Personal Data Policy

Version of 24 August 2018

Except where explicitly agreed otherwise, the capitalised terms are deemed to have the same meanings as those specified in the Pickable Terms of Use and Sale.

Introduction

Pickable attaches great importance to respecting your privacy and protecting your Personal Data, as defined in Regulation No 2016/679 of 27 April 2016 on the protection of natural persons with regard to the processing of personal data (hereinafter “GDPR”). The following provisions constitute the Personal Data Policy in relation to the following types of processing carried out by Pickable (TOP 2 AG, Schindellegistrasse 3, 8808 Pfäffikon, Schwyz, Switzerland, hello@pickable.app) via the Site and the Application, in its capacity as controller of the aforementioned processing. It is pointed out that the Personal Data collected by Pickable is adequate, relevant and not excessive for the purposes for which it is collected and its subsequent processing.

Purposes and legal basis of processing

Management and use of the Application and the Site:

Pickable collects, processes and uses your Personal Data to:

This processing of Personal Data carried out by Pickable is necessary for the performance of a contract to which the Member is a party. As part of this processing, Pickable collects and processes “sensitive” data (sexual orientation, etc. – see “Categories of personal data collected” below). The processing of this sensitive data is based on your explicit consent, given in the form of your registration.

Newsletters:

Pickable processes Personal Data in order to send you emails about products and services offered by Pickable.

Pickable has a legitimate interest in carrying out this processing of Personal Data for sales prospecting purposes. You have the option of objecting to such processing of your Personal Data.

Management of applications:

Through the Site, Pickable publishes job offers for which you can apply. For this purpose, Pickable performs processing of collected Personal Data on the basis of the applicant’s consent.

Categories of personal data collected

Management and use of the Application and the Site:

The Personal Data that must be collected by Pickable is as follows (if this data is not provided, you will not be able to benefit from the Services):

The optional Personal Data that is collected by Pickable is as follows:

Newsletters:

In order to send you its newsletters, Pickable collects and processes the email address provided. The user is free not to provide it. Provision of your email address is mandatory if you wish to receive newsletters from Pickable. If you wish to apply for a vacancy published on the Site, Pickable will collect the Personal Data that is strictly necessary to assess the applicant’s ability to do the envisaged job.

Retention period

Personal Data is kept for no longer than the period necessary for the purposes for which it is collected and processed.

Sharing of your personal data

Management and use of the Application and the Site:

Your Personal Data is can be sent to the following third parties:

Members: other Members of Pickable to whom the Member is suggested for the purposes of dates can access the Personal Data published by the Member through his/her profile.

Service providers: Pickable may share your Personal Data with third parties who provide certain services on Pickable’s behalf, such as external services, including for data hosting and maintenance, analyses, customer support, payment processing and security operations. We go through a rigorous screening process before hiring any service provider or working with any partner. All of our service providers and partners are bound by strict obligations in relation to confidentiality.

Recipients of your Personal Data are carefully selected by Pickable and are required to implement a Personal Data policy which meets its requirements. Pickable ensures that these requirements are met through contracts and other measures, so that your Personal Data is not processed for purposes other than those specified herein, including for advertising purposes.

Newsletters:

Service providers: Pickable may share your Personal Data with third parties who provide certain services on Pickable’s behalf, such as external services, marketing and advertising. We go through a rigorous screening process before hiring any service provider or working with any partner. All of our service providers and partners are bound by strict obligations in relation to confidentiality.

Service providers: Pickable may share your Personal Data with third parties who provide certain services on Pickable’s behalf, such as external services, in order to recruit and follow up on applications. We go through a rigorous screening process before hiring any service provider or working with any partner. All of our service providers and partners are bound by strict obligations in relation to confidentiality.

Transfer of business: Your Personal Data may also be sent to third parties in connection with a transfer of business from Pickable to a third company (merger, transfer, winding up, etc.). In this event, you will be informed of any such transfer of your Personal Data and will have the option of objecting to this transfer.

Other: Pickable may pass on your Personal Data if this is required by law, by a court or by the authorities or appears to be necessary to enable Pickable to establish that its rights exist or to exercise its rights. Pickable may also pass on your Personal Data in order to protect its rights, for the protection and safety of the company, users, its staff or others, to comply with applicable law, or to enforce its GTUS or any other contract or policy.

Transfers of personal data

The sharing of your Personal Data referred to above sometimes involves cross-border data transfers, for example to the United States of America and other countries. Where transfers of Personal Data are made to countries, such as the United States of America, whose legislation does not provide an adequate level of protection, we use standard contractual clauses approved by the European Commission or other appropriate safeguard clauses to govern these transfers and protect the confidentiality and safety of your data.

Cookies

Pickable uses cookies to operate and improve the Site and also to improve the Services that are offered to you.

Pickable reminds you that by continuing to browse the Site, you have given your consent to the use of cookies. To find out more about them and configure cookies, please read the Cookie Policy.

Relationships with third parties

Links to third-party websites

The Site and Messages sent by other Members may contain links to third-party websites which are not controlled by Pickable. Pickable is not responsible for the practices of such third parties in terms of Personal Data protection and encourages you to take note of the statements and practices of such third parties in this regard. When you leave the Site or the Application, this Personal Data Policy no longer applies.

Security

Pickable takes all precautions necessary to protect the security of your Personal Data, including preventing it from being distorted or damaged and preventing unauthorised third parties from accessing it.

Your rights

You have a right to ask Pickable for access to information concerning you (art. 15 GDPR), rectification (art. 16 GDPR) or erasure (art. 17 GDPR) of such information, and restriction of processing (art. 18 GDPR). You also have a right to data portability (art. 20 GDPR).

You may also, as specified in article 21 GDPR, object to the processing of your Personal Data. To this end, you can unsubscribe at any time from Pickable’s sales prospecting lists by sending an email to the address hello@pickable.app.

You can also withdraw your consent at any time, without such withdrawal affecting the lawfulness of processing carried out on the basis of this consent prior to its withdrawal.

Lastly, you have the right to make a complaint to a supervisory authority (in France, the Commission Nationale de l’Informatique et des Libertés – CNIL).

You may exercise the aforementioned rights by writing to the following address: dpo@pickable.app. Pickable will process your request within one month after the request is received, except in special circumstances.

This request must be accompanied by a photocopy of a form of ID which bears the holder’s signature.

If a Member’s requests are manifestly unjustified or excessive, in particular due to their repetitiveness, Pickable may i) charge a reasonable fee taking into account the administrative costs of providing the information or communication or taking the requested action, or ii) refuse to act on such requests.

Changes to the Personal Data Policy

Pickable reserves the right to amend, add, remove or develop sections of this Personal Data Policy at any time and without notice in order to comply with changes in the law in this field, among other reasons.

A new version of the Pickable Personal Data Policy will then be provided to you. If you do not agree to the terms of this new Personal Data Policy as applicable to all future use of the Application and the Site, please stop using the Application and the Site.

Contacting Pickable

For all matters concerning your Personal Data (correction, updating, access, withdrawal of consent, etc.) or if you have any questions, please contact Pickable by writing to the following address: dpo@pickable.app.