Privacy Policy

What is personal data?

Personal data is any information relating to an identified or identifiable natural person. A person is identifiable, if the person can be identified, directly or indirectly, in particular by reference to an identification number or to one or more factors specific to his physical, physiological, mental, economic, cultural or social identity. This may include data such as e.g. name, email address, telephone number and mailing address. We process your data in the context of our service only when you have given us your consent to do so, the data is necessary for the performance of the contract or where it is permissible by law.

You may withdraw your consent to the processing of personal data at any time. A revocation has a direct influence on the admissibility of the processing of your personal data as soon as directed to us.

If the processing of your personal data is based on legitimate interests, you have the right to object to processing the personal data. If you exercise your right of objection, we kindly ask you to explain the reasons why we should not process your personal data. If your objection is justified, we will review the facts and adjust or modify the processing of data or inform you about imperative legitimate grounds for the processing.

We will delete your personal data as soon as the data is no longer necessary for the respective purpose. It may occur that personal data is kept for the time during which possible claims may be asserted against us. Furthermore, we are required by law to store certain data due to the duties of proof and retention, inter alia from the Portuguese Commercial Code, the Portuguese Tax Code or the Money Laundering Act.

What personal information do we collect from the people that visit our website?

Propel may collect your Personal Data through our communication and your usage of our products and services. Personal Data can be directly provided by you or indirectly collected by us (i.e. from your interactions, use, and experiences with our products). When registering on our site, as appropriate, you may be asked to enter your name, email address, and other details related to finding a job or finding employees. Examples include skills and employment history, video interview recording.

When using our website, we collect different events on our website to provide and improve our service.

User Biodata:

When you create an Account or post a Job, you will provide information that could be Personal Information, such as your username, password, address and email address. You acknowledge that this information may be personal to you, and by creating an account on the Services and providing Personal Information to us, you allow others, including us, to identify you and therefore may not be anonymous. We may use your contact information to send you information about our Services, but only rarely when we feel such information is important. You may unsubscribe from these messages through your Account settings’

Banking Information:

When you choose to bid for a Job as a Talent, you will be required to go through a one-time verification process where we collect certain information to authenticate your person and verify your profile for traceability purposes. This is important for us to ascertain the credibility of each Talent, and most importantly, to maintain security on the site. We use the bank verification number of Talent (Nigeria) to verify the Talent full name, phone number and date of birth. The BVN (Bank Verification Number) is linked to the Talent’s bank account on the platform and is used to ensure that users can withdraw their earnings from Jobs completed on the site straight to their individual bank accounts safely and securely, eliminating the risk of wrong transfers to people other than the Talent themselves.

Other Financial Information:

We do not currently collect financial information outside the banking information items listed above, such as your payment method (valid credit card or debit card number, type, expiration date or other financial information); that information is collected and stored by our third party payment processing company (the "Payment Processor"), and use and storage of that information is governed by the Payment Processor's applicable terms of service and privacy policy. However, we may from time to time request and receive some of your financial information from our Payment Processor for the purposes of completing transactions you have initiated through the Services, enrolling you in discount, rebate, and other programs in which you elect to participate, protecting against or identify possible fraudulent transactions, and otherwise as needed to manage our business.

User Content:

Some features of the Services allow you to provide content to the Services, such as written comments. All content submitted to the Services by you may be retained by Propel indefinitely, even after you terminate your account. We may continue to disclose such content to third parties in a manner that does not reveal Personal Information (unless you otherwise publicly disclose it, such as through public comments), as described in this Privacy Policy.

IP Address Information and Other Information Collected Automatically:

We automatically receive and record information from your web browser when you interact with the Services, including your IP address and cookie information. This information is used for fighting spam/malware and also to facilitate collection of data concerning your interaction with the Services (e.g., what links you have clicked on). Generally, the Services automatically collect usage information, such as the number and frequency of visitors to the Site. We may use this data in aggregate form, that is, as a statistical measure, but not in a manner that would identify you personally. This type of aggregate data enables us and third parties authorized by us to figure out how often individuals use parts of the Services so that we can analyze and improve them.

Neither we nor our third party analytics partners will ever use the above information to identify individual users or to match it with further data on an individual user. The legal basis of this processing is Art. 6 (1) sentence 1 lit. f) GDPR. We use the following services to collect information needed for improving our services: Google Analytics, Hotjar, Intercom, Twilio, Error Tracking (Rollbar), IPStack, Mailchimp, Mailgun and HubSpot. The legal basis of this processing is Art. 6 (1) sentence 1 lit. b) GDPR.Neither we nor our third party analytics partners will ever use the above information to identify individual users or to match it with further data on an individual user. The legal basis of this processing is Art. 6 (1) sentence 1 lit. f) GDPR. We use the following services to collect information needed for improving our services: Google Analytics, Hotjar, Intercom, Twilio, Error Tracking (Rollbar), IPStack, Mailchimp, Mailgun and HubSpot. The legal basis of this processing is Art. 6 (1) sentence 1 lit. b) GDPR.

