Primonto Privacy Policy

1. Introduction

Primonto respects your privacy and is committed to protecting your personal data. This privacy policy describes how we collect, use, share and secure your data when you use our platform (both via the website and the application).

This policy applies to all users of the platform, including:

• Job seekers/Workers: individuals looking for work or already hired via the platform.
• Employers: companies that post vacancies and search for candidates.
• Housing providers: parties that offer accommodation via the platform.
• Visitors: individuals who visit the website without logging in.

2. Data Controller

The party responsible for processing your personal data is:

3. What data do we collect?

Depending on your role on the platform, we collect the following data:

3.1 For Job seekers/Workers

• Identification data: Name, address, email address, phone number, date of birth.
• Profile data: CV, work experience, education, skills, language skills, preferences for work location and type, profile photo.
• Application data: Applications, application status, communication with employers.
• Contractual data: If you are hired via our platform: employment contracts, start date, salary data (where applicable for administration).

3.2 For Employers

• Company data: Company name, address, VAT number, sector, description.
• Contact persons: Name, role, email address and phone number of users within the company account.
• Vacancy data: Content of vacancies, requirements, location.
• Billing data: Billing address, payment history.

3.3 For Housing providers

• Provider data: Company or personal data, contact information.
• Accommodation data: Address, description, photos, capacity, facilities, prices.
• Booking data: Availability, reservations linked to workers/employers.

3.4 Automatically collected data (All users)

• Technical data: IP address, browser type, device type, operating system.
• Usage data: Log files, activity on the platform (e.g. pages viewed, click behaviour), login times.

4. What do we use your data for? (Purposes)

We process your data for the following purposes:

• Service provision: Facilitating the matching between job seekers and employers, and linking housing.
• Account management: Creating and managing your account, including authentication and security.
• Communication: Keeping you informed of relevant vacancies, application status, bookings or changes to our services.
• Contract management: Facilitating contract signing and storage of documents.
• Platform improvement: Analysing usage trends to optimise our services and user experience.
• Legal obligations: Compliance with tax, administrative and other legal requirements.
• Security: Detecting and preventing fraud, abuse and security incidents.

5. Legal bases for processing

We base the processing of your data on the following legal grounds (under the GDPR):

• Performance of a contract: Necessary to deliver our services (e.g. matching, account access).
• Consent: For specific purposes such as receiving newsletters (you can always withdraw this).
• Legal obligation: Where we are required to retain or share data (e.g. with government authorities).
• Legitimate interest: For the security of our platform, fraud prevention and improvement of our services, weighing your privacy interests.

6. Data Sharing

We only share your data with third parties in the following cases:

• Between users: Profile data of job seekers is shared with employers they apply to (or who search the database, if enabled). Housing data is shared with searching parties.
• Service providers: We use trusted third parties for hosting (e.g. cloud providers), email delivery, payment processing and analytics. These parties process data solely on our behalf (data processing agreement).
• Legal requirements: If we are legally obliged to do so (e.g. by police or judicial authorities).
• Business transfer: In the event of a merger, acquisition or sale of assets, data may be transferred to the new owner.

We never sell your personal data to third parties for marketing purposes.

7. International transfers

Your data is primarily processed within the European Economic Area (EEA). If we use service providers outside the EEA, we ensure appropriate safeguards, such as the European Commission's Standard Contractual Clauses (SCCs), to guarantee an adequate level of protection.

8. Retention period

We do not retain your data longer than necessary for the purposes for which it was collected, or as long as legally required (e.g. the 7-year tax retention obligation for invoices).

• Active accounts: Data is retained as long as your account is active.
• Inactive accounts: We may delete or anonymise accounts after a prolonged period of inactivity, subject to prior notice.
• Application data: Retained for a reasonable period for ongoing procedures and possibly talent pools, unless you request deletion.

9. Your rights

You have the following rights regarding your personal data:

• Right of access: You can request which data we hold about you.
• Right to rectification: You can have incorrect data corrected.
• Right to erasure (to be forgotten): You can ask us to delete your data (under certain conditions).
• Right to restriction: You can request that processing be temporarily stopped.
• Right to portability: You can request your data in a structured format.
• Right to object: You can object to processing based on legitimate interest.

To exercise these rights, you can contact us at legal@primonto.com. We generally respond to your request within one month.

10. Security

Primonto takes the protection of your data seriously. We take appropriate technical and organisational measures to prevent misuse, loss, unauthorised access, unwanted disclosure and unauthorised modification. If you believe that your data is not properly secured or there are indications of misuse, please contact us immediately.

11. Complaints

If you have a complaint about the processing of your personal data, we ask you to contact us first. If we cannot resolve it together, you have the right to lodge a complaint with the supervisory authority. In the United Arab Emirates, this is the UAE General Data Protection Regulation Authority (GDPRA).

12. Changes

We may amend this privacy policy from time to time. Changes will be published on this page. In the event of significant changes, we will inform you proactively (for example via email or a notification on the platform).