This is the privacy and cookies policy (the “Policy”) for the FIXR Jobs website (fixr.co/jobs) (the “Platform”)) which is owned and operated by VIPR Digital Limited trading as FIXR or FIXR Jobs (“we”, “our” and “us”). VIPR Digital Limited is a private limited company, registered in England (company number: 8184813, registered office: 184 Shepherds Bush Road London, W6 7NL).

The Policy sets out how we process information about you which is personally identifiable when you use the Platform, whether you are an Applicant, Employer, or visitor.

The Platform is a listings service, whereby Employers can showcase information about their company and list available Jobs, and Applicants can apply for these Jobs by way of video application.

By accessing the Platform, registering details, advertising job opportunities, applying for jobs, or carrying out other activities using the Platform, you are subject to our Terms & Conditions of Service and agree to be bound by them.

VIPR Digital Limited is the data processor for the purposes of the General Data Protection Regulation ((EU) 2016/679) or any successor, replacement or implementing legislation.

If you have any questions about this Policy, please contact us on + (44) (0) 2037000610 or team@fixr.co.

This Policy was last updated on 1 March 2019.

DEFINITIONS

For the purposes of this Policy, the following definitions shall apply:

“Applicant” a person who applies for a Job via the Platform.

“Employer” an entity which advertises Jobs on the Platform which are available.

“Job” means a permanent or temporary job, internship or placement (as applicable) as advertised on the Platform from time to time.

PERSONALLY IDENTIFIABLE INFORMATION (PII) / PERSONAL DATA

Personal data or PII means any information relating to a person who can be identified either directly or indirectly, including: name, email address, age, gender, phone number, credit / debit card number, IP address, location data, browsing history (“Personal Data”).

LAWFUL BASES OF PROCESSING

We will only collect and process Personal Data about you where we have a lawful basis for doing so. Lawful bases include consent, contract (where processing is necessary for the performance of a contract with you), legitimate interests and compliance with legal obligations to which we are subject.

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. For further information, please see the section headed “Your Rights” below.

INFORMATION WE MAY COLLECT FROM YOU

We may collect and process the following information about you:

Applicants:

• Personal information when you register with the Platform, including Personal Data, and information supplied to us as part of the Job application process, including, but not limited to, information about your university, course of study, achieved / predicted grade, languages spoken, and year of graduation.
• Information supplied by you when submitting a video Job application (including CVs and covering letters) and answering questions set by an Employer for the purposes of this application. Such questions may be wide-ranging and cover a range of topics.
• In connection with your account log-in, your log-in details and password.
• Information from social networks you are a member of, where you choose to log-in via a social networking site or make use of the Platform’s social networking features.
• Location data.
• Details of any preferences, personal settings and responses to surveys or questionnaires we may send you.
• Details of your visits to the Platform, and resources you choose to access and any data you choose to download.
• Technical data, including device properties such the type of internet browser you are using and any website you may have navigated from to use the Platform. For the purposes of this privacy policy, “technical data” includes “aggregate” and “de-personalised” information, which is data we collect about the use of our services, from which any personally identifiable data has been removed. We may use tools or third-party analytical software to automatically collect and use certain technical data that does not directly enable us to identify you. The types of technical data we may collect and use include, but are not limited to: (i) device properties, including, but not limited to Media Access Control (“MAC”) address and identifier for advertising (“IDFA”) or other device identifier; (ii) device software platform and firmware; (iii) mobile phone carrier; (iv) geographical data such as coarse location; (v) other technical data as reasonably required by us to enhance our products and services.
• Other information that you may consent to give us from time to time. You are under no obligation to provide any such information. However, if you should choose to withhold requested information, we may not be able to provide you with certain services.

Employers:

• Your name, address, contact details, links to your website, and other information required for you to register with the Platform and create an account.
• Payment details, to enable us to collect and make any payments owed to you.
• In connection with your account log-in, your log-in details and password.
• Information supplied by you when submitting a video about your company and available Jobs.
• Details of any preferences, personal settings and responses to surveys or questionnaires we may send you.
• Details of your visits to the Platform, the resources you choose to access and any data you choose to download.
• Technical data, including the type of internet browser you are using and any website you may have navigated from to use the Platform.

Visitors:

• Cookies information as set out under the section “Cookies Policy” below.
• Any other data or information you choose to provide to us.

