Privacy Policy


Introduction

This policy (together with our terms and conditions as set out at https://jobs.udrafter.com/terms-and-conditions (our "T&Cs") and any additional terms of use incorporated by reference into our T&Cs, together our " Terms of Use") applies to your use of:

- Udrafter mobile application software available for iOS, Android, and through a web-browser on our site hosted at www.udrafter.com (together the " App"), once you have downloaded, streamed, or accessed a copy of the App onto your mobile telephone, handheld device, or personal computer (a "Device").

- Any of the services accessible through the App (our " Services"), unless our T&Cs state that a separate privacy policy applies to a particular Service, in which case that privacy policy only applies.

This policy sets out the basis on which any personal data we collect from you, or that you provide to us, will be processed by us.

This App and our Services are not intended for children and we do not knowingly collect data relating to children.

Please read the following carefully to understand our practices regarding your personal data and how we will treat it.

We have prepared this policy in a layered format so that you can click through to the specific areas set out below. Alternatively, you can download a PDF version of the policy here: [LINK].

Important information and who we are

Who we are

We are Udrafter Limited, a company incorporated and registered in Scotland. Our company number is SC547357 and our registered office is at 137 Garthdee Road, Cults, Aberdeen, Aberdeenshire, United Kingdom, AB10 7AT.

But, for the purposes of this policy, it's just easier if we refer to ourselves as "we" or "us".

We are the controller and organisation responsible for the personal data that you give to us.

If you have any questions about this privacy policy, please contact us using the details below.

Contact details

You can contact us in the following ways:

E-Mail address: info@udrafter.com

Postal address: 137 Garthdee Road, Aberdeen, AB10 7AT

Telephone number: 01224262484

You have the right to make a complaint about your personal data at any time to the Information Commissioner's Office (the "ICO"), which is the supervisory authority within the United Kingdom for data protection issues. If you are outside of the United Kingdom but are a member of a country within the European Union then you can also contact your local supervisory authority if you downloaded or registered for our App outside the United Kingdom.

You can find a list of European Union supervisory authorities [HERE] .

Changes to the privacy policy and your duty to inform us of changes

We keep our privacy policy under regular review.

This version was last updated on [October 13, 2018]. It may change and if it does, these changes will be posted on this page and, where appropriate, we will notify you [by SMS, e-mail, or when you next start the App or log onto our site]. The new policy may be displayed on-screen and you may be required to read and accept the changes to continue your use of our App or our Services.

It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during our relationship with you.

Third party links

Our App and Services may, from time to time, contain links to and from websites of our partner network, affiliates, and payment providers. Please note that these websites and any services that may be accessible through them have their own privacy policies and that we do not accept any responsibility or liability for these policies or for any personal data that may be collected through these websites or services. Please check these policies before you submit any personal data to these websites or use their services.

The data we collect about you

We may collect, use, store and transfer different kinds of personal data about you as follows:

- Identity Data

- Contact Data

- Transaction Data

- Device Data

- Content Data

- Profile Data

- Usage Data

- Communications Data

- Location Data

We explain each of these categories of data here .

We also collect, use, and share anonymised information such as statistical or demographic data for any purpose ("Aggregated Data"). Aggregated Data could be derived from your personal data but is not considered personal data in law as this data will not directly or indirectly reveal your identity. For example, we may aggregate your Usage Data to calculate the percentage of users accessing a specific feature of our App - in this case, your information is anonymised and cannot be traced back to you. However, if we combine or connect Aggregated Data with your personal data so that it can directly or indirectly identify you, then we will treat that combined data as personal data and handle it in accordance with this privacy policy.

We not collect any special categories of personal data about you (this includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health, and genetic and biometric data). Nor do we collect any information about criminal convictions or offences.

How is your personal data collected?

We will collect and process the following data about you:

- Information you give us. This is information (including Identity, Contact, Location, Profile, Content, and Communication Data) you consent to giving us by filling in forms in our App and our site, or by corresponding with us (for example, by e-mail or chat). It includes information you provide when you register to use our App, download our App, subscribe to any of our Services, share data via the App's and our sites built-in communication functions, and when you report a problem with our App, our Services, or our site. If you contact us, we will keep a record of that correspondence.

