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QWORK statement

 

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The EU General Data Protection Regulation (“GDPR”) comes into force across the European Union on 25th May 2018 and brings with it the most significant changes to data protection law in two decades. The GDPR aims to standardise data protection laws and processing across the EU, affording individuals stronger, more consistent rights to access and control their personal information. As a consequence of the impending change in the law, QWork is implementing a programme to ensure it complies with the GDPR. QWork are committed to ensuring the security and protection of the personal information that we process, and to provide a compliant and consistent approach to data protection. This statement serves as notice of QWork’s compliance with requirements under the GDPR. Our preparation for GDPR compliance is summarised in this statement and includes the development and implementation of new policies, procedures and controls to ensure maximum and ongoing compliance. How We are Preparing for the GDPR Policies & Procedures – implementing new data protection policies and procedures to meet the requirements and standards of the GDPR and any relevant data protection laws, including: - Data Protection – our main policy and procedure document for data protection meets the standards and requirements of the GDPR. Accountability and governance measures are in place to ensure that we understand and adequately disseminate and evidence our obligations and responsibilities. Data Retention & Erasure – we have updated our retention policy and schedule to ensure that we meet the ‘data minimisation’ and ‘storage limitation’ principles and that personal information is stored, archived and destroyed compliantly. We also have dedicated erasure procedures in place to meet the new ‘Right to Erasure’ obligation. Data Breaches – our breach procedures ensure that we have safeguards and measures in place to identify, assess, investigate and report any personal data breach at the earliest possible time. Subject Access Request (SAR) – we have revised our SAR procedures to accommodate the revised 30-day timeframe for providing the requested information and for making this provision free of charge. Our new procedures detail how to verify the data subject, what steps to take for processing an access request, what exemptions apply and a suite of response templates to ensure that communications with data subjects are compliant, consistent and adequate. Legal Basis for Processing - we are reviewing all processing activities to identify the legal basis for processing and ensuring that each basis is appropriate for the activity it relates to. Where applicable, we also maintain records of our processing activities, ensuring that our obligations under Article 30 of the GDPR and Schedule 1 of the Data Protection Bill are met. Privacy Notice/Policy – we are revising our Privacy Notice to comply with the GDPR, ensuring that all individuals whose personal information we process have been informed of why we need it, how it is used, what their rights are, who the information is disclosed to and what safeguarding measures are in place to protect their information. Obtaining Consent - we are revising our consent mechanisms for obtaining personal data, ensuring that individuals understand what they are providing, why and how we use it. We have developed stringent processes for recording consent, making sure that we can evidence an affirmative opt-in, along with time and date records; and an easy to see and access way to withdraw consent at any time. Direct Marketing - we are revising the wording and processes for direct marketing, including clear opt-in mechanisms for marketing subscriptions; a clear notice and method for opting out and providing unsubscribe features on all subsequent marketing materials. Data Subject Rights In addition to the policies and procedures mentioned above that ensure individuals can enforce their data protection rights, we provide easy access information via [our website/in the app] of an individual’s right to access any personal information that QWork processes about them and to request information about: - What personal data we hold about them The purposes of the processing The categories of personal data concerned The recipients to whom the personal data has/will be disclosed How long we intend to store your personal data for If we did not collect the data directly from them, information about the source The right to have incomplete or inaccurate data about them corrected or completed and the process for requesting this The right to request erasure of personal data (where applicable) or to restrict processing in accordance with data protection laws, as well as to object to any direct marketing from us and to be informed about any automated decision-making that we use The right to lodge a complaint or seek judicial remedy and who to contact in such instances

QWORK statement

Privacy Policy At QWork, respecting the privacy of our users is very important to us. We are committed to complying with the Data Protection Act 1998 and the General Data Protection Regulation 2016/679 and the Data Protection Bill when they come into force. This privacy policy explains how we collect, store and use your personal data when you use the app. By using the app, you confirm that you accept this privacy policy. Personal information we collect about you You are not legally required to provide us with personal information but in order to join the queue, review a barber, connect with customers sign up for other services or pay for a haircut you will need to provide us with certain personal details. When you use the app, we may collect: Information such as your name, address, telephone number, email address, date of birth and credit or debit card details when you register with us or enter your payment card details to pay for your haircut. Information regarding your geographical location and the length of haircuts. Information about your device. Information that you provide to us for the purpose of allowing us to send you notifications and/or promotional information. We may use your personal information: To process payment for your haircut. We use third party processors to process your payment. We collect this information to perform our contract with you and, if you do not give us this information, you will be unable to pay for your haircut via the app. With your consent, the third party may store your payment card details in future. To withdraw your consent, please login to your account and untick the relevant box. To connect you to the nearest barber to your location and provide accurate queue times for other app users. With your consent, the app will use your current geographical location and record the time taken to cut your hair. To withdraw your consent, please login to your account and follow the instructions in account settings. To contact you and enable barbers to contact you about your haircut, other services and offers which we think may be of interest to you, subject to your marketing preferences. To connect barbers with customers and enable them to directly contact them in relation to their haircut and any offers, subject to your consent. To post any of your contributions, including barber reviews, and attribute them to you. To ensure that the content of the app is presented in the most effective manner for you and your device and to improve your experience. To carry out our obligations arising from any contracts entered into between you and us. To enable us to comply with any legal or regulatory requirements and in the detection and prevention of theft, fraud or other crimes. The basis of processing your personal information may vary. We will only process your information for our legitimate business interests, to provide you with a service you requested or because we have your consent to do so in connection with a purpose set out above. Disclosure of your personal information We treat the security and processing of your personal information very seriously. Your personal information may be shared with barbers and barbershops and/or to reputable third parties to perform services on our behalf, for example helping to facilitate your haircut, process your payment or send you communications, among other things. Storage of your personal information The data that we collect from you may be transferred to, and stored at, a destination outside the European Economic Area. It may also be processed by employees who work for us or our third party suppliers. We will ensure appropriate safeguards are in place to ensure your information continues to be treated in accordance with applicable law. By submitting your personal information, you agree to this storing or processing. We will take all steps reasonably necessary to ensure that your data is treated securely. The transmission of information via the internet is not completely secure. We will do our best to protect your personal information but we cannot guarantee the security of information transmitted to our app and any transmission is at your own risk. Requesting copies of or amendments to your personal information You may request details of the personal information we hold about you. Please contact us using the “Contact Us” link on our app in order to do so. Please note that before we are able to provide you with any personal information we hold about you, we may ask you to verify your identity. We will only use the information you provide in order to verify your identity. If you would like to change any information we hold about you, please login to your account and change your personal details Links to other websites and/or apps Our app may contain links to and from other websites or apps, including, but not limited to, social media networks or advertisers. If you follow a link to any of these websites, please note that they have their own privacy policies. We do not accept any responsibility or liability for these policies. Changes to our privacy policy We may update our policy from time to time. Any changes will be posted on this page and, where appropriate, notified to you by email. Please check back frequently to see any changes. Contact To exercise any of your rights in connection with your personal data or if you have any questions or concerns, please contact us at by using the “Contact Us” link on our app.

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