Table of Contents

1- General Information
2. What Personal Data Do We Collect And For What Purposes Do We Use It?
3. What Technical (Non-Personal) Data Do We Collect?
4. How Do We Communicate With You?
5. How Long Do We Keep Your Personal Data?
6. How Do We Share And Disclose Your Data?
7. How Do We Protect Your Personal Data?
8. What Rights Do You Have With Regard To Your Personal Data?
9. Contact

1- General Information

1.1 About the Privacy Policy

This Feedni Privacy Policy (the “Privacy Policy”) governs the processing of personal data collected from natural persons (“you” and “your”) through the platform https://feedni.net, the related domain names, software applications, and services (collectively, “Feedni”). The Privacy Policy does not cover any third-party websites, applications, software, products or services that integrate with Feedni or are linked to from Feedni.

1.2. Account Eligibility

Feedni is owned and operated by Feedni LTD having a registered place of business at Al Maqam Tower, 3507, AL Mariyah Island, Abu Dhabi the UAE (“we,” “us,” or “our”).

1.3. Our role as a data controller and data processor

We act in the capacity of a data controller and a data processor with regard to the personal data processed through Feedni in terms of the applicable data protection laws, including the EU General Data Protection Regulation (GDPR). Our role depends on the specific situation in which personal data is handled by us, as explained in detail below:

• Data controller: We are responsible for the collection of your personal data through Feedni and its further use. We make decisions about the types of personal data that should be collected from you and purposes for which such personal data should be used. Therefore, we act as a data controller with regard to the personal data collected directly through Feedni (e.g., when you send us an inquiry, register your account, or post a job). We comply with the data controller’s obligations set forth in the applicable laws.
• Data processor: We act in the capacity of a data processor in situations when you submit files or generate data through Feedni for processing (e.g., documents, files, images, and videos) (“Your Data”) and Your Data contains other individuals’ personal data. We do not own, control, or make decisions about Your Data. We process Your Data only in accordance with the instructions issued by a respective data controller. To ensure that Your Data is processed in accordance with the strictest data protection standards, we have drafted and offer for conclusion a data processing agreement[1] (the “DPA”). The DPA is incorporated by reference into our Terms of Use[2], therefore, you conclude the DPA automatically upon your acceptance of the Terms of Use[3] [4] .

1.4 Your consent

Before you submit any personal data through Feedni, you are encouraged to read this Privacy Policy that is always available on Feedni to understand on what legal bases (other than your consent) we rely when handling your personal data. In some cases, if required by the applicable law, we may seek to obtain your informed consent for the processing of your personal data. For example, you consent may be necessary if:

1.5 Minors

Feedni is not intended for use by children (i.e., persons who are minors in their country of residence). Therefore, we do not knowingly collect minors’ personal data. If you, as a parent or a legal guardian of a child, become aware that the child has submitted his/her personal data to us, please contact us immediately. We will delete your child’s personal data from our systems without undue delay.

1.6 Term and termination

This Privacy Policy enters into force on the effective date indicated at the top of the Privacy Policy and remains valid until terminated or updated by us.

1.7 Amendments

The Privacy Policy may be changed from time to time to address the changes in laws, regulations, and industry standards. We encourage you to review our Privacy Policy to stay informed. For significant material changes in the Privacy Policy or, where required by the applicable law, we may seek your consent.

2. What Personal Data Do We Collect and for What Purposes Do We Use It?

2.1 Sources of personal data

We obtain your personal data from the following categories of sources:

• Directly from you: For example, if you submit certain personal data directly to us when registering your user account or contacting us; Directly or indirectly through your activity on Feedni. When you use Feedni, we automatically collect technical information about your use of Feedni; and
• From third parties: We may receive information about you from third parties to whom you have previously provided your personal data, if those third parties have a lawful basis for disclosing your personal data to us.

2.2 Types of personal data

We respect data minimisation principles. Thus, we collect only a minimal amount of personal data through Feedni that is necessary to ensure the proper provision of Feedni as described below. We useyour personal data for limited, specified and legitimate purposes explicitly mentioned in this Privacy Policy. We do not use your personal data for any purposes that are different from the purposes for which it was provided. When processing personal data, we make sure that we do so by relying on one of the available legal bases. You can find more information about the legal bases below.

