Privacy Policy


Effective Date: July 9, 2019

1. Introduction and Registration

Welcome to the Solvᵀᴹ Platform.

Concentrix Europe Limited (“Company”, “we”, “our”, “us”) is committed to protecting your Personal Data when you use the Solvᵀᴹ Platform and related software, technology and services (“Solvᵀᴹ Platform”). Company’s provision of the Solvᵀᴹ Platform is referred to as the Services”. Individuals possessing expertise and experience in brands and technologies related to the Services are invited to register and request to qualify as a solver (“Solver”). Solvers can enter into independent contractor agreements with clients of the Company (“Clients”) and use the Solvᵀᴹ Platform and Services to respond to questions and perform other tasks (“Solver Content”) on behalf of Clients.

This privacy policy (“Privacy Policy”) informs you what types of Personal Data and other information Company Processes in connection with your use of the Solvᵀᴹ Platform and Services and the purposes for processing such Personal Data. Subject to applicable privacy and data protection laws, “Personal Data” is generally understood to mean information that identifies an individual and information that can be used to identify an individual. Uniform practices for accessing, collecting, using, disclosing, retaining, disposing, transferring or otherwise processing such Personal Data (“Processing”) enables Company to Process your Personal Data fairly and appropriately in a legally permissible manner. This Privacy Policy explains how we collect, use, and disclose different types of information pertaining to you, including Personal Data, and your rights and choices concerning the Processing of your Personal Data.

This Privacy Policy applies to your use of the Solvᵀᴹ Platform and Services as a Solver or a visitor to the Solvᵀᴹ Platform. The Privacy Policy does not apply to Clients or to customers of Clients who post questions and other requests that are routed to Solvers (“Customers”). Each Client enters into a separate agreement with Company to govern use of the Solvᵀᴹ Platform and Services by the Client and its Customers. Any Processing of your Personal Data by Clients in connection with Solver Content, including, without limitation, any evaluations of your performance or processing of payments to you for Solver Content, are governed by the independent contractor terms and conditions agreement you enter into with each of your respective Clients.

You must be an adult in order to use the Solvᵀᴹ Platform and Services. If you are under the age of 18, you are not permitted to access or use the Solvᵀᴹ Platform or Services, and not permitted to register to become a Solver. Only individuals who are located in the Philippines, India, the United Kingdom, Ireland, or any state in the United States of America that is not an Excluded State, are permitted to access and use the Solvᵀᴹ Platform and Services to register to become Solvers. The “Excluded States” are California, Massachusetts, New Jersey, Washington, New York, Oregon, Hawaii, Alaska, New Hampshire, Maine and Maryland.

Your use of the Solvᵀᴹ Platform and Services constitutes your agreement to the terms of this Privacy Policy. You must read and agree to the Terms of Use Agreement (“Terms”) *[PROVIDE LINK]* which incorporate this Privacy Policy when you register to become a Solver.

2. Changes

We reserve the right to modify or change this Privacy Policy at any time. If we make any substantial changes, we may notify you by sending an e-mail to the last e-mail address you provided to us (if any) and/or by prominently posting notice of the revised Privacy Policy on the Solvᵀᴹ Platform, so it is visible when you visit and/or log-on to the Solvᵀᴹ Platform for the first time after the change is posted. If you are dissatisfied with the updated Privacy Policy, you may cease your access and use of the Services. Any changes to this Privacy Policy will be effective immediately following our posting of notice of the changes on the Solvᵀᴹ Platform. Your use of the Services following our posting of notice of the changes constitutes your acceptance of the changes to the Privacy Policy. You are responsible for providing us with your most current email address. In the event that the last e-mail address that you have provided us is not valid, or for any reason is not capable of delivering to you the notice described above, our dispatch of the e-mail containing such notice will nonetheless constitute effective notice of the changes described in the notice.

