GENERAL

In this privacy and cookies policy (“Policy”), we describe the information that we gather, that you provide to us, is produced to us by third parties, and will be processed by us, as you use this website (our “Website”) and the services available through this Website, our mobile website, (collectively, “Services”). We recommend reading this policy to understand what Privork Limited (“we”, “us”) do with your personal information. Your use of our Website and Services and any dispute over privacy, is subject to this Policy and any of our applicable Terms and Conditions for use of our Services, including their applicable limitations on damages and the resolution of disputes. Our Terms and Conditions for our Services are incorporated by reference into this Policy. By visiting www.privork.com you are accepting and consenting to the practices described in this Policy. Regardless of the applicable law set forth in the Privork Terms and Conditions for use of our Services, however, please note that any disputes arising under this Policy will be interpreted in accordance with the Governing Law provision set forth below.
EUROPEAN ECONOMIC AREA (“EEA”) CUSTOMERS ONLY: Please note that the whole of this Policy applies to you along with the additional provisions which are specific to EEA customers, and can be found at Appendix 1.

WHEN, HOW AND WHAT INFORMATION WE COLLECT?

When does Privork collect my information?
When you register and use our Services, you contact us with questions, and you otherwise choose to provide information to us.
We receive information about you from banking references, affiliates, other Privork users if they provide us your name through our referral programs, and other third parties (e.g., entities that assist us in validating your identity, among others). We may combine this with other information that we gather about you.
We, and our third parties (with consent for EEA users), automatically gather the following information about your use of our Website and our online Services through cookies, web beacons, log files and other technologies: your domain name, your browser type and operating system, web pages you view, links you click, your IP address, the length of time you visit our Website or use our Services, your activities on our Website, and the referring URL or the webpage that led you to our Website.

How does Privork collect my information?
We collect information directly from you, about you from third parties and service providers used to verify your identity and prevent fraudulent activity, other Privork users and other Privork clients or customers for the purpose of providing the Privork Services to you, and automatically as you use our Website and the Services.

What information does Privork collect?
The information we collect about you depends on your interaction with our Services, and when you provide information to us to request our services it might include, where permitted by applicable law:

  • Your contact information (e.g., name, email address, phone number, billing or mailing address)
  • Bank
  • IP address, geolocation
  • Identity validation (e.g., photograph, other information requested to verify your information)
  • National identification numbers
  • Date of birth
  • Details of any transactions carried out using any of the Services
  • Any other information that you choose to provide to us (e.g., if you send us an email/otherwise contact us)
  • Calls/emails/other correspondence
  • Information about your business

HOW DO WE USE INFORMATION?

  • to validate your identity;
  • to deliver our services to you, to communicate with you about your use of our services or any changes in our terms and conditions as applicable;
  • for the purpose for which you specifically give the information to us, including, to respond to your inquiries, to provide any information that you request, and to deliver customer support;
  • to tailor the content and information that we may send or display to you, to offer location customization (where permitted by applicable law);
  • as permitted by applicable law (other than if (where applicable) you opted out), to assist us in advertising our products and services in various mediums including, without limitation, sending you promotional emails, advertising our services on third party sites and social media platforms, sending you direct mail, and by telemarketing;
  • to better understand how users’ access and use our website and our services, both on an aggregated and individualized basis, to administer, monitor, and improve our website and services;
  • for marketing and promotional purposes, for example, where permitted by law (other than if (where applicable);
  • to protect us, our customers, employees or property — for instance, to investigate fraud and prevent fraudulent activity, harassment or other types of unlawful activities involving us or other companies that we do business with, to enforce this policy, as well as our terms and conditions.

WHEN DO WE SHARE YOUR INFORMATION?
We only share your information with third parties by using their products for internal reporting and operational management purposes, that includes service providers, regulated institutions (e.g., financial institutions), affiliated entities, and business partners.

WHERE DO WE STORE YOUR DATA?
All information you provide to us is stored on our and our cloud vendor secure servers.
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 Website; 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 un-authorized access.

CHANGES TO OUR PRIVACY & COOKIES POLICY
This Policy may change from time to time. Any changes in the future will be posted on our Website and, where appropriate, notified to you.

DISCLAIMER
Any and all content provided on this Website or the Services, including links to other websites is provided for the information purposes only and does not constitute advice, recommendation or support of such content or website. Privork makes every effort to provide true and accurate content on its Website. However, Privork provides no warranty, express or implied, of the accuracy, completeness, timeliness, or applicability of such content. Privork accepts no responsibility for and excludes all liability in connection with information provided on the Privork website, including but not limited to any liability for errors, inaccuracies or omissions.

APPENDIX 1: ADDITIONAL TERMS FOR EEA CUSTOMERS
The information below is required pursuant to the EEA law regarding privacy and data protection. The terms below apply to EEA customers in addition to the terms in the rest of the Policy.
For the purposes of the General Data Protection Regulation (“GDPR”), the data controller is Privork Limited, a company established in Grand Cayman.

