Exparang

For Members

We at Exparang AB (559139-0470) (“Exparang”, “we” or “us”) are committed to protect the privacy of individuals (the “Members”, “you”) who are seeking and/or are contacted for work opportunities, either by using our platform or as otherwise engaged by Exparang to connect with future Employers and strive to provide a safe user experience on our platform (the “Platform”).

This privacy notice (the “Notice”) describes how your personal data is collected, used and shared, as well as your rights and how to enforce them. Terms not otherwise defined in this Notice shall have the same meaning ascribed to them in the Terms of Use.

We are the data controller for the processing of your personal data as described herein. Please do not hesitate to reach out to us if you have any questions or comments on your privacy and our processing of your personal data.

You can reach us by using the following contact details:

Email: support@exparang.com
Postal address: Exparang AB, Slottsbacken 8, 111 30 Stockholm, Sweden

Personal Data That We Process

We collect information about you when you use the Platform or is otherwise in contact with us. We receive and store this information when you enter it on our website, send it to us, or provide it to us in any other way. We also collect information about you from other sources, such as LinkedIn, your current or former employer or other Members. You can learn more about how we process your personal data, including what types of personal data we process, below.

Information collected from you

Contact information like name, email address and phone number.
Your job-preferences provided when you fill out your candidate profile. This includes preferences on salary, values, country of work and prior job experience.
Resume, and all information included in it, including previous work history, education and your picture.
Information imported by you from third party sources, e.g., LinkedIn.
Communications data, i.e., on the platform when you are in contact with us or an Employer.
Information otherwise provided by you, e.g., in free-text fields on the Platform, such as gender, age, nationality, and location..

Information collected from others

Recommendation from another Member. Other Members may recommend a person they believe are relevant for a work opportunity. We may collect your name, phone number and email address from that Member.
Information from your LinkedIn or an Employer. We collect information about you (email-address, name, title and employer) in order to invite you to apply for a work opportunity you are considered relevant for.

Information automatically collected about you when you use the Platform

Matching opportunities you view and respond to.
Technical data. We will collect technical data from your device in connection with your use of the Platform, such as IP address, browser type and version, screen resolution, preferred language, operating system and computer platform. Technical data may also include information about how you use the Platform, and if you encounter any technical errors. Even though we do not normally use technical data to identify individuals, sometimes individuals can be recognized from it. When you visit our website, we will collect technical data regarding your device from cookies and similar technologies. For more information on cookies view our cookie policy on our website.
User activity logs. We collect information about your activity on the Platform in order to analyze users’ use of the Platform for improving the Platform, but also to enable user support.

