This Policy explains our privacy practices for the Website and services provided by Emprenur as well as privacy practices that affect Users. By accessing and/or using the Website and its related sites, applications, services, goods and/or registering for an account, you acknowledge that you understand how we process your personal data in accordance with this Policy, including our collection, use, disclosure, processing and retention of personal information. You can also learn how to limit sharing of information in this Policy.

This Policy is supplemental to Emprenur Terms of Service, as applicable (the “ToS”). Capitalized terms used but not defined herein shall have the respective meanings given to them in the ToS.

'Personal information' means information or an opinion about an identified individual, or an individual who is reasonably identifiable. Emprenur's Privacy Policy applies to personal information collected and/or held by Emprenur.

We will review this policy regularly, and we may update it from time to time.

1. The types of personal information we collect and hold

We collect personal information about our Users in order provide our products, services, and customer support. Our products, services, and customer support are provided through many platforms including but not limited to: websites, phone apps, e-mail, and telephone. The specific platform and product, service, or support you interact with may affect the personal data we collect.

Not all information requested, collected, and processed by us is "Personal Information" as it does not identify you as a specific natural person. This will include majority of "User Generated Content" that you provide us with the intention of sharing with other Users. Such "Non-Personal Information" is not covered by this privacy policy. However, as non-personal information may be used in aggregate or be linked with existing personal information; when in this form it will be treated as personal information. As such, this privacy policy will list both types of information for the sake of transparency.

In some situation Users may provide us with personal information without us asking for it, or through means not intended for the collection of particular types of information. Whilst we may take reasonable steps to protect this data, the User will have bypassed our systems, processes, and control and thus the information provided will not be governed by this privacy policy.

In some situations Users may provide us personal information over platforms that are outside our control; for example through social media or forums. Whilst any information collected by us is governed by this Privacy Policy, the platform by which it was communicated will be governed by its own privacy policy.

2. How we collect personal information

Information that you specifically give us

While you use our products and services you may be asked to provide certain types of personal information. This might happen through our website, applications, online chat systems, telephone, paper forms, or in-person meetings. We will give you a Collection Notice at the time, to explain how we will use the personal information we are asking for. The notice may be written or verbal.

We may request, collect, or process the following information:

• Account Details - Username, password, profile picture.
• Contact Details - e-mail address, phone number.
• Location Details - physical address, billing address, time zone.
• Identity Details - full name, proof of identity (e.g. drivers’ license, passport), proof of address (e.g. utility bill), photograph of the User.
• Financial Information - credit card details, wire transfer details, payment processor details, tax numbers and any other information collected by our third-party payment processor.
• User Generated Content - project descriptions and attachments, bid description, User profiles, User reviews, User messages etc.

Information that we collect from others

Users can give permission for us to connect to their account on other platforms to collect personal information. This includes but is not limited to Facebook, LinkedIn, and Google. Information collected will be governed by this Privacy Policy. Users can stop us from collecting data from other platforms by removing our access on the other platform or by contacting our support team.

Users have the ability to invite non-Users to our platform by providing contact details such as e-mail address. In these situations, the information will be collected and stored by us to contact the non-User and to prevent abuse of the invite systems.

Your payment provider may transmit information about the payment that we may collect or process.

In some situations, personal information of Users may be collected from public sources.

We may collect or process the following information:

• Basic Details - Username, profile picture.
• Contact Details - e-mail address, phone number.
• Location Details - physical address, billing address, time zone.
• Financial Information - payment account details, wire transfer details and any other information collected by our third-party payment processor.
• List of contacts - e-mail provider address book.
• User Generated Content - User profile.

Information we collect as you use our service

We maintain records of the interactions we have with our Users, including the products, services and customer support we have provided. This includes the interactions our Users have with our platform such as when a User has viewed a page or clicked a button.

In order to deliver certain products or services we may passively collect your GPS coordinates, where available from your device. Most modern devices such as smartphones will display a permission request when our platform requests this data.

When we are contacted we may collect personal information that is intrinsic to the communication. For example, if we are contacted via e-mail, we will collect the e-mail address used.

