Privacy Policy

Feefor Ltd: Privacy Policy

Last updated: 12^th July 2023

This Privacy Notice explains who we are, how we collect, use and disclose your personal data and how you can exercise your privacy rights. If you have any questions or concerns about our use of your personal data, or would like a printable version of this Privacy Notice, then please contact us using the details provided at the bottom of this Privacy Notice. If you are located in the European Union or the United Kingdom, the controller of your personal data is Feefor Ltd.

About us

Feefor provides an internet-based recruitment solution that uses referrers to help employers (our “Clients”) find the best talent for their roles. We obtain data about referrers and prospective candidates who use our platform.

What does this Privacy Notice cover?

This Privacy Notice applies to our collection, use and disclosure of personal data that relates to:

(a) individuals who use our platform to source candidates for their roles (“Employer Users”);

(b) referrers who help to identify potential candidates for vacancies within our platform (“Users”); and

This Privacy Policy applies only where we are processing personal data as a data controller.

This Privacy Policy does not apply to the actions or activities of third party companies or organizations that we work with or any third party websites or platforms that link to or can be accessed through our website or platform.

What personal data do we collect?

Information about Employer Users:

We need to collect and use information about you in order for you to use our platform. The personal data that we may collect about you broadly falls into the following categories:

Information you provide voluntarily: We ask you to provide certain information voluntarily. This typically includes:

Log-in credentials, such as your username and password;
Identification data, such as name, company, job title, location;
Contact data, such as email address, telephone number;
Payment information, such as your billing address where you pay for our services;
Communications data, such as chat messages;
Support data, such as information about a technical issue you have reported.

We will also generate a unique User ID that we use to identify you when you are using the platform.

If we ask you to provide any other personal data not described above, then the personal data we will ask you to provide, and the reasons why we ask you to provide it, will be made clear to you at the point we collect the information.

Information we collect automatically: Like most companies that offer online services, we may also collect certain information automatically about your computer or device and usage of our services using cookies and similar tracking technology. In some countries, including countries in the European Economic Area and the United Kingdom, this information may be considered personal data under applicable data protection laws. This includes:

Device information, such as your IP address, operating system, device type and manufacturer and browser type;
Usage data, such as the dates and times you access the services and your browsing activities (such as what portions of the services you use, session durations, links clicked, non-sensitive text entered, and mouse movements).

Please see the section “Cookies and similar tracking technology” below for more information.

Information about Candidates:

We collect, use and disclose information about Candidates in the course of providing services to our Clients. The personal data that we may collect about you broadly falls into the following categories:

Information you provide voluntarily: We ask you to provide certain information voluntarily. This typically includes:

Log-in credentials, such as your username and password;
Identification data, such as name, company, job title, location;
Contact data, such as email address, telephone number;
Communications data, such as chat messages;
Support data, such as information about a technical issue you have reported.
A Curriculum Vitae or Personal Profile which you will need to apply for vacancies

We will also generate a unique User ID that we use to identify you when you are using the platform.

Device information, such as your IP address, operating system, device type and manufacturer and browser type;
Usage data, such as the dates and times you access the services and your browsing activities (such as what portions of the services you use, session durations, links clicked, non-sensitive text entered, and mouse movements).

Please see the section “Cookies and similar tracking technology” below for more information.

Information about Users

We need to collect and use information about you in the course of providing our services. The personal data that we may collect broadly falls into the following categories:

Information you provide voluntarily: We ask you to provide certain information voluntarily. This typically includes:

Log-in credentials, such as your username and password;
Identification data, such as name, company, job title, location;
Contact data, such as email address;
Payment information, such as your bank account information where we pay you for referring Candidates to our Clients;
Communications data, such as chat messages;
Support data, such as information about a technical issue you have reported.

We will also generate a unique User ID that we use to identify you when you are using the services.

Device information, such as your IP address, operating system, device type and manufacturer and browser type;
Usage data, such as the dates and times you access the services and your browsing activities (such as what portions of the services you use, session durations, links clicked, non-sensitive text entered, and mouse movements).

Please see the section “Cookies and similar tracking technology” below for more information.

