Privacy Policy

Privacy Policy
Privacy Policy 2018-05-09T13:11:18+00:00

By joining Expact, signing up and accepting our Terms and Conditions and this Privacy Policy, you are giving us your permission to process your personal data pursuant to conditions of this Privacy Policy.

Our company respects your right to privacy. This Privacy Policy explains what information we collect from you, for what purpose and how we use it.

We recommend reading this Privacy Policy together with Terms and Conditions to get the full understanding of the mechanism of privacy protection. Please, read this Privacy Policy and Terms and Conditions carefully.

Terms used in this Privacy Policy have the same meaning as in the Terms and Conditions, unless specified otherwise. In case of any questions regarding this Privacy Policy, do not hesitate to contact us via info@expact.xyz.

  1. About Expact

    1. Expact OÜ is a company registered under the laws of Estonia, that owns online service on the website xyz which provides a marketplace, that connects job seekers to potential employers in the ICT sector. We enable job seekers to send us their profiles and resumes, assess their suitability, interviewing them and connect them with the potential employers.
    2. Hereby we determine and explain the purpose of the processing and collecting the data and the persons to whom communication of the data is permitted, the conditions for communicating the data to third persons and your rights concerning the further processing of your personal data, as well information regarding direct marketing and cookies.
  2. Collection of data

    1. We process (including collect, store, save, distribute, compile, use, make available to, etc.) personal data submitted by you at the sign up and on interviews. We do not collect any personal data about you which is made available outside our website and interviews.
    2. We collect and process the personal identifiable information about you, such as your full name, date of birth, location, work experience, skills, education, contact information and e-mail address. You do not have to provide any other personal data which is not mentioned in our sign up or interview. We do not request sensitive data, such as data, revealing racial or ethnic origin, political opinions, religious or philosophical beliefs, trade-union membership; data concerning health or sex life and sexual orientation; genetic data or biometric data.
    3. We collect and process job seeker’s personal data for the purpose of matching up to employers across the globe for ICT jobs. Upon job seekers separate consent we forward data to the employers to enable to decide whether the job seeker is the one they are looking for. We may also use the personal data such as contact details to resolve any service quality issues between us.
    4. We use your personal information to create a profile of you. As a user of our services, you agree that we may assess your skills, experiences, current location or other characteristics and express our preferences to the employers. Upon your separate consent, we may provide your profile to an employer even if you are not applying for the vacant position. We may help the employers with pre-selection of possible employees during which we may add to your profile some comments on why we feel that you are the best for this position. All the data you make available on your account shall be available to potential employers as it is provided by you.
    5. If you make your social media profiles available when using our services, we assure that we do not store, compile or analyze your social media data, unless you have authorized us to do so.
    6. Expact complies with the Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 on the protection of natural persons with regard to the processing of personal data and on the free movement of such data (General Data Protection Regulation).
  3. Disclosing data

    1. Personal data is disclosed only to employers who are business partners of Expact. Profile and other personal information are not available to general public and it is not allowed to be indexed by search engines. In order to request a report on the data we have about you please contact our support at info@expact.xyz to request this report.
    2. For the purposes of improving your user experience when using Expact services, some of the personal data you have provided to us is disclosed to web analytics service and applicant tracking system (ATS) software provider. Web analytics service provider analyze your use of the Expact website and services so we could improve the way our website functions. Applicant tracking system is a software application that allows an organization to collect and store candidate and job-related data and track and monitor the process of candidates through all stages of the hiring process. At the moment of accepting this Privacy Policy, personal data is transferred to following web analytic service and ATS software provider, which is a Privacy Shield Participant:

    3. The Rocket Science Group, LLC / MailChimp, address in Georgia, USA, e-mail address privacy@mailchimp.com, for further information please also see mailchimp.com/legal/terms;

    4. By accepting our Terms and Conditions and this Privacy Policy you therefore also understand and agree that upon disclosing your personal data to web analytics service and ATS software providers, some of your personal data is transferred to and processed outside the European Economic Area. In case of any question about the transfer of your personal data to web analytics service and ATS software providers, please contact our support at info@expact.xyz.
    5. We will not disclose your personal data to any other third parties or public authorities not mentioned above, except if the person requesting data has a legal basis for doing so pursuant to applicable law.
  4. Accessing and storing data

    1. Only authorized employees of Expact have access to the personal data and they may access the data only for the purpose of resolving issues associated with the use of our services.
    2. Pursuant to an applicable law we may transfer, process and store personal data in reputable and sufficient cloud databases that are located outside of Estonia and European Union. We reserve the right to change the cloud service provider at any time without prior notice. We take necessary steps to ensure an adequate level of protection of stored data as well as limitation of processing of sensitive and special data.
  5. Direct marketing and newsletters

