1. Introduction

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1.1    We are committed to safeguarding the privacy and accuracy of the personal data of Our website visitors, service users and email recipients.

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1.2    This policy applies where We are acting as a Data Controller with respect to the personal data of Our website visitors, service users, email recipients and personal data collected from public sources; in other words, where We determine the purposes and means of the processing of that personal data.

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1.3    In this policy, “We”, “Us” and “Our” refer to Workofo Europe and its subsidiaries – trading as Workofo. For more information about Us, see Section 12.

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1.4    Reference to a Data Subject means a natural person whose personal data is processed by a Data Controller or a Data Processor, in other words, You.

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2.How We use Your personal data

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2.1    In this Section 2 We have set out:

1. The general categories of personal data that We may process;

2. in the case of personal data that We did not obtain directly, the source and specific categories of that data;

3. the purposes for which We may process personal data; and

4. the legal bases of the processing.

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2.1.1 The General Categories Of Personal Data That We May Process

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2.1.1.1  Usage Data

      

We may process data about Your use of Our website and services (“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 and website navigation paths, as well as information about the timing, frequency and pattern of Your service use. The source of the Usage Data is Google Analytics as well as Our analytics tracking system. This Usage Data may be processed for the purposes of analysing the use of the website and services. The legal basis for this processing is Our legitimate interests, namely monitoring and improving Our website and services, and tailoring any communication with You.

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2.1.1.2  Account Data

      

We may process Your Account Data (“Account Data“).  The Account Data may include Your name and email address. The source of the Account Data is You or Your employer. The Account Data may be processed for the purposes of providing Our services, ensuring the security of Our website and services, maintaining back-ups of Our databases and communicating with You. 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.

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2.1.1.3  Service Data

      

We may process Your personal data that are provided in the course of the use of Our services (“Service Data“). The Service Data may include name, email address and telephone number. The source of the Service Data is You or Your employer. The Service Data may be processed for the purposes of providing Our services and communicating with You. 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.

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2.1.1.4  Enquiry Data

      

We may process information contained in any enquiry You submit to Us regarding goods and/or services (“Enquiry Data“). The Enquiry Data may be processed for the purposes of Us offering, marketing and selling relevant goods and/or services to You. The legal basis for this processing is consent which may be withdrawn by You at any time by contacting Us.

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2.1.1.5  Notification Data

      

We may process information that You provide to Us for the purpose of subscribing to Our email notifications and/or newsletters (“Notification Data“). The Notification Data may be processed for the purposes of sending You the relevant notifications and/or newsletters. The legal basis for this processing is consent which may be withdrawn by You at any time by contacting Us.

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2.1.1.6  Correspondence Data

     

We may process information contained in or relating to any communication that You send to Us (“Correspondence Data“). The Correspondence Data may include Your name, email address and the communication content and metadata associated with the communication. Our website will generate the metadata associated with communications made using the website contact forms. The Correspondence Data may be processed for the purposes of communicating with You and record-keeping. The legal basis for this processing is Our legitimate interests, namely the proper administration of Our website and business and communications with users.

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2.1.1.7  Public Data

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We may process information found on public social networking profiles (“Public Data“). This data may include name and job title. Public Data may be processed for the purposes of offering, marketing and selling relevant goods and/or services to Your employer. The legal basis for this processing is Our legitimate interests, namely proper administration of Our business.

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2.1.1.8  Legal Claims Data

We may process any of Your personal data identified in this policy where necessary for the establishment, exercise or defence of legal claims, whether in court proceedings or in an administrative or out-of-court procedure. (“Legal Claims Data”) The legal basis for this processing is Our legitimate interests, namely the protection and assertion of Our legal rights, Your legal rights and the legal rights of others.

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2.1.1.9  Professional Use Data

      

We may process any of Your personal data identified in this policy where necessary for the purposes of obtaining or maintaining insurance coverage, managing risks, or obtaining professional advice. (“Professional Use Data”). The legal basis for processing Legal Claims Data is Our legitimate interests, namely the proper protection of Our business against risks.

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2.2    In addition to the specific purposes for which We may process Your personal data set out in this Section 2, We may also process any of Your personal data where such processing is necessary for compliance with a legal obligation to which We are subject, or in order to protect Your vital interests or the vital interests of another natural person.

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2.3    Please do not supply any other person’s personal data to Us unless We prompt You to do so.

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3. Sharing Your personal data with others

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3.1    We may disclose Your personal data to any member of Our group of companies (this means Our subsidiaries, Our ultimate holding company and all its subsidiaries) (together known as “Group Companies”) insofar as reasonably necessary for the purposes, and on the legal bases, set out in this policy.

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3.2    We may disclose Your personal data to Our insurers and/or professional advisers insofar as reasonably necessary for the purposes of obtaining or maintaining insurance coverage, managing risks, obtaining professional advice, or the establishment, exercise or defence of legal claims, whether in court proceedings or in an administrative or out-of-court procedure.

3.3    In addition to the specific disclosures of personal data set out in this Section 3, We may disclose Your personal data where such disclosure is necessary for compliance with a binding legal obligation arising under EU law to which We are subject, or in order to protect Your vital interests or the vital interests of another natural person. We may also disclose Your personal data where such disclosure is necessary for the establishment, exercise or defence of legal claims, whether in court proceedings or in an administrative or out-of-court procedure.

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4. International transfers of Your personal data

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4.1    In this Section 4, We provide information about the circumstances in which Your personal data may be transferred to countries outside the European Economic Area (“EEA”).

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4.2    You acknowledge that personal data that You submit for publication through Our website or services may be available, via the internet, around the world. We cannot prevent the use (or misuse) of such personal data by others.

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4.3    Our Website may contain links to external Websites run by other organisations. This privacy policy applies only to our Websites not those external Websites that we link to, who will have their own privacy policies. We are not responsible for these external Websites and their privacy policies and practices. In addition, if you linked to our Website from an external site, we cannot be responsible for the privacy policies and practices of the owners and operators of that external Website and recommend that you check the privacy policy of that external site.

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5. Retaining and deleting personal data

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5.1    This Section 5 sets out Our data retention policies and procedure, which are designed to help ensure that We comply with Our legal obligations in relation to the retention and deletion of personal data.

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5.2    Personal data that we process for any purpose or purposes shall not be kept for longer than is necessary for that purpose or those purposes.

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5.3    Notwithstanding the other provisions of this Section 5, We may retain Your personal data where such retention is necessary for compliance with a legal obligation to which We are subject, or in order to protect Your vital interests or the vital interests of another natural person.

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6. Cookies

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6.1    By using Our website and agreeing to this policy, You consent to Our use of cookies in accordance with the terms of Our Cookie Policy.

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7. The Rights of Data Subjects

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7.1    In this Section 7, We have summarised the rights that You have under data protection law. Some of the rights are complex, and not all of the details have been included in Our summaries. Accordingly, You should read the relevant laws and guidance from the regulatory authorities for a full explanation of these rights.

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7.2    Your principal rights under data protection law are:

1. The right to be informed

2. the right to access

3. the right to rectification

4. the right to erasure

5. the right to restrict processing

6. the right to object to processing

7. the right to data portability

8. Rights related to automated decision making including profiling

9. the right to complain to a supervisory authority; and

the right to withdraw consent

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