Last version: June 2018
1. SCOPE OF POLICY
1.1 This policy together with the Terms of Service (ToS) and our Collaboration Contract Policy apply to your use of:
- a) our website at workkola.com (the “Workkola Site” or the “Site”) ;
- b) the Workkola Web-Application (“Workkola” or the “Application”) once you have signed up through the signup page, including, without limitation, any components of Workkola available to logged Users (Students and Companies) pursuant to the Terms of Service (ToS);
- c) our website at skyllz.org (the “Skyllz Website”), including, without limitation, the Skyllz Dashboard available to Skyllz Dashboard Users pursuant to the requirements (together with Workkola Site, the “Sites”); and
- d) any of the services accessible through Workkola or the Sites (the “Services”).
1.2 This policy sets out the basis on which any personal data we collect from you, or that you provide to us, will be processed and used by us.
We are the data controller responsible for your personal data.
Data Protection Officer
We have appointed a data protection officer (“DPO”). Our DPO has a number of important responsibilities including:
- monitoring Workkola’s compliance with the GDPR and other data protection laws;
- raising awareness of data protection issues, training Workkola staff and conducting internal audits; and
- cooperating with supervisory authorities on our behalf.
You have the right to make a complaint at any time to the lead supervisory authority (LSA) for data protection issues in your country or State Member (USA). We would, however, appreciate the chance to deal with your concerns before you approach them so please contact us in the first instance at firstname.lastname@example.org or email@example.com.
Some examples of supervisory authority for data protection:
– UK: Information Commissioner’s Office (ICO). ( www.ico.org.uk)
-Spain: Agencia Española de Protección de Datos (AEPD). (www.agpd.es)
-France: Commission Nationale de l’Informatique et des Libertés (CNIL) (www.cnil.fr)
So that we’re clear and there’s no misunderstanding about how we handle your personal data, we will:
- Always keep your data safe and private.
- Never sell your data.
- Allow you to manage and review your marketing choices at any time.
3. INFORMATION WE COLLECT ABOUT YOU
3.1 We will collect and process the following data about you:
- a) Information you give us “Submitted Information”: This is information you give us about you by filling in forms on Workkola and/or the Sites, or by corresponding with us (for example, by e-mail or via the chat functions on Workkola and/or the Sites). It includes information you provide when you register to use Workkola, subscribe to any of our services, enter into any feature on Workkola or the Sites (such as an Open Challenge, Open Challenge + Job Offer, Talent Story, Personality Quiz, Upload your Curriculum Vitae and/or Portfolio, Contact a User, Redeem your Points, Update your Settings, Apply to become a Rater, Rate a Challenge), participate in discussion boards or other social media functions on Workkola or the Sites, enter a promotion or survey, and when you report a problem with the Services or the Sites. If you contact us, we will keep a record of that correspondence. The information you give us may include your name, address, date of birth, e-mail address, the Device, username, password and other registration information, educational background, relevant working/past experience and portfolio, basic self-defined personality, professional hard and soft skills and values (based on our PV-TASK model), solutions to the Open Challenges, Open Challenge + Job Offers and Talent Stories (together, the “Challenges”) proposed on Workkola (including submitted documents), valuations, recommendations and ratings (together, the “Ratings”) to the Challenges you rate, feedback given while rating other users’ Challenges, company description, company information (mission, business model, KPIs, metrics, and all the information submitted when posting the Challenges), personal description and profile picture and/or logo and any other information you provide us in order to use our Services or your elegibility to our Services or Sites.
- b) Information we collect about you and your device. Each time you visit Workkola or our Sites we will automatically collect the following information:
- (i) technical information, including the internet protocol (IP) address used to connect your computer to the Internet, your login information, browser type and version, time zone setting, browser plug-in types and versions, operating system and platform, device information and the type of mobile device you use, a unique device identifier (for example, your Device’s IMEI number, the MAC address of the Device’s wireless network interface, or the mobile phone number used by the Device), your mobile operating system, the type of browser you use, time zone setting “Device Information“;
- (ii) information about your visit, including the full uniform resource locators (URL), clickstream to, through and from our sites (including date and time), services you viewed or searched for, page response times, download errors, length of visits to certain pages, page interaction information (such as scrolling, clicks, and mouse-overs), methods used to browse away from the page, device information;
- (iii) usage information including date, time, user ID (internal identifier), Challenge ID, area, skills, information added to the Challenge, company information, Challenge description, User’s and Company’s name and registration information, messages sent or received with the Challenge, Ratings, information sent with the Ratings;
- (iv) details of your use of Workkola or your visits to our Sites including Challenges details relating to your use of our services, including which Challenges you post, visit, check, start, finish, receive Ratings, give Ratings and feedback, skills related, area related, final valuations, the time and date.