We may collect or process the following information:

• Metadata - IP address, computer and connection information, referring web page, standard web log information, language settings, time zone, etc.
• Device Information - device identifier, device type, device plugins, hardware capabilities, etc.
• Location - GPS position.
• Actions - pages viewed, buttons clicked, time spent viewing, search keywords, etc.

Links to other sites

On our Website, you may encounter links to third party websites. These links may be from us, or they may appear as content generated by other Users. These linked sites are not under our control and thus we are not responsible for their actions. Before providing your personal information via any other website, we advise you to examine the terms and conditions of using that website and its privacy policy.

3. How we use personal information

The information we request, collect, and process is primarily used to provide Users with the product or service they have requested. More specifically, we may use your personal information for the following purposes:

• to provide the service or product you have requested;
• to facilitate the creation of a User Contract (see Terms of Service for more information);
• to provide technical or other support to you;
• to answer enquiries about our services, or to respond to a complaint;
• to promote our other programs, products or services which may be of interest to you (unless you have opted out from such communications);
• to allow for debugging, testing and otherwise operate our platforms;
• to conduct data analysis, research and otherwise build and improve our platforms;
• to comply with legal and regulatory obligations;
• if otherwise permitted or required by law; or
• for other purposes with your consent, unless you withdraw your consent for these purposes.

      The 'lawful processing' grounds on which we will use personal information about our Users are (but are not        limited to):

• when a User has given consent;
• when necessary for the performance of a contract to which the User is party;
• processing is necessary for compliance with our legal obligations;
• processing is necessary in order to protect the vital interests of our Users or of another natural person.
• processing is done in pursuing our legitimate interests, where these interests do not infringe on the rights of our Users.

We use automated decision when helping matching Users to jobs. The primary way this occurs is through how we rank Users. These rankings are produced by analyzing User generated content, User activity and the outcome of jobs; in this context, User generated content will include reviews that Users receive when completing jobs. More information on these ranking guides can be found in our community articles. Automated decision making is also used to recommend potential jobs to our Users and as a part of our marketplace security systems.

4. When we disclose personal information

We do not sell or rent your personal information to third parties for their marketing purposes without your explicit consent.

We share your personal information with third parties as detailed below:

Our third party service providers

We share personal information for business purposes with service providers that provide us with services for the purpose of operating the Website, opening and operating your Account as well as providing ancillary services and solutions. The personal information of Users may be held, transmitted to or processed on our behalf outside the USA, including 'in the cloud', by our third party service providers. Consistent with applicable legal requirements, we take appropriate technical and organizational measures to require third parties to adequately safeguard your personal information and only process it in accordance with our instructions.

These may include, among others:

• Cloud hosting, storage, networking and related providers
• billing and payment processors, vendors and banking providers
• CRM systems
• forum hosting
• community management services
• data and cybersecurity services and other security providers
• web analytics and performance tools
• translation tools
• IT SaaS services
• session recording
• SMS providers, communication systems and mailing systems
• data optimization and marketing services
• data enrichment services
• legal and financial advisors or technical consultants.

Other disclosures and transfers

We may also disclose your personal information to third parties for the following purposes:

• if necessary to provide the service or product you have requested;

• we receive court orders, subpoenas or other requests for information by public authorities and/or law enforcement;

• if otherwise permitted or required by law; or

• for other purposes with your consent.

As we are a global company, with offices around the world, your personal information may be processed by our staff in any of our offices.

With other Users and Website visitors

Once you register, your username, country, and additional information regarding your activity is made public and is visible to all users of the Website. This information includes photos you upload, your published portfolio, Project information, ratings, and additional information you may choose to add to your profile. We also offer you the opportunity to participate and post content publicly in forums, blogs and on other similar features. Please be aware that certain information, such as your user name and profile, together with the content uploaded by you, will be publicly displayed when you use such features. Your information will also be shared with other users when you message or otherwise communicate with such users. When you publish your information and/or share your data with other Emprenur users, you do so at your own risk. If you choose to share personal information with other Users, including Sellers providing you a service via Emprenur, such personal information is shared with other users as separate controllers. While Emprenur our ToS require Sellers to keep the information shared with them confidential, Emprenur cannot ensure that all Users will do so and it is your responsibility to ensure that other Users will comply with your standards.