3. The information we collect from you

Your registration on the Solvᵀᴹ Platform will require you to share certain Personal Data and other information pertaining to you with Company that will be Processed by or on behalf Company and Clients who have engaged you as an independent contractor. We may collect and store this Personal Data and combine this Personal Data with other Personal Data you may have provided, and use and Process such Personal Data in accordance with this Privacy Policy. You will be required to provide the following “Mandatory Personal Data” in order to register your interest in becoming a Solver:

  • Your name;
  • Your email address;
  • Your phone number;
  • The Country and/or State in which you are located;
  • Your verbal and written language skills; and
  • Your qualifications, skills, preferences and experience to serve as a Solver.

Any of the information we collect from you may be used for one or more of the following purposes:

  • To create your Solvᵀᴹ account;
  • To Identify you when you access the Services, and verify your identity and registration information;
  • To respond to your questions and requests;
  • To enable you to use the Services to provide Solver Content on behalf of your Clients and their Customers;
  • To enable Clients to monitor and assess your use of the Solvᵀᴹ Platform to provide Solver Content through the Services on their behalf, and to determine their payment obligations to you with respect to the Solver Content you provide on their behalf;
  • To determine your qualifications to serve as a Solver;
  • To determine your preferences for serving as a Solver,
  • To send you updates and other information pertaining to the Services, your expressed interest in serving as a Solver for Clients, and inform you of opportunities and requirements to serve as a Solver;
  • To enable payment processors and Clients to disburse payments to you for providing Solver Content;
  • To secure the Services and enforce the Terms and this Privacy Policy;
  • To administer and improve the Services; and
  • To comply with legal obligations and audit requirements.

Company may impose additional terms and duties for your eligibility (“Supplemental Terms”) to serve as a Solver, including privacy terms and services in connection with certain Services. You will be given an opportunity to review and consent to such Supplemental Terms.

You have choices regarding our use and disclosure of your Personal Data. If you no longer want to receive marketing-related emails from us going forward, you may opt-out via the unsubscribe link included in such emails and by following the Unsubscribe Procedure described in Section 8 of this Privacy Policy. If you choose to delete or withdraw your consent to Process any Mandatory Personal Data provided to us by you for non-marketing purposes, you will not be eligible to serve or continue to serve as a Solver and we will be unable to continue to Process any pending request you may have submitted to serve as Solver. In such instances, Company may, at its discretion choose to deactivate your registration.

You may terminate your use of the Services and withdraw or deactivate your registration at any time. Company is not a party to any agreements you have with Clients, and your right to terminate your use of the Services is not a waiver of any responsibilities or obligations you may have under your agreements with Clients including, without limitation, any obligations to use the Services to provide Solver Content on behalf of Clients.

4. Retention of Your Personal Data

Company will retain your Personal Data: a) for no longer than is necessary to fulfill the purposes stated in Section 3 of this Privacy Policy and any additional or revised purposes implemented pursuant to Section 2 of this Privacy Policy; (b) until you object if Company is using your Personal Data for its legitimate interests; or (c) until you withdraw your consent if you consented to Company using your Personal Data. However, Company will continue to retain your Personal Data for as long as is necessary to comply with applicable law or to assert or defend against legal claims. Any objection, or withdrawal of your consent, to Process your Mandatory Personal Data for non-marketing purposes will make you ineligible to serve or continue to serve as a Solver and Company will be unable to continue to Process any pending request you may have submitted to serve as Solver.

5. Sharing Your Personal Information

Your Personal Data may be shared with following categories of recipients, for the purposes stated in Section 3 of this Privacy Policy and any additional or revised purposes implemented pursuant to Section 2 of this Privacy Policy.

5.1 Recipients within the Company Group

Your Personal Data may be received by Company and other companies that, directly or indirectly, control, are controlled by, or under common control with, Company (“Company Group”). Depending on the categories of Personal Data and the purposes for which your Personal Data has been collected, different companies within the Company Group and internal departments within the Company Group may receive your Personal Data. For example, our IT department may have access to your account data for purposes of system administration and our security department may monitor information regarding your use of the Services in order to secure Personal Data and other data on the Solvᵀᴹ Platform. Other departments within the Company Group may have access to certain Personal Data relating to you on a need to know basis, such as the legal and compliance departments, the finance department and internal auditing.

