Privacy Policy
Mission
WorkinEU’s mission is to connect Asian candidates with employer from Europe and, especially from Romania. In order to do that we need access to personal data of Asian citizens which must be collected and accessed by Employer’s HR specialists.
Central
to this access is
our commitment to be transparent about the data we collect, how it is used and
with whom it is shared. Please
be aware that your data will be collected and used in compliance with the
highest protection standards, European Standards. Data protection in the EU -
European Commission (europa.eu)
How does it works
This Privacy
Policy applies when you use our Services
We offer our users choices about the data
we collect, use and share as described in this Privacy Policy, Cookie
Policy, Settings
and our Help
Center.
Our registered
users (“Members”) share their professional identities . Content and data on
some of our Services is viewable to non-members (“Visitors”).
This Privacy
Policy applies to WorkinEU.now and other WorkinEU - related
sites, apps, communications and services (“Services”), including off-site
Services, such as our ad services
Data Controllers and Contracting Parties
WorkinEU will
be the controller of your personal data provided to, or collected by or for, or
processed in connection with our Services.
As a Visitor or
Member of our Services, the collection, use and sharing of your personal data
is subject to this Privacy Policy and other documents referenced in this
Privacy Policy, as well as updates.
WorkinEU (“we” or “us”)
can modify this Privacy Policy, and if we make material changes to it, we will
provide notice through our Services, or by other means, to provide you the
opportunity to review the changes before they become effective. If you object
to any changes, you may close your account.
You acknowledge that your continued use of our Services after we publish or send a notice about our changes to this Privacy Policy means that the collection, use and sharing of your personal data is subject to the updated Privacy Policy, as of its effective date.
1. Data We Collect
1.1. Data You Provide To Us
Registration
To create an
account you need to provide data including your name, email address and/or
mobile number, and a password. If you register for a premium Service, you will
need to provide payment (e.g., credit card) and billing information.
Profile
You have choices
about
the information on your profile, such as your education, work experience,
skills, photo, city
or area and
endorsements. You don’t have to provide additional information on your profile;
however, profile information helps you to get more from our Services, including
helping recruiters and business opportunities find you. It’s your choice
whether to include sensitive information on your profile
and to make that sensitive information public. Please do not post or add
personal data to your profile that you would not want to be publicly available.
Posting and Uploading
We collect
personal data from you when you provide, post or upload it to our Services,
such as when you fill out a form, respond to a survey, or submit a resume or
fill out a job application on our Services. If you opt to import your address
book, we receive your contacts (including contact information your service
provider(s) or app automatically added to your address book when you
communicated with addresses or numbers not already in your list).
If you sync your
contacts or calendars with our Services, we will collect your address book and
calendar meeting information to keep growing your network by suggesting
connections for you and others, and by providing information about events, e.g.
times, places, attendees and contacts.
You don’t have
to post or upload personal data; though if you don’t, it may limit your ability
to grow and engage with your network over our Services.
1.2. Data From Others
Partners
We receive
personal data (e.g., your job title and work email address) about you when you
use the services of our customers and partners, such as employers or
prospective employers and applicant tracking systems providing us job
application data.
Related Companies and Other Services
We receive data about you when you use some of the other services provided by
us or our affiliates, including
Microsoft. For example, you may choose to send us information about your
contacts in Microsoft apps and services, such as Outlook, for improved
professional networking activities on our Services
1.3. Service Use
We log usage
data when you visit or otherwise use our Services, including our sites, app and
platform technology, such as when you view or click on content (e.g., learning
video) or ads (on or off our sites and apps), perform a search, install or
update one of our mobile apps, share articles or apply for jobs. We use
log-ins, cookies, device information and internet
protocol (“IP”) addresses to identify you and log your use.
1.4. Cookies and Similar Technologies
As further
described in our Cookie
Policy,
we use cookies and similar technologies (e.g., pixels and ad tags) to collect
data (e.g., device IDs) to recognize you and your device(s) on, off and across
different services and devices where you have engaged with our Services. We
also allow some others to use cookies as described in our Cookie Policy.
1.5. Your Device and
Location
When you visit
or leave our Services (including some plugins and our cookies or similar
technology on the sites of others), we receive the URL of both the site you
came from and the one you go to and the time of your visit. We also get
information about your network and device (e.g., IP address, proxy server,
operating system, web browser and add-ons, device identifier and features,
cookie IDs and/or ISP, or your mobile carrier). If you use our Services from a
mobile device, that device will send us data about your location based on your
phone settings. We will ask you to opt-in before we use GPS or
other tools to identify your precise location.
