billing contact details, ship to and bill to information
User Contributions & User Content	Personal information in content and communications uploaded, sent, shared, or inputted through our Services or via our networks and infrastructure, including feedback you provide to us and the content of communications between you and us or sent via our network and Services
Device & Browser Information	Network and internet service provider (ISP) information, Internet Protocol (IP) addresses, device and browser identifiers, device and browser information, advertising identifiers, cookie/tracker identifiers and related information
Usage and Browsing Information	Usage, search, and browsing history, user journey history (including clicks, navigation, user actions, interactions, and session replays), usage and diagnostics analytics and metrics, including on our Services and on our internal networks and corporate devices by employees, contractors, and site visitors.
Location Data	Region, country, state, and coarse and precise geolocation data
Demographic Information	Age, date of birth, marriage status, gender, physical characteristics, military status, political, religious, or philosophical beliefs, sexual orientation, racial or ethnic origin, union membership
Pictures, audio, video recordings	Pictures, audio recordings, video recordings, including footage from CCTV and other security cameras used at our locations and events
Inferences from Personal Information	Profiles reflecting a person’s preferences, characteristics, psychological trends, predispositions, behaviour, attitudes, intelligence, abilities, and aptitudes.
Career, Education, and Organisation Information	Affiliated organizations (such as employer, industry associations, or licensing bodies) and status, position and title, information about colleagues and contacts, career and training/education history, professional certifications and licenses, employee identification number, employee record (including performance and compensation information), job application information, Affiliated organizations (such as employer, industry associations, or licensing bodies) and status, position and title, information about colleagues and contacts, career and education history, professional certifications and licenses, employee identification number, employee record (including performance and compensation information), job application information
Background Checks	Information from background checks, including criminal history
Health, Benefits, and Insurance Information	Enrolment and participation in insurance or benefits programs, personal information of beneficiaries, family members, emergency contacts, or dependents, medical records, disability information
Identity Information	Government identification, governmental identifiers (such as tax identifiers, social security or national insurance numbers, and passport or driver’s license numbers) together with any identification provided by industry recognised credentials providers and identifiers
Financial Information	Financial status, tax returns and related information, financial filings, credit standing, payroll and related information
Legal Information	Legal status, immigrations status, legal court cases and proceedings, governmental records, personal property or real estate records, liens & judgments, death records, public filings, driving records, licenses and registrations, and criminal information (such as arrests, charges, convictions, and incarceration records)

 

Our online Services provide information solutions intended for professionals and we do not knowingly collect any personal information from children under the age of sixteen (16).

How do we collect personal information?

• Direct Interactions: You provide your personal information when you interact with us, such as when you register for Services, fill in forms, communicate with us, apply for jobs, and work for us.
• User Contributions: We collect your personal information when you or others upload, share, send, or input that information through our Services or networks, or when you or they communicate with us.
• Automatically: We automatically collect personal information about you when you interact with us, such as when use our Services, visit our offices or events, open emails or view advertisements from us, or communicate with us. We may collect some of this personal information by using cookies and other similar technologies, and we recommend you review our Cookie Statement for more information.
• Third Party or Publicly Available Sources: We may receive your personal information from third parties, such as our third party business partners (including data brokers and advertising partners), your organisations, governmental agencies who publish public records, and other publicly or generally available sources (including online websites).

How do we use personal information?

This section includes details of the purposes for which we use personal information and the different legal reasons (also called legal basis) for processing that personal information.

 

 

Purpose	Legal Basis
To fulfil our contractual obligations, including to register your account and provide our Services and to fulfil our obligations as an employer Communicate with you about our Services and process related transactions   For any purpose with your consent or to follow your instructions	Our performance of a contract   As outlined in your consents or instructions
To operate, improve, and/or personalize our Services, corporate networks and devices, offices, events, and related infrastructure   Develop new products, services, content, and other offerings   Monitor the usage of our Services, corporate networks and devices, offices, events, and related infrastructure   Audit usage of our Services, corporate networks and devices, offices, events, and related infrastructure, including consumer interactions   Ensure the security of our Services, corporate networks and devices, offices, events, and related infrastructure   Detect fraud and abuse, including for our Services, corporate networks and devices, offices, events, and related infrastructure   Manage our internal operations (such as account administration, corporate asset deployment, billing, troubleshooting, repair)	Our performance of a contract   As outlined in your consents or instructions   To pursue legitimate interests
Provide our Services to third parties where our Services and content includes your personal information.	Our performance of a contract   As outlined in your consents or instructions   To pursue legitimate interests
Send you personalized and interest-based advertising and marketing   Improve and develop new marketing campaigns, segments, and materials   To enable you to partake in a prize draw, competition, or complete a survey	As outlined in your consents or instructions   To pursue legitimate interests
Manage the applicant and employee relationship (such as for the application process, background checks, onboarding process, employee management)   Provide, manage, and/or improve the benefits made available to employees   To improve our employee experience   Communicate with you regarding recruiting and alumni purposes, as well as human resources administration	Our performance of a contract   As outlined in your consents or instructions   To pursue legitimate interests
Exercise our rights and/or protect our or others’ rights or property   Effectuate the sale, merger, acquisition, or other disposition of our business   Advance our other commercial and economic interests as permitted by law   For other purposes as required by or permitted by law	To pursue legitimate interests   To comply with our legal obligations   To protect your vital interests or those of another person

 

Who do we share personal information with?

