VERYLOCALS Privacy Policy Last update: 01 Mar 2022

VERYLOCAL, (“VERYLOCAL”, “we”), are responsible for the use and processing of your personal data shared with us in accordance with this privacy policy and in compliance with the relevant data protection Regulation and laws around the globe. This document provides you with the necessary information regarding your rights and our obligations, and explains how, why and when we process your personal data.

VERYLOCAL is concerned with your privacy and strives to protect your identity.

It is VERYLOCAL’s intention to comply with current laws and policies concerning privacy. This document is being provided to inform you, among other things, of what kind of information is being collected by VERYLOCAL and how it is processed.

We require you to explicitly accept this privacy policy before sharing any private or personal information with us. If you do not accept this privacy policy then you should not share any personal or private information with us. By explicitly accepting this privacy policy you consent to the use of your personal data in accordance with what is stated in this privacy policy

By using this website and/or sharing private information like a Resume or CV with us you accept this privacy policy and consent to the use of your personal data in accordance with what is stated in this privacy policy.

This Policy sets out the procedures that are to be followed when dealing with personal data. The procedures and principles set out herein must be followed at all times by VERYLOCAL, its employees, agents, contractors, or other parties working on behalf of VERYLOCAL.

What type of personal data do we process?

We will use all the personal data that is either provided by you at any time, or information which we have gathered using online cookies in order to be able to process and administrate our services provided to you according to your expectations as a user of our services. The personal data which is processed by VERYLOCAL includes name, email address, browser, IP address, phone number and any additional information you choose to share with us by email or phone or via submitting your resume to us.

We may share some of your personal data with our clients and business partners, for example when you would like us to discuss your resume with one of our clients.

How do we use personal data?

Your personal data may be used to analyze browsing patterns in order to provide you with more relevant information and marketing, deliver the services, perform identification assessments, risk assessments, enhancement of VERYLOCAL’s products/services to benefit the customer- relationship, customer analysis, direct marketing, customer surveys, newsletters, internally generated statistics, and tools for analysis for commercial and marketing purposes to the benefit of VERYLOCAL and carefully selected VERYLOCAL partners and clients. The information may also be used for marketing purposes by sending out marketing letters, emails and SMS to you as a customer. All marketing messages are sent in accordance with applicable law and we ask for your consent to receive promotional offers from us. You may opt-out of receiving these message at any time by sending your request to unsubscribe@verylocals.com or by following the opt-out instructions in each message.

We may also process your personal data for purposes of preventing fraud and similar types of criminal activity as well as complying with legal requirements, i.e. in accordance with measures against money laundering and funding of terrorist organizations. We may use your personal data to comply with other legal obligations. For example, we may disclose it to government authorities if subject to a subpoena or other valid court order.

Your information may further be used to analyze purchasing patterns in order to provide you with relevant marketing and account information and also to enhance our website and services, solutions and processes. Enhancing solutions and processes may also include transferring your personal data to third party suppliers to be used as analysis data. We may also share your personal data with service providers who provide products and services on our behalf (e.g., direct marketing, printing and distribution). If and when we transfer your personal data to a third party, we will do so only in accordance with this privacy policy and applicable law. Such third parties are required by us to apply the same or greater protections to your personal data than are provided for in this privacy policy.

Transfers of data outside VERYLOCAL

VERYLOCAL may transfer, process and store information about you on servers located in a number of countries. Accordingly, VERYLOCAL may share your information with other selected partners, or subcontract processing to, or share your information with, third parties located in countries other than your home country in order to carry out the activities specified in this privacy policy. Your personal data may therefore be subject to privacy laws that are different from those in your country of residence. Information collected may be transferred to and processed by third parties identified above, located in a country outside of the USA, EEA, ME, IN, where you may have fewer legal rights in relation to your information. However, if we do transfer your personal data collected within the operating country to third parties outside the EEA, such transfer will be based on the safeguards either of the standard contractual clauses issued by the EU Commission, or ME, IN and the EU – U.S. Privacy Shield or comparable legally permissible mechanism.

In the event that parts, or the entirety of VERYLOCAL’s operations are sold or integrated with another entity, your personal data may be provided to our advisers, potential buyers and their advisers, and be handed over to the businesses’ new owner.

How do we protect your personal data?

To make sure your personal data is safely stored, a number of security measures are in place. VERYLOCAL has implemented safety routines, both technical as well as organizational measures to protect your personal data. Firewalls and necessary antivirus software are all in place to protect the information from being subject to hacker attacks or malware and access to data by unauthorized agents. Access to the spaces in which the data is stored is limited and requires employee identification (or identification of agents working on our behalf) for access. VERYLOCAL also uses SSL (Secure Socket Layer) which is a protocol for secure transfer of data on the Internet (or other networks). The customer should control that the SSL function is not de-activated in the browser settings.

By law we have appointed a representative to oversee the application of our privacy policy. Any concerns over the retention, use or disclosure of your information can be addressed to them via privacy@Verylocals.com.

How long do we store your personal data?

The information is stored for as long as it is needed in accordance with legal requirements, for example to avoid the organization from being used for money laundering purposes or financing of terrorism. Your personal data may also be stored for the purposes of fulfilling VERYLOCAL’s commitments to you and for maintaining the customer relationship such as fulfilling delivery and warranty commitments.

Your information is never stored for longer than what is legally permitted under current legislation.

Access, updating and change of your personal data?

As a customer you have the legal right to obtain information regarding what personal data is stored about you regardless of how the data has been collected. If you make such a request we will ask you to verify your identity and possibly ask you to give us more information about such a request. We may need to charge a nominal fee for this service for administrative purposes. We will only refuse your request if we are legally permitted or required to do so. If this is the case then we will give you reasons for doing so. To make a request for information, please contact us.

