Privacy Policy

This Privacy Policy explains how FINSIMCO LTD (“Finsimco”) collects, uses, shares and protects personal information.

Finsimco provides realistic, live, role-based business simulations for students, universities, employers and corporate clients. Our simulations are designed to help participants experience real workplace situations, develop practical skills, and, where applicable, demonstrate capability to universities, employers or other organisations.

This policy applies to website visitors; simulation participants, whether you register directly or take part through a university, employer or other organisation; Career Launch Simulation participants; candidates who opt in to employer introductions; and people who work for or represent our clients, partners and suppliers.

1. Who we are

FINSIMCO LTD is a company registered in England and Wales.

Company number: 12300845

Registered office: 1 Canada Square, 37th Floor, London E14 5AB, United Kingdom

Privacy contact: privacy@finsimco.com

Data Protection Lead: Gerhard Wortche, Managing Director

In this Privacy Policy, “Finsimco”, “we”, “us” and “our” mean FINSIMCO LTD.

For some activities, Finsimco decides how and why personal information is processed. For example, we usually act as the data controller when you register directly for a Career Launch Simulation, use our website, opt in to employer introductions, contact us, or receive communications from us.

For some university, corporate training, corporate assessment or employer-specific programmes, the university, employer, corporate client or other commissioning organisation may decide how your information is used. In those cases, we may act as a processor, independent controller or joint controller, depending on the programme and our contract with that organisation. The relevant organisation may also provide its own privacy notice.

2. What personal information we collect

The personal information we collect depends on how you interact with us.

2.1 Account, identity and contact information

This includes your name; email address; phone number, where provided; account login details; user, participant or other platform identifiers; your university, school, employer or organisation and cohort; course, programme or event information; role or job title, where relevant; and country or city.

2.2 Education, employment and candidate profile information

Where relevant - mainly if you take part in a Career Launch Simulation or opt in to employer introductions - we collect education and candidate information such as your degree, university and graduation year; your CV and work experience; your career interests and preferred roles, sectors and locations; your work authorisation and availability; and other background you choose to share, such as languages, certifications or extracurricular achievements.

2.3 Simulation participation and performance information

When you take part in a simulation, we collect or create information about your participation, such as:

•      the simulation, date and cohort, and your assigned role and team;

•      your actions, decisions, submissions and written inputs in the user interface;

•      your interactions and communications with other participants, teams and facilitators, including chat messages;

•      transcripts of spoken and written communication during live sessions - for example, in the Career Launch Simulation we record and retain transcripts of what is said, but we do not retain video recordings of participants unless we tell you otherwise for a specific event;

•      performance metrics, benchmarks, rankings, feedback, reports and, where applicable, advisory recommendations generated from your participation;

•      technical logs connected to the simulation, such as timestamps and access records.

2.4 Career Launch and employer introduction information

If you take part in a Career Launch Simulation and later opt in to be considered for employer introductions, we collect and use your CV and candidate profile; your contact details; your career interests and target roles; your preferred sectors and locations; your work authorisation and availability; your simulation performance profile; information needed to avoid unsuitable introductions, such as not recommending you to an employer you currently work for or previously worked for; limited publicly available professional information, where lawful and relevant; and records of which employers, recruiters or agencies we shared your profile with.

We only put participants forward where we believe there is a positive match. We do not send employers negative recommendations or weak-performer lists.

2.5 Website, device and technical information

When you use our website or platform, we automatically collect technical information such as your IP address, browser and device information, pages visited, session logs and cookie identifiers. See our Cookie Policy for details.

2.6 Communications and support

If you contact us, we keep the content of the communication and related records, including anything we need to verify your identity when you exercise data rights.

2.7 Business contacts and billing

If you work for or represent a university, corporate client, employer, recruiter, supplier or partner, we collect your business contact details, our communications with you, and contract, billing and relationship records. Card payments are handled by our payment provider; we do not store full payment card details ourselves.

2.8 Special category information

We do not require you to provide special category personal information - such as information about health, disability, ethnicity, religion, political opinions, sexual orientation or trade union membership - to use our services.

You may choose to provide such information in limited situations, for example if you request a reasonable adjustment or accessibility support, or include it in a CV, message or uploaded document. Where we process special category information, we do so only where we have a lawful basis and an additional condition under applicable data protection law, such as your explicit consent, a legal obligation, or where it is necessary to establish, exercise or defend legal claims. Please do not include unnecessary special category information in simulation submissions, chats, CVs or other materials.

2.9 Age requirements

Our services are not directed at children. You must be at least 18 years old to register directly with Finsimco (for example, for a Career Launch Simulation). Where you participate through your university, school or employer, that organisation is responsible for ensuring your participation is appropriate and for obtaining any consents required for participants under 18.

3. How we collect personal information

We collect personal information directly from you; from the university, employer or other organisation that registers you for a programme; from employers and recruiters who provide role requirements or candidate criteria; from your interactions with other participants and facilitators during simulations; automatically through our website, platform and security systems; from our service providers; and, in limited cases, from publicly available professional sources.