How do we use your personal data?

We use personal data about you for the following purposes:

Provide, maintain and improve our services;
Enable users to register a user account with our platform and create and maintain their profile;
Share information about Candidates with our Clients so that they can assess their adequacy for a given job opportunity;
Share information about vacancies with Users so they can refer Candidates they know to the respective Client;
Send out technical notices, updates, security alerts, and support and administrative messages to our Users;
Communicate with our Users about news and information relating to our services;
Monitor and analyze trends, usage, and activities in connection with our services;
Personalize and improve our services;
Detect, prevent and respond to potential fraud, violations of our terms and conditions or other misuse of our services;
Comply with our legal obligations.

In general, we will use the personal data we collect from you only for the purposes described in this Privacy Notice or for purposes that we explain to you at the time we collect your personal data. However, we may also use your personal data for other purposes that are not incompatible with the purposes we have disclosed to you if and where this is permitted by applicable data protection laws.

Feefor only uses sensitive personal information to provide the services that you have requested, including to maintain your account and ensure the security of the services. Feefor does not share your personal information except as approved by you or as otherwise described in this Privacy Notice.

We may also collect aggregate and/or de-identified data. Information that is an aggregate, non-identifiable form or that has been de-identified is not personal information. Where we have de-identified information, we will not attempt to re-identify the information except as permitted by applicable law.

Who do we share your information with?

We may disclose your personal data to the following categories of recipients:

We may share your information with our third party service providers and partners who provide data processing services to us (such as data storage providers, analytics services, marketing services, and external consultants and professional advisers);
For Candidates, we may share your information with our Clients in order to provide our services to them and for the purposes described in this Privacy Notice;
For Candidates, we may share some of your information with our Users with whom we liaise in connection with providing the services to our Clients;
We may share your information with any competent law enforcement body, regulatory, government agency, court or other third party where we believe disclosure is necessary (i) as a matter of applicable law or regulation, (ii) to exercise, establish or defend our legal rights, or (iii) to protect your vital interests or those of any other person;
We may share your information with a potential buyer (and its agents and advisers) in connection with any proposed purchase, merger or acquisition of any part of our business, provided that we inform the buyer it must use your personal data only for the purposes disclosed in this Privacy Notice;
We may share your information with any other person with your consent to the disclosure.

What is our legal basis to process your information? (European individuals only)

If you are located in the European Union or the United Kingdom, we need a legal basis to collect, use and disclose your personal data. Our legal basis for collecting, using and disclosing your information will depend on the information concerned and the context in which it is processed.

Users:

We may process your personal data in order to perform a contract with you (such as to register and maintain your account and process your payment information). In other circumstances, we may process your information where the processing is in our legitimate interests (such as to communicate with you about news and information relating to our services, monitor and analyze usage trends, and personalize and improve our services).

When required, we will process your personal data only where we have your consent to do so (for example, if we need to collect and process any sensitive personal data about you). In limited cases, it may be necessary for us to process your information to comply with a legal obligation to which we are subject (such as to share your information with a law enforcement body or regulatory agency where disclosure is required by law, or to exercise, establish or defend our legal rights).

Candidates:

We will usually process your information where the processing is in our legitimate interests (such as when we share certain information about you with our Clients, or when we contact you on behalf of our Clients to tell you about a job opportunity that may be of interest to you). We only share your contact information with our Clients where we have your consent to do so.

In limited cases, it may be necessary for us to process your information to comply with a legal obligation to which we are subject (such as to share your information with a law enforcement body or regulatory agency where disclosure is required by law, or to exercise, establish or defend our legal rights).

Cookies and similar tracking technologies

We use cookies and similar tracking technologies to collect and use personal data about you on our website and through the services. Specifically, the information we collect automatically may include information like your IP address, device type, unique device identification numbers, browser-type, broad geographic location (e.g. country or city-level location) and other technical information. We may also collect information about how you have interacted with our website and services, including the pages accessed and links clicked, session duration, non-sensitive text entered, and mouse movements. Collecting this information enables us to better understand how people are using our website and services and we use the information for our internal analytics purposes to improve the quality and relevance of our services.