PURPOSES FOR WHICH WE PROCESS PERSONAL DATA

We will only process your Personal Data, in accordance with applicable law, for the following purposes:

• To provide the Platform services to you, including the submission of videos by Applicants and Employers.
• To facilitate the introduction of Applicants to Employers and enable Employers to see details of, and information about, Applicants.
• To contact you by instant message, phone or email when necessary to discuss activity by you on the Platform.
• To help us build a profile for you so that we may offer you features, promotions and services based on your preferences. In order to tailor such offers appropriately, we will undertake profiling of you on the basis of our legitimate interests.
• To monitor your use of the Platform and investigate any complaints or potential breaches of use of the Platform.
• To notify you of any changes to the Platform, request feedback from you as to your use of the Platform or respond to any communications you send us by using the contact details you have provided.
• To identify users of the Platform.
• To resolve any refunds or disputes.
• For other purposes to which you may consent from time to time.
• To comply with applicable law, for example, in response to a request from a court or regulatory body, where such request is made in accordance with the law.

We will also use information you provide to us for the purposes of contacting you, or enabling third parties to contact you, with information or offers regarding Jobs, promotions, products, services or surveys. This shall only be done with your consent and our direct marketing policy which is explained in full below.

NOTIFICATIONS AND MARKETING TO YOU

Notifications: From time-to-time, we may send you notifications, including by way of email, instant message, and push notification, provided you have indicated that you do not object to receiving such notifications. We will always give you the option to opt-out of receiving notifications by following the unsubscribe instructions on communications sent to you. Notifications may include information about Jobs, promotions, products, services, and surveys. In respect of the latter, we may use surveys (or similar) to gather additional information from you so that we can determine if we should introduce additional services or product lines. Notifications may also include communications distributed on behalf of FIXR and/or our commercial partners (if applicable).

Service messages: If necessary, we may send you service emails, regardless of your preference settings.

Third party marketing: Additionally, if you consent by opting-in to receive such information and offers, we may allow carefully selected third parties to send you information directly which you may find useful regarding their products and services. If you decide to engage with such third parties, note that their terms and conditions and privacy policy will then apply.

Advertisements: From time-to-time we may display banner (or similar) advertisements or promotions for our commercial partners on the Platform.

Jobs Information: When applying for a Job, Applicants will be asked to complete additional information to complete their profile. This may include but not be limited to: name of university, course length and start year, and predicted / achieved grade. This information will be passed to Employers as part of the Job application. In providing us with information, you will be asked if you are happy for us to use this to communicate with you about additional Job opportunities. This may include contacting you directly about these opportunities, and displaying advertisements or promotions relating to Jobs within specific parts of the Platform.

Further third-party sales and marketing: When using the Platform, you may be offered an opportunity to purchase third party products or services or enter into third party promotions or loyalty programmes. If you expressly consent to purchase those products or services or enter into the promotions or programmes you authorise us to share your name, phone number, e-mail address and, where necessary and only where you have consented for us to do so, your financial and billing details with that third party. The use of your Personal Data will be governed by the terms of that entity’s own terms of supply and privacy policy, so please ensure that you read the relevant terms and privacy policy carefully before you agree to purchase from, or engage with, that third party.

INFORMATION WE MAY SHARE WITH THIRD PARTIES

There are circumstances where we wish to disclose or are compelled to disclose your Personal Data to third parties. This will only take place in accordance with the applicable law and for the purposes listed above. These scenarios include disclosure:

• To enable debit or credit card purchases to be transacted, for example through our payment provider Stripe.
• To comply with any legal or regulatory obligation or so as to uphold or enforce our Terms & Conditions of Service.
• To exchange information with other companies for the purposes of fraud prevention and detection, including police authorities.
• To share data with social networking sites, if you allow us to do so.
• To check or verify your age or identity.
• Subject to your consent, to third parties for marketing purposes, who may contact you by email, telephone, SMS or by other means.
• To third party service providers and consultants in order to protect the security or integrity of our business, including our databases and systems and for business continuity reasons.
• To potential partners, advertisers and merchants with a view to promoting the Platform and its services.
• To another legal entity, on a temporary or permanent basis, for the purposes of a joint venture, collaboration, financing, sale, merger, reorganisation, change of legal form, dissolution or similar event. In the case of a merger or sale, your Personal Data will be permanently transferred to a successor company; and
• To any other third party where you have provided your consent.

INTERNATIONAL TRANSFER OF PERSONAL DATA

We may transfer your Personal Data to a third party in countries outside the country in which it was originally collected for further processing in accordance with the purposes set out above. In particular, your Personal Data may be transferred to our outsourced service providers located in other countries in the EEA. In these circumstances we will, as required by applicable law, ensure that your privacy rights are adequately protected by appropriate technical, organisation, contractual or other lawful means.

PUBLIC FORUMS, EXTERNAL WEBSITES AND SOCIAL NETWORKING FEATURES

The Platform may, from time to time, make public forums available to its users. Any information that is disclosed in these areas becomes public information and you should exercise caution when using these and never disclose your Personal Data.

The Platform may, from time to time, contain links to external websites, or external websites may host / integrate our Platform functionality. We are not responsible for the terms and conditions, data protection, privacy, or security (including SSL compliance and data encryption practices) or content of such websites.

