GINJOB Privacy and Data Protection Policy
Last updated: 22.04.2019
When you use GINJOB Services, you trust us with your information. We are committed to keeping that trust, so we have prepared this Privacy and Data Protection Policy (“Policy”) to explain how we collect, use and share your personal data.
This Policy details the personal data we receive about you, how we process it and your rights and obligations in relation to your personal data. Private entrepreneur Khromyy Nazar GinJoB (including its subsidiaries, affiliates, agents, and assigns) (“GINJOB”, “we”, “us”, “our”) is a data controller for the purposes of the General Data Protection Regulation and any relevant local legislation (“Data Protection Laws”).
YOU ARE REQUIRED TO READ THIS POLICY TO UNDERSTAND HOW WE COLLECT AND PROCESS YOUR PERSONAL DATA AND WHAT SECURITY MEASURES ARE BEING APPLIED. By using or accessing our application, you agree to the terms of this Policy. YOU SHOULD PRINT A COPY OF THIS Policy FOR YOUR RECORDS.
Capitalized terms not defined here have the meanings set forth in the Terms of Service, so we recommend that you read this along with our Terms of Service.
This Policy explains:
- what information we collect and why we collect it;
- how we use that information;
- the choices we offer you to protect your privacy and the rights you have, including how you can access and update your information;
- how to contact us if you have questions or concerns.
- Principles Relating to the Processing of Personal Data.
We process your personal data in accordance with the fundamental principles stated in the relevant Data Protection Laws. These are as follows:
- lawfulness, fairness and transparency – personal data shall be processed lawfully, fairly and in a transparent manner in relation to you;
- purpose limitation – personal data shall be collected for specified, explicit and legitimate purposes and not further processed in a manner that is incompatible with those purposes;
- data minimisation – personal data shall be adequate, relevant and limited to what is necessary for relation to the purposes for which they are processed;
- accuracy – personal data shall be accurate and, where necessary kept up to date; every reasonable step must be taken to ensure that personal data that is inaccurate, having regard to the purposes for which they are processed are erased or rectified without delay;
- storage limitation – personal data shall be kept in a form which permits identification of data subjects for no longer than is necessary for the purposes for which the personal data are processed; personal data may be stored for longer periods insofar as the personal data will be processed solely for achieving purposes in the public interest, scientific or historical research purposes or statistical purposes subject to implementation of the appropriate technical and organisational measures required by the Data Protection Laws in order to safeguard the rights and freedoms of the data subject;
- integrity and confidentiality – personal data shall be processed 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, using appropriate technical or organisational measures;
- accountability – controller shall be responsible for, and be able to demonstrate compliance with all of these principles both in the processing it currently carries out and as part of the introduction of new methods of processing.
- Personal Data We Collect.
The following information is collected by or on behalf of us:
|Information that you provide to us, such as when you create your account
||· login name
· phone number
|Information that you may provide to us, such as when you use GINJOB Services
||· your location information
· financial transactions details related to your use of GINJOB Services, including your payment details (except the transaction details referred to the subscription fees as stated in Section 4 of this Policy)
· information regarding Tasks including the number and specification of Tasks, date and time they were posted and carried out
· device ID
· information that you submit when you contact our customer support, rate experience or leave feedback about other users, or otherwise contact us
Processing of your personal data does not provide for automated decision-making, including profiling, which produces legal effects concerning you or similarly significantly affects you.
- Personal Data We DO NOT Collect.
When you purchase a subscription you may be asked by third parties to provide additional information in order to pay fees for greater number of the GINJOB Services. We do not collect such information and do not control, supervise or respond for the processing of such information. Any request regarding such personal data should be directed to such third parties.
We do not collect and process the personal data revealing racial or ethnic origin, political opinions, religious or philosophical beliefs, or trade union membership, and the processing of genetic data, biometric data, data concerning health or data concerning a natural person's sex life or sexual orientation.
- Purposes of Processing.
We use the personal data we collect for purposes including:
||Purposes of Processing
|· login name
· phone number
||· create and maintain your account
· assist you when you contact our customer support services or otherwise contact us
|· location information
· financial transaction details related to your use of GINJOB Services, including your payment details (except the transaction details referred to the subscription fees as stated in Section 4 of this Policy)
· device ID
· information regarding Tasks including the number and specification of Tasks, date and time they were posted and carried out
||· enable features that allow you to post, see available or offer to perform Tasks
· track the progress of Tasks
· enable features that allow you to rate experience or leave feedback about other users
· investigate or address claims or disputes relating to your use of GINJOB Services
· sharing your information with law enforcement and other government authorities as necessary to enforce official inquiries
|· information that you submit when you contact our customer support, rate experience or leave feedback about other users, or otherwise contact us
||· assist you when you contact our customer support services or otherwise contact us
We may process data for any other purposes disclosed to you in connection with the GINJOB Services from time to time. If we intend to process your personal data for a purpose other than set out above and which is not compatible with the original processing purpose, we will provide you with relevant information prior to such processing and will obtain your consent where necessary.