1.6. Messages
We collect
information about you when you send, receive, or engage with messages in
connection with our Services. For example, if you get a WorkinEU connection
request, we track whether you have acted on it and will send you reminders. We
also use automatic
scanning technology
on messages to support and protect our site. For example, we use this
technology to suggest possible responses to messages and to manage or block
content that violates our User Agreement.
1.7.
Sites and Services of Others
We receive
information about your visits and interaction with services provided by others
when you log-in with WorkinEU or visit others’ services or our ads, cookies or similar technologies.
1.8.
Other
Our Services are
dynamic, and we often introduce new features, which may require the collection
of new information. If we collect materially different personal data or
materially change how we collect, use or share your data, we will notify you
and may also modify this Privacy Policy.
2. How We Use
Your Data
How
we use your personal data will depend on which Services you use, how you use
those Services and the choices you make in your settings. We use the
data that we have about you to provide and personalize our Services, including
with the help of automated systems and inferences we make, so that our Services
(including ads) can be more relevant and useful to you and others.
2.1. Services
We use your data
to authorize access to our Services and honor your settings.
We use data about you (such as your profile, profiles you have viewed or data
provided through address book uploads or partner integrations) to help others
find your profile, suggest connections for you and others (e.g. Members who
share your contacts or job experiences) and enable you to invite others to
become a Member and connect with you. You can also opt-in to allow us to use
your precise location or proximity to others for certain tasks (e.g. to suggest
other nearby Members for you to connect with, calculate the commute
to a new job, or notify your connections that you are at a professional event).
It is your choice whether to invite someone to our Services, send a connection
request, or allow another Member to become your connection. When you invite
someone to connect with you, your invitation will include your network and
basic profile information (e.g., name, profile photo, job title, region). We
will send invitation reminders to the person you invited. You can choose
whether
or not to share your own list of connections with your connections.
Visitors have choices
about
how we use their data.
Stay Informed
Our Services allow you to stay informed about new
ads,
events and ideas regarding professional topics you care about, and from
professionals you respect. Our Services also allow you to improve your
professional skills, or learn new ones. We use the data we have about you
(e.g., data you provide, data we collect from your engagement with our Services
and inferences we make from the data we have about you), to personalize our
Services for you, such as by recommending or ranking relevant content and
conversations on our Services. We also use the data we have about you to
suggest skills you could add to your profile and skills that you might need to
pursue your next opportunity. So, if you let us know that you are interested in
a new skill (e.g., by watching a learning video), we will use this information
to personalize content in your feed, suggest that you follow certain members on
our site, or suggest related learning content to help you towards that new
skill. We use your content, activity and other data, including your name and
photo, to provide notices to your network and others. For example, subject to
your settings, we may notify
others that you have updated your profile, posted content, took a social
action,
used a feature, made new connections or were mentioned
in the news.
Career
Our Services allow you to explore careers, evaluate educational opportunities, and seek out, and be found for, career opportunities. Your profile can be found by those looking to hire (for a job or a specific task) or be hired by you. We will use your data to recommend jobs or mentees, show you and others relevant professional contacts (e.g., who work at a company, in an industry, function or location or have certain skills and connections). You can signal that you are interested in changing jobs and share information with recruiters. We will use your data to recommend jobs to you and you to recruiters. We may use automated systems to provide content and recommendations to help make our Services more relevant to our Members, Visitors and customers. Keeping your profile accurate and up-to-date may help you better connect to others and to opportunities through our Services.
2.2. Premium Services
We sell premium Services that provide our customers and subscribers with customized-search functionality and tools (including messaging and activity alerts) as part of our talent, marketing and sales solutions. Customers can export limited information from your profile, such as name, headline, current company, current title, and general location (e.g., Dublin), such as to manage sales leads or talent, unless you opt-out. We do not provide contact information to customers as part of these premium Services without your consent. Premium Services customers can store information they have about you in our premium Services, such as a resume or contact information or sales history. The data stored about you by these customers is subject to the policies of those customers.
2.3. Communications
We will contact you through email, mobile phone, notices posted on our websites or apps, messages to your WorkinEU inbox, and other ways through our Services, including text messages and push notifications. We will send you messages about the availability of our Services, security, or other service-related issues. We also send messages about how to use our Services, network updates, reminders, job suggestions and promotional messages from us and our partners. You may change your communication preferences at any time. Please be aware that you cannot opt out of receiving service messages from us, including security and legal notices.
We also enable communications between you and others through our Services, including for example e-mail , groups and messages between connections.
