In accordance with the legislation applicable to personal data, i.e. Regulation (EU) 2016/679, of 27 April, (GDPR) and in O.L. 3/2018, of 5 December, on data protection and guarantee of digital rights (LOPDGDD), this Policy informs Users about the processing of their personal data and digital rights.
Collection and use of information
Our main objectives in collecting, using and processing information through the Platform are to provide users with access to and use of our Platform, to improve and further develop our Platform and to enable users to enjoy and navigate the Site easily.
Personally Identifiable Information
During your use of the Platform (whether as a Client or as a Contractor), we may ask you to provide or grant us access or permission to obtain certain personally identifiable information that may be used to contact or identify you; personally identifiable information may include, but is not limited to, your name, company name, e-mail address, mailing address, work experience and interests, and telephone number ("Information").
If you use the Platform to make payments, we will also collect certain Personal Information such as credit card, Swipe, PayPal or other financial account information, and billing address.
We may collect additional personal information to validate your identity, and we may authenticate you in accordance with applicable law from time to time.
As described in more detail in our Terms of Service, you can register or enter data on our Platform directly through the Website or by logging into your account with certain third party social networking services (including but not limited to LinkedIn or Facebook) ("SNS" - "Social Networks Sites") through our Website. If you choose to enter data through an SNS, we will use the personal information you have provided to the SNS (such as your "real" name, email address, gender, previous experience, and other information you make publicly available through the SNS) to modify and update your account; the information we collect may depend on the privacy settings you have with the SNS. Other than what we may share with SNSs as described below, the personal information an SNS holds about you is obtained by the SNS independently of our Platform, and QALEON is not responsible for its accuracy, legality or non-infringement.
You can link your QALEON account to your SNS account, in which case the SNS may share certain information about you with other SNS users, as well as share certain information about other SNS users with you. You declare that you are authorised to use your SNS account for the purposes described in this document without breaching any of the terms and conditions governing the SNS, and without obliging QALEON to pay any fees or make QALEON subject to any limitations of use imposed by the SNS. You can deactivate the link between your account with QALEON and your SNS account at any time through the "Settings" section of the Site. PLEASE NOTE THAT YOUR RELATIONSHIP WITH ANY SNS IS GOVERNED ONLY BY YOUR AGREEMENT(S) WITH SUCH SNS. If your SNS account terminates, then the functions enabled through the link between your QALEON account and your SNS account will also terminate.
We also collect other information that you provide in connection with your use of the Platform (e.g., your postcode (for yourself) and individual preferences) ("Non-identifiable information"). We collect additional non-identifiable information from customers in the form of information related to jobs posted through the Platform (e.g., budget, location, job listing history, job performance time and feedback/classification information). We also collect additional non-identifiable information from contractors in relation to their profiles (e.g. information about previous jobs performed, skills, tests performed, hourly pay rates and feedback/qualification information).
We use your personal information (in some cases, along with your non-identifiable information) primarily to provide the Platform, complete your transactions and manage your enquiries.
Certain Non-Personally Identifiable Information would be considered part of your Personal Information if it were combined with other identifiers (for example, by combining your postcode with your address) in a manner that allows you to be identified. But the same pieces of information are considered Non-Identifiable Information when taken alone or combined only with other non-identifiable information (for example, your viewing preferences). We may combine your Personal Information with Non-Identifiable Information and add it to the information collected from other QALEON Users to try to provide you with a better experience, improve the quality and value of the Platform, and analyse and understand how our Site and the Platform are used, and generate general industry analysis. We may also use the combined information without aggregation to serve you specifically, for example, to deliver a product to you in accordance with your preferences or restrictions.
When you register, if applicable, on the relevant QALEON Platform, you will opt-in to receive emails, newsletters, marketing and/or promotional materials from QALEON. We will also use your personal information to send you this content. If you decide at any time that you no longer wish to receive such communications from us, you may opt-out or customize the type of messages you receive from QALEON by visiting the "Notifications" section under "Account Settings", or by clicking on the unsubscribe link included at the bottom of QALEON emails, or by emailing us at email@example.com. Please note that any such opt-out applies only to marketing-related emails. QALEON will still need to communicate with you by email regarding non-marketing related matters on the Platform and you acknowledge and agree that QALEON has the right to do so.