1. Registration of your user account: When you register your account on Feedni, we collect your email address, name, phone number, country, and any information you decide to provide about yourself, including location, images and photos. We use the said information to register and maintain your user account, enable your access to Feedni, feature your profile, provide you with the requested services, contact you, if necessary, and maintain our business records. The legal bases on which we rely are ‘performing a contract with you’ and ‘pursuing our legitimate business interests’ (i.e., operate, analyse, grow, and administer Feedni). We store such data until you amend it or delete your user account.
2. Registration of your Provider account: When you register your Provider account on Feedni, we collect your email address, name, country, phone number, website URL, and any other information you decide to provide about your skills, education, and professional experience. We use the said information to register and maintain your user account, enable your access to Feedni, feature your profile, provide you with the requested services, contact you, if necessary, and maintain our business records. The legal bases on which we rely are ‘performing a contract with you’ and ‘pursuing our legitimate business interests’ (i.e., operate, analyse, grow, and administer Feedni). We store such data until you amend it or delete your user account.
3. Registration: of your Agency account. When you register your Agency account on Feedni, we collect your email address, company name, trade license, government-issued support documents and phone number. We use the said information to register and maintain your user account, feature your profile, enable your access to Feedni, provide you with the requested services, contact you, if necessary, and maintain our business records. The legal bases on which we rely are ‘performing a contract with you’ and ‘pursuing our legitimate business interests’ (i.e., operate, analyse, grow, and administer Feedni). We store such data until you amend it or delete your user account.
4. Postings: When you post a job on Feedni or apply for a job, we collect any information that you decide to provide in your post (for example, information about you, your company, business activities, skills, education, and professional experience). We use such information to feature your post, provide you with the requested services and maintain our business records. The legal bases on which we rely are ‘performing a contract with you’, ’pursuing our legitimate business interests’ (i.e., operate and administer ElancerZ), and ‘your consent’ (for optional personal data). We keep such data until you remove your posting.
5. Inquiries: When you contact us by email or through our contact form, we collect your name, email address, and any information that you decide to include in your message. We use such data to respond to your inquiries. The legal bases on which we rely are ‘pursuing our legitimate business interests’ (i.e., to grow and promote our business) and ‘your consent’ (for optional personal data). We store such data until you stop communicating with us.
6. Payments: When you make or request a payment, you will be asked to provide your name, phone number, and payment details like your credit card number, expiration date, security code, and billing address. Please note that we do not process payments – it is done by our third-party payment processors. We may have access to a limited amount of your personal data as disclosed to us by the payment processors (e.g., your email address). Your payment data is used to process your payments and maintain our business records. The legal bases on which we rely are ‘performing a contract’ and ‘pursuing our legitimate business interests’ (i.e., administering our business). We store such data for the time period we are required by law to keep our accountancy records.
7. Cookies: When you browse Feedni, we collect your cookie-related data. For more information about the purposes for which we use cookies, please refer to our Cookie Policy[5] . The legal bases on which we rely are ‘pursuing our legitimate business interests’ (i.e., to analyse and promote our business) and ‘your consent’ (for non-essential cookies). We store such data until your cookies expire, you disable cookies, or you withdraw your consent, whichever earlier.
8. IP address: When you use Feedni, we or our third-party analytics service providers (as explained in section 3 below) collect your IP address (mostly, in an anonymised form). We use your IP address to analyse the technical aspects of your use of Feedni, prevent fraud and abuse of Feedni, ensure the security of Feedni, and tailor Feedni for your location. The legal basis on which we rely when processing your IP address is ‘pursuing our legitimate business interests’ (i.e., to analyse and protect Feedni) and ‘your consent’. We store such data until it is necessary for analysing and protecting Feedni or you withdraw your consent.

2.3 Sensitive data

We do not collect or have access to any special categories of personal data as defined by Art. 9 of the GDPR (“sensitive data”) from you, unless you decide, at your own discretion, to provide such data to us. Sensitive data is information that relates to your health, genetics, biometrics, religious and political beliefs, racial origins, membership of a professional or trade association, sex life, or sexual orientation. If you decide, at your sole discretion, to include the said sensitive data into Your Data, we will process such data for the purpose of fulfilling our contractual obligations.

