Communication Policy

WEBSITE COMMUNICATION POLICY

Policy version: 29 July 2023

INTRODUCTION

This Communication Policy is provided by Freelance Magnet Limited (trading as QWIDPRO), a company registered in England and Wales under company number: 13393638 with registered office Cardiff Bay Business Centre Titan House, Lewis Road, Cardiff, United Kingdom, CF24 5BS ('we', 'our' or 'us') for use of our products and services including our website (Services).

We take your means of recieving notifications from us very seriously. These notifications include emails about our newsletter and updates on the latest jobs, and message notifications when using the application. Please read this communications policy carefully as it contains important information on how and why we collect, store, use and share any information relating to you (your personal data).

It also explains your rights in relation to what notifications you will be recieving from our platform, your personal data and how to contact us or the relevant regulator in the event you have a complaint. Our collection, storage, use and sharing of your personal data is regulated by law, including under the UK General Data Protection Regulation (UK GDPR).

We are the controller of personal data obtained via the Services, meaning we are the organisation legally responsible for deciding how and for what purposes it is used.

WHAT THIS POLICY APPLIES TO

This communication policy relates to your use of the Services only.
The Services may link to or rely on other apps, websites, APIs or services owned and operated by us or by certain trusted third parties to enable us to provide you with Services. These other apps, websites, APIs or services may also gather information about you in accordance with their own separate privacy policies. For privacy information relating to these other apps, websites or services, please consult their privacy policies as appropriate. For more information see the section 'Who we share your personal data with' below.

PERSONAL DATA WE COLLECT ABOUT YOU

The personal data we collect about you depends on the particular activities carried out through the Services. We will collect and use the following personal data about you:

Category of data	In more detail
Identify and account data you input into the Services Registration is mandatory in order to use the Services	Your name, contact numbers and email address Your account details, such as username and password Details of information uploaded by yourself on the QWIDPRO Platform Details of correspondence via phone, email, post or via communication facilities on the QWIDPRO Platform Details of any feedback you give us by phone, email, post, social media or via communication facilities in the QWIDPRO Platform
Data collected when you use specific functions in the Services	Data you store online with us using the Services including your usage history or preferences (while such data may not always be personal data as defined at law in all cases we will assume it is and treat it in accordance with this policy as if it were)
Data collected when you permit the collection of location data	Details of your location with a high degree of precision, see the section 'Location services/data' below data concerning location is collected when using the Maps function of the Services
Other data the Services collects automatically when you use it	Your activities on, and use of, the Services which reveal your preferences, interests or manner of use of the Services and the times of use device type, IMEA numbers, MAC address of networks, other unique device identification, device operating system, mobile network information, app version number, storage usage, data usage, time zone settings

If you do not provide personal data we ask for where it is required, including the geo-localisation services, it may prevent us from providing services and/or the Services to you.
We collect and use this personal data for the purposes described in the section 'How and why we use your personal data' below.

ACCEPTANCE OF TERMS

Please read these Terms and Conditions (“Agreement”) carefully before subscribing to receive updates for our latest jobs, newsletter, and notifications on our website. This agreement sets forth the legally binding terms and conditions for your use of our services. By subscribing to our updates on our latest jobs, newsletter, and notifications, you agree to be bound by this agreement.

DATA PROTECTION (GDPR)

We are committed to protecting your privacy and handling your personal data in accordance with the General Data Protection Regulation (GDPR) and other applicable data protection laws. We will only collect, store, and process your personal data for the purpose of providing you with updates on our latest jobs, notifications from our newsletter, and notifications, as well as for any other purposes disclosed to you and with your consent. Please refer to our Privacy Policy for detailed information on how we handle your personal data.

HOW YOUR PERSONAL DATA IS COLLECTED

We collect personal data from you directly when you sign up to the Services, contact us directly or reach out to us via social media, make submissions via the Services when a forum element is available, or indirectly, such as your activity while using the Services.
We do not collect any personal information about you using cookies or similar technologies. In the event that this were to change and if we were to decide to collect personal data about you using cookies, you would be notified of this change by means of in-app notification, with detailed information regarding our use of cookies and similar technologies to be made available in the relevant cookies policy.