Google Analytics: We may use cookies served by Google Analytics to collect limited data directly from you to enable us to better understand your use of our website, including making use of the demographics and interests reports services of Google Analytics. Further information on how Google collects and uses this data can be found at www.google.com/policies/privacy/partners/. You can opt-out of all Google supported analytics within the services by visiting https://tools.google.com/dlpage/gaoptout.

International data transfers

Your personal data may be transferred to, and processed in, countries other than the country in which you are located. These countries may have data protection laws that are different to the laws of your country (and, in some cases, may not be as protective).

Feefor is headquartered in the United Arab Emirates and our servers are located in Dubai (probably India in the short term). Our third party service providers and partners operate globally, and this means that when we collect your personal data we may process it in any country worldwide.

Data retention

We retain personal data we collect from you where we have an ongoing legitimate business need to do so (for example, to provide you with a service you have requested or to comply with applicable legal, tax or accounting requirements).

When we have no ongoing legitimate business need to process your personal data, we will either delete or anonymise it or, if this is not possible (for example, because your personal data has been stored in backup archives), then we will securely store your personal data and isolate it from any further processing until deletion is possible.

Your privacy rights

Depending on your location and applicable data protection laws, you may have certain rights with regard to the personal data we control about you.

Right of access. You may have the right to confirm whether we are processing your personal data and obtain a copy of your personal data.
Right of correction. You may have the right to request that we correct any inaccurate personal data that we process about you, subject to certain exceptions.
Right to deletion. You may have the right to request that we delete your personal data, subject to certain exceptions.
Right to data portability. You may be able to request portability of your personal data by obtaining a copy of your data in a portable, read-usable format.
Right to object and restrict processing. If you are located in the European Union or United Kingdom, you can object to processing of your personal data or ask us to restrict processing of your personal data.
Opt-out from marketing. You have the right to opt-out of marketing communications we send you at any time. You can exercise this right by clicking on the “unsubscribe” or “opt-out” link in the marketing e-mails we send you or by contacting us as described below.
Withdrawing consent. If we have collected and process your personal data with your consent, then you can withdraw your consent at any time. Withdrawing your consent will not affect the lawfulness of any processing we conducted prior to your withdrawal, nor will it affect processing of your personal data conducted in reliance on lawful processing grounds other than consent.

Users in some geographies also have the right to opt out from the “sale” of their personal data. This term is defined broadly and may apply to our sharing of personal data about Candidates with our Clients. If you are a Candidate, we may have “sold” your identification data, contact data, and/or professional profile data (as described above) to our Clients.

How to exercise your rights.

If you wish to exercise your rights, you can do so at any time by emailing us at info@feefor.com. In some cases, you may also authorize an agent to submit a request on your behalf.

We respond to all requests we receive from individuals wishing to exercise their data protection rights in accordance with applicable data protection laws. To help protect the security of your information, we may ask you to provide additional information to verify your identity before responding. In addition, if you authorize an agent to make a request on your behalf, we may require the agent to provide proof of authorization or require you to confirm that you gave the agent permission to submit the request. If we are unable to verify your identity, or confirm your agent’s authorization, we may not be able to fulfil your request.

Appeals and complaints.

If you are unhappy with how we have handled your request, you may have the right to appeal our decision under applicable data protection laws. In order to do so, please email us at info@feefor.com and provide information relating to your request and our handling of it, so that we may adequately address your appeal. We will respond to your appeal in accordance with applicable data protection laws. Similarly, you may also have the right to complain to a data protection authority about our collection and use of your personal data. Please note that we will not discriminate against you for exercising any of your rights under applicable data protection laws.

Updates to this Privacy Notice

We may update this Privacy Notice from time to time. We will take appropriate steps to notify you of any material changes to this Privacy Notice and obtain your consent if and where this is required by applicable data protection laws. You can see when this Privacy Notice was last updated by checking the “last updated” date at the top of this Privacy Notice.

How to contact us

If you have any questions or concerns about our use of your personal data, or would like to submit a rights request, please contact us by email at info@feefor.com