- c) Information to help us deliver our service to you. We work closely with third parties in order to help us deliver our Service to you. These third parties are business partners (such as those we partner with to offer additional Services such as e-learning platforms), sub-contractors in technical and payment, advertising networks, analytics providers, search information providers, fraud prevention agencies, customer service providers and developers. Information we may collect about you from such parties can include information which helps us to verify your identity. Please see the ‘Disclosure of your Information’ section for more information.
4. USES MADE OF THE INFORMATION
4.1 Below is a summary of the key types of data that we make use of as part of the Workkola Services. For more information on how these types of data are used and for which purposes then please see the table below.
We use information held about you in the following ways:
- (a) Submitted Information: We will use this information:
- to carry out our Services and provide the best possible Challenges and learning/ working paths;
- to provide and notify you with information about other Challenges and services we offer that are similar to those that you have already started, submitted or have been interested in;
- to provide you with information about goods or services we feel may interest you. Please see the section on ‘Third Party Services’ below for more information;
- to verify your identity to protect against fraud, comply with financial crime laws and to confirm your eligibility to use our products and services (mostly on the Skyllz Site);
- to notify you about changes to our service;
- to notify you about important information related to the Challenges or Services you started such as days to deadline, new public question/answer, new solution submitted, new Rating received, new contact requested or accepted/denied, a summary of the Personality Quiz; and
- to ensure that content from our site is presented in the most effective manner for you and for your computer.
- (b) Device Information: We will use this information:
- to administer our Sites and Workkola for internal operations, including troubleshooting, data analysis, testing, research, statistical and survey purposes;
- to improve our Sites and Workkola to ensure that content is presented in the most effective manner for you and for your computer;
- to allow you to participate in interactive features of our service, when you choose to do so;
- as part of our efforts to keep our Sites and Workkola safe and secure;
- to measure or understand the effectiveness of advertising we serve to you and others, and to deliver relevant advertising to you;
- to verify your identity, protect against fraud, comply with anti-financial crime laws and to confirm your eligibility to use our products and services (mostly for Skyllz Site); and
- to comply with our regulatory obligations.
- c) Third Party Information: We will combine this information with information you give to us and information we collect about you. We will use this information and the combined information:
- to help us better understand your professional and learning path, and behavior so that we may make decisions about how we manage your Workkola Account; and
- for the purposes set out above (depending on the types of information we receive).
4.2 We may associate any category of information with any other category of information and will treat the combined information as personal data in accordance with this policy for as long as it is combined.
For example, we may use your information combined with your performance and Rating received in past Challenges as an indicator to adapt our algorithm to make future Challenges or job opportunities available to you based on suitability.
4.3 If we decide to engage advertisers to promote our products and services, the advertisers and their advertising networks may require anonymized personal data to serve relevant adverts to you and others. We will never disclose identifiable information about individuals to advertisers, but we may provide them with aggregate information about our users (for example, we may inform them that 500 men aged under 30 have clicked on their advertisement on any given day). We may also use such aggregate information to help our advertising partners provide a tailored and targeted campaign, relevant for a sub-section of our users (for example, women in Barcelona). In some instances, we may use personal data we have collected from you to enable our advertising partners to display their advertisement to their target audience.
5. PURPOSES OF USING YOUR THIS INFORMATION
We have set out below, a description of all the ways we use your personal data as stated above.
a) To provide Workkola Services:
Processing your Personal Data is necessary in order to provide you with our services of professional-related self-development, talent branding, and talent assessment. These are the ways we use it while providing you our Services:
- Create a user account and grant you access to it and modify it. To access our Services you must create an account and log into it as a User (“Student” or “Startup”). You can modify your Personal Information provided whenever you deem appropriated via in-application “My account>Settings” on the side navigation bar.
