Privacy Policy

We collect and process your personal data in different ways and for different purposes. We process personal data in accordance with the obligations that are relevant for our processing, i.e. the GDPR. We process personal data to observe legal obligations that we are subject to, to perform specific agreements and consent from you.

Processing based on legal obligations

In some instances, Folq will process personal data with legal basis in law. Laws such as the:

• Working Environment Act
• Personal Data Act
• Copyright Law
• Anti-Money Laundering Act
• Taxation Act
• Accounting Act
• Bookkeeping Act

Other examples are Regulations, Case law or Authorial decisions.

Performance of a contract

Every user of the Marketplace is associated with a company that has entered into the Cooperation Agreement with Folq. Moreover, every user shall individually accept Folq’s Terms of Use for the Marketplace. Folq processes personal data about you in accordance with these agreements, for example so that we can create and manage your user account when you login to the Marketplace. Folq’s standard Data Processing Agreement is published on Folq's open websites and applies for all processing of personal data by Folq, and Folq is a processor for companies that has entered into the Cooperation Agreement for the Marketplace.

Processing based on legitimate interests

Sometimes we process data because it is in our legitimate interest to do so. When we process data based on legitimate interest, we have performed a balancing of interests and have concluded that the individual’s interest does not override our legitimate interest for processing personal data on the Marketplace and Folq's open websites. We process personal data based on our legitimate interest to prevent fraudulent activity and other security breaches on our website and the Marketplace.

Processing based on consent

We will only process data, beyond what is necessary to fulfil an agreement, comply with legal obligations, or our legitimate interests, when you consent to it. We process personal data based on consent to send you marketing communications by e-mail, and for the use of on the Marketplace and Folq's open websites that are not strictly necessary. You withdraw your consent at any time by contacting us.

In order to gain access to the Marketplace, all End Users must create a user account. To create a user account, we must process the following personal data about you as a minimum:

• Name
• E-mail
• Company affiliation

We will process this personal data in accordance with the Terms of Use for the Marketplace. When you have created a user account, you can create a profile with information about yourself. Which personal data we process will depend on whether you are affiliated with the Consultant or the Customer.

You can choose to login with your chosen password, email link, or your Google or LinkedIn profile. If you choose to login with your profile from Google or LinkedIn, you consent to Google or LinkedIn sharing your profile information with Folq, so that Folq can create and later manage your user account on the Marketplace. If you choose to login with Google or LinkedIn, we receive your name, email address, language preference and profile picture from Google or LinkedIn so that we can create a user account for you. You can withdraw your consent for sharing your profile information from Google or LinkedIn at any time by discontinuing the link to Folq on your Google or LinkedIn profile. We will, however, keep your profile with the information you have given us for as long as you have a user account with us.

Please contact us if you wish to end your user account on the Marketplace, and want us to delete the information about you. We will end your account and delete all information about you which we are not legally required to process further.

If you are a consultant, Folq processes personal information about you that is necessary for you to have contact with clients that fit your profile.

We process the following personal data about consultants:

Name, email, and company affiliation

Work and project experience, including start and end date, and contact information for your references

Information about your education, expertise, and other CV information the consultant chooses to share:

• Profile picture
• Phone number
• Geographic location
• Other information the consultant shares via the Marketplace
• Data from working time registration if you are on assignment via Folq

To ensure the quality of all consultants on the Marketplace, we carry out an evaluation of the consultant’s competence and experience. The evaluation is used to justify whether a consultant is rejected or approved, and the information is only used internally by Folq.

If your company uses CVPartner, your company can share you CV with us through CVPartner based on the company’s agreement with us. If so, we collect your personal data from your CV through CVPartner.

If you are logged in as a user account for the Customer on the Marketplace, we will only process personal data that is necessary to enable you to contact consultants on the Marketplace, and so that consultants can have relevant information about you and your company.

We process the following personal data about user account for the Customer:

• Name, email, and affiliation to the Customer
• Phone number
• Other information the Customer or the Customer’s end users choose to share about you via the Marketplace.