VERYLOCAL wants to ensure that your personal data is correct and up to date. If any of the information you have provided has changed (i.e. change of email address, name or credit information), please notify VERYLOCAL by sending an email to: privacy@verylocals.com. You have the right to request that information is corrected, blocked or deleted at any time. Under the right to erasure you can also request for deletion of your file, although you should be aware that in some circumstances we may not be required or able to do so, particularly where your file also holds information about our clients or financial information that we need to keep for regulatory or legal reasons; i.e. which relate to tax matters. If, under any circumstances, we cannot comply with your request for information we will provide a full explanation as to why this is so.

If you explicitly indicate that you do not wish your personal data to be used for marketing purposes, it will not be. You have the right to withdraw permission granted with regards to your personal data at any time. This type of withdrawal can be limited to only include parts of the processing, e.g. parts about direct marketing. Opt-out instructions are included above and in every marketing message we send out.

Notification of a Data Breach

All personal data breaches are reported immediately to VERYLOCAL’s data protection officer. If a personal data breach occurs and that breach is likely to result in a risk to the rights and freedoms of Data Subjects (e.g. financial loss, breach of confidentiality, discrimination, reputational damage, or other significant social or economic damage), the data protection officer must ensure that the Information Commissioner’s Office is informed of the breach without delay, and in any event, within 72 hours after having become aware of it. In the event that a personal data breach is likely to result in a high risk to the rights and freedoms of Data Subjects, the data

protection officer must ensure that all affected Data Subjects are informed of the breach directly and without undue delay. Data breach notifications shall include the following information:

• –  The categories and approximate number of Data Subjects concerned;
• –  The categories and approximate number of personal data records concerned
• –  The name and contact details of VERYLOCAL’s data protection officer (or other contact point where more information can be obtained);
• –  The likely consequences of the breach;
• –  Details of the measures taken, or proposed to be taken, by VERYLOCAL to address the breach including, where appropriate, measures to mitigate its possible adverse effects.

Data Protection Principles

This Policy aims to ensure compliance within and outside the EU GDPR (Regulation) and all the data protection regulations around the globe. The Regulation sets out the following principles with which any party handling personal data must comply. All personal data must be:

• –  Processed lawfully, fairly, and in a transparent manner in relation to the data subject;
• –  Collected for specified, explicit, and legitimate purposes and not further processed in a manner that is incompatible with those purposes; further processing for archiving purposes in the public interest, scientific or historical research purposes or statistical purposes shall not be considered to be incompatible with the initial purposes;
• –  Adequate, relevant and limited to what is necessary in relation to the purposes for which it is processed;
• –  Accurate and, where necessary, kept up to date; every reasonable step must be taken to ensure that personal data that is inaccurate, having regard to the purposes for which they are processed, is erased or rectified without delay;
• –  Kept in a form which permits identification of Data Subjects for no longer than is necessary for the purposes for which the personal data is processed; personal data may be stored for longer periods insofar as the personal data will be processed solely for archiving purposes in the public interest, scientific or historical research purposes or statistical purposes subject to implementation of the appropriate technical and organizational measures required by the Regulation in order to safeguard the rights and freedoms of the data subject;
• –  Processed in a manner that ensures appropriate security of the personal data, including protection against unauthorized or unlawful processing and against accidental loss, destruction or damage, using appropriate technical or organizational measures.

Links

Our website may contain links to other websites. When you navigate away from our website by clicking on one of these links, you are no longer protected by this privacy policy. Please be careful when visiting other sites as their privacy protections may not be as robust as our own. We encourage you to read the privacy policies of any third party website carefully before using it. Note that VERYLOCAL does not take responsibility for the handling of your personal data by other websites unless expressly noted.

Changes to the privacy policy

VERYLOCAL reserves the right to make changes to this privacy policy at any time to the extent these changes are needed to resolve issues or to stay compliant with new legal requirements or technical requirements. All changes to the policy will be posted on our website. Please check this privacy policy each time before using other parts of the website to see if there have been any changes and to ensure you still agree to these terms. If required by law, we may also notify you of changes by email.

Cookies

VERYLOCAL’s webpage uses cookies. Cookies are text files which are stored on a visitor’s computer that make it possible to track the visitor’s activity on the webpage.

There are two categories of cookies: 1) A permanent cookie which is stored on the visitor’s computer for a limited amount of time. 2) A session cookie which is only temporarily stored in the computer’s memory while the visitor is on a webpage. Session cookies disappear as soon as you close your browser.

VERYLOCAL uses cookies to enhance the webpage for the visitor by, among other things, tailoring it to the visitor’s requests, choices and interests, ensuring that the visitor is logged in on the webpage, and thus is not required to re- log in on every additional website that is visited, and to tailor our services so you get relevant information for us to live up to our commitments to you as a customer.

Permanent cookies are used to, among other things, store your personal settings on VERYLOCAL’s webpage to avoid having to enter the same settings repeatedly, and also to tailor the information and marketing that is directed

to you. Session cookies are used mainly to gather statistics over the use of the webpage.

By using this website you accept the use of cookies in accordance with what is stated in this policy. If you do not accept cookies this can be turned off in the security settings of your browser. You can also make sure your browser asks you whether to accept cookies every time VERYLOCAL’s webpage tries to place a cookie on your computer. Through the browser, previously stored cookies may be deleted. More information about cookies can be found in your browser settings. You can manually delete cookies from your hard drive at any time.

Note that if cookies are disabled, some features of the webpage may be limited.

Questions?

If you have any questions or concerns about this privacy policy or how VERYLOCAL uses your personal information, please contact Customer Service, via SUPPORT@VERYLOCALS.COM/support@verylocals.in