2.4 Processing of Your Data

When you upload or create Your Data on Feedni, we process Your Data as requested by you, including any personal data that you make available through Your Data. We process Your Data in order to:

2.5 Refusal to provide personal data

If you refuse to provide us with your personal data when we ask to, we may not be able to perform the requested operation and you may not be able to use the full functionality of Feedni or get our response. Please contact us immediately if you think that any personal data that we collect is excessive or not necessary for the intended purpose.

3. What Technical (Non-Personal) Data do We Collect?

3.1 Log files and analytics data.

3.2 Your feedback

3.3 Purposes of technical (non-personal) data

3.3 Purposes of technical (non-personal) data

If we combine your non-personal data with certain elements of your personal data and such a combination allows us to identify you as a natural person, we will handle such aggregated data as personal data. If your personal data is de-identified in a way that it can no longer be associated with a natural person, it will not be considered personal data and we may use it for any business purpose.

3.4 Aggregated and de-identified data

If we combine your non-personal data with certain elements of your personal data and such a combination allows us to identify you as a natural person, we will handle such aggregated data as personal data. If your personal data is de-identified in a way that it can no longer be associated with a natural person, it will not be considered personal data and we may use it for any business purpose.

4- How Do We Communicate with You?

4.1 Newsletters

If we have your email address, we may, from time to time, send you a newsletter informing you about the latest developments related to Feedni and our special offers. You will receive our newsletters in the following instances:

4.2 Opting-out

You can opt-out from receiving our commercial communication at any time free of charge by clicking on the “unsubscribe” link included in our newsletters, adjusting the settings of your user account, or by contacting us directly.

4.3 Tracking pixels

The newsletters sent by us may contain tracking pixels that allow us to conduct analysis of our marketing campaigns. Tracking pixels allow us to see whether you opened the newsletter and what links you have clicked on. We use such information to conduct analytics and pursue our legitimate business interests.

4.4 Service-related notices

If necessary, we will send you important informational messages, such as confirmation receipts, payment information, technical emails, and other administrative updates. Please note that such messages are sent on an “if-needed” basis and they do not fall within the scope of commercial communication that may require your prior consent. You cannot opt-out from service-related notices.

5- How Long Do We Keep Your Personal Data?

5.1 Retention of personal data

We store your personal data in our systems only for as long as such personal data is required for the purposes described in this Privacy Policy or until you request us to delete your personal data, whichever comes first. After your personal data is no longer necessary for its primary purposes and we do not have another legal basis for storing it, we securely delete your personal data from our systems.

5.2 Retention of technical (non-personal) data

We retain non-personal data pertaining to you for as long as necessary for the purposes described in this Privacy Policy. For example, we can store it for the period of time needed for us to pursue our legitimate business interests, conduct audits, comply with (and demonstrate compliance with) legal obligations, resolve disputes and enforce our agreements.

5.3 Retention as required by law

In certain cases, we are required by law to store your personal data for a certain period of time (e.g., your payment data should be stored for business records or accounting purposes). Thus, we keep your personal data for the time period stipulated by the applicable law and securely delete it as soon as the required storage period expires.

6- How Do We Share And Disclose Your Data?

6.1 Disclosure to data processors

From time to time, your personal data is disclosed to our service providers with whom we cooperate (our data processors). For example, we share your personal and non-personal data with entities that provide certain technical support services to us, such as hosting and email distribution services. We do not sell your personal data to third parties. The disclosure is limited to the situations when your personal data is required for the following purposes:

• Ensuring the proper operation of Feedni
• Ensuring the delivery of the services ordered by you
• Providing you with the requested information
• Pursuing our legitimate business interests
• Enforcing our rights, preventing fraud, and security purposes
• Carrying out our contractual obligations
• If you provide your prior consent to such a disclosure

6.2 List of our data processors

We use a limited number of data processors. We choose them only if they agree to ensure an adequate level of protection of your personal data that is consistent with this Privacy Policy and the applicable data protection laws. The data processors that have access to your personal data are:

• Our hosting and cloud storage service provider Amazon Web Services (AWS) located in the United States of America
• Our payment service provider in the United Arab Emirates is PayBy Technology Projects L.L.Clocated in the United Arab Emirates
• Our newsletter service provider Amazon Web Services located in the United States
• Our analytics service provider Google located in the United States
• Our email service provider is Microsoft located in the United States
• Our independent contractors and consultants

6.3 Disclosure of technical (non-personal) data

Your technical (non-personal) data may be disclosed to third parties for any purpose. For example, we may share it with prospects or partners for business or research purposes, for improving Feedni, responding to lawful requests from public authorities or developing new products and services.

