Privacy Policy

Last updated: 6 Sep 2018

 

Introduction

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:

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:

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.

We may disclose your information to trusted third parties for the purposes set out in this Privacy Policy. We require all third parties to have appropriate technical and operational security measures in place to protect your personal data, in line with EU law on data protection rules.

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.

We may also share your personal data with the following third parties for the purpose described in this Privacy Policy:

(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;

(e) Social media:You may be able to access third party social media services through our website or App or before coming to our website or App. When you are registered with your social service account, we will obtain the personal information you choose to share with us through these social media services pursuant to their privacy settings in order to improve and personalize your use of our website or App. We may also use social media plugins on our website or App. As a result your information will be shared with your social media provider and possibly presented on your social media profile to be shared with others in your network. Please refer to the privacy policy of these third-party social media providers to find out more about these practices.

Cookies and site tracking

This site uses cookies to enable us to improve our service to you and to provide certain features that you may find useful. This may include cookies of media and advertising partners that are being placed on your machine when visiting our website or App. Please visit our partners’ websites for information on their privacy and cookie policy.

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:

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 (gdpr@papayaglobal.com).

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.

Changes to privacy policy

Our Privacy Policy may change from time to time and any changes to the statement will be communicated to you by way of an e-mail or a notice on our website.