• Your organisations, project groups and contacts.
• Affiliates within the Universal Identity Ltd group of companies.
• Third party business partners that support our business, such as our content and other partners, ambassadors, vendors and subcontractors, construction industry associations and credential providers, analytics providers, advertising and marketing agencies, credit agencies, and other third parties we engage.
• Third parties to market their products or services to you.
• Third party customers and users where the Services and content includes your personal information, such as when we aggregate information from various public and private sources to create listings, reports, profiles, and directories (like construction and professional services directories), in which this content may be made available to all users of those Services.
• With governmental agencies and third parties involved in our sale or purchase of a business or assets, including in connection with a merger, divestiture, restructuring, reorganisation, bankruptcy, liquidation, dissolution, or other disposition of assets.
• With law enforcement, government agencies, or other third parties in order to comply with any law, court order, legal request, or other legal process, as well as to enforce our agreements or protect the rights, property, or safety of our business, employees, customers, or others (including for the purposes of cybersecurity, fraud protection, and credit risk reduction).
• With others when necessary to fulfil your consents or to follow your instructions.

Where do we store personal information?

We interact and deal with global organisations so your personal information may be transferred outside of your home country and may be stored in and accessed from multiple countries, including the United States. When you interact with us, you authorize us to transfer your personal information outside of your home country and you acknowledge the risk that we may transfer your personal information to countries that may provide less protection than your home country’s privacy laws and we may not be able to prevent government authorities in some countries from accessing your personal information.

What steps do we take to secure personal data?

We work to implement technical and organisational measures designed to protect the security of personal information. However, no method of transmission over the Internet or electronic storage is 100% secure, and we cannot guarantee its absolute security. The security of your information also depends on you: you are responsible for using unique, strong usernames and passwords for each of your accounts, and for keeping those usernames and passwords confidential. We are not responsible for the circumvention of any privacy settings or cybersecurity measures contained on our Services, and any transmission of personal information is at your own risk.

How long do we retain personal information?

We retain personal information as required by our enterprise records retention schedule, which varies by Service, business function, record classes, and record types. We calculate the retention period based upon the time the personal information is needed to: (a) fulfil the purposes described in this Privacy Policy, (b) meet the timelines required or recommended by regulators, professional bodies, or associations, (c) comply with applicable laws, legal holds, and other legal obligations (including contractual obligations), and (d) comply with your requests.

What rights do I have over my personal information?

Your local privacy laws may grant you rights with respect to your personal information, and we will not knowingly discriminate against you because you have exercised any of your privacy rights. These rights differ based on the local laws that apply to you, but could include one or more of the following:

Right to confirm we process your personal information and, if so, to access, correct, complete, object to or restrict the processing of, and delete certain personal information we hold about you, including the rights to receive your personal information in a portable copy. To submit a request, you can contact us via our data protection officer.

To opt-out of marketing emails from us, in which you may email us or click the unsubscribe link at the bottom of each email that you receive from us.

IMPORTANT: These rights are not absolutely guaranteed and there are several exceptions where we may not have an obligation to fulfil your request. We are only required to honour these rights to the extent we act as a controller of that data and the requested rights have been granted and apply to you under applicable data protection laws. Please consult your local data protection laws to determine what rights may be available to you and when access to these rights is limited. You may appeal an adverse decision on your requests by emailing or writing to us; and you have the right to lodge a complaint to your local regulator if you are not satisfied with our responses to your requests or how we manage your personal information. However, we encourage you to first contact us so we can address your concerns directly.

Changes to this Privacy Policy

This Privacy Policy is expected to change over time. We reserve the right to update it at any time, for any reason. We will notify you of changes to our Privacy Policy by updating the “Last Updated” date and posting the updated Privacy Policy on this page. We may e-mail periodic reminders of our notices and terms and conditions, but you should check our Services frequently to see the current Privacy Policy and any changes made to it.

If there are any differences between the English version of our Privacy Policy and a version translated in another language, the English version prevails.

Supplemental Privacy Policies

Depending on the specific Service you are using or specific interactions you have with us (such as when you apply for a job or work for us), we may provide different or supplemental Privacy Policies that describe and govern how we use your personal information. When we do so, those different or supplemental Privacy Policies apply to that specific Service or those specific interactions.

This Privacy Policy was last updated on 12^th May 2023.