Privacy Policy

Privacy Policy

Introduction, Controller and Processor
This Privacy Policy details how EPUmatch OG a company registered in Graz, Austria with registered office at Krottendorfer Strasse 4, A-8052 Graz, collect, use and process personal data provided to us.  If you have any questions on this Privacy Policy or otherwise relating to how we process your personal data you can contact us at support@epumatch.com.

We collect or receive personal data as a controller, and as a processor in as far we deal with your data directly. The processor under applicable laws is also Whitelance, a trade name of Crowdskills Ltd, a company registered in England and Wales with company number  09050188 and registered office at Impact Hub, 34b York Way, Kings Cross, London N1 9AB.

If you provide personal data to us directly, such as through our website, or we collect your personal data as a result of the operation of our business, we are a controller of that personal data.

Any job posted on a marketplace platform powered by WhiteLance is automatically posted on all relevant WhiteLance-powered platforms unless the Buyer User opts out within their account. For the avoidance of doubt, no personal data is shared with Users on other platforms.

Users agree that in our and their legitimate interests, we may send Users relevant job notifications for jobs posted on any WhiteLance-powered platforms. If Users of EPUmatch wish to apply for such jobs of other platforms they must register as a User on the platform of the Buyer User. Then the Buyer User will hire the User under the standard terms of that platform.

We may therefore hold personal data about you if you are on our EPUmatch database. 

This Privacy Policy affects your legal rights and obligations so please read it carefully. If you do not agree to be bound by this Privacy Policy, please do not provide your personal data to us. 

We may update this Privacy Policy from time to time at our discretion and in particular to reflect any changes in applicable laws. If we do so, and the changes substantially affect your rights or obligations, we shall notify you if we are the controller of your personal data.  Otherwise, you are responsible for regularly reviewing this Privacy Policy so that you are aware of any changes to it.

 

  1. What personal data do we collect?

Information you provide to us

From time to time you may provide personal data to us. This may be because you wish to:

  • use our Website;
  • create an account on our Website;
  • engage on and use our Website either as a Seller or a Buyer;
  • provide services to us;
  • purchase services from us;
  • apply to us for work;
  • otherwise contact us including with feedback, review, queries, comments or complaints.

You may provide personal data to us directly, or to us through our social media platforms.   

By personal data we mean identifiable information about you, such as:  

  • Name, and contact information, such as email address, phone number, mobile telephone number, physical address, and (depending on the service used) sometimes financial information, such as bank account numbers;
  • transactional information based on your activities on our Website (such as bidding, buying, selling, item and content you generate or that relates to your account), billing and other information you provide to purchase an item;
  • personal information you provide to us through correspondence, chats, dispute resolution, or shared by you from other social applications, services or websites;
  • additional personal information we ask you to submit to authenticate yourself if we believe you are violating site policies (for example, we may ask you to send us an ID to answer additional questions online to help verify your identity);
  • information from your interaction with our sites, services, content and advertising, including, but not limited to, device ID, device type, location, geo-location information, computer and connection information, statistics on page views, traffic to and from the sites, ad data, IP address and standard web log information.

We do not collect  special categories of personal data about you.

Certain personal data is mandatory to be provided to us in order that we can fulfil your request, for example to create an account with us, and we shall make this clear to you at the point of collection of the personal data.

All personal data that you provide to us must be true, complete and accurate.  If you provide us with inaccurate or false data, and we suspect or identity fraud, we will record this and we may also report this to the appropriate authorities.   

At our request, you shall promptly provide evidence of your identity.   

When you contact us by email or post, we may keep a record of the correspondence and we may also record any telephone call we have with you.

 

Information we automatically collect about you

When you use our Website, we automatically collect and store information about your device and your activities. This information could include:

  • technical information about your device such as type of device, web browser or operating system;
  • your preferences and settings such as time zone and language; and
  • how long you used the Website and which services and features you used.

Some of this information is collected using cookies and similar tracking technologies. If you want to find out more about the types of cookies we use, why, and how you can control them, please see our Cookies Policy.

When you use a Website the processor hosts for any WhiteLance platform, the following technical data are automatically collected and processed:

  • IP address
  • Geographical location data based on the IP address
  • Service access times
  • Statistics on page views
  • Any other automatically collected technical data

 

Information we receive from others

Given the nature of the services we provide on our Website, we may receive information about you from other users.  If we have your information as a processor, then we have received that information from our website.  

We may also receive personal data about you from our subcontractors and agents such as companies we engage to provide IT services or payment services to us.

If we reasonably believe that any of the personal data you have provided to us is inaccurate, we may receive further personal data from third parties, confirming or otherwise, your identity.

 

  1. Lawful use of your personal data

We will use your personal data only where we have a lawful basis to do so.  The lawful purposes that we rely on under this Privacy Policy are: 

  • consent (where you choose to provide it);
  • performance of our contract with you;
  • compliance with legal requirements; and
  • legitimate interests. When we refer to legitimate interests we mean our legitimate business interests in the normal running of our business which do not materially impact your rights, freedom or interests.

If you wish to access and use our website, we shall use your personal data to allow you to do so all in accordance with our Terms of Use.   In particular, if you are a Seller (or a freelancer) on our Website, you agree that the following information is publicly available: Name, Skills, Rating, Introduction, Approximate location.

We may from time to time need to use your personal data to comply with any legal requirements, for example:

  • as part of anti-money laundering processes;
  • when required by law such as to comply with requests by competent authorities or in response to a subpoena, court order or other governmental request;
  • when we believe in good faith that disclosure is necessary to protect our rights, investigate fraud or to protect a third party’s property, safety or rights.

