Privacy Policy

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Last updated on April 11, 2023

This privacy policy for Kounselly JSc. (“Company,” “we,” “us,” or “our“), describes how and why we might collect, store, use, and/or share (“process“) your information when you use our websites and services (“Services“), such as when you:

Visit our website at https://devmarketplace.kounselly.com, or any website of ours that links to this privacy policy

Engage with us in other related ways ― including any sales, marketing, or events

This privacy policy will help you understand your privacy rights and choices. If you do not agree with our policies and practices, please do not use our Services. If you still have any questions or concerns, please contact us via our “Contact Us” form.

1. YOUR INFORMATION THAT WE COLLECT

We collect the following information from you:

The Personal information you disclose to us

We collect personal information that you voluntarily provide us when you register to use our Services, express an interest in obtaining information about us or our products and Services, the choices you make, and the products/services or features you use, or when you contact us. The personal information we collect may include the following:

Identity information: In all cases, we will collect your full name. In case you register to use our services, if you apply for the Seller role, according to the currently applicable law, the information you need to provide us are:
- Full name. This is the compulsory information that you need to provide us to verify your identity.
- We may also collect information on your identity card or passport and your photograph for identity verification purposes as well as to ensure your age compliance (18 and over). This is compulsory by the currently applicable law unless you give us your Personal Income Tax ID instead. We need this information as required by the currently applicable law as well as to increase the trustworthiness of your profile.
- Personal Income Tax ID in case you do not provide your ID card or passport. This is required by our current applicable law to ensure your Tax liability.
- If you register as an Institutional Seller, the information we will need from you is your VAT Tax Number or your Corporate ID Number and Your Business Registration Certificate to verify your organizational identity as well as to ensure your tax liability with the government.

Contact data: email addresses, phone numbers, and the country where you are located are compulsory information that we collect. Accordingly, the Email address and phone number are to verify your contact information, for us to contact you and update you with our product/ service and policies as well as for you to receive notifications about your activities and our services. Country data is collected to ensure we will display the appropriate content for you, including your language, currency, or payment methods.

Profile data: This information includes your username and password to register with our system and use our services. Language selection is not compulsory but it will help other users to decide to contact you and it will determine the language of your notifications from us. If you are Seller on our website, you should also post your CV (including your skills, certifications, education, and employment history) to attract Buyers to you. Besides, we collect information about your activities on our website and when you use our services, including job/service posts, request posts, order and transaction history, account balances, top-up and withdrawal history, level upgrade history, your interests, favorites, and preferences, feedback, reviews, and ratings, followings, and messages. This information is necessary for us to provide you with our services, as well as help you monitor and manage your activities on our website.

Usage information: This information includes information about how you access and use our services, such as your actions on our website, including your interactions with others, photos and media you upload, your username, and other content you provide (“usage information”). We only access your device camera roll, camera, and microphone (mic) with your permission. If you need to update your permissions, you can do so in your device’s settings. Please remember that Kounselly may, but has no obligation to, monitor, record, and store Usage information in order to protect your safety or the safety of other users, to assist with regulatory or law enforcement efforts, to protect and defend our rights, and property, or for other reasons relating to our provision of the Services. By using our Services, you consent to the recording, storage, and disclosure of such information you send or receive for these purposes.

Additional information: This includes information that you submit via polls, contests, customer support, Contact Us form, or other similar means. We may also collect any communications between us and you (including emails, communications via the support center, recording calls if any) and any other information you provide to us.

Business sensitive information: Sensitive business information includes anything that poses a risk to your company if discovered by your competitor or the general public. Such information includes, without limitation, trade secrets, acquisition plans, business ideas, business plans, financial data, and supplier and customer information. We do not collect this information from you. But during your use of our services, you may exchange this information with other users (e.g. you provide this information to consultants and sellers on our website for their consulting services). All of our users are required to comply with our Terms of Service in which the non-disclosure of information term is applied. However, for safety reasons, we recommend that you ask the consultants and sellers to sign a Non-disclosure agreement that takes effect before, during, and after your transaction ends to protect your sensitive information. We do not collect this information directly from you. However, your messages that are exchanged with other users or files transmitted through our system may be stored in our system. This is to ensure the functionality of our services, as well as allow us to access and use this information when you ask Kounselly to become an arbitrator to solve your conflicts and disputes, or to submit to the governmental authorities or the court if required.