5.2 Transfer to Third Party Providers

We may engage external service providers (“Third Party Providers”), who Process Personal Data on our behalf in order to provide certain services to us, such as website service providers, customer care providers, IT support service providers, and other service providers who support us in maintaining and operating the Solvᵀᴹ Platform and Services and supporting our commercial relationship with you. When providing such services, it may be necessary for such Third Party Providers to access and/or otherwise Process your Personal Data. We require Third Party Providers to implement and maintain appropriate security safeguards to protect the privacy and security of your Personal Data.

5.3 Other recipients

In compliance with applicable law, we may transfer your Personal Data to law enforcement agencies, governmental authorities, judicial authorities, legal counsel, external consultants, or business partners. As discussed in Sections 1 and 3 of this Privacy Policy, we also transfer certain Personal Data to Clients for the applicable purposes set forth in Section 3. In case of a corporate merger or acquisition, involving all or part of the assets or capital stock of a company within the Company Group, Personal Data may be transferred to the third party or parties involved in such merger or acquisition.

6. Links to other sites

You should be aware that when you are on the Solvᵀᴹ Platform you might have access to links to other sites that are operated by third parties and are therefore beyond our control. This Privacy Policy does not apply to the Processing of your Personal Data and other information on or in connection with such third party sites and features and services associated with such sites. These third-party sites may collect or solicit your Personal Data in order to use the features and services available on such third-party sites, and you may be required to create an account with, or otherwise login to, the applicable third-party site. Any Personal Data or other information provided through any such third-party site, feature or services is collected by the applicable third party and the servers that support the site, and is governed by the third party’s terms of service and privacy policy. That information may be shared with Company; and you hereby consent to such third party sharing that information with Company. If the Solvᵀᴹ Platform links to any third-party site, we make no representation as to the existence or sufficiency of the third party’s security measures for protecting your Personal Data or to the existence, sufficiency, accuracy or completeness of their privacy policies.

7. General Privacy Principals

Subject to the provisions of Section 8 concerning the Processing of Personal Data of individuals located in the European Economic Area or the Philippines, these general principles apply to the Processing of Personal Data by Company.

7.1 Accountability

Company understands its accountability and responsibility for any Personal Data that it may receive, use, Process, store as part of its business. Accordingly, Company will:

  • Have and maintain appropriate policies, procedures and measures to demonstrate that Personal Data is used, stored, Processed, retained, disposed of and transferred in compliance with applicable privacy and data protection laws; and
  • Designate an individual or individuals who are accountable for Company’s compliance with the privacy principles described in this Section 7.

7.2 Fairness and Purpose

Company will collect adequate, relevant and necessary Personal Data, and will Process such Personal Data fairly and lawfully for the purposes for which the Personal Data is collected. The purposes for collecting Personal Data, if not disclosed in Section 3 of this Privacy Policy, will be specified in accordance with Section 2 of this Privacy Policy upon or before its initial collection as well as before any previously collected Personal Data is processed for a new or different purpose.

7.3 Accuracy

Company will implement appropriate policies, processes and measures to keep Personal Data as accurate, complete and up-to-date as is necessary for the purposes for which the Personal Data is processed.

7.4 Disclosure and Data Sharing

Subject to applicable laws, Company may share Personal Data with departments within Company and with other Group Companies, Clients, Third Party Providers and other third party entities in accordance with Section 5 of this Privacy Policy in order for such departments and entities to Process Personal Data for the purposes described in Section 3 of this Privacy Policy and any additional or revised purposes implemented in accordance with Section 2 of this Privacy Policy.

7.5 Cross-Border Data Flows

Subject to compliance with data sharing requirements set forth in subsection 7.4 of this Privacy Policy and applicable law, Company may transfer Personal Data to other Group Companies, Third Party Providers, Clients and other third parties who are located outside of the United Kingdom where the Solvᵀᴹ Platform is located. To the extent required under applicable data protection laws, Company will implement appropriate data transfer mechanisms for any such transfers of Personal Data which may include, for example:

  • A data transfer agreement with the party who will Process the Personal Data;
  • Notice to and/or approval from a country’s local data protection authority; or
  • Notice to and/or consent from the individual whose data is to be transferred.