Information we collect about you and your device. Each time you use our App, our site, and any of our Services, we will automatically collect personal data including information about your Device, Content, and Usage Data. We collect this data using cookies and other similar technologies that may be integrated into our App and our site. Please see our https://jobs.udrafter.com/privacy-policy - cookies for further details.

- Location Data. We may also use GPS technology, BSSID technology, or other similar technologies to determine your current location. Some of our location-enabled Services require your personal data for the feature to work. If you wish to use these particular features, you will be asked to consent to your data being used for this purpose. You can withdraw your consent at any time by disabling Location Data in your settings.

- Information we receive from other sources. We will receive personal data about you from various third parties as set out below:

o Google. We may receive data, including Device Data, from our analytics provider Google through its Google Analytics service. Google is a global company with many of its services based outside of the United Kingdom and the European Union. Your personal data may be transferred outside of the United Kingdom and the European Union.

You can find out more about how Google treats your personal data [HERE].

o Stripe. We may receive Identity, Contact, and Transaction Data from providers of our payment services provider Stripe. Stripe is our payment gateway and facilities the transfer of funds from a job poster to you. Stripe is a global company headquartered in the United States of America. Your personal data may be transferred outside of the United Kingdom and the European Union.

You can find out more about how Stripe treats your personal data [ HERE].

o MailChimp. We may send Contact Data to our e-mail list/subscription provider MailChimp in order to communication with you and keep you up to date about our App, our site, and our Services. MailChimp is headquartered in the United States of America. Your personal data may be transferred outside of the United Kingdom and the European Union.

You can find out more about how MailChimp treats your personal data [ HERE].

o We may also receive Identity and Contact Data about you from publicly available sources such as Companies House and the electoral register based inside the European Union.

- Device Data. When you install and use our App or access our Services through our site, including downloading updates to our App, we may collect information about your Device such as the operating system and your web-browser type or version.

We may also use cookies and other tracking technologies in our App and on our site to distinguish you from other users of our App, our Services, the distribution platform you accessed to obtain our App (for example the Apple App Store or the Google Play Store), and to remember your preferences. Collecting and retaining this information helps us to provide you with a good experience when you use our App or browse our site and also allows us to improve the App and our site. For detailed information on the cookies we use, the purposes for which we use them, and how you can exercise your choices regarding our use of your cookies, see our Cookie Policy .

How we use your personal data

Lawful basis

We will only use your personal data when the law allows us to do so. Most commonly, we will use your personal data in the following circumstances:

o Where you have consented before the processing.

Consent means processing your personal data where you have signified your agreement by a statement or clear opt-in to processing for a specific purpose. Consent will only be valid if it is a freely given, specific, informed and unambiguous indication of what you want. You can withdraw your consent at any time by contacting us.

o Where we need to perform a contract that we are about to enter or have entered with you, including our T&Cs.

Performance of contract means processing your data where it is necessary for the performance of a contract to which you are a party or to take steps at your request before entering into such a contract. This includes complying with our T&Cs.

o Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights to not override those interests.

Legitimate interest means the interest of our business in conducting and managing our business to enable us to give you the best service/product and the best and most secure experience. We make sure we consider and balance any potential impact on you (both positive and negative) and your rights before we process your personal data for our legitimate interests. We do not use your personal data for activities where our interests are overridden by the impact on you (unless we have your consent or are otherwise required or permitted to by law). You can obtain further information about how we assess our legitimate interests against any potential impact on you in respect of specific activities by contacting us.

o Where we need to comply with a legal or regulatory obligation.

Complying with a legal obligation means processing your personal data where it is necessary for compliance with a legal obligation that we are subject to.

We will only send you direct marketing communications by e-mail, SMS, or the App if we have your consent. You have the right to withdraw that consent at any time by contacting us.

We will not sure your personal data with any third party for marketing purposes.