Payment Data. To make payments or get paid on our websites while using our services, you need to provide us with your bank account information or your email address/phone number that you use to connect with payment gateways that you will use for your payment and getting paid. This information is only stored on our system, to connect with your bank/payment gateways to process your payment. We do not reveal that information to any other third parties. Besides, our third-party payment service providers will collect the payment data necessary to process your payment if you make purchases, such as your credit card number and billing address. You may find their privacy policy on their websites.

Social Media Login Data. We may provide you with the option to register with us using your existing social media account details, like your Facebook, Google, Linkedin, or other social media accounts. If you choose to register in this way, we will collect the information described in the section called “HANDLING YOUR SOCIAL LOGINS”.

All personal information that you provide to us must be true, complete, and accurate, and you must update or notify us of any changes to such personal information.

Information automatically collected

We automatically collect certain information when you visit, use, or navigate our website and Services. This information does not reveal your specific identity (like your name or contact information) but may include device and usage information, such as your IP address, browser and device characteristics, operating system, language preferences, referring URLs, device name, country, location, information about how and when you use our Services, and other technical information. This information is primarily needed to maintain the security and operation of our Services and for our internal analytics and reporting purposes. Like many other businesses, we also collect information through cookies and similar technologies. You can find out more about this in our Cookie Policy when you access our website. The information we collect includes:

Location Data. To help us protect against fraud, provide our services to you, and improve our services, we collect location information, including current and historical information concerning a user’s geographic location, your device’s location, GPS location, transaction location, and IP addresses that you use in conjunction with our Services, which can be either precise or imprecise. How much information we collect depends on the type and settings of the device you use to access the Services. We collect information about your location through Google Maps API, GPS, Wi-Fi, wireless network triangulation, or other methods in order to obtain your location. We may also approximate your location by your IP address. You can opt out of allowing us to collect this information either by refusing access to the information or by disabling your Location setting on your device. However, if you choose to opt-out, you may not be able to use certain aspects of the Services.

Usage and Device Data collected automatically through tracking technologies. To provide a personalized and enhanced user experience, we, and our third-party partners, automatically collect certain types of usage information when you visit or use our Services, read our emails, or otherwise engage with us. We typically collect this information through a variety of tracking technologies, including cookies, Flash objects, web beacons, embedded scripts, location-identifying technologies, file information, and similar technology (collectively, “Tracking Technologies”). For example, we collect information about your device and its software, such as your IP address, browser type, Internet service provider, platform type, device type, operating system, date and time stamp, a unique ID (that allows us to uniquely identify your browser, mobile device, or your account), and other similar information. We use tracking technologies to help ensure that you have a high-quality experience on our Service. We also use Tracking Technologies to aid in the targeted advertising of our services on other platforms. From your device manufacturer, we also may collect the names of other third-party applications that you have downloaded on your device.

Information collected from other sources

In order to enhance our ability to provide relevant marketing, offers, and services to you and update our records, we may obtain information about you from other sources, such as public databases, joint marketing partners, affiliate programs, data providers, social media platforms, and from other third parties. This information includes mailing addresses, job titles, email addresses, phone numbers, intent data (or user behavior data), Internet Protocol (IP) addresses, social media profiles, social media URLs, and custom profiles, for purposes of targeted advertising and event promotion. If you interact with us on a social media platform using your social media account (e.g., Facebook or Linkedin), we receive personal information about you such as your name, email address, and gender. Any personal information that we collect from your social media account depends on your social media account’s privacy settings.

Information collected through Social logins

We by default access your basic account information, including your name, email, gender, birthday, current city, profile picture URL, your employment, education, skills as well as other information that you choose to make public. We may also request access to other permissions related to your account, such as friends, check-ins, and likes, and you may choose to grant or deny us access to each individual permission.