    1. We only use your e-mail address to send notifications regarding certain actions on your profile or to suggest opportunities that match your profile. If you no longer wish to receive these opportunities, please click the “Unsubscribe” link in the footer of our e-mail.
  6. Cookies

    1. When using expact.xyz you agree that we may send cookies – text files containing alphanumeric information – to your device that uniquely identifies your browser and lets us provide services to you more effectively. Expact.xyz uses session cookies, which are deleted after you close your browser, and persistent cookies, which are stored on your computer indefinitely. Expact.xyz reserves a right to use first-party or third-party cookies. Expact.xyz may use user-input, authentication, user-centric security, multimedia content player, load-balancing, user-interface customization and third-party social plug-in content sharing cookies, which do not necessarily require informed consent from the user to be used. In order to use other types of cookies, we require your informed consent.
    2. If you wish to delete or block the cookies on your device, please refer to the technical information provided by your device or software manufacturer. Please bear in mind that disabling and/or deleting cookies may prevent you from using some or all services provided by expact.xyz. If you have any questions regarding our cookie policy, please do not hesitate to contact us at info@expact.xyz.
  7. Rights of data subjects

    1. Each data subject shall have the right granted by the European legislator to obtain from the controller the confirmation as to whether or not personal data concerning him or her are being processed. If a data subject wishes to avail himself of this right of confirmation, he or she may, at any time, contact the expact.xyz.
    2. Each data subject shall have the right granted by the European legislator to obtain from the controller free information about his or her personal data stored at any time and a copy of this information. Furthermore, the European directives and regulations grant the data subject access to the following information:

      -the purposes of the processing;

      -the categories of personal data concerned;

      -the recipients or categories of recipients to whom the personal data have been or will be disclosed, in particular recipients in third countries or international organizations;

      -where possible, the envisaged period for which the personal data will be stored, or, if not possible, the criteria used to determine that period;

      -the existence of the right to request from the controller rectification or erasure of personal data, or restriction of processing of personal data concerning the data subject, or to object to such processing;

      -the existence of the right to lodge a complaint with a supervisory authority;

      where the personal data are not collected from the data subject, any available information as to their source;

      -the existence of automated decision-making, including profiling, referred to in Article 22(1) and (4) of the GDPR and, at least in those cases, meaningful information about the logic involved, as well as the significance and envisaged consequences of such processing for the data subject.

      Furthermore, the data subject shall have a right to obtain information as to whether personal data are transferred to a third country or to an international organization. Where this is the case, the data subject shall have the right to be informed of the appropriate safeguards relating to the transfer.

    3. Each data subject shall have the right granted by the European legislator to obtain from the controller without undue delay the rectification of inaccurate personal data concerning him or her. Taking into account the purposes of the processing, the data subject shall have the right to have incomplete personal data completed, including by means of providing a supplementary statement. If a data subject wishes to exercise this right to rectification, he or she may, at any time, contact our Data Protection Officer or another employee of the controller.
    4. Each data subject shall have the right granted by the European legislator to obtain from the controller the erasure of personal data concerning him or her without undue delay, and the controller shall have the obligation to erase personal data without undue delay where one of the following grounds applies, as long as the processing is not necessary:

      -The personal data are no longer necessary in relation to the purposes for which they were collected or otherwise processed.

      -The data subject withdraws consent to which the processing is based according to the point (a) of Article 6(1) of the GDPR, or point (a) of Article 9(2) of the GDPR, and where there is no other legal ground for the processing.

      -The data subject objects to the processing pursuant to Article 21(1) of the GDPR and there are no overriding legitimate grounds for the processing or the data subject objects to the processing pursuant to Article 21(2) of the GDPR.

      -The personal data have been unlawfully processed.

      -The personal data must be erased for compliance with a legal obligation in Union or Member State law to which the controller is subject.

      -The personal data have been collected in relation to the offer of information society services referred to in Article 8(1) of the GDPR.

      If one of the aforementioned reasons applies, and a data subject wishes to request the erasure of personal data stored by the expact.xyz, he or she may at any time contact the expact.xyz. The Data Protection Officer of the expact.xyz or another employee shall promptly ensure that the erasure request is complied with immediately.

