Last updated: 6 Sep 2018
Papaya is committed to protecting its Users privacy and takes its responsibility regarding the security of Users information very seriously. We will be clear and transparent about the information we are collecting and what we will do with that information.
This Policy sets out the following:
- What personal data we collect and process about you in connection with your relationship with us through your use of our website and mobile applications;
- What we do with that data;
- How we store the data;
- Who we transfer/disclose that data to;
- How we deal with your data protection rights;
- And how we comply with the data protection rules.
All personal data is collected and processed in accordance with EU data protection laws.
What personal data we collect
Personal data means any information relating to you which allows us to identify you, such as your name, contact details, payment details and information about your access to our website.
We may collect personal data from you, directly or indirectly from a third party on your behalf, whenever we create or change your account in the Platform.
Specifically, we may collect the following categories of information:
(a) Name, home address, e-mail address, telephone number, passport or other recognized personal ID card numbers and details, bank account details or other payment details;
(b) Necessary details according to governmental authorities, insurance companies and other mandatory demands;
(c) Information you provide about you and your person of contact;
(d) Information about your use of our website and/or App;
(e) The communications you exchange with us or direct to us via letters, emails, chat service, calls, and social media.
What do we use your personal data for, why and for how long
Your data may be used for the following purposes:
(a) Providing services you or anyone on your behalf request: we use the information you give us to perform the services you have asked for in relation to your employment;
(b) Contacting you in the event of need;
(c) we send you communications about the services you have asked for and any changes to such services. These communications are not made for marketing purposes and cannot be opted-out of;
(d) we use your payment information for accounting, billing and audit purposes and to detect and / or prevent any fraudulent activities;
(e) Administrative or legal purposes;
(f) Immigration: we may be obliged to provide your information to immigration agencies;
(g) Security, health, administrative, crime prevention/detection: we may pass your information to government authorities or enforcement bodies for compliance with legal requirements;
(h) User Services communications: we use your data to manage our relationship with you as our User and to improve our services and enhance your experience with us;
(i) Marketing: from time to time we will contact you, either through Papaya’s platform or through e-mails, with information regarding HR and global Payroll. You will have the choice to opt in or opt out You will also be given the opportunity on every e-communication that we send you to indicate that you no longer wish to receive our direct marketing material. To unsubscribe from push notifications, you must update your App settings. Push notifications are set out in the initial permissions when downloading an app and vary depending on whether you have an IOS or android device. You should check the settings and permissions on your device in relation to push notifications and change your settings according to your preferences.
We will only process your personal data where we have a legal basis to do so. The legal basis will depend on the reasons we process and store your personal data for.
We may also process your personal data for one or more of the followings:
- To comply with a legal obligation (e.g. Immigration requirements);
- You have consented to us using your personal data (e.g. for marketing related uses);
- To protect your vital interests or those of another person (e.g. in case of a medical emergency);
- It is in our legitimate interests in operating as a global workforce management company (e.g. for administrative purposes).
We will not retain your data for longer than is necessary to fulfil the purpose it is being processed for. To determine the appropriate retention period, we consider the amount, nature and sensitivity of the personal data, the purposes for which we process it and whether we can achieve those purposes through other means.
We must also consider periods for which we might need to retain personal data in order to meet our legal obligations (e.g. in relation to claims) or to deal with complaints, queries and to protect our legal rights in the event of a claim being made.
When we no longer need your personal data, we will securely delete or destroy it. We will also consider if and how we can minimize over time the personal data that we use, and if we can anonymize your personal data so that it can no longer be associated with you or identify you, in which case we may use that information without further notice to you.
Security of your personal data
We follow strict security procedures in the storage and disclosure of your personal data, and to protect it against accidental loss, destruction or damage. The data you provide to us is protected using SSL (Secure Socket Layer) technology. SSL is the industry standard method of encrypting personal information.
International data transfer
Papaya operates businesses in multiple jurisdictions, some of which are not located in the European Economic Area (EEA), such as Israel, China and USA. While countries outside the EEA do not always have strong data protection laws, we require all services providers to process your information in a secure manner and in accordance with EU law on data protection.