7.6 Security

Company will implement reasonable technical and organizational security measures to safeguard Personal Data collected in connection with the Services and instruct other Group Companies and Third Party Providers Processing Personal Data on behalf of Company to Process and manage such Personal Data in a manner which is consistent with Company’s measures for safeguarding Personal Data.

7.7 Access

Upon request and to the extent required under applicable law Company will, within a reasonable period of time, provide individuals appropriate access to their Personal Data Processed by or on behalf of Company and to exercise any other rights such individuals may have concerning their Personal Data.

8. Personal Data of individuals located in the EEA or the Philippines

8.1 Company’s roles as a Data Controller

The General Data Protection Regulation (“GDPR”) and other data protection laws applicable to countries in the European Economic Area (“EEA”), and the Philippine Data Privacy Act of 2012 (“PDPA”), make a distinction between the roles and responsibilities of a “Data Controller” that is responsible for determining the purposes and means for Processing an individual’s Personal Data (referred to as a “Data Information Controller” under PDPA), and a “Data Processor” that is responsible for Processing an individual’s Personal Data on behalf of, and at the direction of, a third party that serves as the Data Controller for the individual’s Personal Data (referred to as “Data Information Processor” under PDPA). With respect to the Processing of your Personal Data by or on behalf of Company in connection with the delivery of the Services, Company functions as a Data Controller. In its capacity as a Data Controller, Company’s responsibilities include, for example, providing adequate security for your Personal Data you submit to the Solvᵀᴹ Platform and responding to your requests in accordance with Section 8.4 of this Privacy Policy. Your Clients serve as Data Controllers for your Personal Data Processed by Clients and your Personal Data and Personal Data of their Customers that is Processed in connection with the Solver Content you provide on behalf of your Clients. When you respond to Client and Customer requests concerning Solver Content you are serving as a Data Processor performing services on behalf of your Client in its capacity as Data Controller. Any Processing of your Personal Data and Personal Data of Customers by Clients in connection with Solver Content, including, without limitation, any evaluations of your performance and the processing of payments to you in connection with Solver Content, are governed by the provisions of the independent contractor terms and conditions agreement you enter into with each of your respective Clients.

8.2 Legal Grounds for Processing your Personal Data.

We rely on the following legal grounds for Processing your Personal Data if you are located in the EEA or the Philippines:

  • The Processing is necessary to provide the Services, and services related to the Services as requested by you;
  • Your consent;
  • The Processing is necessary for the performance of a contract to which you are a party or to take steps at your request prior to entering into a contract;
  • The Processing is necessary for compliance with a legal obligation to which we are subject; and
  • The Processing is necessary for the purposes of the legitimate interests pursued by us or by a third party, except where such interests are overridden by the interests or fundamental rights and freedoms of you which require protection of Personal Data under applicable privacy laws; such legitimate interests are the fulfilment of the Processing purposes set out above in Section 3 of this Privacy Policy.

8.3 International Data Flow

The Solvᵀᴹ Platform is located in the United Kingdom. Company, as Data Controller for the Personal Data of registered Solvers and other visitors collected via the Solvᵀᴹ Platform, is also located in the United Kingdom. Furthermore, the Personal Data that we collect or receive about you may be transferred to and Processed by recipients that are located inside or outside the EEA or the Philippines.

If you are located in the EEA, some of the recipients of your Personal Data are certified under the EU-U.S. Privacy Shield and others are located in countries with adequacy decisions, and, in each case, the transfer is thereby recognized as providing an adequate level of data protection from a European data protection law perspective (see Art. 45 the GDPR).