      Where the controller has made personal data public and is obliged pursuant to Article 17(1) to erase the personal data, the controller, taking account of available technology and the cost of implementation, shall take reasonable steps, including technical measures, to inform other controllers processing the personal data that the data subject has requested erasure by such controllers of any links to, or copy or replication of, those personal data, as far as processing is not required. The Data Protection Officer of the expact.xyz or another employee will arrange the necessary measures in individual cases.

    5. Each data subject shall have the right granted by the European legislator to obtain from the controller restriction of processing where one of the following applies:

      -The accuracy of the personal data is contested by the data subject, for a period enabling the controller to verify the accuracy of the personal data.

      -The processing is unlawful and the data subject opposes the erasure of the personal data and requests instead the restriction of their use instead.

      -The controller no longer needs the personal data for the purposes of the processing, but they are required by the data subject for the establishment, exercise or defense of legal claims.

      -The data subject has objected to processing pursuant to Article 21(1) of the GDPR pending the verification whether the legitimate grounds of the controller override those of the data subject.

      If one of the aforementioned conditions is met, and a data subject wishes to request the restriction of the processing of personal data stored by the expact.xyz, he or she may at any time contact us. The Data Protection Officer of the expact.xyz or another employee will arrange the restriction of the processing.

    6. Each data subject shall have the right granted by the European legislator, to receive the personal data concerning him or her, which was provided to a controller, in a structured, commonly used and machine-readable format. He or she shall have the right to transmit those data to another controller without hindrance from the controller to which the personal data have been provided, as long as the processing is based on consent pursuant to point (a) of Article 6(1) of the GDPR or point (a) of Article 9(2) of the GDPR, or on a contract pursuant to point (b) of Article 6(1) of the GDPR, and the processing is carried out by automated means, as long as the processing is not necessary for the performance of a task carried out in the public interest or in the exercise of official authority vested in the controller.

      Furthermore, in exercising his or her right to data portability pursuant to Article 20(1) of the GDPR, the data subject shall have the right to have personal data transmitted directly from one controller to another, where technically feasible and when doing so does not adversely affect the rights and freedoms of others.

      In order to assert the right to data portability, the data subject may at any time contact the expact.xyz.

    7. Each data subject shall have the right granted by the European legislator to object, on grounds relating to his or her particular situation, at any time, to processing of personal data concerning him or her, which is based on point (e) or (f) of Article 6(1) of the GDPR. This also applies to profiling based on these provisions.

      The expact.xyz shall no longer process the personal data in the event of the objection unless we can demonstrate compelling legitimate grounds for the processing which override the interests, rights, and freedoms of the data subject, or for the establishment, exercise or defense of legal claims.

      If the expact.xyz processes personal data for direct marketing purposes, the data subject shall have the right to object at any time to the processing of personal data concerning him or her for such marketing. This applies to profiling to the extent that it is related to such direct marketing. If the data subject objects to the expact.xyz to the processing for direct marketing purposes, the expact.xyz will no longer process the personal data for these purposes.

      In addition, the data subject has the right, on grounds relating to his or her particular situation, to object to processing of personal data concerning him or her by the expact.xyz for scientific or historical research purposes, or for statistical purposes pursuant to Article 89(1) of the GDPR, unless the processing is necessary for the performance of a task carried out for reasons of public interest.

      In order to exercise the right to object, the data subject may directly contact the expact.xyz. In addition, the data subject is free in the context of the use of information society services, and notwithstanding Directive 2002/58/EC, to use his or her right to object by automated means using technical specifications.

    8. Each data subject shall have the right granted by the European legislator not to be subject to a decision based solely on automated processing, including profiling, which produces legal effects concerning him or her, or similarly significantly affects him or her, as long as the decision (1) is not is necessary for entering into, or the performance of, a contract between the data subject and a data controller, or (2) is not authorized by Union or Member State law to which the controller is subject and which also lays down suitable measures to safeguard the data subject’s rights and freedoms and legitimate interests, or (3) is not based on the data subject’s explicit consent.

      If the decision (1) is necessary for entering into, or the performance of, a contract between the data subject and a data controller, or (2) it is based on the data subject’s explicit consent, the expact.xyz shall implement suitable measures to safeguard the data subject’s rights and freedoms and legitimate interests, at least the right to obtain human intervention on the part of the controller, to express his or her point of view and contest the decision.

      If the data subject wishes to exercise the rights concerning automated individual decision-making, he or she may at any time directly contact the expact.xyz.

    9. Each data subject shall have the right granted by the European legislator to withdraw his or her consent to the processing of his or her personal data at any time. If the data subject wishes to exercise the right to withdraw the consent, he or she may at any time directly contact the expact.xyz.