6.4 Legal requests

If we are contacted by a public authority, we may need to disclose information about you to the extent necessary for pursuing a public interest objective, such as national security or law enforcement.

6.5 Successors

In case Feedni is sold partly or fully, we will provide your personal data to a purchaser or successor entity and request the successor to handle your personal data in line with this Privacy Policy. We will notify you of any changes of the data controller.

6.6 Selling personal data

We do not directly sell your personal data to third parties. However, some of your personal data, including online identifiers (e.g., cookie-generated data and IP addresses) may be used for advertising, marketing, and monetisation purposes (e.g., programmatic advertising, retargeting, third-party marketing, profiling, or cross-device tracking). To make sure that you have full transparency and control over your personal data, we provide you with a possibility to manage your personal data used for such purposes as described in our Cookie Policy[6] .

6.7 International transfers

Some of our data processors listed above are located outside the country in which you reside. For example, if you reside in the European Economic Area (EEA), we may need to transfer your personal data to jurisdictions outside the EEA. In case it is necessary to make such a transfer, we will make sure that the jurisdiction in which the recipient third party is located guarantees an adequate level of protection for your personal data or we conclude a data processing agreement with the respective third party that ensures such protection. We will not transfer your personal data internationally if no appropriate level of protection can be granted.

7. How Do We Protect Your Personal Data?

7.1 Our security measures

We implement organisational and technical information security measures to protect your personal data from loss, misuse, unauthorised access, and disclosure. The security measures taken by us include:

• Access control
• Secured networks
• SSL protocol
• Strong passwords
• Anonymisation of personal data (when possible)
• Carefully selected data processors

7.1 Our security measures

We implement organisational and technical information security measures to protect your personal data from loss, misuse, unauthorised access, and disclosure. The security measures taken by us include:

7.2 Security breaches

Although we put our best efforts to protect your personal data, given the nature of communications and information processing technology and the Internet, we cannot be liable for any unlawful destruction, loss, use, copying, modification, leakage, and falsification of your personal data that was caused by circumstances that are beyond our reasonable control. In case a serious breach occurs, we will take reasonable measures to mitigate the breach, as required by the applicable law. Our liability for any security breach will be limited to the highest extent permitted by the applicable law.

8. What Rights Do You Have With Regard To Your Personal Data?

8.1 The list of your rights

You have the right to control how your personal data is processed by us by exercising the rights listed below (unless, in very limited cases, the applicable law provides otherwise):

• Right of access: you can get a copy of your personal data that we store in our systems and a list of purposes for which your personal data is processed
• Right to rectification: you can rectify inaccurate personal data that we hold about you
• Right to erasure (‘right to be forgotten’): you can ask us to erase your personal data from our systems
• Right to restriction: you can ask us to restrict the processing of your personal data
• Right to data portability: you can ask us to provide you with a copy of your personal data in a structured, commonly used and machine-readable format and move that personal data to another processor
• Right to object: you can ask us to stop processing your personal data
• Right to withdraw consent: you have the right to withdraw your consent, if you have provided one
• Right to complaint: you can submit your complaint regarding our processing of your personal data

8.2 How to exercise your rights?

If you would like to exercise any of your rights, please contact us by email at info@feedni.net or by post (you can find our postal address at the end of this Privacy Policy) and explain your request in detail. In order to verify the legitimacy of your request, we may ask you to provide us with an identifying piece of information that allows us to identify you in our system. We will answer your request within a reasonable time frame but no later than 2 weeks.

8.3 Complaints

If you would like to launch a complaint about the way in which we process your personal data, we kindly ask you to contact us first and express your concerns. If we receive your complaint, we will investigate it and provide you with our response as soon as possible. If you are not satisfied with the outcome of your complaint, you have the right to lodge a complaint with your local data protection authority.

8.4 Non-discrimination

We do not discriminate against you if you decide to exercise your rights. It means that we will not:

9- Contact

If you have any questions about this Privacy Policy or our data protection practices, please contact us by:

Email: info@feedni.net

Postal address: Feedni LTD, 969751 Abu Dhabi, the UAE