Purposes for which we will use your personal data

Purpose/Activity

Type of data

Lawful basis for processing

To install the App and register you as a new App user (whether you register through the App or on site)

Identity

Contact

Device

Profile

Your consent

To process in-App or site communications, including managing financial transactions, and delivering our Services to you

Identity

Contact

Transaction

Device

Communications

Location

- Your consent

- Performance of a contract with you

- Necessary for our legitimate interests (to confirm and track jobs from start to finish)

To manage our relationship with you, including notifying you of changes to the App or any of our Services

Identity

Contact

Communications

- Your consent

- Performance of a contract with you

- Necessary for our legitimate interests (to keep records updated and to analyse how customers use our Services and our App)

- Necessary to comply with legal obligations (to inform you of any changes to our T&Cs)

To enable you to apply for job postings and to communicate with our job posters

Profile

Communications

- Your consent

- Performance of a contract with you

- Necessary for our legitimate interests (to ensure adherence to our T&Cs, ensure compliance with laws)

To deliver content to you, including making recommendations about job postings which may interest you, to measure and analyse the effectiveness of job postings, and to monitor trends so we can improve the App and our Services

Identity

Contact

Device

Content

Profile

Usage

Communications

Location

- Your consent

- Performance of a contract with you

- Necessary for our legitimate interests (to develop and improve our App and grow our business)

To administer and protect our business, our App, our Services, and our site including troubleshooting, data analysis, and systems testing

Identity

Contact

Device

Location

Necessary for our legitimate interests (for running our business, provision of our Services, and systems security)

Disclosures of your personal data

When you consent to providing us with your personal data, we will also ask you for your consent to share your personal data with our job posters. Our job posters will only see your Profile Data if you have applied for a job that they have posted. If you communicate with a job poster through our App or our site then you may also disclose Communication Data that relates only to that job. If you accept a job posting, then our job posters may also receive Identity and Contact Data about you. Our job posters may only use your personal data for the purposes of our Services.

We may also disclose your personal data to third parties to whom we may choose to sell, transfer, or merge parts of our business or our assets. Alternatively, we may seek to acquire other businesses or merge with them. If a change happens to our business, then the new owners may use your personal data in the same way as set out in this privacy policy.

International transfers

Many of our third party partners, such as Stripe and Mailchimp, are based outside of the European Economic Area (the "EEA"), so their processing of your personal data may involve a transfer of data outside the EEA.

Whenever we transfer your personal data out of the EEA we ensure a similar degree of protection is afforded to it by ensuring at least one of the following safeguards is implemented:

- We will only transfer your personal data to countries that have been deemed to provide an adequate level of protection for personal data by the United Kingdom or the European Commission. For further details, see European Commission: Adequacy of the protection of personal data in non-EU countries .

- Where we use providers based in the United States of America, we may transfer data to them if they are part of the Privacy Shield program which requires US companies to provide similar levels of protection to personal data as within the United Kingdom and the European Union. For further details, see European Commission: EU-US Privacy Shield .

- Where we use certain service providers, we may use specific contracts approved by the ICO or the European Commission which give personal data the same protection it has in Europe. For further details, see European Commission: Model contracts for the transfer of personal data to third countries .

Please contact us if you want further information on the specific mechanism used by us when transferring your personal data out of the EEA

We currently have three third party partners located within the United States of America. Each of these organisations is registered with the EU-US Privacy Shield program that enables the transfer and protection of your personal data in accordance with certain rules and guidelines approved by the European Commission. You can find out more about each of these organisations' certification with Privacy Shield below:

- Google [Certification Link]

- Stripe [Certification Link]

- MailChimp [Certification Link]

Data security and storage

Other than the information collected or received from Google, Stripe, or Mailchimp, we endeavour to store all personal data within the United Kingdom and the European Union. The personal data we receive from you is stored and hosted by Amazon on its Amazon Web Services/AWS platform. The majority of personal data is stored within AWS datacentres within the United Kingdom, however, we may store e-mail information at the AWS datacentres in Ireland, see Amazon Web Services compliance program - which includes ISO 27001 , ISO 27018, and Cyber Essentials Plus .

All information you provide to us is stored on our secure servers. Any payment transactions through our App and our site are carried out by our chosen third party payment provider Stripe and will be encrypted using industry standard technologies such as Transport Layer Security (TLS) in accordance with Stripe's Security Policy .