We may also use your personal data for our legitimate interests including:

  • to improve our Website and services;
  • in connection with, or during negotiations of, any merger, sale of assets, consolidation or restructuring, financing, or acquisition of all or a portion of our business by or into another company or in the unlikely event that we go out of business or enters bankruptcy, we would transfer your personal data to a third party. You acknowledge that such transfers may occur, and that any acquirer may continue to use your personal data as set forth in this Privacy Policy;
  • to deal with any questions or comments you raise;
  • for audit purposes; and
  • to contact you about changes to this Privacy Policy.

If our processor receive your personal data for us, they shall only use that personal data to comply with their contract to provide services to us.

We and the processor may also collect other anonymized statistics and technical data about the way you use either our Website, our services and/or the services the processor provides. We shall use that information to review and improve our Website, services and business generally and we or the processor may display information publicly to others in an aggregate format that does not reveal statistics of any single marketplace.  

 

  1. Who do we share your data with?

Given the nature of the services we provide on our Website, we may provide information about you to other users if you have interacted with them.  If we do so, or you otherwise provide your personal data to any third party user on our Website, you agree that the third party’s own privacy policy may apply. 

For our legitimate interests we may share your personal data with our sub-contractors and agents that we may appoint to perform functions on our behalf and in accordance with our instructions, including IT service providers, payment providers, accountants, auditors and lawyers.   

We shall provide our sub-contractors and agents only with such personal data as they need to provide the service for us and if we stop using their services, we shall request that they delete your personal data or make it anonymous within their systems.

 

  1. Where we hold and process your personal data

Some or all of your personal data may be stored or transferred outside of Austria, the United Kingdom or the European Economic Area (the EEA) if for example, if our email server is located in a country outside the EEA or the United Kingdom if any of our sub-contractors are based outside of the EEA.

Where your personal data is transferred outside the EEA or United Kingdom, it will only be transferred to countries that have been identified as providing adequate protection for personal data or to a third party where we have approved transfer mechanisms in place to protect your personal data – i.e., by entering into the European Commission’s Standard Contractual Clauses, or by ensuring the entity is Privacy Shield certified (for transfers to US-based third parties). 

 

  1. Security

We shall process your personal data in a manner that ensures appropriate security of the personal data, including protection against unauthorised or unlawful processing and against accidental loss, destruction or damage.  In particular, access is restricted to employees who need to know your personal data, and we use appropriate password protection, firewalls and encryption electronic measures together with information access controls within our electronic data management systems.

However, unfortunately, because of the nature of electronic storage,  we cannot promise that your personal data or any other data you provide to us will always remain secure. If there is a security breach, we will do all that we can as soon as we can to stop the breach and minimise the loss of any data.

  1. Marketing

We may send you marketing email messages from us about our Website and business and to solicit feedback either because you have consented to receive the emails, or for our legitimate interests.

You can choose to no longer receive marketing emails from us by contacting us or clicking unsubscribe from a marketing email.  Please note that it may take us a few days to update our records to reflect your request.

If you ask us to remove you from our marketing list, we shall keep a record of your name and email address to ensure that we do not send to you marketing information. We will still contact you as necessary about your account.

  1. Your rights

You have a number of rights under applicable data protection legislation. Some of these rights are complex, and not all of the details have been included below. Further information can be found here

  • Right of access: You have the right to obtain from us a copy of the personal data that we hold for you.
  • Right to rectification: You can require us to correct errors in the personal data that we process for you if it is inaccurate, incomplete or out of date.
  • Right to portability: You can request that we transfer your personal data to another organisation.
  • Right to restriction of processing: In certain circumstances, you have the right to require that we restrict the processing of your personal data.
  • Right to be forgotten: You also have the right at any time to require that we delete the personal data that we hold for you, where it is no longer necessary for us to hold it. However, whilst we respect your right to be forgotten, we may still retain your personal data in accordance with applicable laws.
  • Right to stop receiving marketing information: You can ask us to stop sending you information about our business, but please note we shall continue to contact you in relation to any matters relating to your EPUmatch account, if you have one.

You may be able to exercise some of these rights within your account on the Website. We reserve the right to charge an administrative fee if your request in relation to your rights is manifestly unfounded or excessive.

If you have any complaints in relation to this Privacy Policy or otherwise in relation to our processing of your personal data, please tell us. We shall review and investigate your complaint and try to get back to you within a reasonable time.

 

  1. Retention of personal data

If you request us to do so, the processor shall delete your personal data or make it anonymous within the processor’s systems.

Subject to the provisions of this Privacy Policy, we will retain personal data in accordance with applicable laws.

In particular, we shall retain your personal data for as long as you have an account on our Website. However, we may also be required to retain personal data for a particular period of time to comply with legal, auditory or statutory requirements, including requirements in respect of financial documents.

Where we have no legal basis for continuing to process your personal data, the processor shall either delete or anonymise it or, if this is not possible (for example, because your personal information has been stored in backup archives), then they will securely store your personal information and isolate it from any further processing until deletion is possible. 

  1. General

If any provision of this Privacy Policy is held by a court of competent jurisdiction to be invalid or unenforceable, then such provision shall be construed, as nearly as possible, to reflect the intentions of the Privacy Policy. All other provisions shall remain in full force and effect. 

This Privacy Policy shall be governed by and construed in accordance with European and Austrian law and you agree to submit to the exclusive jurisdiction of the Courts in Graz, Austria.

Last updated: April 2020.