2.4. Advertising
We target (and
measure the performance of) ads to Members, Visitors and others both on and off
our Services directly or through a variety of partners, using the
following data, whether separately or combined:
·
Data
from advertising technologies on and off our Services, pixels, ad tags,
cookies, and device identifiers;
·
Member-provided
information (e.g., profile, contact information, title and industry);
·
Data
from your use of our Services (e.g., search history, feed, content you read,
who you follow or is following you, connections,groups participation,
page visits, videos you watch, clicking on an ad, etc.), including as described
in Section 1.3;
·
Information
from advertising partners , vendors and publishers; and
·
Information
inferred from data described above (e.g., using job titles from a profile to
infer industry, seniority, and compensation bracket; using graduation dates to
infer age or using first names or pronoun usage to infer gender; using your
feed activity to infer your interests; or using device data to recognize you as
a Member).
We will show you ads called sponsored content which look similar to
non-sponsored content, except that they are labeled as advertising (e.g., as
“ad” or “sponsored”). If you take a social action (such as like, comment or
share) on these ads, your action is associated with your name and viewable by others,
including the advertiser. Subject to your settings if you take a social action on the WorkinEU Services, that action may be mentioned with related
ads. For example, when you like a company we may include your name and photo
when their sponsored content is shown.
Ad Choices
We adhere to self-regulatory principles for interest-based
advertising and participate in industry opt-out from
such ads. This does not opt you out of receiving advertising; you will continue
to get other ads by advertisers not listed with these self regulatory tools.
You can also opt out specifically
from our uses of certain categories of data to show you more relevant ads.
Info to Ad Providers
We do not share your personal data with any third-party advertisers or ad
networks except for: (i) hashed IDs or device identifiers (to the extent they
are personal data in some countries); (ii) with your separate permission (e.g.,
in a lead generation form) or (iii) data already visible to any users of the
Services (e.g., profile). However, if you view or click on an ad on or off our
Services, the ad provider will get a signal that someone visited the page that
displayed the ad, and they may, through the use of mechanisms such as cookies,
determine it is you. Advertising partners can associate personal data collected
by the advertiser directly from you with hashed IDs or device identifiers
received from us. In such instances, we seek to contractually require such
advertising partners to obtain your explicit, opt-in consent before doing so.
2.5. Marketing
In addition to
advertising our Services, we use Members’ data and content for invitations and
communications promoting membership and network growth, engagement and our
Services, such as by showing your connections that you have used a feature on
our Services.
2.6. Developing Services and Research
Service Development
We use data, including public feedback, to conduct research
and
development for our Services in order to provide you and others with a better,
more intuitive and personalized experience, drive membership growth and
engagement on our Services, and help connect professionals to each other and to
economic opportunity.
Other Research
We seek to
create economic opportunity for Members of the global workforce and to help
them be more productive and successful. We use the personal data available to
us to research social, economic and workplace trends, such as jobs availability
and skills needed for these jobs and
policies that help bridge the gap in various industries and geographic areas.
In some cases, we work with trusted third parties to perform this research,
under controls that
are designed to protect your privacy. We publish or allow others to publish
economic insights, presented as aggregated data rather than personal data.
Surveys
Polls and surveys are conducted by us and others through our Services. You are
not obligated to respond to polls or surveys, and you have choices about the
information you provide. You may opt-out of
survey invitations.
2.7. Customer Support
We use data to
help you and fix problems.
We use data
(which can include your communications) to investigate, respond to and resolve
complaints and for Service issues (e.g., bugs).
2.8. Insights That Do Not
Identify You
We use data to
generate insights that do not identify you.
We use your personal
data to
produce and share insights that do not identify you. For example, we may use
your data to generate statistics about our members, their profession
or industry, to calculate ad impressions served or clicked on, or to publish
visitor demographics for a Service or create demographic workforce insights.
2.9. Security and Investigations
We use your data (including your communications) for security purposes or to prevent or investigate possible fraud or other violations of our User Agreement and/or attempts to harm our Members, Visitors or others.
3. How We Share
Information
3.1. Our Services
Any data that
you include on your profile and any content you post or social action (e.g.,
likes, follows, comments, shares) you take on our Services will be seen by
others, consistent with your settings.
Profile
Your profile is fully visible to all Members and customers of our Services.
Subject to your settings, it can also be visible to others on or
off of our Services (e.g., Visitors to our Services or users of third- party
search engines). Your
settings, degree of connection with the viewing Member, the subscriptions they
may have, their Usage
of Services,
access channels and search types (e.g., by name or by keyword) impact the
availability of your profile and whether they can view certain fields in your
profile.