Use of personal information by QALEON
QALEON uses personal information for the following general purposes:
- To provide our products and the Platform,
- For billing, identification and authentication, and fraud prevention
- To analyse the use of the Site and improve our products and the Platform,
- To contact you and provide you with administrative notices and communications relevant to the use of our products and services
- For internal market research, problem solving and the detection and protection against error, fraud or other criminal activity,
- For distribution to third party contractors who provide services to QALEON and to partners of QALEON who are bound by confidentiality obligations with regard to any personal information we share with them,
We may employ third party companies and individuals to provide our Platform, to provide Platform services on our behalf, to perform Site-related services (e.g., without limitation, maintenance services, database management, web analytics, payment processing, fraud detection and enhancement of Site features) or to help us analyse how our Site and Platform are being used. These third parties have access to your Personal Information only to perform these tasks on our behalf and are required not to disclose it or use it for any other purpose. Although we ensure that our third party agents ("Agents") who receive your information are bound by confidentiality obligations. QALEON is not responsible and will not be liable for any issues that may arise in relation to the Privacy Policies of any of its agents, affiliates, advertisers and/or any other third party. By using this website, you agree to maintain QALEON indemnified, defend and hold QALEON harmless from any claim and/or damages that may arise from the actions of any of QALEON's agents, affiliates and/or advertisers.
Two things drive QALEON's decisions regarding the use of information collected from users: 1) improving the user's experience by offering personalised services, content and advertising, and 2) market research.
QALEON may analyse the Personal Information and Web Browsing Data based on your interests and may use the analysis of this information so that it does not contain any Personal Information ("Market Research") for the purpose of
- Market the Platform
- Improve the probability of a sale to a new user
- Increase the likelihood that a user's experience with the Platform is relevant to their interests
QALEON uses the data at an individual level to sell products and services to users who express an interest in these products and services, through a survey, for example, or to users who can be assumed to have an interest based on the results of our market research.
QALEON may use your mobile phone number to call or text you in order to provide the Platform. If you would like more information about our policy, or to opt out, please review our Terms of Service and send an email to firstname.lastname@example.org; by agreeing to these Terms of Service you are indicating your consent to be contacted at the phone number you have provided for the purposes described above.
When you submit information to QALEON, it is collected, processed and maintained solely by us or by third party agents who are bound by confidentiality obligations. We may allow our business partners to collect information about users that is not extremely sensitive information or information legally considered personal data. If you wish to opt out of having your information transferred to our non-agent partners, you may email us at email@example.com . Please include the word "privacy" in the subject line of the email and all of your registration information in the body of the email.
We may share or otherwise use aggregated information that does not include personal information and may otherwise disclose non-identifying information and registration data with third parties for industry analysis, demographic profiling, and other purposes. Any aggregate information shared in these contexts will not contain your Personal Information.
Some contents of QALEON are "sponsored by" or "presented by" other companies. QALEON shares market research data (how the sponsorship was carried out, names of winners of competitions, etc.) collected on this website or through email surveys with these partners. This information is aggregated and not linked to specific users.
QALEON reserves the right to disclose Personal Information from the private and public areas of this website at our discretion, if required by law or if we are given reason to believe, in our sole discretion, that such disclosure is necessary to avoid harm to our Platform or our Users or to protect the rights of our Users, the general public, or QALEON, to comply with a judicial proceeding, court order or legal process.
Customer-Contractor Communication and Work Product
As part of the Platform, we may collect information and communication transferred between the Client and the Contractor, including without limitation the Work Product. Such data may include information entered, submitted or delivered by the Contractor or the Client, such as a memorandum, project and schedule details and responses to queries. QALEON may use this information for statistical analysis, product development, marketing and research. Except as stated above, we do not treat the information contained in these communications as Personal Information, but we may use such information in association with the Personal Information, and we may aggregate, analyse and evaluate such information for the same purposes as stated above with respect to other Non-Identifiable Information.
When you visit the Site, either as a registered user or as an unregistered user who only browses the Site (a "User"), our servers automatically record information that your browser sends whenever you visit a website ("Registration Data"). This Log Data may include information such as the Internet Protocol ("IP") address of your computer, the type of browser, the version of browser software or the web page you were visiting before coming to our Site, pages on our Site that you visit, the time spent on those pages, information you search on our Site, times and dates of access and other statistics. In addition, we may use third party services, such as Google Analytics, which collect, monitor and analyse this type of information to increase the functionality and user-friendliness of our Site, to better tailor our Site to the needs of our visitors and to detect suspicious activity. These third-party service providers have their own privacy policies that address how they use such information. We do not treat registration data as personal information, but we may use it in association with personal information, and we may aggregate, analyse and evaluate such registration data for the same purposes as stated above with respect to other non-identifiable information.