- Grounds of Processing.
Data Protection Laws require that companies processing the personal data do so on the basis of specific legal grounds. As described below, we process the personal data based on the following grounds.
6.1. Explicit Consent.
We collect and use your personal data on the basis of your explicit consent. You may withdraw your consent at any time in accordance with Section 10 of this Policy. If you withdraw your consent, you will not be able to use any GINJOB Services or features that requires collection or use of the information we collected or used on the basis of consent.
We are located in Ukraine that does not ensure an adequate level of protection for the personal data as determined by the European Commission. However, we shall implement appropriate technical and organisational measures to ensure an adequate level of security of your personal data in accordance with Data Protection Laws. The main enforceable rights and effective remedies set out in Data Protection Laws are available for you.
We obtain explicit consent from you by offering an explicit consent screen that contains the sign “I, hereby, consent to the processing of my data” and “Yes” and “No” check boxes.
The following types of data are processed on the basis of your explicit consent:
6.2. The processing is necessary to provide the GINJOB Services and features you request in accordance with this Policy.
- location information;
- device ID.
We must collect and use certain information in order to provide GINJOB Services and features you request under the agreement between you and us (Terms of Service). This includes:
- login name;
- phone number;
- financial transaction details related to your use of GINJOB Services, including your payment details (except the transaction details referred to the subscription fees as stated in Section 4 of this Policy);
- information regarding Tasks including the number and specification of Tasks, date and time they were posted and carried out;
- information that you submit when you contact our customer support, rate experience or leave feedback about other users, or otherwise contact us.
Collection and processing of this information is obligatory for using our Application. We cannot provide you with GINJOB Services or other features under the agreement between you and us without processing of such data.
6.3. The processing is necessary to protect the vital interests of our users or of others.
We may process personal data, including disclosing data with law enforcement authorities in case of threats to the safety of users or of others.
6.4. The processing is necessary for the establishment, exercise or defense of legal claims.
We collect and use personal data to the extent necessary for the establishment, exercise or defense of legal claims. This includes collecting and using information to:
- investigate or address claims or disputes relating to your use of GINJOB Services;
- sharing your information with law enforcement officials, government authorities as necessary to enforce official inquiries.
- Your Age.
We provide the GINJOB Services intended for use by people age 18 and over. By using or accessing Application, you acknowledge that you are 18 years old and have all rights necessary to provide us with the explicit consent for the processing of your personal data. We shall not be liable for any consequences if it becomes clear that you have not reached the age of 18 at the moment of the consent is being provided.
If you know that we process data of individuals under 18 years old, please inform us of it by sending email to: email@example.com
- Period of Storage.
We require information about you in order to provide GINJOB Services, and retains such information for 30 days, based on when you were last active in your account.
After the end of the storage period, we are obliged to delete your personal data or ask you to provide us with a new or an additional consent, if the necessity of processing remains actual for us or another purpose of processing appears. We may keep storing the personal data if subsequent processing is foreseen by law and is deemed relevant for a purpose which is not compatible with the original purpose of processing stated in this Policy.
9.1. Your rights.
- Data Subject Rights.
You have the following rights:
9.2. Exercising your rights.
- right to be informed – the right to information on data is being collected, how it is being used, how long it will be kept and whether it will be shared with any third parties. This information must be provided concisely and in plain language;
- right of access – the right to ask us for copies of your personal data;
- right to rectification – the right to ask us to rectify information you think is inaccurate. You also have the right to ask us to complete information you think is incomplete;
- right to erasure – the right to ask us to erase your personal data in certain circumstances stated in the Data Protection Laws;
- right to restriction of processing – the right to ask us to restrict the processing of your personal data in certain circumstances stated in the Data Protection Laws;
- right to object to processing – the right to object to the processing of your personal data in certain circumstances stated in the Data Protection Laws;
- right to data portability – the right to ask that we transfer the information you gave us to another organisation, or to you, in certain circumstances stated in the Data Protection Laws;
- right to not be subject to automated decision making and profiling – the right to object to any automated profiling that is occurring without consent. You have the right to obtain human intervention on the part of the controller.
You can exercise any of the rights described above by sending a request to the email address: firstname.lastname@example.org . Your request must include your name, contact information, right that you want to exercise, personal data processed by us, details and reason/justification for such request.
Each of your rights is supported by appropriate procedures that allow the required action to be taken within the timescales stated below.
|The right to be informed
||When data if collected
|The right of access
|The right to rectification
|The right to erasure
||Without undue delay
|The right to restrict processing
||Without undue delay
|The right to date portability
|The right to object
||On receipt of objection
|The right to not be subject to automated decision making and profiling
- Withdrawal of Consent.