2. PROCESSING YOUR INFORMATION

We process your information to provide, improve, and administer our Services, communicate with you, for security and fraud prevention, and to comply with the law. We may also process your information for other purposes with your consent. We process your personal information for a variety of reasons, depending on how you interact with our Services, including:

To facilitate account creation and authentication and otherwise manage user accounts. We may process your information so you can create and log in to your account, as well as keep your account in working order.

To deliver and facilitate the delivery of services to the user. We may process your information to provide you with the requested service.

To respond to user inquiries/ offer support to users. We may process your information to respond to your inquiries and solve any potential issues you might have with the requested service.

To send administrative information to you. We may process your information to send you details about our products and services, changes to our terms and policies, and other similar information.

To fulfill and manage your orders. We may process your information to fulfill and manage your orders, payments, refunds, and exchanges made through the Services.

To enable user-to-user communications. We may process your information if you choose to use any of our offerings that allow for communication with another user.

To request feedback. We may process your information when necessary to request feedback and to contact you about your use of our Services.

To send you marketing and promotional communications. We may process the personal information you send to us for our marketing purposes if this is in accordance with your marketing preferences. You can opt out of our marketing emails at any time.

To deliver targeted advertising to you. We may process your information to develop and display personalized content and advertising tailored to your interests, location, and more.

To protect our Services. We may process your information as part of our efforts to keep our Services safe and secure, including fraud, sabotage, and pretend-to-be-someone monitoring and prevention.

To identify usage trends. We may process information about how you use our Services to better understand how they are being used so we can improve them.

To determine the effectiveness of our marketing and promotional campaigns. We may process your information to better understand how to provide marketing and promotional campaigns that are most relevant to you.

To save or protect an individual’s vital interest. We may process your information when necessary to save or protect an individual’s vital interest, such as to prevent harm.

3. LEGAL BASES WE RELY ON TO PROCESS YOUR INFORMATION

We only process your personal information when we believe it is necessary and we have a valid legal reason (i.e., legal basis) to do so under applicable law, like with your consent, to comply with laws, to provide you with services, to enter into or fulfill our contractual obligations, to protect your rights, or to fulfill our legitimate business interests. Below are the details of legal bases we rely on to process your personal information:

Consent. We may process your information if you have given us permission (i.e., consent) to use your personal information for a specific purpose.

Performance of a Contract. We may process your personal information when we believe it is necessary to fulfill our contractual obligations to you.

Legitimate Interests. We may process your information when we believe it is reasonably necessary to achieve our legitimate business interests and those interests do not outweigh your interests and fundamental rights and freedoms. For example, we may process your personal information for some of the purposes described below, in order to:
- Send users information about special offers and discounts on our products and services
- Develop and display personalized and relevant advertising content for our users
- Analyze how our services are used so we can improve them to engage and retain users
- Support our marketing activities
- Diagnose problems, serve the investigation, and/or prevent fraudulent, sabotaging, and pretending-to-be-someone activities.
- Understand how our users use our products and services so we can improve user experience

Legal Obligations. We may process your information where we believe it is necessary for compliance with our legal obligations, such as to cooperate with a law enforcement body or regulatory agency, exercise or defend our legal rights, or disclose your information as evidence in litigation as required by the court or authorized agencies in which we are involved.

Vital Interests. We may process your information where we believe it is necessary to protect your vital interests or the vital interests of a third party, such as in situations involving potential threats to the safety of any person, whether it is mental, life-threatening, or financial harm.