How and Why We Use Your Personal Data

Purpose	Categories of personal data	Legal basis	Storage period
To invite you to apply for a membership on the Platform.	Contact information, information imported by you from third party sources and resume.	Our legitimate interest in upholding our contractual obligations with our customers and finding relevant people for the work opportunities our customers have published in the Platform (GDPR, art 6.1(f)). Contact us if you want to learn more about how we have balanced your interests against ours.	We temporarily store this information for the sole purpose of sending a one-time email.
To evaluate your application to become a member and to accept or deny your application.	Contact information, information imported by you from third party sources and resume.	To take measures prior to entering into a contract with you (GDPR art 6.1(b)).	If you become a member: For as long as you are active on the Platform and for 5 years since your last activity. If we deny your application: 24 hours after we have handled your application.
To register your account and administrate our contractual relationship.	Contact information, your job preferences and information provided by you in the free text fields.	Performance of the contract with you (i.e., the Terms of Use (GDPR art 6.1(b)).	For as long as you are active on the Platform and for 5 years since your last activity.
To provide the Platform to you and to manage your account.	Contact information and technical data.	Performance of the contract with you (i.e., the Terms of Use (GDPR art 6.1(b)).	For as long as you are active on the Platform and for 5 years since your last activity.
To create matching opportunities. This may include profiling, please learn more below.	Contact information, your job-preferences, resume, information imported by you from third party sources and matching opportunities.	Performance of the contract with you (i.e., the Terms of Use (GDPR art 6.1(b)).	For as long as you are active on the Platform and for 5 years since your last activity.
To share your full profile with the Employer or other career databases.	All categories of personal data	You consent (GDPR 6.1(a)).	Until the position has been filled or you withdraw your consent.
To communicate with you (e.g., send you reminders, confirmations, application messages and other relevant information about the Platform).	Contact information and communications data	Our legitimate interest to enhance and maximize your use of the Platform and to communicate effectively with you (GDPR, art 6.1(f)). Contact us if you want to learn more about how we have balanced your interests against ours.	For as long as you are active on the Platform and for 5 years since your last activity.
For marketing of our Platform and other services (send newsletters or other information about the Platform and us).	Contact information	Our legitimate interest of being able to market the Platform and ourselves to our existing users (GDPR, art 6.1(f)). Contact us if you want to learn more about how we have balanced your interests against ours.	For as long as you are active on the Platform and for 5 years since your last activity.
To provide user support (respond to and resolve complaints and problems with the Platform (e.g., bugs)).	Contact information, technical data and user activity logs	Our legitimate interest to provide you with excellent functionality (GDPR, art 6.1(f)). Contact us if you want to learn more about how we have balanced your interests against ours.	For as long as you are active on the Platform and for 5 years since your last activity.
To conduct user surveys (gain a deeper understanding of our users’ problems and needs).	Contact information.	Our legitimate interests in developing and improving the Platform (GDPR, art 6.1(f)). Participation is always voluntary. Contact us if you want to learn more about how we have balanced your interests against ours.	For as long as you are active on the Platform and for 5 years since your last activity.
To develop and improve the Platform including troubleshooting, data analysis, research, statistical purposes and testing (such as beta testing and evaluation of new features, in line with the fundamental nature of the Platform), to understand how the Platform is used in order to make it more intuitive.	Contact information, technical data and user activity logs, information provided by you.	Our legitimate interests in developing and improving the Platform and its features (GDPR, art 6.1(f)). Contact us if you want to learn more about how we have balanced your interests against ours.	For as long as you are active on the Platform and for 5 years since your last activity.
To fulfil and uphold our legal obligations under applicable laws (e.g., for bookkeeping and reporting to the authorities).	Contact information, technical data and user activity logs.	Our legal obligation according to Chapter 7, Section 2, the Accounting Act (1999:1078). (GDPR art 6.1(c)).	For 7 years after you have deleted or stopped using your account.
If we need to defend ourselves in legal proceedings, in case of supervision or when responding to data subject requests or claims.	All categories of personal data.	Our legitimate interest to protect ourselves, you or others and to defend against or enforce legal claims or misconduct on the Platform (GDPR, art 6.1(f)). Contact us if you want to learn more about how we have balanced your interests against ours.	As long as we have to keep the data to be able to establish, exercise or defend the legal claim in question, we are under supervision, or have responded to the request.
Anonymization and aggregation of your personal data to enhance our services and products.	All categories of personal data.	Our legitimate interest in enhancing our services and products (GDPR, art 6.1(f)). Contact us if you want to learn more about how we have balanced your interests against ours.	Not applicable. Once anonymized/aggregated, it does not longer amount to personal data. However, please note that we may store your personal data for other purposes in accordance with this Notice.

Profiling

The personal data we collect and hold about you will be used in order for us to provide you with matching career opportunities with Employers. The personal data used for this purpose include contact information, your job-preferences, resume, information imported by you from third party sources and matching opportunities. The matching opportunities are created through an algorithm built on machine learning. The algorithm learns from the personal data we hold about our users including preferences and choices on which matching opportunities are reviewed and declined or accepted. Based on this, a matching opportunity is either created or not.

This means that profiling is a part of the Platform, for the purpose of providing the most suitable job matches for you. Profiling is conducted based on performance of the contract with you (the Terms of Use), where we have committed to provide you with the Platform and to match and connect you and Employers based on your skills and preferences.

Please note that if you do not provide us with the personal data mentioned above, or you object to profiling, we may not be able to match you with an Employer. However, you may always contact us to have a decision contested or explained.

With Whom We Share Personal Data

The information we gather will be shared with the following categories of third parties:

Employers. Your personal data will never be shared with an Employer unless you explicitly agree to reveal parts of, or your full, profile to a specific Employer. Your profile may also be shared with other career databases if you agree to such sharing. When registering a profile, you will see clearly marked what data that, by default, is only visible to us for the purpose of creating matching opportunities and what data you may decide to share with a specific Employer or another career database.
Our service providers. We share your personal data with our suppliers and partners who help us provide the Platform or supply other services to us which require the processing of personal data, this includes:

Hosting providers,
Electronic communication service providers (e.g., SMS and e-mail providers) and,
Advertising and marketing partners.

Authorities and other public actors. Sometimes legal obligations may require us to share information about you, e.g., to respond to lawful requests from law enforcement agencies, regulatory agencies, and other public and government authorities. We may also disclose information if needed to detect and prevent fraud or in connection with a legal process, for example to enforce our Terms of Use or to protect our rights, or the rights of our affiliates, you or others.
Merger, acquisition or other business transfer. We may share or transfer your personal data in connection with any merger, sale of company assets, financing, or acquisition of all or a portion of our business to another company.
Other third parties, if you consent to such sharing, for example personality assessment companies.