How does Propel use my personal data?

Propel may use the information it collects from you when you register, make a purchase, sign up for our newsletter, respond to a survey or marketing communication, surf the website, or use certain other site features in the following ways:

• To personalize your experience.
• To improve our website in order to better serve you.
• To deliver our service of finding a job/finding employees.
• To administer a contest, promotion, survey or other site feature.
• To send periodic emails regarding your order or other products and services.
• To follow up with the user after correspondence (live chat, email or phone inquiries.
• To inform you about changes to our service.

The specified data and your entire user account can always be deleted in the user profile. You agree to treat personal access data confidentially and not to make such data available to unauthorized third parties. We do not assume liability for misused passwords unless we are responsible for the abuse. You should notify us immediately if you are concerned about a third party having knowledge of your password, if the password is used unauthorized or this seems to be likely.

You are responsible for ensuring that your information is accurate and complete and that you notify us of any changes to the information provided. You can review and update the information provided and your account settings section of our website. After completing communication with Propel you should log out and close the browser window, especially if you share the computer with other people.

Due to commercial, legal and tax regulations, we may be obliged to store part of the personal data transferred (e.g. payment data) for a period of time.

Does Propel transfer data to third parties?

We respect your rights as a Data Subject and only share your Personal Data with third parties if we are legally obliged to do so or where we need to comply with our contractual obligations, for example we may need to share certain information to external service providers. Any third party with whom we share Personal Data is subject to an extensive security and privacy assessment review to ensure they can provide adequate technical and organizational security measures.

When providing our services, we may also share your Personal Data with other Data Controllers, such as financial institutions, lawyers or notaries, licensed auditors assisting or supervising us in connection with our compliance obligations, HR and payroll providers, identity verification service providers and others. They are carefully chosen and instructed by us. They are bound by our instructions and are regularly inspected. The data provided to our service providers may be used by them to fulfill their tasks only.

We might also need to disclose your Personal Data 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.

Propel operates at a global level and therefore Personal Data may need to be transferred to countries outside of where it was originally collected. If we transfer personal data outside the European Economic Area (EEA), we will do so only if the EU Commission has decided that the third country ensures an adequate level of data protection or other appropriate safeguards exist (e.g. EU standard contractual clauses or binding corporate rules) or a person has given its consent to do so. For the transfer of special categories of Personal Data we ensure compliance with any other relevant requirements under local laws enacted pursuant to the GDPR.

Do Propel use Cookies?

The Website uses "cookies" to help personalize your online experience. A cookie is a text file that is placed on your hard disk by a web page server. We use cookies to configure a visit to our website more attractive and to enable the use of certain functions.

• Cookies cannot be used to run programs or deliver viruses to your computer.
• Cookies are uniquely assigned to you and can only be read by a web server in the domain that issued the cookie to you.
• We may use cookies to collect, store, and track information for statistical purposes to operate our Website and Services. You can accept or decline cookies.
• Most web browsers automatically accept cookies, but you can modify your browser settings to disable cookies if you prefer (check your browser's Help page).
• If you choose to decline cookies, you may not be able to experience all the features of the Website and Services.

Privacy choices

Although restricting access to certain data might affect your experience, you can always make changes, such as:

• Disable cookies: You can block cookies in your web browser.
• Don't provide Personal Data: You can still navigate the Website and access all our features that don't require your personal information.
• You can withdraw your consent for marketing communications: We will contact you directly if we receive your explicit consent to send marketing communication, but if you don't wish to hear from us again, please click the unsubscribe button on the communication.

What are my rights in relation to Propel?

You have the right of access, rectification or erasure, restriction of processing, to object and to data portability with respect to your personal data.

Propel is available for corresponding requests or messages at the specified address below:

• Please note that the deletion of data is only possible if there are no precluding legal regulations. Information concerning your requests or messages is transmitted in electronic form (by e-mail). Should you use this option of providing information via e-mail, the specified e-mail address (both sender and recipient) will not be used for any purpose other than the provision of information and its documentation. You also have the right to lodge a complaint concerning the processing of your personal data by us with a supervisory authority.
• If we are legally required to disclose data to local, state, national or international authorities, we will comply with this obligation.
• We will also disclose information to third parties when required by applicable laws and regulations.
• In addition, we may disclose information to investigate, prevent, or initiate countermeasures against illegal activities or suspected fraud, or to apply or enforce any of our contracts and licensing rights.

