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.
- What personal information we collect
- How do we use your Personal Information
- How long we will use your personal information
- Sharing your personal information
- Your data protection rights
- Cookies and site tracking
- Additional notices
What Personal Information we Collect
During and as part of the use of our Sites, depending on the Users, we collect and process: (i) non-identifiable and anonymous information, which consists of technical information and behavioral information that does not pertain to a specific individual (“Non-Personal Information”); and (ii) personal information, which is information relating to an identified or identifiable natural person (“Personal Information”), as follows:
|Technical information||technical information such as the type and version of your device and its operating system, the type of browser, screen resolution and keyboard language, Wi-Fi connectivity, the type and name of the device and/or browser, etc.;|
|Behavioral information||Behavioral information which may include your click-stream, your activities on the Site and additional information of a similar nature (collectively, “Technical and Behavioral Information”).|
|Aanlytics||We may also use third-party service providers such as Google Analytics to obtain detailed analytics on your device and your behavior on the Site, for purposes of analytics, research, security and fraud prevention.|
Provided by Users
|Contact Details||E.g., email, telephone physical address
|Identifying||E.g., name, government-issued ID, profile picture, birthdate|
|Professional||E.g, role, company, education|
|Social||E.g., marital status and number of dependents|
|Financial||E.g. bank accounts, salary, benefits|
|Emergency Contact||E.g. name, surname and contact details of emergency contact|
|Communication||E.g. email conversations and the personal information that users might freely share with us in the communications|
Collected via Technology
|Geolocation data||uring your use of the Sites, Papaya will access, collect, process, monitor and/or remotely store "geolocation data", including through the collection of Internet Protocol (IP) addresses and other similar information to determine your location for analytics, advertising and security purposes.|
|Identifiers||during your use of the Sites, we will access, collect, process, monitor and/or remotely store online identifiers, such as Internet Protocol (IP) address, AD-ID or other unique identifiers, for the purpose of providing you with targeted advertising and for statistical and metric purposes.|
|Technical and Behavioral Information||To the extent that the Technical and Behavioral Information detailed above is linked to or associated with a specific individual then such information will be considered as Personal Information.|
How do we use your Personal Information
- Provide our services;
- Secure access to our services;
- Enable the operation of the Sites;
- Examine Users’ job applications
- Provide Users with technical support and assistance;
- Send you transactional communications, notices, announcements, and additional information related to Papaya and/or the Sites;
- Develop and send you newsletters and information about our products and services by email, SMS, phone or otherwise;
- Conduct internal operations, such as troubleshooting, data analysis, testing, research, statistical analysis, as well as the improvement of the Sites;
- Keep the Sites safe and secure against fraudulent and criminal activity;
- Comply with our legal obligations and provide us with the ability to protect our rights and legitimate interests;
- Maintain data processing records and general administrative purposes.
How long will we use your Personal Information
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.
If the Personal Information is no longer required, we will delete it regularly, unless its further temporary storage is still necessary 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.
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.
For more detailed information about the retention periods of the Personal Data that Papaya processes you can contact us at: email@example.com.
Sharing your Personal Information
In addition to using the information collected by us for the purposes described above, we may also share your Personal Information in the following cases:
|Papaya’s Personnel||Personal Information that we collect and process may be transferred to or accessed by personnel of Papaya for the sole purpose of enabling the operation of the Sites and to contact you. Please note that all of Papaya’s personnel that will have access to your Personal Information have an obligation of strict confidentiality with respect to such Personal Information.|
|Service Providers||We share Personal Information with vendors, commercial software providers, consultants and data processors who perform services on our behalf, including without limitation, companies that provide analysis, messaging services and services which host the Sites. Please note that we collect, hold and manage your Personal Information through third parties' cloud-based services, as reasonable for business purposes, which may be located in countries outside of the Users’ jurisdiction.|
In addition, we might also need to share your Personal information to comply with applicable law, enforce contractual rights, and respond to requests from courts, law enforcement, or regulatory agencies and government authorities as long as the request is deemed lawful.
Your data protection rights
Under certain circumstances, by law you have the right to:
|Information Request||You may request information about whether we hold Personal Information about you, and, if so, what that information is and why we are holding/using it.|
|Access||You can request access to your Personal Information which enables you to receive a copy of the Personal Information we hold about you and to check that we are lawfully processing it.|
|Rectification||You can request to have any incomplete or inaccurate information we hold about you corrected.|
|Erasure||You may 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 to continue 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||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 device.|
|Restrict processing||You can restrict your data from being processed if, for example, you want us to establish its accuracy or the reason for processing it.|
|Data Portability||You have the right to receive, upon request, your Personal Information that we process in an electronic and structured form to you or to another party.|
|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.|
This policy should help you to better understand how we use your Personal Information. If you have any further questions about this policy or if you wish to exercise your rights related to the Personal Data we process, please write us at firstname.lastname@example.org.
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.
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.
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 track visitors to our Sites thus enabling us to understand better the products and services that will be most suitable to you.
Privacy of minors
We do not knowingly collect any Personal Information from persons under the age of 18. If you are under the age of 18, please do not submit any Personal Information through the Sites.
Your acknowledgment of this policy
Privacy point of contact
We have appointed a privacy point of contact for your convenience at email@example.com. In addition, you always have the right to make a complaint at any time to a supervisory authority.