PRIVACY POLICY

Who we are

We are Pairwise (“we“) and we are committed to protecting and respecting your privacy. This privacy notice will tell you about the personal data we collect from you, how we use this, how we look after it, your privacy rights and how the law protects you and your personal data.

Unless specifically stated otherwise in this policy, we act as data controller in respect of your personal data and are responsible for your personal data.

We operate the Pairwise platform for global clients and experts, which can be accessed at www.pairwise.co (Platform).

How to contact us

You can contact us by email to hello@pairwise.co.

About this notice

This notice sets out the basis on which any personal data we collect from or about you, or that your employer/business provides to us, will be processed by us.



What personal data do we hold about you, how do we collect this and how is it used?

The personal data we may hold about you depends on the capacity in which you are using the Platform or otherwise engaging with us, which primarily falls into three categories being:

  1. Where you register as an expert (Expert) or mentor (Mentor) to use the Platform;

  2. Where you (or your employer/business) register as a client seeker (Seeker) or client mentee (Mentee) to use the Platform (together "Client"); and

  3. Where, other than as an Expert, Mentor, Seeker or Mentee, you browse and/or submit any personal data to our Platform and/or contact us by email, phone, social media or post (Other User).


We have set out below how we collect personal data from these categories of individual, what personal data is collected and how we use the personal data. This personal data may be provided by you or collected by us during your use of the Platform/engagement with us.


Experts / Mentors:

How and what personal data do we collect?

On registration for an account with us your:

  • full name and title

  • location (country and city)

  • email address

  • phone number

  • any personal data contained in your professional resume, including your educational details, qualifications, professional history, competencies, interests and hobbies, and referee contact details

  • other personal data, such as personality type

  • details of criminal convictions and any other relevant civil fines, penalties, actions and proceedings to which you are or have been subject

  • any other personal data you may provide to us during the registration process,

together “Application Data”.

What do we do with your personal data?

  • Carry out internal checks to ensure you satisfy our criteria for registration on the Platform.

  • Register your account with us.

  • Provide our Platform services to you which includes:

    • Storing your details

    • Analysing your details and matching them to appropriate clients

    • Sharing your details with our client matches

    • Notifying you of any potential opportunities

  • Send you service updates (including information in respect of our terms and policies)

  • Correspond with you in respect of the Platform.

  • To send you our latest news, events and information, vacancies, clients and industry insights by email and/or SMS.


How and what personal data do we collect?

During your use of the Platform, we may collect technical information about you including your IP address.

What do we do with your personal data?

To ensure our Platform works as effectively as possible and to secure our Platform.

How and what personal data do we collect?

During your use of the Platform, we may also collect the following:

  • Account/billing details where you upload any invoices to the Platform

  • Personal data contained in any correspondence between you and any Clients and you and us.

What do we do with your personal data?

  • Where you use the Platform to upload invoices and/or send correspondence to Clients we will act as your data processor in respect of such information and will process this solely for the purpose for which it was uploaded.

  • Where you correspond with us via the Platform or any other medium we will use any personal data only to deal with your enquiry.


Clients:

How and what personal data do we collect?

On you or your business/employer registering for an account with us:

  • your name

  • professional title and employer/business

  • phone number and email address

  • other personal data, such as personality type

What do we do with your personal data?

  • To register your or your business’/employers’ account with us

  • Provide our Platform services to you or your business/employer which includes:

  • Storing your details

  • Analysing your details and matching them to appropriate Experts or Mentors

  • Sharing details of potential Expert or Mentor matches with you

  • To send you service updates (including information in respect of our terms and policies)

  • To correspond with you in respect of the Platform

  • To send you our latest news, events, information and industry insights by email and/or SMS.


Other Users:

How and what personal data do we collect?

When you use or submit information to us using the Platform or any other medium:

  • your name, email address, phone number and address

  • any other personal data submitted to us as part of any enquiry

  • any personal data contained in our correspondence with you

  • where you engage with us on social media, your name and other profile information that you make publicly available

  • Technical information about your use of the Platform (including your IP address, screen resolution, browser type, operating system software type and device type)

What do we do with your personal data?

  • To deal with your enquiry

  • To send you our latest news, events, information and industry insights by email, if requested

  • To ensure our Platform works as effectively as possible and secure our Platform.

  • To anonymise and aggregate data about our users so we can better understand their preferences and improve the Platform.


Where you are a Expert or Mentor, we may carry out automated processing of your personal data

The Platform analyses your Application Data to identify whether you are a suitable match for our Client requirements. This automated analysis may be used to create a short-list of potential Experts / Mentors and may be reviewed in person to recommend Experts / Mentors to the Client. Please see the rights you have in relation to automated decision-making below.

Please let us know if your personal data changes

It is important that the personal data we hold about you is accurate and current so please let us know (using the contact details included in this notice) if your personal data changes during your use of the Platform.

Disclosures of your personal data

As set out above, where you are a Expert or Mentor, we may share your Application Data with Clients who you have been matched with using the Platform. Once we have shared this personal data with the Client, they will become a data controller of the personal data and we would recommend that you review their privacy policy to understand how they may use your data.


In addition, we may share your personal data with our carefully selected third party service providers including the following:

  • Our Platform host.

  • Our IT service providers.

  • Any marketing agencies we may engage from time to time.