Please take care when using the Platform’s social networking features since the information you choose to make available may be seen by other users of the social network. We do not monitor the use of such features in the normal course of business although we reserve the right to do so at our discretion.

HOW WE PROTECT YOUR INFORMATION

We treat the security of Personal Data provided by you very seriously. Save as expressly set out in this policy all information that you provide to us is stored by us or on our behalf on secure servers based in the UK or other European Economic Area (“EEA”) Countries.

No credit or debit card information is stored on our servers. We use Stripe, a leading PCI compliant service payment provider, to store your debit and credit card information. Stripe has been audited by an independent PCI Qualified Security Assessor (QSA) and holds the highest level of certification given by card issuers (PCI-DSS Level 1),

When moving your data, we protect it with multiple layers of security, including leading encryption technology like HTTPS and Transport Layer Security.

Your data is backed up to servers in different geographical locations within the EEA in order to provide resilience against fire or other disasters.

We monitor our services and underlying infrastructure to protect them from threats, including spam, malware, viruses and other forms of malicious code.

RETENTION OF PERSONAL DATA

Your Personal Data will be retained in accordance with our Data Retention Policy, a copy of which is available on request.

YOUR RIGHTS

Data protection law provides you with numerous rights, including the right to: access, rectify, erase, restrict, transport, and object to the processing of, your Personal Data. You also have the right to lodge a complaint with the relevant data protection authority if they believe that your Personal Data is not being processed in accordance with applicable data protection law.

Right to make subject access request (SAR): You may, where permitted by applicable law, request copies of your Personal Data. If you would like to make a SAR, (i.e. a request for copies of the Personal Data we hold about you) you may do so by writing to us using the heading “Subject Access Request” at the address above or at team@fixr.co. You may also be required to submit a proof of your identity.

Right to rectification: You may request that we rectify any inaccurate and/or complete any incomplete Personal Data. Applicants can also access your own account details and amend them yourself at any time by going to “Settings”.

Right to withdraw consent: You may, as permitted by applicable law, withdraw your consent to the processing of your Personal Data at any time. Such withdrawal will not affect the lawfulness of processing based on your previous consent. Please note that if you withdraw your consent, you may not be able to access the entire Platform or benefit from certain service features for which the processing of your Personal Data is essential.

Right to object to processing, including automated processing and profiling: You may, as permitted by applicable law, request that we stop processing your Personal Data. In relation to automated processing and profiling, you may object to the processing.

Right to erasure: You may request that we erase your Personal Data and we will comply, unless there is a lawful reason for not doing so. For example, there may be an overriding legitimate ground for keeping your Personal Data, such as, a legal obligation that we have to comply with, or if retention is necessary for us to comply with our legal obligations.

Right to data portability: In certain circumstances, you may request that we provide your Personal Data to you in a structured, commonly used and machine-readable format and have it transferred to another provider of the same or similar services. We will comply with such transfer obligations as far as it is technically feasible. Please note that a transfer to another provider does not imply erasure of your Personal Data which may still be required for legitimate and lawful purposes.

Your right to lodge a complaint with the supervisory authority. We suggest that you contact us about any questions or if you have a complaint in relation to how we process your Personal Data. However, you do have the right to contact the relevant supervisory authority directly. To contact the Information Commissioner’s Office in the United Kingdom, please visit the ICO website for instructions.

AGE

Please note that the Platform is not intended for anyone under the age of 16.

COOKIES POLICY

We use certain cookies to help make the service we provide and your interaction with the Platform more meaningful. Cookies are encoded text files that help your browser navigate through a website and store information about your use of a website. We use both “Session” cookies, which last only for the duration of your browsing session and expire when you close the Platform. We also use “Persistent” cookies which remember you when you return to the Platform and last for a longer duration.

We use cookies to remember you have visited the Platform before, process and collect information and customise certain parts of the Platform. You can choose to disable cookies through your browser settings, although you should note that in doing so, your ability to use the Platform may be affected.

You can learn more about cookies at www.allaboutcookies.org.

Tracking GIFs may also be used by us or third parties to help us understand which parts of the Platform are being visited and are of interest.

AMENDMENTS

We may amend this Policy at any time to reflect changes to the Platform or services provided thereunder. We may amend this Policy at any time by posting the amended Policy on our website and / or by amending the Policy as it is accessed from the Platform. It is your responsibility to review the Policy from time to time to check if it has been amended. The effective date of each new version of the Policy will be included at the top of this page. If you continue to use the Platform or you download any content or upgrade to a new version of the Platform after we have posted any amended Policy that will demonstrate that you accept our updated Policy. Should you not accept these amendments, you may choose to stop using the Platform at any time.