Privacy Policy Last update 6 months ago
The terms “us,” “we,” “our” refer to Xp Freelancer and its managing companies: Paperjet Technologies Ltd. (71-75 Shelton Street, Covent Garden, London, United Kingdom, London, United Kingdom). “You” or “User” means you as a user of the Site.
Xp Freelancer provides this Privacy Policy to inform you about the policies and procedures governing our collection, use, and disclosure of information through Xp Freelancer Services. For more on Xp Freelancer Services, please review our Terms of Service page, which governs your use of the Service.
You must read, agree to, and accept all of the terms and conditions contained in Xp Freelancer's Terms of Service to use Xp Freelancer Products. If you do not accept the Terms of Service or the Privacy Policy, you must not access or use Xp Freelancer Products after the Last Updated date. For more detailed policies surrounding the activity and usage on the Site, please access the designated sections herein.
Definitions
Personal data
Personal data means any information relating to an identified or identifiable natural person; an identifiable natural person is one who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier, or one or more factors specific to the physical, physiological, genetic, mental, economic, cultural, or social identity of that natural person.
Processing
Processing means any operation or set of operations that is performed on personal data or on sets of personal data, whether or not by automated means, such as collection, recording, organization, structuring, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination, or otherwise making available, alignment or combination, restriction, erasure, or destruction.
Third party
Third party means a natural or legal person, public authority, agency, or body other than the information subject, controller, processor, and persons who are authorized to process personal information under the direct authority of the controller or processor.
Controller
Controller means the natural or legal person, public authority, agency, or other body which, alone or jointly with others, determines the purposes and means of the processing of personal data; where the purposes and means of such processing are determined by law, the controller or the specific criteria for its nomination may be provided for by law.
Processor
Processor means a natural or legal person, public authority, agency, or other body which processes personal information on behalf of the controller.
Xp Freelancer acts as the Controller of the personal data you provide directly to us via the Contact Support form, when creating an account, or via phone or email communication. You are not required to provide your personal information for purposes of navigating through the public areas of our website.
Xp Freelancer acts as the Processor of your personal data whenever you are an employee or an authorized representative of one of our clients, who has entered into an agreement with us for the provision of our products or services. Our client will act as the Controller of your information. As the Processor, we do not own, control, or use any data provided to us by our clients who act as Controllers.
Sub-processors
Sub-processors mean any Data Processor engaged by Xp Freelancer to assist in fulfilling its obligations with respect to providing the Services pursuant to the Terms of Service or this Privacy Policy. A complete list of Sub-processors is available at the bottom of this document.
Personal information
Personal information is any information that identifies you as a specific individual and can be used to contact or identify you. Examples of personal information include your name, your company name, email address, billing address, and phone number. See “Personal Data.”
Payment information
If you use the Service to make payments as a buyer or receive payments as a seller, we will collect your payment information for the sole purpose of such actions and only to the extent required by law.
General Audience Service
Xp Freelancer Services are available and intended for users who have reached the age of majority in the jurisdiction in which they conduct business. We do not knowingly collect personal information from minors. If we become aware that an individual who has yet to reach the age of majority has provided us with personal information, we will use reasonable efforts to delete such information from our files.
User profiles
Users (buyers and sellers alike) create a personal profile with certain or all information publicly available.
When a user creates a profile, which consists of information about them and may include personal information, photographs, profile pictures, examples of work, information on work previously performed, skills, rates, ratings and reviews, and username, such information will be visible to all the users of Xp Freelancer Services.
USE OF INFORMATION
Xp Freelancer uses Google Analytics to collect data about visitors. Xp Freelancer Services use the information collected to provide and improve services, process your requests, prevent fraud, provide you with information that may interest you, comply with the law, and as otherwise permitted with your consent.
The information we collect is used to:
Provide you services and improve such services, complete your transactions, address your inquiries, process your registration, and for compliance and internal business purposes. Internal business purposes may include, but are not limited to the following: ban of a User’s IP address in case of repeated violation of Xp Freelancer’s Terms of Service; blocking of a User’s access to other services provided by Paperjet in case of violation of Xp Freelancer’s Terms of Service, etc.
Contact you with administrative communications, Xp Freelancer’s newsletter, and marketing or promotional materials relevant to Xp Freelancer’s. You receive such emails because your email address is registered on Xp Freelancer and you provided your consent upon signing up. If you wish to unsubscribe, click the link at the bottom of Xp Freelancer marketing emails or contact us at [email protected].
Tailor content we display to you and offers we present to you.
Protect the property and rights of Xp Freelancer Services, to prevent or stop an activity that we may consider to be, or to pose a risk of being fraudulent, illegal or legally actionable.
We do not collect sensitive information such as GPS information, race or ethnicity, political opinions, religious or philosophical beliefs, trade union membership, genetic data, sexual orientation and gender identity, biometric data, or health data.