- Allow you to access, check, start, add information, submit a solution and receive/give Ratings on our available Challenges.
- Allow you to create, modify and post Challenges (only available for Startup Users).
- Allow you to review, rate, validate skills and give feedback while Rating other users’ solutions to Challenges submitted.
- Assess and showcase a track record and metrics of your performance in Workkola along with some of your Submitted Information (such as name, profile picture, education background, working/past experience, portfolio, and results of your Personality Quiz) in a Public Profile that you can make public or private via in-application“My account>Settings” on the sidebar. The Public Profile is designed to help you showcase your best achievements on Workkola inside and outside the application.
- Match you with Challenges, Challenges to rate, companies and job opportunities that suit your interests and professional and learning path.
- Allow you to contact and get contacted by other Users to connect with for professional opportunities
- Contact you to notify any important information about your account, the Challenges available for you, days to the deadline of started Challenges, new public questions/answers on a Challenge, new Challenge posted, new solution submitted, and new Rating received or given. We will primarily use the email and in-application notifications to contact you.
- Allow you to have a history of Challenges started and finished with the final Ratings and feedback associated. You just need to access “My Challenges” within Workkola.
- Allow you to have a history of Challenges created, posted and payments done.
- Send you the results of your Personality Quiz to the email you provided
- Notify you when another user adds you or accepts you as a team member of an uploaded project to the portfolio
- Help and guide you through the process of completing a Challenge. This help would only be possible with your Personal Data.
- Assist you when you contact us via email.
- Any other question related to our Services.
b) To conduct internal and marketing campaigns
We will use your Personal Data to send you news, updates, and promotions related to our Services, Workkola and our Sites such as weekly newsletters, important releases
You can always personalize your email notifications via your in-application “My Account>Settings” on the sidebar or unsubscribe from our email marketing campaigns directly from the email received.
What do we mean when we say:
Legitimate Interest: this means the interest of ours as a business in conducting and managing Workkola to enable us to provide to you our Services and offer the best possible experience. We make sure we consider and balance any potential impact on you (both positive and negative) and your rights before we process your personal data for our legitimate interests. We do not use your personal data for activities where our interests are overridden by the impact on you (unless we have your consent or are otherwise required or permitted to by law).
Our Legal Obligation: this means processing your personal data where it is necessary for compliance with a legal or regulatory obligation that we are subject to.
6.1 We want to make it crystal clear how we use your data for marketing purposes and how you can ‘opt-out’ from receiving any marketing communications from us whenever you want.
6.2 We strive to provide you with choices regarding certain personal data uses, particularly around marketing and advertising. We have established a “Settings” section within the “My Account” section of the Application (sidebar) where you can view and make certain decisions in relation to notifications emails. Please see the “Settings” section within the “My Account” section of the Application for more details.
PROMOTIONAL OFFERS FROM US
6.3 We may use your personal data (such as your Submitted Information or Location Information) to form a view on what we think you may want or need, or what may be of interest to you. This is how we decide which products, services
6.4 You will receive marketing communications from us if you have signed up to and/or uses our Services and, in each case, you have not opted out of receiving marketing notifications directly from the unsubscribe form that you will find on every email received.
6.6 You can ask us to stop sending you marketing messages at any time by following the unsubscribe links on any marketing message sent to you.
7. DISCLOSURE OF YOUR INFORMATION
DATA PROCESSING PARTNERS
7.1 We will disclose the data we collect from you to certain third parties who use personal data in delivering their services to us, they use data securely and confidentially and under strict contractual controls in accordance with data protection laws and enforced by Workkola.
7.2 We send personal data to the following sets of data processors in order to perform our Services:
- a) Cloud storage providers (such as Amazon or Microsoft)
- This is in order to safely and securely store your data with Workkola and Skyllz;
- b) Financial services partners (such as Stripe)
- Financial services providers that help us provide our Services such as payments services providers;
- c) Marketing tools (such as Active Campaign or Hubspot) and analytics (such as Mixpanel or Google) providers
- We use marketing tools to deliver our promotions and engage with you;
- We also use analytics and search engine providers that assist us in the improvement and optimisation of our site;
d) Fraud prevention agencies (only for Skyllz)
- This is in order to verify your identity, protect against fraud, comply with anti-money laundering laws and to confirm your eligibility to participate in certain events. Please note that If fraud is detected, you could be refused certain services. Further details of how your information will be used by us and these fraud prevention agencies, and your data protection rights, can be found by emailing us at firstname.lastname@example.org.