HOW AND WHY WE USE YOUR PERSONAL DATA

Under data protection law, we can only use your personal data if we have a proper reason, e.g.:

where you have given consent
to comply with our legal and regulatory obligations
for the performance of a contract with you or to take steps at your request before entering into a contract, or
for our legitimate interests or those of a third party

A legitimate interest is when we have a business or commercial reason to use your information, so long as this is not overridden by your own rights and interests. We will carry out an assessment when relying on legitimate interests, to balance our interests against your own. You can obtain details of this assessment by contacting us (see 'How to contact us' below).
The table below explains what we use your personal data for and why.

What we use your personal data for	Our reasons
Create and manage your account with us	To perform our contract with you or to take steps at your request before entering into a contract
Providing services and/or the functionalities of the Services to you	Depending on the circumstances: to perform our contract with you or to take steps at your request before entering into a contract (in this case, the contract means the Terms and Conditions of Use which apply to the Services) the Maps Function will use data relating to your location only based on your consent as described in 'Location services/data' (above)
To enforce legal rights or defend or undertake legal proceedings	Depending on the circumstances: to comply with our legal and regulatory obligations in other cases, for our legitimate interests or those of a third party, i.e. to protect our business, interests and rights or those of others
Communications with you not related to marketing, including about changes to our terms or policies or changes to the Services or service or other important notices	Depending on the circumstances: to comply with our legal and regulatory obligations in other cases, for our legitimate interests or those of a third party, i.e., to provide the best service to you
Protect the security of systems and data	To comply with our legal and regulatory obligations we may also use your personal data to ensure the security of systems and data to a standard that goes beyond our legal obligations, and in those cases our reasons are for our legitimate interests or those of a third party, i.e., to protect systems and data and to prevent and detect criminal activity that could be damaging for you and/or us
Operational reasons, such as improving efficiency, training, and quality control or to provide support to you	For our legitimate interests or those of a third party, i.e., to be as efficient as we can so we can deliver the best service to you
Statistical analysis to help us manage our business, e.g., in relation to our performance, customer base, app and functionalities and offerings or other efficiency measures	For our legitimate interests or those of a third party, i.e. to be as efficient as we can so we can deliver the best service to you and improve and develop our app
Updating and enhancing user records	Depending on the circumstances: to perform our contract with you or to take steps at your request before entering into a contract (in this case, the contract means the Terms and Conditions of Use which apply to the Services) to comply with our legal and regulatory obligations where neither of the above apply, for our legitimate interests or those of a third party, eg making sure that we can keep in touch with our customers about their accounts and new products or functionalities related to the Services and our services
To comply with our legal and regulatory obligations	Depending on the circumstances: to perform our contract with you or to take steps at your request before entering into a contract (in this case, the contract means the Terms and Conditions of Use which apply to the Services) to comply with our legal and regulatory obligations where neither of the above apply, for our legitimate interests or those of a third party, e.g. making sure that we can keep in touch with our customers about their accounts and new products or functionalities related to the Services and our services
To share your personal data with members of our group and third parties in connection with a significant corporate transaction or restructuring, including a merger, acquisition, asset sale, initial public offering or in the event of our insolvency. In such cases information will be anonymised where possible and only shared where necessary	Depending on the circumstances: to comply with our legal and regulatory obligations in other cases, for our legitimate interests or those of a third party, i.e., to protect, realise or grow the value in our business and assets

See 'Who we share your personal data with' for further information on the steps we will take to protect your personal data where we need to share it with others.

MARKETING

We intended to send emails from marketing to inform you of our services such as promotions.
We will always ask you for your consent before doing sending you marketing communications, except where you have explicitly opted-in to receiving email marketing from us in the past or except where you were given the option to opt-out of email marketing when you initially signed up for your account with us and you did not do so.
You will have the right to opt out of receiving marketing communications at any time by:

contacting us at marketingoptout@QWIDPRO.com
using the 'unsubscribe' link included in all marketing emails you may received from us

We will always treat your personal data with the utmost respect and never sell or share it with other organisations for marketing purposes.
For more information on your right to object at any time to your personal data being used for marketing purposes, see 'Your rights' below.