Where we have given you (or where you have chosen) a password that enables you to access our App or certain parts of our site, you are responsible for keeping this password confidential. We ask you not to share this password with anyone.

Once we have received your information, we will use strict procedures and security features to try to prevent your personal data from being accidently lost, used, or accessed in an unauthorised say. We use a number of industry standard security features such as encryption-at-rest and encryption-in-transit to protect your personal data.

We may also collect and store personal data on your Device using application data caches and browser web storage (including HTML5) and other similar caching technologies.

Certain Services include communication features such as chat/messaging. Please ensure when using these features that you do not submit any personal data that you do not want to be seen, collected, or used by other users, such as job posters. Our platform is designed to enable job posters to see the relevant Profile, Contact, Identity, and Communication Data about you without requiring you to submit further information on your own.

If you have been asked by anyone to provide any personal data about you, please get in touch with us as soon as possible.

We have put in place procedures to deal with any suspected personal data breaches and will notify you and any applicable regulator when we are legally required to do so.

Data retention

Due to the nature of our App and our Services we have to keep basic information about you, including Contact Data and Identity Data for a period of five (5) years after you cease being a user of our Services and our App. Feel free to get in touch with us if you would like more information about why we retain your personal data for this period of time. But in short, we need to ensure that the users of our App and our Services are legally allowed to work within the United Kingdom, are valid and current users of approved educational institutions, and to assist in protecting the health and safety of our users.

In the event that you do not use our App or our Services for a period of more than [twelve (12) months] we will suspend and limit access to your account. After a further period of [four (4) years] we will treat the account as expired and your personal data may be deleted.

In some circumstances you can ask us to delete your personal data, please the section 'Your legal rights' below for further information.

Your legal rights

Under certain circumstances you have the following rights under data protection laws in relation to your personal data.

You have the right to:

- Request access to your personal data (commonly known as a "data subject access request"). This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it. Data subject access requests must be in writing. Please see our contact details at the top of this page if you wish to submit a request.

- Request correction of the personal data that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.

- Request erasure of your personal data. This enables you to ask us to delete or remove personal data where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal data where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully, or where we are required to erase your personal data to comply with local law. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.

- Object to processing of your personal data where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms. You also have the right to object where we are processing your personal data for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms.

- Request restriction of processing of your personal data. This enables you to ask us to suspend the processing of your personal data in the following scenarios:

o If you want us to establish the data's accuracy;

o Where our use of the data is unlawful but you do not want us to erase it;

o Where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims; or

o You have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.

- Request the transfer of your personal data to you or to a third party. We will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.

- Withdraw consent at any time where we are relying on consent to process your personal data. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain products or services to you. We will advise you if this is the case at the time you withdraw your consent.

You also have the right to ask us not to continue to process your personal data for marketing purposes.

You can exercise any of these rights at any time by contacting us at 137 Garthdee Road, AB10 7AT or info@udrafter.com

Description of categories of personal data

We may collect and process the following personal data about you, if we have established a legal basis for processing:

- Identity Data: First name, last name, gender, title, date of birth, right to work information (which may include passport or VISA information), driving licence, national insurance number, username or similar identifiers.

- Contact Data: Current address, university e-mail address, personal e-mail address, and telephone/mobile number.

- Transaction Data: Includes details about payments from job posters to you from within our App or our site, this is usually through an automated API between our Services and Stripe. We do not collect financial information about you.

- Device Data: Includes the type of device you use, a unique device identifier (for example, your Device's IMEI number, the MAC address of the Device's wireless network interface, or the mobile phone number used by the Device), App version, your Device operating system, the type of browser you use, and time zone setting.

- Content Data: Includes information stored on your Device, including login information, photos, videos or other digital content.

- Profile Data: Includes your username and password, job history, your interests, preferences, qualifications, educational background, geographic area, work history, biography, feedback, and survey responses.

- Usage Data: Includes details of your use of our App or your visits to our site including, but not limited to, traffic data and other communication data, whether this is required for our own purposes or otherwise and the resources that you access.

- Communications Data: Includes the messages/communications that you may send or receive from us and any communication between you and job posters.

- Location Data: Includes your current location disclosed by GPS technology or BSSID.