Other recipients might be located in countries that do not provide an adequate level of protection from a European data protection law perspective. We will take all necessary measures to ensure that transfers out of the EEA are adequately protected as required by applicable data protection law. With respect to transfers to countries that have not been deemed to provide an adequate level of data protection, we will base the transfer on appropriate safeguards, such as standard contractual clauses adopted by the European Commission or by a supervisory authority (Art. 46(2)(c) or (d) GDPR), approved codes of conduct together with binding and enforceable commitments of the recipient (Art. 46 (2)(e) GDPR), or an approved certification mechanisms together with binding and enforceable commitments of the recipient (Art. 46 (2)(f) GDPR).

8.4 What rights do you have?

If you have declared your consent regarding certain collecting, Processing and use of your Personal Data, you can withdraw this consent at any time. If you withdraw your consent to Process any Mandatory Personal Data you provided to us for non-marketing purposes, you will not be eligible to serve or continue to serve as a Solver and we will be unable to continue to Process any pending request you may have submitted to serve as Solver. In such instances, Company may, at its discretion choose to deactivate your registration.

As further discussed below, pursuant to applicable data protection law and subject to certain exceptions you may also have the right to: (i) request access to your Personal Data; (ii) request rectification of your Personal Data; (iii) request erasure of your Personal Data; (iv) request restriction of Processing of your Personal Data; (v) request data portability; (vi) object to the Processing of your Personal Data (including objections to profiling); and (vii) exercise other rights in connection with automated decision-making.

(i) Right to request access to your Personal Data

You may have the right to obtain from us confirmation as to whether or not Personal Data concerning you is being Processed and, if that is the case, to request access to your Personal Data. Any such right to access your Personal Data that is being Processed includes access to the purposes of the Processing, the categories of Personal Data Processed, and the recipients or categories of recipients to whom the Personal Data have been or will be disclosed.

You may have the right to obtain a copy of your Personal Data that is being Processed by Company. For further copies requested by you, we may charge a reasonable fee based on administrative costs.

(ii) Right to request rectification

You may have the right to have us rectify any inaccurate Personal Data pertaining to you. Depending on the purposes of the Processing, you may have the right to have us complete any incomplete Personal Data, including by means of providing a supplementary statement.

(iii) Right to request erasure (right to be forgotten)

You may have the right to have us erase Personal Data pertaining to you.

(iv) Right to request restriction of Processing

You may have the right to have us restrict the Processing of your Personal Data. In such case, the respective data will be marked and may only be Processed by us for certain purposes.

(v) Right to request data portability

You may have the right to receive your Personal Data which you have provided to us in a structured, commonly used, and machine-readable format, and you may have the right to transmit that data to another entity.

(vi) Right to object

Under certain circumstances, you may have the right to object, on grounds relating to your particular situation, to the Processing of your Personal Data by us and we may be required to no longer Process your Personal Data or no longer process your Personal data for certain purposes. Such right to object may, for example, apply if Company collects and Processes your Personal Data for profiling purposes in order to better understand your business interests in serving as a Solver. Further you may object to the use of your data for direct marketing purposes. If you have a right to object and you exercise this right, your Personal Data will no longer be Processed for such purposes by us. To exercise this right please contact us as stated under Section 10 below.

However, such a right to object may not exist if, for example, the Processing of your Personal Data is necessary to take steps prior to entering into a contract or to perform a contract already concluded.

(vii) Other rights in connection with automated decision-making

Furthermore, with respect to automated decision-making involving your Personal Data, you have the right to obtain human intervention, express your point of view, and contest the decision.

To exercise your rights discussed in this subsection 8.4 of the Privacy Policy, please contact us as stated under Section 10 below. You also have the right to lodge a complaint with your applicable data protection supervisory authority.

9. Cookies

9.1. What are Cookies?

When you visit the Solvᵀᴹ Platform via our website, Company or an authorized third party may send you a cookie. Cookies are small text files located in your browser directory that may be placed on your device. When a website is accessed, a cookie that is placed on a device will send information to the party that placed the cookie. Cookies are extremely common and used on a number of websites. For a more thorough explanation of what cookies are and how they operate, please visit http://www.aboutcookies.org/ or www.allaboutcookies.org.