Does Propel save my data in case of me making a request?

In case you direct an inquiry to Propel, Propel saves the communication history with you as well as information and data submitted in the course of this communication (e.g. email address), in order to optimally answer your request and any further follow-ups. Propel will delete the relevant data after the storage is no longer required or restrict the processing if statutory retention periods exist.

Is my data secure?

Propel takes all appropriate technical and organizational security measures to protect your data against manipulation, loss, destruction or unauthorized access by third parties. Our systems are secured against unauthorized access. However, we have to point out that the Internet does not allow for absolute data security despite all technical measures. We are not liable for actions of third parties.

Does Propel link to external sites?{" "}

Our Site and Site Services may contain links to websites created and maintained by other public or private organizations. We provide these links as a service to our users. Please note that when you follow a link to an external site, you will be leaving Propel’s Site Services and are subject to the privacy and security policies of the site to which you are visiting. Propel is not responsible for the security practices or the content of such external sites.

Privacy of minors

We do not knowingly collect any Personal Data from persons under the age of 18. If you are under the age of 18, please do not submit any Personal Data through our Website or Service.

Acceptance of this policy

You acknowledge that you have read this Policy and agree to all its terms and conditions. By using the Website or its Services, you agree to be bound by this Policy. If you do not agree to abide by the terms of this Policy, you are not authorized to use or access the Website and its Services.

Is an amendment of the Privacy Policy possible?

Propel reserves the right to amend this Privacy Policy at any time, but Propel will always observe the applicable statutes concerning data protection. An up-to-date version is available at our website. Propel recommends that users regularly review our Privacy Policy in order to be informed about our current Privacy Policy.

As part of our commitment to transparency and compliance with the General Data Protection Regulation (GDPR), we ensure that you are informed of your rights regarding your personal data. You are entitled to the following rights:

1. Right to Access (Article 15)

You have the right to request access to the personal data we hold about you. This includes obtaining:

•       A copy of the personal data.

• The purposes of processing.

• The categories of personal data involved.

• The recipients or categories of recipients who receive your personal data.

• The retention period or criteria for storing your data.

2. Right to Rectification (Article 16)

You have the right to request the correction of any inaccurate or incomplete personal data. If you believe the information we hold about you is incorrect, you can request that it be updated.

3. Right to Erasure (Right to be Forgotten) (Article 17)

You have the right to request the deletion of your personal data in certain circumstances, such as:

• When the data is no longer necessary for the purpose for which it was collected.

• If you withdraw your consent (and no other legal grounds for processing exist).

• When you object to the processing and there are no overriding legitimate grounds.

4. Right to Restrict Processing (Article 18)

You have the right to request a restriction of processing in the following cases:

• If you contest the accuracy of the data.

• If the processing is unlawful and you oppose erasure.

• If we no longer need the data but you require it for legal claims.

• If you have objected to the processing pending verification of overriding legitimate grounds.

5. Right to Data Portability (Article 20)

You have the right to receive the personal data you have provided to us in a structured, commonly used, and machine-readable format. You also have the right to request that we transfer this data to another data controller where technically feasible.

6. Right to Object (Article 21)

You have the right to object to the processing of your personal data, particularly where the processing is based on our legitimate interests or for direct marketing purposes. In such cases, we will stop processing unless there are compelling legitimate grounds to continue.

7. Right to Withdraw Consent (Article 7)

If the processing of your personal data is based on your consent, you have the right to withdraw your consent at any time. The withdrawal of consent will not affect the lawfulness of processing based on consent before its withdrawal.

8. Right to Lodge a Complaint (Article 77)

If you believe that the processing of your personal data infringes GDPR, you have the right to lodge a complaint with a supervisory authority, particularly in the EU country where you reside, work, or where the alleged infringement occurred.

9. Right to Automated Decision-Making and Profiling (Article 22)

You have the right not to be subject to a decision based solely on automated processing, including profiling, which produces legal effects or significantly affects you. Exceptions apply in cases where:

• Automated decision-making is necessary for entering or performing a contract.

• You have provided explicit consent.

• It is authorized by EU or member state law.

How to Exercise Your Rights

To exercise any of these rights, please contact our Data Protection Officer (DPO) at:

• Email: grow@withpropel.com

We will respond to your request as soon as possible and within one month, in compliance with GDPR requirements. For certain requests, we may require additional information to verify your identity.