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.
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.
3. The information we collect from you
- 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 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 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
5. Sharing Your Personal Information
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
6. Links to other sites
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.
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 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
7.5 Cross-Border Data Flows
- 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.
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.
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
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
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.
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
9.4 First Party Cookies used on this Website
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.
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.
10. Privacy Contact Information
Concentrix Europe Limited
49 East Bridge Street