Effective Date: May 20, 2024
This Privacy Policy (the “Policy”) is an integral part of the Tevna Terms of Use (the “Agreement”). All the terms used herein are used with the same meanings as the Agreement provides, unless otherwise are directly set out hereby.
We are dedicated to protecting and respecting your privacy. We take your privacy seriously and will only use your personal data (the “data”) to make the Website available and process your requests after obtaining your consent for the collection and processing of your data as outlined below. This Policy details what data we collect, when, where, and why we collect it, the legal basis for processing it, how we use it, the conditions under which we may disclose it to others, your rights regarding your personal information, and how we keep it secure.
As we may use tracking technologies on the Website (cookies), please review our Cookies Policy for more information on the purposes and methods of our use of cookies.
Whether you have any questions, please contact us at: [email protected].
1. CHANGES AND UPDATES TO POLICY
1.1. Policy Revisions. We may update this Policy to reflect new developments or changes in legislation and the broader data protection landscape. Please check this page regularly to ensure you are aware of any changes.
1.2. Notification of Changes. If we make any material changes to this Policy, we will notify you via email (to the address you have provided). Notifications regarding other changes may be posted at https://tevna.com.
2. YOUR DATA CONTROLLER AND DATA PROCESSORS; THIRD PARTIES
2.1. Data Controller and Processor Information. It is important to know who your data controller and processors are. The data controller is the entity that determines the purposes and means of processing your data, while the data processor is the entity that processes the data on behalf of the controller.
2.2. Data Controller. In this case, your data controller is UnitedTech LP.
2.3. Data Processors. When processing your data, we may engage the following data processors:
G-Suite service which may be represented by Google LLC (California, USA), Google Ireland Limited (the Republic of Ireland), Google Asia Pacific Pte. Ltd. (Singapore), or any other entity that directly or indirectly controls, is controlled by, or is under common control with Google LLC, which is the storage place provider, in order to store the data. Google provides more information on how it processes data in its Privacy Policy;
Google Analytics services which may be represented by Google LLC (California, USA), Google Ireland Limited (the Republic of Ireland), Google Asia Pacific Pte. Ltd. (Singapore), or any other entity that directly or indirectly controls, is controlled by, or is under common control with Google LLC, which is an analytical services provider, in order to analyze the data. Google provides more information on how it processes data in its Privacy Policy;
Facebook Ads Pixel services represented by Facebook, Inc. with a registered office at 1601 Willow Road, Menlo Park, CA, 94025, USA, which is analytical services provider, in order to analyze the data. Facebook provides more information on how it processes data in its Privacy Policy;
LinkedIn Ads Pixel services represented by LinkedIn Corporation with a registered office at 1000 W Maude, Sunnyvale, CA 94085, US, which is analytical services provider, in order to analyze the data. LinkedIn provides more information on how it processes data in its Privacy Policy;
Lever services represented by Lever, Inc. with a registered office at 1125 Mission St, San Francisco, CA, 94103-1514, United States, which is HR processes automatization services provider, in order to direct HR processes. Lever provides more information on how it processes data in its Privacy Policy.
2.4. Third-Party Services. When necessary, we may also engage third-party services and share data with them to help us operate, provide, improve, integrate, customize, support, and market our service and the Website. Specifically, we share data for purposes outlined in section 5 of this Policy. Types of third parties we share information with include:
Cloud storage providers
Data analytics providers
Measurement partners
Marketing partners
Payment processing providers
Communication services providers
By providing these services, these third parties will also be your data processors.
2.5. Legal and Safety Disclosures. We may use and disclose your data to enforce the Agreement, protect our rights, privacy, safety, or property, as well as that of our affiliates, you, or others. We may also respond to requests from courts, law enforcement agencies, regulatory agencies, and other public and government authorities, or in other cases as required by law.
2.6. International Data Transfers. If we transfer personal data originating from the EEA to countries with inadequate levels of data protection, we use one of the following legal bases:
Standard Contractual Clauses approved by the European Commission
European Commission adequacy decisions about certain countries (details available here).
3. NOTE ABOUT CHILDREN
3.1. Age Restriction. You are prohibited from using the Website if you are under 18 years old or under the age of legal majority in your country. We do not knowingly process personal data from individuals under 18 years of age.
3.2. Handling Minors' Information. If a minor submits personal information to us, and we become aware that the information belongs to a child under the legal age range, we will attempt to delete the information as soon as possible. If you believe we may have any personal information of a child under the legal age range, please contact us at [email protected].
4. DATA THAT WE PROCESS
4.1. Definition of Data. “Data“ refers to any information related to you that, alone or combined with other information, allows the person who collected and processed it to identify you as an individual. “Processing“ of data includes any action taken with your data, such as collecting, storing, transferring, etc.
4.2. Types of Data Collected. We, either independently or with the help of data processors, may collect the following data about you:
Data received when you contact us: Preferred language of communication (English or Ukrainian), name, email, CV, and any information included in the CV.
Data received when you use the Website: Session duration, interaction history with the Website, survey responses, data provided to our support team including the language of your requests, and other information you may voluntarily provide by adding it to your profile or sending us direct messages.