When do we share your information?
The heading “WHEN DO WE SHARE YOUR INFORMATION” lists who we may share your information with, which include transfers for reasons of legal compliance and necessity in order to provide you with our Services.
You should be aware that when sharing your information, it may be transferred to, and stored at, a destination outside the EEA.
Please note that where data is transferred to non-EEA countries which may not offer the same level of protection for personal data as is available in the EEA. Privork will take various measures to ensure that your data is treated securely.
Please contact us if you require more detailed information about international transfers of your information, and the particular safeguards used.

Legal grounds for processing your personal data
We process your information based on the following legal grounds, as recognized by and in compliance with the applicable data protection laws:

  • the processing is necessary to perform our contract with you or to take steps requested by you before entering into said contract;
  • the processing is in Privork’s or someone else’s legitimate interests, and these interests are not overridden by your interests or rights in the protection of your personal data. this may include processing your data for prevention of fraudulent activity, internal research and analytics assessments, for purposes of communication with you, and informing you about new products and services we are offering or to promote new products and services of other parties which we think may be of interest to you, etc.;
  • you have given your consent to the processing of your data;
  • the processing is necessary to meet a legal obligation which applies to Privork.

If you would like more information about the legal grounds used to process your information, please contact us.
In instances where we have asked for, and you have given, your consent to our processing of your personal data, you have the right to withdraw such consent at any time.

Do you have to give your information?
In most cases, providing your personal data to us is optional, however, if you do not provide it, you will not be able to use our Services. For example, we need details such as your name, address and bank account details to provide you with estimates and invoices. In other instances, you have a choice over whether we gather your personal data, for example, you can turn off cookies on your browser and we will not place any cookies on your device or computer (although in this case you may not be able to use all parts of our website).

How long do we keep your information?
Privork retains your information as required by applicable laws or regulations and/or in accordance with Privork’s internal policies and procedures for purposes of prevention of fraudulent activity, risk management and security. Privork will periodically review the necessity of retention of your data.

EEA CUSTOMERS ONLY: YOUR RIGHTS
You have several rights in relation to your personal data which are described in more detail below.

Accessing your data
You can ask us to:

  • confirm whether we are processing your personal data
  • give you a copy of that data
  • provide you with other information about your personal data such as what data we have, what we use it for, who we disclose it to, whether we transfer it abroad and how we protect it, how long we keep it for, what rights you have, where we got your data from.

You do not have to pay a fee for a copy of your information unless your request is unfounded, respective or excessive, in which case we will charge a reasonable amount in the circumstances. We will let you know of any charges before completing your request.

We aim to respond to you within 1 (one) month of receiving your request unless it is particularly complicated, or you have made several requests, in which case we aim to respond within 3 (three) months. We will let you know if we are going to take longer than 1 (one) month in dealing with your request. If we have a lot of information about you we might ask you if you can tell us what exactly you want to receive. This will help us action your request more quickly.

Correcting your data
You can ask us to correct any data which is inaccurate or incomplete free of charge.
If we cannot action a request to correct your data, we will advise you.

Erasing your data
“The right to be forgotten” is not an absolute right, but you have the right to have your data erased, free of charge, in certain circumstances.

You can ask for your data to be erased where:

  • it is no longer necessary for the purpose for which it was originally collected or processed;
  • we are processing your data based on your consent, and you withdraw that consent;
  • you object to the processing and we do not have an overriding legitimate interest for continuing;
  • your data has been unlawfully processed;
  • your data must be erased to comply with a legal obligation;
  • the data was processed to offer information society services to a child.

There are some exceptions to this right where we do not have to delete the data.
If we have shared your data with third parties, we will tell them about the erasure of your data unless it is impossible or would involve disproportionate effort.

Restricting the processing of your data
You can ask us to restrict the processing of your personal data in some circumstances, free of charge. This is not an absolute right. If processing is restricted we can store the data and retain enough information to make sure the restriction is respected, but we cannot further process your data.

You can restrict the processing of your personal data in the following instances:

  • if you contest the accuracy of your data, we will restrict processing until we have made sure the data is accurate;
  • if you object to our processing and we are considering this objection;
  • if the processing is unlawful but you do not want us to erase your data;
  • if we no longer need the personal data but you require the data to establish, exercise or defend a legal claim.

If we have disclosed the data to a third party, we will inform them about the restriction unless it is impossible or would require a disproportionate effort. We will tell you if we decide to lift a restriction on processing your data.

Data Portability
This allows you to obtain and reuse your personal data for your own purposes across different services.

It applies where the following conditions are met:

  • you provided the personal data to us yourself;
  • we are processing the data either based on your consent or because it is necessary for the performance of a contract; and
  • the processing is carried out by automated means.

We will provide your data free of charge in a structured, commonly used and machine-readable form. We aim to provide your data within 1 (one) month of receiving your request unless it is particularly complicated, or you have made several requests, in which instance we aim to respond within 3 (three) months. If we are going to take longer than 1 (one) month we will let you know and advise why we need more time. If we consider that we cannot provide you with your data, we will contact you and advise of the reason.