Sharing your personal data
Your personal data may be shared with other parties that is in relation with Papaya for providing the services given to you.
(a) Government authorities, law enforcement bodies and regulators for compliance with legal requirements;
(b) Suppliers and other Services Providers required to deliver the services you have asked for;
(c) Trusted service providers we are using to run our business such as cloud service and e-mail marketing service providers assisting our marketing team with running User surveys and providing targeted marketing campaigns;
(d) Legal and other professional advisers, law courts and law enforcement bodies in all countries we operate in, in order to enforce our legal rights in relation to our contract with you;
Cookies and site tracking
Cookies are small text files that are transferred to your computer’s hard drive through your web browser to enable us to recognize your browser and help us to track visitors to our site; thus enabling us to understand better the products and services that will be most suitable to you. Most Web browsers automatically accept cookies, but, if you wish, you can change these browser settings by accepting, rejecting and deleting cookies. The “help” portion of the toolbar on most browsers will tell you how to prevent your browser from accepting new cookies, how to have the browser notify you when you receive a new cookie, or how to disable cookies altogether. If you choose to change these settings, you may find that certain functions and features will not work as intended. The cookies we use do not detect any information stored on your computers.
Your data protection rights
Under certain circumstances, by law you have the right to:
- Request information about whether we hold personal information about you, and, if so, what that information is and why we are holding/using it.
- Request access to your personal information (commonly known as a “data subject access request”). This enables you to receive a copy of the personal information we hold about you and to check that we are lawfully processing it.
- Request rectification of the personal information that we hold about you. This enables you to have any incomplete or inaccurate information we hold about you corrected.
- Request erasure of your personal information. This enables you to ask us to delete or remove personal information 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 information where you have exercised your right to object to processing (see below).
- Object to processing of your personal information 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. You also have the right to object where we are processing your personal information for direct marketing purposes. You can object to our processing of your data for direct marketing purposes by unsubscribing from our mailing list or updating the settings for your App (see section ‘What do we use your personal data for, why and for how long’ for more details).
- Request the restriction of processing of your personal information. This enables you to ask us to suspend the processing of personal information about you, for example if you want us to establish its accuracy or the reason for processing it.
- Request transfer of your personal information in an electronic and structured form to you or to another party (commonly known as a right to “data portability”). This enables you to take your data from us in an electronically useable format and to be able to transfer your data to another party in an electronically useable format.
- Withdraw consent. In the circumstances where you may have provided your consent to the collection, processing and transfer of your personal information for a specific purpose, you have the right to withdraw your consent for that specific processing at any time. Once we have received notification that you have withdrawn your consent, we will no longer process your information for the purpose or purposes you originally agreed to, unless we have another legitimate basis for doing so in law.
If you want to exercise any of these rights, you can contact our GDPR point of contact, according to the details in the Platform.
This policy should help you to better understand how we use your personal information, it explains in detail the types of personal information we collect, what we use it for and who we may share it with. If you have any further questions about this policy or how we handle your personal information, which are not dealt with here or through our platform, please get in touch with us by writing to our GDPR point of contact (firstname.lastname@example.org).
Please note that requests for data access, erasure, etc. are dealt with via the platform. Requests to unsubscribe from our mailing list can be made by clicking on the “unsubscribe” link in any of our marketing emails addressed to you. To unsubscribe from e-communications you must update your app settings. These requests cannot be processed if made via email, due to their volume and the need to verify your identity before we can act on your request. This is another appropriate security measure to ensure that personal information is not disclosed to any person who has no right to receive it.
You will not have to pay a fee to access your personal information (or to exercise any of the other rights). However, we may charge a reasonable fee if your request for access is clearly unfounded or excessive. Alternatively, we may refuse to comply with the request in such circumstances.
GDPR point of contact
We have appointed a GDPR point of contact for your convenience. In addition, you always have the right to make a complaint at any time to a supervisory authority.