WHO WE SHARE YOUR PERSONAL DATA WITH

We routinely share personal data with service providers we use to help us run our business or provide the services or functionalities in the Services, including developers, cloud storage providers and Google, Inc. for Google Maps location functionality. We exert no control over Google's Privacy Policy and we therefore recommend that you consult their privacy policy for further information on how Google protect personal data - https://policies.google.com/privacy?hl=en-US
We only allow service providers to handle your personal data if we are satisfied they take appropriate measures to protect your personal data. We also impose contractual obligations on service providers to ensure they can only use your personal data to provide services to us and to you.
We only allow service providers to handle your personal data if we are satisfied they take appropriate measures to protect your personal data. We also impose contractual obligations on service providers to ensure they can only use your personal data to provide services to us and to you.
We or the third parties mentioned above may occasionally also need to share your personal data with:

external auditors, e.g. in relation to the audit of our accounts and our company —the recipient of the information will be bound by confidentiality obligations
professional advisors (such as lawyers and other advisors)—the recipient of the information will be bound by confidentiality obligations
law enforcement agencies, courts or tribunals and regulatory bodies to comply with legal and regulatory obligations
other parties in connection with a significant corporate transaction or restructuring, including a merger, acquisition, asset sale, initial public offering or in the event of our insolvency—usually, information will be anonymised but this may not always be possible, however, the recipient of the information will be bound by confidentiality obligations

If you would like more information about who we share our data with and why, please contact us (see 'How to contact us' below).
We will not share your personal data with any other third party.

HOW LONG YOUR PERSONAL DATA WILL BE KEPT

We will keep your personal data for as long as you have an active account with us and for a period of up to 6 years thereafter to comply with any accounting or legal obligations including in the event of the pursuit or defence of legal claims. Once you have closed your account with us, we will move your personal data to a separate database so that only key stakeholders in our business on a 'need to know basis' have access to such data.
Following the end of the of the aforementioned retention period, we will delete or anonymise your personal data.

TRANSFERRING YOUR PERSONAL DATA OUT OF THE UK

At this point in time, we do not transfer your personal data outside of the UK. If this changes, we would comply with applicable UK laws designed to ensure the continued protection and privacy of your personal data. Any updated destinations to which we send your personal data, would be indicated in the present section and notified to you in accordance with the section on 'Change to this privacy policy' below.
Furthermore, under UK data protection laws, we can only transfer your personal data to a country outside the UK where: the UK government has decided the particular country ensures an adequate level of protection of personal data (known as an 'adequacy regulation') further to Article 45 of the UK GDPR; there are appropriate safeguards in place, together with enforceable rights and effective legal remedies for you; or a specific exception applies under relevant data protection law. Accordingly, if we were to start transferring your personal data from the UK to:

The EEA: we would rely on the adequacy finding granted by the UK to the EU under the Withdrawal Agreement to do; for any transfers from the EU to the UK, we would rely on the adequacy regulation granted to the UK under the Adequacy Decision.
Any country located outside the UK/EEA: we would rely an appropriate safeguards under the UK GDPR, such as by including the relevant Standard Contractual Clauses in our data processing agreements

In the event we could not or choose not to continue to rely on either of those mechanisms at any time we would not transfer your personal data outside the UK unless we could do so on the basis of an alternative mechanism or exception provided by UK data protection law.

SYSTEM UPDATES AND NOTIFICATIONS

By using our services, you acknowledge and agree to receive system updates and notifications from us. These updates and notifications are essential for the smooth functioning and improvement of our platform and are designed to enhance your overall user experience. By accepting, you grant us permission to send you system updates and notifications. These updates may include, but are not limited to, new feature announcements, bug fixes, improvements, job-notifications, and important service-related information.

System updates and notifications will be delivered to you through various channels, including but not limited to email, in-app messages, push notifications, or other communication methods as deemed appropriate by us. It is your responsibility to ensure that your contact information is accurate and up to date to receive these updates and notifications effectively.