You do not have a statutory obligation to provide us with any information, but you may have a contractual obligation to do so (see our Terms of Service); in the absence of such information, we may not be able to provide our Services to you, in whole or in part.
DATA RETENTION
If you choose to provide us with personal information, we encourage you to routinely update the data to ensure that we have accurate and up-to-date information about you.
We keep your personal information for as long as is required to fulfill the purpose for which it was collected, unless:
You request that we delete certain information (exceptions apply).
The client of whom you are an authorized representative is no longer our client.
How we store information:
We store payment information to ensure the withdrawal of funds, to identify the recipient of funds (only card and wallet numbers).
We do not store payment information for payments.
Your information may persist in copies made for backup and business continuity purposes for additional time only to the extent permitted by law.
Data is deleted upon the formal termination of your relationship with Xp Freelancer, unless otherwise indicated by law.
INFORMATION SHARING AND DISCLOSURE
We may share information we have collected about you with the following parties:
Sub-processors: Sub-processors mean any Data Processor engaged by Xp Freelancer to assist in fulfilling its obligations with respect to providing the Services pursuant to the Terms of Service or this Privacy Policy. A complete list of Sub-processors is available at the bottom of this document.
Authorities and other authorized bodies, and government agencies: In response to lawful requests and as required by law. This includes the provision of services to the user, in case of violations, crimes, and suspicion. We cooperate with government and law enforcement officials to enforce and comply with the law. We will disclose your personal information at our sole discretion and as we believe necessary to respond to claims and legal process, or at the request of authorities conducting an investigation where we determine in our sole discretion the disclosure is necessary to:
Protect the property and rights of Xp Freelancer Services.
Protect the safety of the public or any person.
Prevent or stop activity we may consider to be, or pose a risk of being illegal, fraudulent, unethical, or legally actionable.
Successors: In connection with a merger, acquisition, reorganization, or sale of assets or in the event of bankruptcy to a successor, as required by law and within the framework of universal legal succession. We will require the transferee to agree to our commitments provided in this Privacy Policy.
Auditors: To the extent not exceeding the amount required for the audit.
To comply with the requirements of payment systems, we may request information from you when withdrawing funds from the service. This information may include, but is not limited to:
Full name.
Identity document.
Residential address.
The user assumes responsibility for providing accurate data independently.
Xp Freelancer will store this information in encrypted form and provide it upon request to the payment system or government agencies if required by law (for example, AML).
We do not request any additional information from residents of the Russian Federation.
We may share your personal information for the following reasons: to facilitate our services, to provide such services, provide security, optimization, and maintenance services, database management, web analytics and online advertising, and improvement of Xp Freelancer’s features.
We do not share your personal information with third parties for those third parties’ marketing purposes. All user data is stored on secure servers; it is not provided to third parties, except when needed to support the operation of Xp Freelancer, for marketing purposes to Google Analytics, and when required by law.
REMARKETING
Xp Freelancer Services may use third-party vendor remarketing tracking cookies and pixels, including Google Ads tracking cookies, Facebook and Google Tag Manager tracking code.
You may opt-out of Google’s use of cookies by visiting the Ads Preferences Manager. You may opt-out of Facebook Ads on your Facebook account. Also, you can opt-out of other third-party use of cookies by visiting the Network Advertising Initiative opt-out page.
This means we continue to show ads to you across the Internet, specifically on Google Content Network, and Facebook Ads.
Third-party vendors, including Google, will place cookies in web browsers to serve ads based on past visits to our website. This allows us to make special offers and continue to market our products to those who have shown interest in them. We do not remarket to users in the European Union.
COOKIES AND OPT-OUT RIGHTS
According to applicable law, you have rights associated with your personal information.
Cookies are text files with small pieces of data that are used to identify your computer as you use a computer network. You agree to the storing of cookies on your device in accordance with our Privacy policy.
We make use of and collect cookies and similar technologies (such as pixels, including the Google Ads tracking cookie, Facebook and the Google Tag Manager tracking code) to enhance site navigation, improve and personalize your experience, provide our services, analyze website performance and for marketing purposes. Cookies also allow us to track usage behavior and compile website usage information that will allow for the improvement of content. You have the right to opt-out of cookies by activating the setting on your browser. However, if you decide to opt-out, you may be unable to access certain parts of our website.
IDENTIFICATION AND VERIFICATION FOR PAYOUTS
In order to avoid fraudulent actions while paying out funds, a verification of the recipient of those funds (Cardholder) may be performed.
Users must verify their identity through an authorized partner - a verification service (sumsub.com) (hereinafter – Verification service) when they create a withdrawal request via the Unlimited payment system.
Xp Freelancer does not collect, process, or store personal data necessary for User verification for the purpose of making payouts to the User’s card. Such personal data is collected, processed and stored by the Verification service.