Where We Process Your Personal Data

We always strive to process and store your personal data within the EU/EEA. However, your personal data may be processed in the United States when we analyze traffic and acquisition data, when managing our database and when providing our matching function on the Platform.

When your personal data is transferred outside the EU/EEA, we will ensure that it continues to enjoy the same level of protection as awarded within the EU/EEA. Hence, personal data will only be transferred outside of the EU/EEA if there is a valid transfer mechanism in place. In most situations, this includes the EU Standard Contractual Clauses, or alternatively the recipient country enjoys an adequacy decision by the EU Commission.

Your Rights

Right to access your data. You have the right to know if we process personal data about you. If we do, you also have the right to receive information about the personal data we process and why we do it. In addition, you may receive a copy of all personal data we have about you together with information on how the data has been collected, processed, shared, etc.

If you are interested in specific information, please indicate it in your request. For example, what contact and identification data we have about you or if you want information from a certain time period.)
Right to have erroneous data corrected. If the personal data we hold about you is incorrect, you have the right to have it corrected. You also have the right to supplement incomplete personal data with additional information that may be needed for the personal data to be correct.

Once we have corrected your data, or once it has been supplemented, we will inform those we have shared your personal data with about the update, unless this is impossible or too cumbersome. If you ask us, we will also tell you who we have shared your personal data with.

If you request to have data corrected, you also have the right to request that we restrict our processing during the time we investigate the matter.

Please note that you can always correct, supplement and delete your personal data by editing your profile on the Platform.
Right to have data deleted. In some cases, you have the right to have your personal data deleted. You have the right to have your data deleted if:
1. The personal data is no longer needed for the purposes for which it was collected,
2. You withdraw your consent (if applicable),
3. The personal data is used for direct marketing and you unsubscribe from it,
4. You oppose use that is based on our legitimate interest, and we cannot show compelling grounds that outweigh your interests,
5. The personal data has been used illegally, or
6. Deletion is required to fulfill a legal obligation.
Right to restriction. Restriction means that the personal data is marked so that it may only be used for certain limited purposes. The right to restriction applies:
1. When you believe the personal data is incorrect and you have requested correction. If so, you can also request that we limit our use while we investigate if the personal data is correct or not.
2. If the processing is illegal but you do not want the personal data to be deleted.
3. When we no longer need the personal data for the purposes for which we collected it, but you need it to be able to establish, assert or defend legal claims.
4. If you object to the processing. If so, you can request that we limit our processing while we investigate if our interest in processing your personal data outweighs your interests.
Even if you have asked us to restrict our processing of your personal data, we have the right to process it for storage, if we have obtained your consent to use it, to assert or defend legal claims or to protect someone else’s rights. We may also use the data for reasons relating to an important public interest.

We will let you know when the restriction expires. If we restrict the processing of your personal data, we will also inform those we have shared your personal data with, unless this is impossible or too cumbersome. If you ask us, we will also tell you who we have shared your personal data with.
Right to data portability. You have the right to receive personal data, that you have provided us with, in a structured, commonly used and machine-readable format, and transfer this personal data to another controller, provided that the processing is based on consent or a contract to which you are a party.
Right to object. You have right to object to processing that is based on our legitimate interest. If you object to the processing, we will, based on your situation, evaluate if our interests in using the data outweigh your interests in the data not being used for that purpose. This means we will no longer process the personal data for the purpose that you object to, unless we can demonstrate compelling legitimate grounds that outweigh your rights and freedoms. However, we may still use the personal data to establish, exercise or defend legal claims. If you object to the processing, you also have the right to request that we restrict our processing during the time we investigate the matter.

You may always object to your personal data being processed for direct marketing purposes. Feel free to set or turn off notifications in your account settings, or you can follow the unsubscribe instructions contained in the emails received from us (unsubscribe).
Right to withdraw your consent. You have the right to withdraw your consent for a specific processing at any time. You can withdraw your consent on the Platform or by contacting us by the contact details in the beginning of this Notice. However, please note that it will not affect any processing that has already taken place.
Right to lodge a complaint. Please let us know if you do not agree with the way we are processing your personal data. You may also lodge a complaint with the supervisory authority in the Member State where you live, work or where you believe and infringement of the GDPR has taken place. In Sweden the supervisory authority is the Swedish Authority for Privacy Protection (Sw. “Integritetsskyddsmyndigheten”) Swedish Authority for Privacy Protection.

Changes to this Notice

We reserve the right to change this Notice from time to time to reflect changes in the Platform or our collection and use of your personal data. You will be informed of any significant changes separately, but we also recommend that you review this Notice from time to time.