4. How we use personal information

We use personal information for the purposes below.

Where we rely on legitimate interests, we consider whether our interests are overridden by your interests, rights and freedoms. Where we rely on consent, you may withdraw it at any time; withdrawal does not affect processing that took place before it.

Benchmarking with anonymised data. Simulation data is used to calibrate our benchmarks, difficulty models and scoring across cohorts - this is how every cohort makes the next simulation better. Wherever possible we do this using data that has been anonymised or aggregated so that it no longer identifies any individual. Anonymised data is not personal information and may be retained and used indefinitely.

5. Simulation and referral scenarios

5.1 Career Launch Simulation: direct participants

If you register directly with Finsimco for a Career Launch Simulation, we use your information to register you and provide joining instructions; run and facilitate the simulation; assign you to a team or role; record your participation and simulation interactions, including transcripts of live sessions; generate simulation performance data; assess whether your profile may be suitable for employer introductions if you later opt in; and improve and secure the platform.

We do not share your individual Career Launch performance data with employers, recruiters, agencies or other third parties for recruitment purposes unless you opt in to be considered for employer introductions and we decide there is a positive match between your profile and an employer or recruiter requirement. If you do not opt in, we do not put you forward to employers or recruiters.

5.2 Employer introduction opt-in

After completing a Career Launch Simulation, you may choose to opt in to be considered for employer introductions. If you opt in, our Employer Introduction Policy applies, and we may use your CV, contact details, career preferences, location and work-authorisation information, simulation performance profile and other relevant candidate information to identify potential matches with employers, recruiters or recruitment agencies.

If we believe there is a positive match, we may share the relevant parts of this candidate information (as described in section 2.4) with the employer, recruiter or agency, together with our positive recommendation or assessment of fit.

We only put participants forward where we believe there is a positive match. We do not send employers negative recommendations or weak-performer lists. Opting in does not guarantee that you will be recommended, contacted, interviewed or hired. Employers, recruiters and agencies make their own recruitment decisions.

You may opt out at any time. Opting out stops future introductions by Finsimco, but organisations that have already received your information are responsible for their own use of it as independent controllers, unless they are acting as our processor.

5.3 Programmes run through your university or employer

If you participate through a university, business school, corporate client, employer or other organisation, that organisation may provide us with your name, email address, course or cohort information and other details needed to register you and run the programme.

We share programme data with that organisation, including attendance and participation data; platform interactions and user-interface activity; submissions, written inputs, analysis and decisions; team and individual performance data; simulation reports, feedback, metrics and benchmarks; and facilitator observations and technical records relevant to the programme.

A university may use this information for teaching, feedback, grading, academic records, internal analytics, employability support or other programme purposes. An employer or corporate client may use it for training, onboarding, assessment, recruitment, internal analytics, performance management or other employment-related purposes. In each case, that organisation is responsible for its own decisions. For university programmes, we provide simulation data and reports only; we do not recommend grades. For assessment and recruitment programmes, where agreed with that organisation, we may also provide advisory recommendations - for example, on which candidates may merit progression to interview. All grading, academic, assessment, hiring, training and progression decisions are made solely by the relevant organisation, which may accept, adapt or disregard any data, report or recommendation we provide. Grade-related questions and academic appeals should be raised with your institution; employment-related questions should be raised with your employer.

5.4 Employer-specific and sponsored simulations

If you participate in a simulation run for or sponsored by a specific employer, recruiter, corporate client or other sponsoring organisation, your participation, submissions, interactions and performance data will be shared with that organisation. This may include your registration and attendance data; simulation interactions and submissions; performance data, reports, benchmarks or assessment outputs; CV or profile information, where provided; facilitator or assessor observations; and technical records relevant to the event.

The organisation is responsible for its own hiring, employment, progression, assessment and recruitment decisions. Finsimco does not guarantee any interview, job, offer, feedback or particular outcome. For assessment simulations, individual feedback may not be provided.

6. Visibility to other participants

Some Finsimco simulations are live, multiplayer, team-based and interactive.

Depending on the format, other participants may see your name; your assigned role or team; your messages, comments or chat contributions; your video or audio presence, where enabled; your team’s decisions, outputs or performance; and leaderboards or top-performer information, where used.

For training and learning simulations, we may show team performance or top-performing participants within the relevant cohort. We do not intend to publicly display weak-performer lists. For assessment simulations, individual performance data is generally not shown to other participants unless we tell you otherwise for that specific simulation.

7. Performance metrics, profiling and automated tools

Finsimco simulations generate performance metrics using our platform, simulation design, benchmarking methods, human facilitation and, where relevant, third-party tools. We may use automated tools to help record simulation interactions, calculate performance metrics, identify patterns in simulation behaviour, generate reports or feedback, support candidate matching, and improve the platform and simulation design.

These tools support our services, but they do not guarantee a complete or perfect assessment of any participant. Simulation performance is one form of evidence and may be affected by context, role, team dynamics, technical conditions, time pressure and other factors.