While these system updates and notifications are integral to the functionality of our platform, we understand that you may prefer not to receive certain communications. You may have the option to opt out of non-essential notifications, but please note that opting out of critical updates may hinder your ability to use our services optimally.

We strive to limit the frequency of non-critical updates and notifications to prevent any undue disruption to your user experience. Critical updates, such as security-related information, may be sent more frequently if necessary for your safety and protection.

We will make reasonable efforts to ensure that the information provided in system updates and notifications is accurate and up to date. However, we do not guarantee the timeliness or accuracy of such communications and shall not be liable for any consequences arising from reliance on this information.

YOUR RIGHTS

You generally have the following rights, which you can usually exercise free of charge. For more information regarding these rights, please visit the ICO website here.

. The right to receive the personal data you provided to us, in a structured, commonly used and machine-readable format and/or transmit that data to a third party—in certain situations.

Access to a copy of your personal data	The right to be provided with a copy of your personal data.
Correction (also known as rectification)	The right to require us to correct any mistakes in your personal data.
Erasure (also known as the right to be forgotten)	The right to require us to delete your personal data—in certain situations.
Restriction of use	The right to require us to restrict use of your personal data in certain circumstances, e.g. if you contest the accuracy of the data.
Data portability
To object to use	The right to object: at any time to your personal data being used for direct marketing (including profiling) in certain other situations to our continued use of your personal data, e.g. where we use you personal data for our legitimate interests.
Not to be subject to decisions without human involvement	The right not to be subject to a decision based solely on automated processing (including profiling) that produces legal effects concerning you or similarly significantly affects you We do not make any such decisions based on data collected by the Services.

For further information on each of those rights, including the circumstances in which they do and do not apply, please contact us (see 'How to contact us' below). You may also find it helpful to refer to the guidance from the UK's Information Commissioner on your rights under the UK GDPR.
If you would like to exercise any of those rights, please complete a request form—available on our website at https://QWIDPRO.com/contactor email GDPR@QWIDPRO.com , call or write to us—see below: 'How to contact us'. When contacting us please:

provide enough information to identify yourself (e.g., your full name and username) and any additional identity information we may reasonably request from you, and
let us know which right(s) you want to exercise and the information to which your request relates

KEEPING YOUR PERSONAL DATA SECURE

We have appropriate security measures to prevent personal data from being accidentally lost, or used or accessed unlawfully. We limit access to your personal data to those who have a genuine business need to access it.
We also have procedures in place to deal with any suspected data security breach. We will notify you and any applicable regulator of a suspected data security breach where we are legally required to do so.
If you want detailed information from Get Safe Online on how to protect your information and your computers and devices against fraud, identity theft, viruses and many other online problems, please visit www.getsafeonline.org. Get Safe Online is supported by HM Government and leading businesses.

HOW TO COMPLAIN

Please contact us if you have any queries or concerns about our use of your information (see below 'How to contact us'). We hope we will be able to resolve any issues you may have.
You also have the right to lodge a complaint with the Information Commissioner.
The Information Commissioner can be contacted at https://ico.org.uk/make-a-complaint or telephone: 0303 123 1113.

CHANGES TO THIS PRIVACY POLICY

We may change this privacy policy from time to time. When we make significant changes we will take steps to inform you, for example via the Services or by other means, such as email.

INTELLECTUAL PROPERTY

All content, including but not limited to text, images, graphics, logos, and trademarks, provided through updates for our latest jobs, newsletters, and notifications, is the intellectual property of our company or our licensors. You agree not to reproduce, distribute, modify, or create derivative works of any such content without our prior written consent.

LIMITATION OF LIABLITY

To the maximum extent permitted by law, we shall not be liable for any direct, indirect, incidental, consequential, or punitive damages arising out of or in connection with your subscription to receive updates for our latest jobs, newsletters, and notifications, or your use of any content provided therein.

HOW TO CONTACT US

You can contact us by post, email or telephone if you have any questions about this privacy policy or the information we hold about you, to exercise a right under data protection law or to make a complaint.
Our contact details are shown below:

38 Chancery Lane, The Cursitor, London, WC2A1EN
info@QWIDPRO.com
+44 20 4571 5741