Follows,
Comments, Messages
Our Services allow viewing and sharing information including through posts,
likes, follows and comments.
·
Any
information you share through companies’ or other organizations’ pages on our
Services will be viewable by it and others who visit those pages.
·
When
you follow a person or organization, you are visible to others and that “page
owner” as a follower.
·
We
let senders know when you act on their message,where applicable.
·
We
let a Member know when you view their profile.
·
When
you like or re-share or comment on another’s content (including ads), others
will be able to view these “social actions” and associate it with you (e.g.,
your name, profile and photo if you provided it).
·
Your
employer can see how you use Services they provided for your work (e.g. as a
recruiter or sales agent) and related information. We will not show them your
job searches or personal messages.
Enterprise Accounts
Your employer may offer you access to our enterprise Services such as
Recruiter,. Your employer can review and manage your use of such enterprise
Services.
Depending on the enterprise Service, before you use such Service, we will ask
for permission to share with your employer relevant data from your profile or
use of our non-enterprise Services. For example, users of Sales
Navigator will be asked to share their “social selling index”, a score
calculated in part based on their personal account activity. We understand that
certain activities such as job hunting and personal messages are sensitive, and
so we do not share those with your employer unless you choose to share it with
them through our Services (for example, by applying for a new position in the
same company or mentioning your job hunting in a message to a co-worker through
our Services).
Subject to your setting when
you use workplace tools and services (e.g., interactive employee directory
tools) certain of your data may also be made available to your employer or be
connected with information we receive from your employer to enable these tools
and services.
3.2. Communication Archival
Regulated
Members may need to store communications outside of our Service.
Some Members (or
their employers) need, for legal or professional compliance, to archive their
communications and social media activity, and will use services of others to
provide these archival services. We enable archiving of messages by and to
those Members outside of our Services. For example, a financial advisor needs
to archive communications with her clients through our Services in order to
maintain her professional financial advisor license.
3.3. Others’ Services
You may link
your account with others’ services so that they can look up your contacts’
profiles, post your shares on such platforms, or enable you to start
conversations with your connections on such platforms. Excerpts from your
profile will also appear on the services of others.
Other services
may look up your profile. When you opt to link your account with other
services, personal data will become available to them. The sharing and use of
that personal data will be described in, or linked to, a consent screen when
you opt to link the accounts. For example, you may link your Twitter or WeChat
account to share content from our Services into these other services, or your
email provider may give you the option to upload your WorkinEU contacts
into its own service. Third-party services have their own privacy policies, and
you may be giving them permission to use your data in ways we would not. You
may revoke the
link with such accounts.
Subject to your setting,
excerpts from your profile will
appear on the services of others (e.g., search engine results, mail and
calendar applications that show a user limited profile data of the person they
are meeting or messaging, social media aggregators, talent and lead
managers). “Old” profile information remains on these services until they
update their data cache with changes you made to your profile.
3.4. Related Services
We share your
data across our different Services and WorkinEU affiliated entities.
We will share
your personal data with our affiliates to provide and develop our Services. We
may combine information internally across the different Services covered by
this Privacy Policy to help our Services be more relevant and useful to you and
others. For example, we may personalize your feed or job recommendations based
on your learning history.
3.5. Service Providers
We may use
others to help us with our Services.
We use others to
help us provide our Services (e.g., maintenance, analysis, audit, payments,
fraud detection, marketing and development). They will have access to your
information as reasonably necessary to perform these tasks on our behalf and
are obligated not to disclose or use it for other purposes.
3.6. Legal Disclosures
We may need to
share your data when we believe it’s required by law or to help protect the
rights and safety of you, us or others.
It is possible
that we will need to disclose information about you when required by law,
subpoena, or other legal process or if we have a good faith belief that
disclosure is reasonably necessary to (1) investigate, prevent or take action
regarding suspected or actual illegal activities or to assist government
enforcement agencies; (2) enforce our agreements with you; (3) investigate and
defend ourselves against any third-party claims or allegations; (4) protect the
security or integrity of our Services (such as by sharing with companies facing
similar threats); or (5) exercise or protect the rights and safety of WorkinEU, our Members, personnel or others. We attempt to notify Members
about legal demands for their personal data when appropriate in our judgment,
unless prohibited by law or court order or when the request is an emergency. We
may dispute such demands when we believe, in our discretion, that the requests
are overbroad, vague or lack proper authority, but we do not promise to
challenge every demand.
3.7. Change in Control or Sale
We may share
your data when our business is sold to others, but it must continue to be used
in accordance with this Privacy Policy.