Verification will include but is not limited to:
Verification of ID document.
Verification of residence address.
Sanctions screening (OFAC / PEP lists).
ANALYTICS PROVIDERS
Xp Freelancer works, or may in the future work with, network advertisers, ad agencies, analytics service providers, and other vendors to provide us with information regarding traffic on our Services.
Our service providers may collect certain information about your behavior on our Platform.
Such providers are:
Google Analytics: Google Analytics is a web analytics service offered by Google that tracks and reports website traffic.
Google utilizes the data collected to track and examine the use of this website, to prepare reports on its activities, and to share them with other Google services.
Information collected: Cookie and Usage Data. Visit the Privacy Policy. You may opt-out of the Google Analytics service with the Google's Browser Add-on.
CHILDREN’S PRIVACY
As per Xp Freelancer Terms of Service, we do not allow the use of our Services to individuals who have not reached the age of majority in the jurisdiction in which they conduct business. We do not knowingly collect Personal Information from minors. Parents and guardians should supervise their children’s activities on the Internet at all times. If we learn we have collected or received Personal Information from a minor, we will delete that information. Please contact us at [email protected] if you believe we might have any information about a minor.
DO NOT TRACK REQUESTS
Do Not Track (DNT) is a web browser setting that requests that a web application disable its tracking of an individual user. When you turn on the DNT setting in your browser, your browser sends a special signal to websites, analytic companies, ad networks, plug-in providers, and other web services you encounter while browsing to stop tracking your activity. Every browser communicates DNT requests to websites differently, which may give rise to possible technical errors.
To ensure the best possible Xp Freelancer experience for our users, we currently do not honor DNR requests. However, as the technology and communications between browsers and xpfreelancer.com improve, we will reevaluate our ability to honor DNT requests and may make changes to this Privacy Policy.
LINKS TO OTHER WEBSITES
Our Service may contain links to other websites. If you choose to click on a third-party link, you will be directed to that third party’s website. The fact that we link to a website is not an endorsement, authorization or representation of our affiliation with that third party, nor is it an endorsement of their privacy or information security policies or practices. We do not exercise control over third party websites. These websites may place cookies or other files on your devices, collect data or solicit personal information from you. We encourage you to read the privacy policies of the other websites you visit.
INTERNATIONAL TRANSFER OF PERSONAL INFORMATION
Our servers are located in Germany, we process and store your information in Germany, and our Sub-processors may process Personal Information elsewhere. These countries may not have the same data protection laws as the country in which you initially provided the information.
When we transfer Personal Information from territories in the EEA (The European Economic Area) or similar laws to our service providers outside the EEA, we rely on approved data transfer mechanisms, which may include standard contractual clauses approved by the European Commission.
SUPPLEMENTAL PRIVACY NOTICE FOR EUROPEAN UNION AND EEA RESIDENTS
The EU General Data Protection Regulation (GDPR) is the authority that governs how personal data of individuals in the EU may be processed and transferred. GDPR
Under applicable EU regulation, in respect of your Personal Information, you have the right to:
Obtain information about how and on what basis your personal information is processed and obtain a copy.
Rectify inaccurate personal information.
Request deletion, anonymization or blocking of your Personal information when processing is unnecessary or noncompliant.
Request restriction of or object to processing of your Personal Information when processing is noncompliant.
Obtain a copy of or access to safeguards under which your personal information is transferred outside the EEA.
Xp Freelancer will cooperate with the appropriate EU Data Protection Authorities during investigation and resolution of complaints brought.
As a last resort, complaints regarding a violation of personal privacy that remain unresolved after pursuing these and other channels are subject to mandatory internal arbitration.
YOUR CHOICES AND RIGHTS
As a registered user, you may update your choices regarding the type of communications you receive from us.
You may opt-out of receiving our marketing emails from us by following the opt-out instructions provided in those emails.
Registered users may receive push notifications on their Xp Freelancer’s mobile app. Notifications preferences can be modified in the settings menu for the mobile application.
In accordance with applicable law, you have the right to:
Access Personal Information about you.
Request correction of your Personal Information where it is inaccurate, incomplete, or outdated.
Request deletion of your Personal Information when processing is unnecessary or noncompliant.
Request restriction of or object to processing of your Personal Information when processing is noncompliant.
Withdraw your consent to processing of your Personal Information.
CHANGES TO THIS POLICY
We may update this Privacy Policy at any time, and any changes to it will be effective upon posting. We will notify users to the email address provided upon registration should there be substantial changes to the way we treat Personal Information.
CONTACT US
We would be happy to address any questions or concerns you may have at [email protected] or by mail addressed to:
Xp Freelancer
71-75 Shelton Street, Covent Garden, London, United Kingdom WC2H 9JQ London, UK
Phone: +44 7465 280990