9.2 Why are Cookies useful?

Cookies allow a website owner to obtain useful information. For example, a cookie permits a website owner to determine whether an individual previously used the same computer or other device to visit the website. In general, the purpose of cookies is to improve the performance of the website and an individual’s experience in using that website. Cookies help to make a website more efficient, enable additional functionality, and provide website owners with additional information about your visit to the website. Cookies also allow a website owner to track overall usage of the website and to determine preferences for using the website. Cookies help to optimize the user’s visits to a website by recognizing the user and providing a customized experience.

9.3 First Party and Third Party Cookies

Our website places first party cookies and allows certain third parties to place cookies on your device. The difference between a first party cookie and a third party cookie relates to the control of the party who serves the cookie. First party cookies are cookies that are specific to the website that created them. Their use enables Company to operate an efficient service and to track patterns of behavior pertaining to visitors to the website. Third party cookies, on the other hand, are placed on your device by a third party (i.e., not by Company). While we may allow third parties access to the website to place these cookies on user devices, we do not retain control over the information supplied by the cookies. This information is controlled wholly by that third party in accordance with their respective privacy policy. Please review the respective third party privacy policy for further information. The description of each third party cookie in subsection 9.5 of this Privacy Policy is based on information provided by the applicable third party that controls the information provided by the cookie.

9.4 First Party Cookies used on this Website

We use cookies to track whether a user has accepted the terms of use for their applicable country and this Privacy Policy. We also uses cookies to enable authentication of Solvers and visitors to the registration fields on the Solvᵀᴹ Platform. The information generated by these cookie about the use of the website by the users will generally be retained on our behalf on servers in the United Kingdom.

9.5 Third Party Cookies used on this Website

a. Google re CAPTCHA uses a cookie to enable a service that determine whether a natural person is attempting to access a registration field on the Solvᵀᴹ Platform or an artificial “robotic” computerized program or algorithm is attempting to impersonate a natural person in order to access a registration field. The information generated by the cookie about the use of the website by the users will generally be retained by Google on servers in the United States.

b. Google Analytics uses cookies to help the website analyze how users use the website. The information generated by the cookie about the use of the website by the users will generally be transferred to and stored by Google on servers in the United States. This website has activated the IP-address anonymization functionality so that the IP-address of the user located within the EEA are shortened by Google prior to such a transfer. In exceptional cases only, the full IP-address may be transferred to the servers of Google in the USA in order to shorten the addresses. Google will process this information on our behalf for purposes of analyzing the usage of the website by users, compiling reports on website activities and providing other services relating to the usage of the website and the internet vis-à-vis the website operator. Google will not link your IP address which is transferred by your browser via Google Analytics with any other data held by Google. You may further opt-out of the collection of your data (including your IP-address) generated by the Google Analytics cookies by downloading and installing an add-on for your current web browser from the following link: http://tools.google.com/dlpage/gaoptout

c. Auth0 uses cookies to enable services that provide authentication and authorization with respect to website users. The information generated by the cookies concerning use of the website will generally be retained by Auth0 on servers in Argentina.

9.6 Disabling, Deleting, or Opting-Out of Cookies

If you do not want to have cookies placed on your device by third parties, there are ways to opt-out of receiving the cookies. Please note that if you disable cookies, you may not be able to use the full functionality of our website. In particular, you may have limited access to certain features and functionality available on our website or have a different experience while surfing on the website.

In addition, most web browsers allow users to have at least some control of most cookies through browser settings. You may refuse the use of cookies by selecting the appropriate settings on your browser. You may also delete existing cookies through your browser. Please visit one of the following websites to learn more about cookie settings for the applicable browser you are using to visit our website: Firefox , Internet Explorer , Google Chrome and Safari.

10. Privacy Contact Information

If you want to exercise your data privacy rights as discussed in Section 7 of this Privacy Policy and subsection 8.4 of this Privacy Policy if you are located in the EEA or the Philippines, or if you have concerns or questions regarding this Privacy Policy, please contact us:

Concentrix Europe Limited
Mayfield
49 East Bridge Street
Belfast
BT1 3NR
United Kingdom

privacy@concentrix.com