We
can also share your personal data as part of a sale, merger or change in
control, or in preparation for any of these events. Any other entity which buys
us or part of our business will have the right to continue to use your data,
but only in the manner set out in this Privacy Policy unless you agree
otherwise.
4. Your Choices &
Obligations
We keep most of your personal data for as long as your account is open.
We generally
retain your personal data as long as you keep your account open or as needed to
provide you Services. This includes data you or others provided to us and data
generated or inferred from your use of our Services. Even if you only use our
Services when looking for a new job every few years, we will retain your
information and keep your profile open, unless you close your account. In some
cases we choose to retain certain information (e.g., insights about Services
use) in a depersonalized or aggregated form.
4.1. Rights to Access and Control Your Personal Data
You can access
or delete your personal data. You have many choices about how your data is
collected, used and shared.
We provide many choices
about
the collection, use and sharing of your data, from deleting or correcting data
you include in you profile and
controlling the visibility of your posts to
advertising opt-outs and communication controls. We offer you
settings to
control and manage the personal data we have about you.
For personal data that we have about you, you can:
·
Delete
Data: You can ask us to erase or delete all or some of your personal data
(e.g., if it is no longer necessary to provide Services to you).
·
Change
or Correct Data: You can edit some of your personal data through your account.
You can also ask us to change, update or fix your data in certain cases,
particularly if it’s inaccurate.
·
Object
to, or Limit or Restrict, Use of Data: You can ask us to stop using all or
some of your personal data (e.g., if we have no legal right to keep using it)
or to limit our use of it (e.g., if your personal data is inaccurate or
unlawfully held).
· Right to Access and/or Take Your Data: You can ask us for a copy of your personal data and can ask for a copy of personal data you provided in machine readable form.
4.2 Account Closure
We keep some of
your data even after you close your account.
If you choose to
close your WorkinEU account,
your personal data will generally stop being visible to others on our Services
within 24 hours. We generally delete closed account information within 30 days
of account closure, except as noted below.
We retain your personal data even after you have closed your account if
reasonably necessary to comply with our legal obligations (including law
enforcement requests), meet regulatory requirements, resolve disputes, maintain
security, prevent fraud and abuse , enforce our User Agreement, or fulfill your
request to "unsubscribe" from further messages from us. We will
retain de-personalized information after your account has been closed.
1. Information you
have shared with others (e.g., through InMail, updates or group posts) will
remain visible after you close your account or delete the information from your
own profile or mailbox, and we do not control data that other Members have
copied out of our Services. Groups content and ratings or review content
associated with closed accounts will show an unknown user as the source. Your
profile may continue to be displayed in the services of others (e.g., search
engine results) until they refresh their cache.
5. Other
Important Information
5.1. Security
We monitor for
and try to prevent security breaches. Please use the security features
available through our Services.
We implement
security safeguards designed to protect your data, such as HTTPS. We regularly
monitor our systems for possible vulnerabilities and attacks. However, we
cannot warrant the security of any information that you send us. There is no
guarantee that data may not be accessed, disclosed, altered, or destroyed by
breach of any of our physical, technical, or managerial safeguards.
5.2. Cross-Border Data Transfers
We store and use
your data outside your country.
We process data
both inside and outside of the European Union and rely on legally-provided mechanisms to
lawfully transfer data across borders. Countries where we process data may have
laws which are different from, and potentially not as protective as, the laws
of your own country.
5.3 Lawful Bases for Processing
We have lawful
bases to collect, use and share data about you. You have choices about our use
of your data. At any time, you can withdraw consent you have provided by going
to settings.
We will only
collect and process personal data about you where we have lawful bases. Lawful
bases include consent(where you have given consent), contract (where
processing is necessary for the performance of a contract with you (e.g., to
deliver the WorkinEU Services you have requested) and “legitimate
interests.”.
Where we rely on your consent to process
personal data, you have the right to withdraw or decline your consent at any
time and where we rely on legitimate interests, you have the right to object.
If you have any questions about the lawful bases upon which we collect and use
your personal data, please contact our Data Protection Office (DPO)
5.4. Direct Marketing and Do Not Track Signals
Our statements
regarding direct marketing and “do not track” signals.
We currently do
not share personal data with third parties for their direct marketing purposes
without your permission. about this and about our response to “do not track”
signals.
5.5. Contact Information
You can contact
us or use other options to resolve any complaints.
If you have
questions or complaints regarding this Policy, please first contact WorkinEU online.
You can also reach us by physical mail. If contacting us does not resolve your
complaint, you have more options.