7.3 We may also disclose your personal information in the following circumstances:
- If Workkola or substantially all of its assets are acquired by a third party, in which case personal data held by it about its customers will be one of the transferred assets.
- If we are under a duty to disclose or share your personal data in order to comply with any legal or regulatory obligation or request.
- In order to:
- (i) enforce or apply the Terms of Service and/or the Collaboration Contract Policy and/or any other agreements between you and us or to investigate potential breaches; or
- (ii) protect the rights, property or safety of Workkola, our customers or others. This includes exchanging information with other companies and organizations for the purposes of fraud protection and security.
THIRD PARTY SERVICES PARTNERS
7.4 From time-to-time, we may partner with certain third parties in order to offer you co-branded services or promotional offers. In order to provide these services to you and to allow us and any associated third party to optimize their/our offering to you, we will share some of your personal data with such third parties. We will obtain your express opt-in consent before we share your personal data with any company outside Workkola for these purposes.
8. STORAGE SECURITY & INTERNATIONAL TRANSFERS
8.1 The data that we collect from you will be transferred
8.2 All information you provide to us is stored on our secure servers. Any payment transactions carried out by our third-party provider of payment processing services will be encrypted using
8.3 Unfortunately, the transmission of information via the internet is not completely secure. Although we will do our best to protect your personal data, we cannot guarantee the security of your data transmitted to our Application or our Sites; any transmission is at your own risk. Once we have received your information, we will use strict procedures and security features to try to prevent unauthorised access.
8.4 Certain Services include social networking, chat or public profiling. Ensure when using these features that you do not submit any personal data that you do not want to be seen, collected or used by other users.
9. RETAINING YOUR INFORMATION
In order to not hold your information for longer than is strictly necessary taking into consideration how lifelong learning and the future of workforce is impacting our professional life, we will not hold any of your personal data for more than 6 years after the termination of our business relationship.
10. YOUR LEGAL RIGHTS
You have rights under data protection laws in relation to your personal data. Please see below to find out more about these rights:
You have the right to:
Request access to your personal data (commonly known as a “data subject access request“). This enables you to receive a copy of the personal data we hold about you. If you require this, then please reach out to us by email at email@example.com.
Request correction of the personal data that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us. If you require this, then please reach out to us by email at firstname.lastname@example.org.
Request erasure of your personal data. This enables you to ask us to delete or remove personal data where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal data where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your personal data to comply with local law. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request. If you require this, then please reach out to us by email at email@example.com.
Request restriction of processing of your personal data. This enables you to ask us to suspend the processing of your personal data in the following scenarios: (a) if you want us to establish the data’s accuracy; (b) where our use of the data is unlawful but you do not want us to erase it; (c) where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims; or (d) you have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it. Please note that any requests in relation to the restriction of the processing of your data
Request the transfer of your personal data to you or to a third party. We will provide to you, your personal data in a structured, commonly used, machine-readable format, which you can then transfer to an applicable third party. We are working hard to create a self-sovereign and portable professional reputation with Skyllz so you can expect future enhancements and features that will reinforce even more your rights for this specific field. If you require this, then please reach out to us by email at firstname.lastname@example.org.
Withdraw consent at any time where we are relying on consent to process your personal data. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide our Services to you. We will advise you if this is the case at the time you withdraw your consent. If you require this, then please reach out to us by email at email@example.com.
NO FEE USUALLY REQUIRED
You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we may refuse to comply with your request in these circumstances.
WHAT WE MAY NEED FROM YOU
We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.
TIME LIMIT TO RESPOND
We try to respond to all legitimate requests within one month. Occasionally it may take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.
IF YOU FAIL TO PROVIDE PERSONAL DATA
Where we need to collect personal data by law, or under the terms of a contract we have with you and you fail to provide that data when requested, we may not be able to perform the contract we have or are trying to enter into with you (including our Services). In this case, we may have to cancel your use of the our Services but we will notify you if this is the case at the time.