Although QALEON takes security and privacy very seriously, QALEON is not a HIPAA business partner and the QALEON platform is not HIPAA compliant and should not be used to store any protected health information ("PHI") or any specially protected personal information. You agree that you will not upload or store any documents containing PHI. Doing so would be a violation of our Terms of Service.
Identity theft and the practice currently known as "phishing" are of great concern to QALEON. Safeguarding information to help protect against identity theft is a priority. We do not and will not at any time request your credit card information, account ID, password or national identification numbers in an unsecured or unsolicited email or phone communication. We suggest that you are advised not to respond and to promptly report any e-mail or telephone communication purporting to be from QALEON in which such information is collected.
If you choose to use the Platform as a Contractor, you will be able to create a profile, which will be publicly visible through the Platform. Such profile information may include, but is not limited to, profile picture, name, location, information about previous work done through the Platform and outside the Platform, skills, tests performed, hourly/weekly/monthly pay rates and feedback/classification information. You can edit your Contractor profile through your account.
If you choose to publish a job list through the Platform as a Customer, the content of that job list will be visible through the Platform. Job listings can include information such as budget, location, history of the Client's job listing, Client comments and qualification information and the time of completion of the job. If you decide to apply for a job as a Contractor through the Platform, we will share with the relevant Client the information related to your application, including, but not limited to, the information contained in your Client profile.
We collect users' comments on their experience with other users of the Platform. Please note that any user comments provided through the Platform will be publicly visible through the Platform.
Law enforcement and compliance
QALEON cooperates with government, law enforcement and private entities to enforce the law. We will disclose information to administrative or judicial law enforcement authorities or legally authorized private entities as deemed necessary or appropriate, in QALEON's discretion, to respond to claims and legal process (including, but not limited to subpoenas), to protect the property and rights of QALEON or a third party, to protect public safety or the safety of any person, or to prevent or stop activity that may be deemed to be, or that poses a risk of being, illegal, unethical or legally reprehensible activity.
Modification or elimination of your data
All registered users may review, update, correct or delete personal information in their registration profile by contacting us or making modifications through their accounts. If you completely delete all such information, your account may be deactivated. If you would like us to delete your account in our system, please contact us at firstname.lastname@example.org . If you have a Contractor or Client profile on the Platform, you can update the information stored in your profile by logging into your account. We will use commercially reasonable efforts to comply with your request; however, your personal information may remain on file with us. We may retain an archived copy of your records as required by law or for the proper performance of QALEON's legal, contractual, tax or business obligations or responsibilities. Please note that neither you nor QALEON can delete all copies of information that has been previously shared with others on the Site.
QALEON is very concerned about safeguarding your personal information. The security of such personal information is important to us. But remember that no method of transmission over the Internet, or method of electronic storage, is 100% secure. When you enter sensitive information (such as credit card number or social security number) on our registration or order forms, we encrypt that information using secure socket layer technology (SSL). In some cases, we also encrypt sensitive information when it is stored on our systems. When the Platform is used to share the Work Product and Personal Information, that Work Product and Personal Information will be made available to Users with whom you agree to share that information. These Users, and not QALEON, will be responsible for the privacy and security of their Work Product and Personal Information in accordance with the terms of any agreement, including, without limitation, any non-disclosure agreement entered into with these other Users.
The Personal Information will be treated in accordance with the appropriate levels of security, as considered by the current laws on the protection of Personal Data, by implementing the relevant security measures, whether technical or organisational, to avoid its modification, alteration, loss and unauthorised access or treatment, considering the state of the art, complying with the obligation of secrecy that guarantees the confidentiality of such Data.
Links to other sites
Our site contains links to other websites. If you choose to click on a link from a third party, you will be directed to that third party's website. The fact that we link to a website is not an endorsement, authorization, or representation of our affiliation with that third party, nor is it an endorsement of their privacy or information security policies or practices. We do not exercise control over third party websites. These other websites may place their own cookies or other files on your computer, collect data or solicit personal information from you. Other sites follow different rules regarding the use or disclosure of Personal Information you submit to them. We encourage you to read the privacy policies or statements of the other websites you visit.
This site is not directed to persons under the age of 18. We do not knowingly collect personally identifiable information from children under the age of 16. If a parent or guardian becomes aware that their child has provided us with personal information without their consent, they should contact us at email@example.com . If we become aware that a child under the age of 16 has provided us with personal information, we will request the consent of the parent, guardian or legal representative; otherwise, we will use commercially reasonable efforts to delete such information from our files.
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