Unless we tell you otherwise in a specific notice, we do not make decisions about you based solely on automated processing that produces legal or similarly significant effects. Introduction decisions and any advisory recommendations are subject to human review, and employers, universities and corporate clients make their own final decisions about recruitment, grading, employment, training, progression or academic outcomes.

We do not disclose proprietary scoring methods, thresholds, benchmarking models, confidential client criteria, employer requirements or internal deliberations, except where required by law.

8. Who we share your information with

Section 5 explains when we share your data with the organisation responsible for your programme - your university, employer or corporate client - and, where you opt in, with employers, recruiters and recruitment agencies. Section 6 explains what other participants may see during live simulations. In addition, we may share personal information with the following recipients.

8.1 Service providers

We use trusted service providers to help operate our website, platform and business. These include providers of cloud hosting and infrastructure; platform development and maintenance; communications, conferencing and event tools; analytics, CRM and support systems; payment processing and billing; authentication and security services; CV review and candidate-checking support, where applicable; and professional advisers such as legal, accounting and insurance services. Where service providers process personal information on our behalf, we require them to protect it and use it only for authorised purposes.

8.2 Legal, regulatory and safety purposes

We may share personal information where necessary to comply with law, regulation, court orders or legal process; respond to lawful requests from regulators, public authorities or law enforcement; enforce our terms and policies; protect our rights, property, platform, users, clients or others; detect, prevent or investigate fraud, misuse, security incidents or unlawful activity; or obtain legal advice and manage insurance, complaints or claims.

8.3 Business transfers

If we sell, merge, acquire, restructure or transfer all or part of our business or assets, personal information may be disclosed to the relevant buyer, seller, investor, adviser or successor organisation, subject to appropriate confidentiality and data protection safeguards.

9. Where data is hosted and international transfers

Personal information is hosted in the United Kingdom and the European Economic Area. Where a client requires hosting in a specific region, this can be agreed in the client contract.

Some of our service providers may process limited personal information in other countries, for example when providing support, communications or analytics tools. Where personal information is transferred outside the United Kingdom or the European Economic Area, we put safeguards in place as required by law, such as adequacy regulations, standard contractual clauses, or the UK International Data Transfer Agreement or Addendum.

10. How long we keep your information

We keep personal information only for as long as reasonably necessary for the purposes described in this policy, unless a longer period is required or permitted by law. The exact retention period depends on the type of data, the programme, the client contract, legal requirements, whether you opt in to employer introductions, and whether there is an active complaint, dispute, data-rights request or legal hold.

Our general retention approach is set out below.

Once identifiable data has been deleted or anonymised, we cannot reconstruct it. Deletion happens on a routine schedule and does not indicate anything about how you performed or whether you were considered for any opportunity. If your data has already been shared with a university, corporate client, employer, recruiter or agency, that organisation may retain its own copy under its own privacy notice and retention policy. We may keep minimal records confirming that data was deleted, shared or subject to a request, where needed for accountability and compliance.

11. Your rights and complaints

Depending on where you are located and the laws that apply, you may have rights in relation to your personal information. These may include the right to be informed about how we use your personal information; access a copy of your personal information; ask us to correct inaccurate or incomplete information; ask us to delete your personal information in certain circumstances; ask us to restrict processing in certain circumstances; object to processing in certain circumstances; withdraw consent where we rely on consent; ask for certain information in a portable format; object to direct marketing; raise concerns about automated decision-making, where applicable; and complain to a data protection authority.

To exercise your rights, contact us at privacy@finsimco.com or by post at FINSIMCO LTD, 1 Canada Square, 37th Floor, London E14 5AB, United Kingdom.

We may ask you for information to verify your identity before responding. If a request is made by someone else on your behalf, we may ask for proof that they are authorised to act for you. We will respond to valid requests within the timeframe required by applicable law - in many cases within one month, although this may be extended where permitted.

If you make a request after your identifiable data has been deleted or anonymised under our retention schedule, we will confirm that we no longer hold personal information about you. This is a routine consequence of our retention policy.

Your rights are not absolute. We may refuse, limit, redact or delay a request where the law allows us to do so, including where:

•      we no longer hold the information;

•      the request is manifestly unfounded or excessive;

•      we need the information for legal claims, security, regulatory, accounting or compliance reasons;

•      the information includes personal information about other people;

•      disclosure would reveal confidential information relating to our clients, employers, recruiters or universities, our correspondence with them, legally privileged material, or trade secrets such as proprietary scoring methods, benchmarks, thresholds or internal deliberations;

•      another exemption or restriction applies.

Where we cannot comply with a request, we will explain why, unless the law allows or requires us not to.

Please contact us if you have concerns about how we use your personal information, and we will try to resolve the issue. You also have the right to complain to the UK Information Commissioner’s Office (ICO): ico.org.uk, telephone 0303 123 1113. If you are located in the European Economic Area or another jurisdiction, you may also have the right to complain to your local data protection authority.

12. Changes to this Privacy Policy

We may update this Privacy Policy from time to time. If we make material changes, we will take appropriate steps to bring them to your attention, such as posting the updated policy on our website, notifying users through the platform, or sending an email where appropriate. The latest version will always be available on our website.