4. SHARING YOUR PERSONAL INFORMATION

We may share your information in specific situations described in this section and/or with the following third parties. Vendors, Consultants, and Other Third-Party Service Providers. We may share your data with third-party vendors, service providers, contractors, or agents (“third parties”) who perform services for us or on our behalf and require access to such information to do that work. In this case, we will have contracts in place with our third parties, to require them to safeguard your personal information. This means that they cannot do anything with your personal information unless we have instructed them to do it. They will also not share your personal information with any organization apart from us. They also commit to protect the data they hold on our behalf and to retain it for the period we instruct. The third parties we may share personal information with are as follows:

Ad Networks

Affiliate Marketing Programs

Cloud Computing Services

Communication & Collaboration Tools

Data Analytics Services

Data Storage Service Providers

Finance & Accounting Tools

Government Entities

Payment Processors

Performance Monitoring Tools

Product Engineering & Design Tools

Retargeting Platforms

Sales & Marketing Tools

Social Networks

Testing Tools

User Account Registration & Authentication Services

Website Hosting Service Providers

We may share your information in specific situations described in this section and/or with the following third parties.

Business Transfers. We may share or transfer your information in connection with or during negotiations of, any merger, sale of company assets, financing, or acquisition of all or a portion of our business to another company.

When we use Google Maps Platform APIs. We may share your information with certain Google Maps Platform APIs (e.g., Google Maps API, Places API).

Affiliates. We may share your information with our affiliates, in which case we will require those affiliates to honor this privacy policy. Affiliates include our parent company and any subsidiaries, joint venture partners, or other companies that we control or that are under common control with us.

Business Partners. We may share your information with our business partners to offer you certain products, services, or promotions.

Other Users. When you share personal information (for example, by posting comments, reviews, contributions, or other content to the Services) or otherwise interact with public areas of the Services, such personal information may be viewed by all users and may be publicly made available outside the Services in perpetuity. If you interact with other users of our Services and register for our Services through a social network (such as Facebook), your contacts on the social network will see your name, profile photo, and descriptions of your activity. Similarly, other users will be able to view descriptions of your activity, communicate with you within our Services, and view your profile.

5. OUR STANCE ON THIRD-PARTY WEBSITES

We are not responsible for the safety of any information that you share with third parties that we may link to or who advertise on our Services but are not affiliated with our Services. The Services, including our offer wall, may link to third-party websites, online services, or mobile applications and/or contain advertisements from third parties that are not affiliated with us and which may link to other websites, services, or applications. Accordingly, we do not make any guarantee regarding any such third parties, and we will not be liable for any loss or damage caused by the use of such third-party websites, services, or applications. The inclusion of a link to a third-party website, service, or application does not imply an endorsement by us. We cannot guarantee the safety and privacy of the data you provide to any third parties. Any data collected by third parties is not covered by this privacy policy. You should review the policies of such third parties and contact them directly to get responses to your questions.

6. COOKIES AND OTHER TRACKING TECHNOLOGIES

We may use cookies and similar tracking technologies (like web beacons and pixels) to access or store information. Specific information about how we use such technologies and how you can refuse certain cookies is set out in our Cookie Policy which you can access right after visiting our website.

7. HANDLING YOUR SOCIAL LOGINS

If you choose to register or log in to our services using a social media account, we may have access to certain information about you. Our Services offer you the ability to register and log in using your third-party social media account details (like your Facebook or Linkedin logins). Where you choose to do this, we will receive certain profile information about you from your social media provider. The profile information we receive may vary depending on the social media provider concerned, but will often include your name, email address, friends list, and profile picture, as well as other information you choose to make public on such a social media platform. If you log in using Facebook, we may also request access to other permissions related to your account, such as your friends, check-ins, and likes, and you may choose to grant or deny us access to each individual permission. We will use the information we receive only for the purposes that are described in this privacy notice or that are otherwise made clear to you on the relevant Services. Please note that we do not control, and are not responsible for, other uses of your personal information by your third-party social media provider. We recommend that you review their privacy policy to understand how they collect, use, and share your personal information, and how you can set your privacy preferences on their sites and apps.

8. TRANSFERING YOUR INFORMATION INTERNATIONALLY

We may transfer, store, and process your information in countries other than your own. Our server is located in Singapore. If you are accessing our Services from outside this county, please be aware that your information may be transferred to, stored, and processed by us in our facilities and by those third parties with whom we may share your personal information, in Countries where Third-Party Servers are Located, and other countries.