For payments and fraud detection

We share personal information with payment processors, fraud detection agencies and similar third parties for the purpose of facilitating payments done via the Website and securing the Website and protecting it against fraud, unauthorized transactions (such as money laundering), claims or other liabilities.

With social media partners

Our Website includes certain social media features, including single sign on features. We also share limited personal information with such social media platforms and marketing partners, such as Facebook and Google, to promote our services or the Emprenur marketplace. Such features and third party services collect certain information about you and may set a cookie to enable their functionality. Such third parties’ features are governed by their own policies.

With users with whom you interact

We share personal information to help facilitate interactions between Users. For example, if you are a Buyer we may share certain limited information about you (such as the fact it is your first purchase on Emprenur) with the Seller to ensure the services you receive from the Seller will fit your needs; such sharing of information is limited in scope, and is only intended to improve the services provided by the Seller and your user experience.

With our corporate affiliates

We share personal information with Emprenur’s corporate affiliates that are related by common control for the purpose of operating the Website, providing our services to you and for other purposes listed herein.

In the context of a corporate transaction.

Personal information will also be disclosed if we go through a business transition such as a merger, sale, transfer of all or a portion of Emprenur's assets, acquisition, bankruptcy or similar event. In the event that we sell any business or assets, we will disclose your data to the prospective buyer. If we or substantially all of our assets are acquired by a third party, information held by us about our users will be one of the transferred assets.

5. Accessing, correcting, or downloading your personal information

You have the right to request access to the personal information Emprenur holds about you. Unless an exception applies, we must allow you to see the personal information we hold about you, within a reasonable time period, and without unreasonable expense for no charge. Most personal information can be accessed by logging into your account. If you wish to access information that is not accessible through the platform, or wish to download all personal information we hold on you in a portable data format, please contact our Privacy Officer.

You also have the right to request the correction of the personal information we hold about you. All your personal information can be updated through the User settings pages. If you require assistance please contact our customer support.

6. Exercising your other rights

You have a number of other rights in relation to the personal data Emprenur holds about you, however, there may be restrictions on how you may exercise the rights. This is largely due to the nature of the products and services we provide. Much of the data we collect is in order to facilitate contracts between Users, facilitate payments, and provide protection for the legitimate Users of our marketplace - these data uses are protected against the below rights.

You have the right to:

• seek human review of automated decision-making or profiling
• opt-out of direct marketing, and profiling for marketing
• deletion
• temporary restriction of processing

Human review of automated decision making / profiling - In the case of our ranking algorithms, it is not possible to exercise this right as this ranking is a fundamental part of the marketplace that Users participate in, opting out would mean not being able to participate in the marketplace. Decisions affecting marketplace security are already reviewed by humans.

Deletion - Most personal information and User generated content cannot be deleted as they are used to support contracts between Users, document financial transactions, and are used in providing protecting other legitimate Users of the marketplace. In the case of non-personal data that can be linked with personal data, it will either be deleted or otherwise anonymized from the personal data.

Temporary restriction to processing - under certain circumstances you may exercise this right, in particular if you believe that the personal data we have is not accurate, or you believe that we do not have legitimate grounds for processing your information. In either case you may exercise this right by contacting our Privacy Officer.

Users may exercise any of the above rights by contacting our Privacy Officer.

7. Contact Us

If you have an enquiry or a complaint about the way we handle your personal information, or to seek to exercise your privacy rights in relation to the personal information we hold about you, you may contact our Privacy Officer as follows:

By Email: privacy-officer@emprenur.com

While we endeavor to resolve complaints quickly and informally, if you wish to proceed to a formal privacy complaint, we request that you make your complaint in writing to our Privacy Officer via e-mail. We will acknowledge your formal complaint within 10 working days of receipt.

If we do not resolve your privacy complaint to your satisfaction, you may lodge a complaint with Mount Vernon Consumer Protection (https://cmvny.com/239/Consumer-Protection), phone number: 914-665-2300, Mt. Vernon City Hall, 1 Roosevelt Square N, Mt. Vernon, NY 10550.