You are entitled to withdraw consent at any time you wish, without affecting the lawfulness of processing based on consent before the withdrawal.
You may exercise the right to withdraw consent by sending a request to the email address: email@example.com . The request for withdrawal of consent shall be verified within 72 hours since the respective request was received. We shall inform you of the progress and the outcome of the request.
- Complaint Lodgement.
You have the right to lodge a complaint with us if you consider that the processing of your personal data infringes the applicable Data Protection Laws.
You may exercise the right to lodge a complaint by sending a complaint to the email address: firstname.lastname@example.org. The complaint shall be verified within 72 hours since the respective complaint was received. We shall inform you of the progress and the outcome of the complaint.
- Managing Your Account.
You remain in control of the information you provide to us. You may request deletion of your account in accordance with the Terms of Service. Following such request, we delete the information that it is not required to retain. In certain circumstances, we may be unable to delete your account, such as if there is an unresolved claim or dispute. Upon resolution of the issue preventing deletion, we will delete your account as described above.
If we ban your account because of unsafe behavior or unlawful activities, we may retain certain information about your account to prevent you from opening a new account in the future.
The security of personal data is important to us and we take all measures reasonably necessary to protect against the unauthorized access, use, alteration or destruction of personal data. These efforts include:
- the security and integrity of the Application, that includes investigating, detecting and preventing or reporting fraud, security breaches or incidents, other potentially prohibited or illegal activities or to otherwise help protect your account;
- protecting our and third parties’ rights and property and enforcing our Terms of Service or other applicable agreements or policies;
- verifying your identity. In some cases, we may need to verify your identity in order to protect the security and integrity of your account;
- complying with any relevant Data Protection Laws. This includes appropriately responding to lawful requests for information from the government or third parties through the legal process;
- contacting you to provide assistance.
We follow generally accepted industry standards to protect the personal data submitted to us, both during transmission and once we receive it. If you have any questions about security measures taken by us, you can contact us email@example.com .
If we know or have reason to know of a systems security breach by an unauthorized party of your data where that data is being or is likely to be used for an unauthorized purpose, we will promptly notify you so that you can take appropriate steps.
14.1. Share with other users.
- Data Sharing and Disclosure.
We may share your login name, average rating and feedback about you given by other users, your location and Content including information regarding the number and specification of your Tasks, date and time they were posted and carried out, with other users in order to provide GINJOB Services.
14.2. Share with processors.
In the course of processing of your personal data, we may engage processors that act only in accordance with our written instructions, contracts and any other appropriate confidentiality, security or other requirements in order to comply with the relevant Data Protection Laws. The processors are not entitled to define any additional purposes for the processing of personal data that are not specified in this Policy.
We reserve the right to transfer your personal data to the processors in accordance with the terms specified in this Policy. The transfers of personal data will be carefully reviewed prior to the transfer to ensure that they fall within the limits imposed by the relevant Data Protection Laws. We do not sell or trade your personal data to any legal or natural persons.
Your personal data may be processed by such processors to provide you with the information and support you request, including technical notices, security alerts, and other administrative messages to provide assistance for problems you may encounter with your account.
14.3. For legal reasons or in the event of a dispute.
We may share your information if it is required by applicable law, regulation, legal process or governmental request, or where the disclosure is otherwise appropriate due to safety or similar concerns.
This includes sharing your information with law enforcement officials, government authorities or other third parties as necessary to enforce our Terms of Service, or other policies, to protect our rights or property or the rights, safety or property of others, or in the event of a claim or dispute relating to your use of GINJOB Services.
14.4. With your consent.
We may share your information other than as described in this Policy if we notify you and you consent to the sharing.
- Data Breach Notification.
We comply with relevant Data Protection Laws. We take all reasonable steps to minimize the risk of the personal data breach involved by the processing of personal data.
If a personal data breach is likely to result in a risk to your rights and freedoms, the relevant supervisory authority will be informed within 72 hours.
If a personal data breach is likely to present high risks to your rights and freedoms, we are obligated to inform you of such breaches without undue delay, so that you can take appropriate steps.
- Changes to this Policy.
We reserve the right to modify this Policy at any time, so please review it frequently. If we materially change how we process your personal information, we will notify by email and/or by means of a notice in Application prior to the change becoming effective. If you disagree with these changes, you can delete your account at any time and/or stop using the Application. By using Application after such notice, you consent to our updates to this Policy.
We encourage you to periodically review this Policy for the latest information on our privacy practices.
- Contact Us.
If you have questions or wish to send us comments about this Policy, please contact us firstname.lastname@example.org or write to us:
Private entrepreneur Khromyy Nazar, urban village Pidvolochisk, lane Nadzbruchansky 8a,index 47800