9. HOW LONG DO WE KEEP YOUR INFORMATION?

We will only keep your personal information for as long as it is necessary for the purposes set out in this privacy policy unless a longer retention period is required or permitted by law (such as tax, accounting, or other legal requirements). No purpose in this policy will require us to keep your personal information for longer than 24 months past the start of the idle period of the user’s account. Therefore this will be the period we keep your information. When we have no ongoing legitimate business need to process your personal information, we will either delete or anonymize such information, or, if this is not possible (for example, because your personal information has been stored in backup archives), then we will securely store your personal information and isolate it from any further processing until deletion is possible.

10. THE SAFETY OF YOUR INFORMATION

We aim to protect your personal information through a system of organizational and technical security measures. We have implemented appropriate and reasonable technical and organizational security measures designed to protect the security of any personal information we process. However, despite our safeguards and efforts to secure your information, no electronic transmission over the Internet or information storage technology can be guaranteed to be 100% secure, so we cannot promise or guarantee that hackers, cybercriminals, or other unauthorized third parties will not be able to defeat our security and improperly collect, access, steal, or modify your information. Although we will do our best to protect your personal information, the transmission of personal information to and from our Services is at your own risk. You should only access the Services within a secure environment.

11. INFORMATION FROM MINORS

We do not knowingly solicit data from or market to children under 18 years of age. By using the Services, you represent that you are at least 18 or that you are the parent or guardian of such a minor and consent to such minor dependent’s use of the Services. If we learn that personal information from users less than 18 years of age has been collected, we will deactivate the account and take reasonable measures to promptly delete such data from our records. If you become aware of any data we may have collected from children under the age of 18, please contact us via the “Contact Us” form.

12. YOUR PRIVACY RIGHTS

You have the following rights with your personal information: Withdrawing your consent: If we are relying on your consent to process your personal information, which may be express and/or implied consent, you have the right to withdraw your consent at any time. However, please note that this will not affect the lawfulness of the processing before its withdrawal, nor will it affect the processing of your personal information conducted in reliance on lawful processing grounds other than consent. Opting out of marketing and promotional communications: You can unsubscribe from our marketing and promotional communications at any time by clicking on the unsubscribe link in the emails that we send, replying “STOP” or “UNSUBSCRIBE” to the SMS messages that we send, or by contacting us via the “Contact Us” form. You will then be removed from the marketing lists — however, we may still communicate with you, for example, to send you service-related messages that are necessary for the administration and use of your account, to respond to service requests, or for other non-marketing purposes. Account Information If you would at any time like to review or change the information in your account or terminate your account, you can:

Upon your request to terminate your account, we will verify your identity and then deactivate or lock your account. However, we may retain some information in our database to prevent fraud, troubleshoot problems, assist with any investigations, enforce our legal terms, and/or comply with applicable legal requirements. Verification process Upon receiving your request, we will need to verify your identity to determine whether you are the same person with whom we have the information in our system. These verification efforts require us to ask you to provide information so that we can match it with the information you have previously provided us. For instance, depending on the type of request you submit, we may ask you to provide certain information so that we can match the information you provide with the information we already have on file, or we may contact you through a communication method (e.g., phone or email) that you have previously provided to us. We may also use other verification methods as the circumstances dictate. We will only use the personal information provided in your request to verify your identity or authority to make the request. To the extent possible, we will avoid requesting additional information from you for the purposes of verification. However, if we cannot verify your identity from the information already maintained by us, we may request that you provide additional information for the purposes of verifying your identity and for security or fraud-prevention purposes. We will delete such additionally provided information as soon as we finish verifying you. Cookies and similar technologies. You can choose to remove cookies or reject cookies. However, this could affect certain features or services of our Services. If you have questions or comments about your privacy rights, you may contact us through our “Contact Us” form.

13. UPDATES TO THIS PRIVACY POLICY

We may update this privacy policy from time to time. The updated version will be indicated by an updated date and the updated version will be effective as soon as it is accessible. If we make material changes to this privacy policy, we may notify you either by prominently posting a notice of such changes or by directly sending you a notification via email. We encourage you to review this privacy policy frequently to be informed of how we are protecting your information.