  • Our regulatory due diligence service providers.

  • Our professional advisers, including lawyers, accountants and insurers, as required by them from time to time to enable them to effectively advise us.

  • Any company within our group of companies.

  • We require all third party service providers to respect the security of your personal data and to treat it in accordance with the law. We do not allow our third-party service providers to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our instructions.



Required disclosures to third parties

We may make the following disclosures of your personal data to third parties, where required:

  • in the event that we sell or buy any business or assets, in which case we will disclose your personal data to the prospective seller or buyer of such business or assets.

  • if we or substantially all of our assets are acquired by a third party, in which case personal data held by us about our users 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 obligation, or in order to enforce or apply any contract between you (or your employer/business) and us or to protect the rights, property, or safety of Pairwise, our users, or others. This includes exchanging information with other companies and organisations for the purposes of fraud protection and credit risk reduction.

  • to HM Revenue & Customs, regulatory and other authorities who require this information for any purpose.



Where we store your personal data and when there may be international transfers of your personal data

We may need to share your personal data within the Pairwise Group. This may involve transferring your data outside the European Economic Area (EEA). Such transfers are necessary for the performance of our contracts with Clients and Experts/Mentors (or to carry out pre-contractual steps with potential Clients/Experts/Mentors).

Where you are an Expert/Mentor, we may share your Application Data to Clients who you have been matched with using the Platform. This may involve transferring your data outside the EEA for example where any such Client is located outside the EEA (unless you have informed us that you do not wish to be matched with Clients outside the EEA). Such transfers are necessary for the performance of our contracts with Experts/Mentors. As mentioned above, once we have shared this personal data with the Client, they will become a data controller of the personal data and we would recommend that you review their privacy policy to understand how they may use your data, particularly where they are located outside of the EEA.

How we will protect your data

We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. We will limit access to your personal data to those employees, agents, contractors and other third parties who need to know such information.

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.



How long we will store your personal data

We will only retain your personal data for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements.

To determine the appropriate retention period for personal data, we consider the amount, nature and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal requirements.

Details of retention periods for your personal data are set out below:

  • We will keep information you provide to us when you contact us in respect of a query (in cases where we do not have a business relationship with you or your employer/business) for six months following the date on which we finish dealing with your query.

  • We will keep information you provide to us and which we collect about you during your registration for and use of the Platform for so long as you are a member of the Platform and for a period of up to two years thereafter.

  • Where you have requested to receive our newsletter but you have not registered for an account to use the Platform, we will retain your email address for so long as you wish to continue receiving emails from us or, if less, 24 months after your last “engagement” with us.

  • We will keep technical information collected about you for no more than one month following collection.

  • We do not retain (other than within our own social media profile) or export to our system any personal data we obtain from your social media profile for any purpose.


You have the following rights in respect of the personal data we hold about you:

  • a right of access to a copy of such personal data;

  • a right to object to processing on the basis of our legitimate interests that is likely to cause or is causing damage or distress to you;

  • a right to object to processing for direct marketing;

  • a right in certain circumstances to have inaccurate personal data rectified, blocked or destroyed;

  • a right to request that we restrict our processing of your personal data in certain circumstances;

  • a right in certain circumstances to request that your personal data be transferred to you or another provider;

  • a right to request erasure of the personal data we hold about you; and

  • a right not to be subject to a decision based on solely automated processing which produces legal or other significant effects on you.

If you wish to exercise any of these rights, please contact us using the details below.

Cookies

Our website uses cookies to distinguish you from other users of our website. This helps us to provide you with a good experience when you browse our website and also allows us to improve our site.

A cookie is a small file of letters and numbers that we store on your browser or the hard drive of your computer if you agree. Cookies contain information that is transferred to your computer’s hard drive.

We use a number of short lasting cookies including:

  • Strictly necessary cookies. These are cookies that are required for the operation of our website. They include, for example, cookies that enable you to log into secure areas of our website.

  • Functionality cookies. These are used to recognise you when you return to our website. This enables us to personalise our content for you, greet you by name and remember your preferences (for example, your choice of language or region).

You block cookies by activating the setting on your browser that allows you to refuse the setting of all or some cookies. However, if you use your browser settings to block all cookies please note that some parts of our website may become inaccessible or not function properly.

Except for essential cookies, all cookies will expire after a defined number of days.

Please be aware that other terms may apply to you

Our Platform may, from time to time, contain links to and from other websites or applications. If you follow a link to any of these websites or applications, please note that these websites or applications may have their own privacy policies and that we do not accept any responsibility or liability for these policies. Please check these policies before you submit any personal data to these websites or applications.



We may make changes to our privacy notice

Any changes we make to our privacy notice in the future will be posted on our Platform and, where such changes affect the way we collect and/or use your personal data, notified to you the first time you access the Platform following such change.

Your right to make a complaint in respect of our use of your personal data

You have the right to complain in respect of our use of your personal data. If you are a UK resident, your complaint should be addressed to the Information Commissioner’s Office (ICO) (www.ico.org.uk). We would, however, appreciate the chance to deal with your concerns before you approach your relevant supervisory authority so please contact us first before you escalate your complaint.

You can contact us in respect of your personal data

Questions, comments and requests regarding this privacy notice are welcomed and should be addressed to hello@pairwise.co.

 

©2020 by Pairwise