Data collected automatically: How you found us, IP address, time zone, device type and model, device settings, operating system, Internet service provider, mobile carrier, hardware ID, country, region, city, and your activity on the Website.
Cookies and tracking identifiers: As outlined in our Cookies Policy.
5. PURPOSES AND LEGAL BASES OF DATA PROCESSING
5.1. Processing Purposes. We process your information for the following purposes:
Website Access and Services: To make the Website accessible to you and provide you with relevant services.
Communication: To communicate with you regarding your use of the Website, respond to your requests, and update you on services, information, and products.
Notifications: To inform you of any crucial information or changes within the Website that may affect you.
Analytics and Optimization: To analyze the number of active users, support users from different regions, ensure proper functionality of various Website versions, and optimize the Website.
Security and Enforcement: To keep the Website safe and secure, enforce the Agreement, and prevent and combat fraud.
Statistical Studies: To generate statistical studies of the market.
Legal Compliance: To comply with our legal obligations.
5.2. News and Information. We may send you news and information about us and the Website, either upon your request or if we believe it may interest you. In most cases, we will contact you via email.
5.3. Legal Bases for Processing Your Data. We process your data under the following legal bases:
Performing the Contract (the Agreement) with You:
To make the Website available for your access and provide you with the most relevant services.
To communicate with you regarding your use of the Website, respond to your requests, and update you on services, information, and products.
To notify you of any crucial information or changes within the Website that may affect you.
Our Legitimate Interest:
To send you marketing communications.
To analyze the number of active users, support users from different regions, and ensure the proper functioning of various versions of the Website, as well as to develop and optimize the Website.
To keep the Website safe and secure, enforce the Agreement, and prevent and combat fraud.
To comply with our legal obligations.
5.4. Marketing and Consent. Please note that when data is collected for marketing purposes, you will be asked for your consent for such processing. Additionally, you will always have the option to withdraw your consent free of charge by clicking on the “Unsubscribe“ button in the marketing email sent to you.
6. DURATION AND LOCATION OF PROCESSING
6.1. Duration of Data Processing. Your data will be processed for the duration of your use of the Website and up to the termination of such use or the Agreement. This includes the deletion, blocking, or suspension of your account on the Website. After this period, we will terminate the processing of your personal information, unless a special retention period is mandated by relevant legislation.
6.2. Right to Restrict Data Processing. You have the right to restrict our processing of your data by sending a data erasure request or a notice prohibiting us from processing your data. Please note that this action may result in the loss of access to the Website and may prevent us from responding to your inquiries.
6.3. Data Location. Our servers are based in the UK. Therefore, the place of your data collection is within the territory of the European Economic Area (EEA).
7. TRACKING TECHNOLOGIES
7.1. Use of Cookies and Other Tracking Technologies. We may use cookies and other tracking technologies to enhance your user experience and to gather data on how the Website is being used. This data helps us develop and optimize the Website. Please refer to our Cookies Policy for more information.
8. YOUR DATA SUBJECT’S RIGHTS
8.1. Being a data subject, you have the following rights:
a right to request us to access to your data: you can ask us what personal information of yours is being processed as well as for the clarifications on the information described above, i.e. purpose of collecting and processing, period of processing, third parties that have access to information. To exercise the right, please contact us at [email protected];
a right to request us to rectify your personal information: you can ask all the inaccurate personal information concerning you being corrected. You can also complete the personal information if you feel there is a need to do so. To exercise the right, please contact us at [email protected] or use a specific area of your account on the Website;
a right to request us to erase personal information: you can request us to erase such data if its processing is no longer necessary in relation to the purposes for which it was collected, as well as if there are no legal grounds for the processing. In most cases we will erase it unless otherwise will be required by legislation. To exercise the right, please contact us at [email protected];
a right to request us to restrict the processing of your data: for example if you contest the accuracy of your data being processed or in case we will not be interested to process your personal information any longer, but you will want us to do this on different reasons, for example, to bring some claim for somebody and instead of the erasure of information its processing will be just restricted. To exercise the right, please contact us at [email protected];
a right to withdraw your consent for the collection and processing of your data by us at any time, without affecting the lawfulness of processing based on consent before its withdrawal. To exercise the right, please contact us at [email protected];
a right to lodge a complaint with supervisory authority;
a right to data portability. To exercise the right, please contact us at [email protected].
8.2. We will provide information on action taken on your request related to your rights specified above within one month of receipt of the request for the longest. That period may be extended by two further months if we are overwhelmed by the number of requests. We will inform you of any such extension within one month of receipt of the request, together with the reasons for the delay.
9. PROTECTION OF DATA
9.1. We implement technical and organizational measures to ensure that your information is processed in a manner that ensures its security. This includes protection against unauthorized or unlawful processing, as well as against accidental loss, destruction, or damage. For instance, we employ verified contractors who might have access to your data as specified in section 4 of this Policy. We ensure that relevant data processing agreements are signed with these contractors to maintain the security and integrity of your data.
10. REACH US OUT
We will be glad to hear something from you. If you have any questions regarding this Policy, please contact us at [email protected].
UnitedTech LP, Office 7 Centrum Offices, 38 Queen Street, Glasgow, Scotland, G1 3DX, reg. number SL035946