When you use the Marketplace logged into your user account, whether you represent the Consultancy Company or the Customer, we collect information about how you use the Marketplace. We collect the following data:

Generally

• When you login to the Marketplace
• When you update your profile, including which parts of your profile you update
• Who you have received direct messages from, and who you send direct messages to
• How quickly you respond to direct messages

About customers

• Search history
• Information about which profiles you visit and who has visited your profile
• Information about which assignments and contact persons you have published
• Information about which consultants you have marked as favourites
• Information about which profiles you share, and with whom and when
• Which CVs you download and when you download them
• Information about whom you invited to the platform

About consultancy company

• Information about which assignments you have look at
• Information about which assignments you have expressed an interest in

We use the information to ensure that you as, a consultant, find work that suits you. And to ensure that those who are logged in and is affiliated with the Customer, find consultants that suit their needs. We also use the information to ensure that the process by which you find each other is always efficient.

Furthermore, we register the use of the Marketplace in order to provide support and maintenance, as well as in order to fulfil security and registering requirements.

We process personal data about the Consultancy Company and the Customer when they enter into an Assignment Agreement. We process the following: contact information about the contact persons in the agreement, information about the consultant’s role and the duration of the assignment, and any personal data that may appear in the text of the Assignment Agreement itself.

We process personal data about you when you contact us with questions by email, telephone, or in our chat on the website. We will, with your consent, process the information you give us when you use our chat or contact customer services in another way. We may process information about your name, email, and phone number. We use a chat on the Marketplace provided by HubSpot. HubSpot will also process your personal data if you consent to cookies from HubSpot.

It is important for us that the processing of your personal data is safe and secure. Folq and our partners ensures that we comply with the obligations for information security in the GDPR.

We perform a risk assessment of all our third-party services in according with GDPR, and only use data centres in countries within the EU/EEA. We encrypt all use of our services through TLS/HTTPS. We have strict access control to our database, which is without direct access from the internet, and located in a protected network through our supplier AWS.

We only share personal data with our partners and others based on an agreement, when there is a legal obligation, based on legitimate interests, or with your consent. Subcontractors will only process personal data on behalf of Folq based on a signed data processing agreement. We will always perform a risk assessment of every subcontractor we use.

We will share personal data with a third-party if it is necessary for our services to function. We will also share personal data with third parties with your consent.

For a full overview of which third parties we share personal data with, see our list of third parties we share personal data with. Below, we include the most important third parties that process personal data about users of the Marketplace.

Banks

To process payment from the Customer to the Consultancy Company, we receive and transfer personal data to the bank that the Customer and the Consultancy use. Banks are independent data controllers and are subject to strict security obligations in addition to the Personal Data Act. Which bank process your personal data depends on which bank you or your employer use.

User Account

We use Auth0 to complete your login to your user account on the Marketplace. We have made sure that Auth0 stores data in in data centres in countries within EU/EEA.

We use HubSpot to register your user account on the Marketplace, as well as to registerthe Customer and the Consultancy Company.

Storage

Personal data collected through the Marketplace will be safely stored in Amazon Web Services (AWS) in data centres in countries within the EU/EEA.

Experience on your CV

For companies using CV Partner, we have an integration that allows us to retrieve CV data from CV Partner in order to maintain and share relevant information on the Marketplace.

For companies not using CV Partner, we offer parsing of PDF CVs through our in-house parser, powered by Azure AI Services and hosted in a data center within the EU/EEA.

We store your personal data only for the period necessary pursuant to an agreement with you or our legal obligations. As long as you have a user account and an agreement with us, we will not delete your personal data. If you ask us to delete your personal data we will, shortly after receiving your request, delete your user account and the information about you. However, the information will be stored in our backup for up to 30 days after deletion. We are, in some instances, legally obliged to continue with certain processing of your personal data, even if we have deleted your user account.

Your personal data will be deleted within two years from registration, if you are registered on folq.com, but do not have a user account.

We will also delete your personal data if you ask us to do so, unless we have legal obligation or other legal basis to store the personal data for longer.

You have several right according to GDPR, which we comply with as a data controller: Transparency – you can request access to all personal data we process about you.

• Correction: You have a right to request us to correct any inaccuracies.
• Deletion: You also have the right to request that we erase your personal data.
• Restriction: In certain circumstances, you have a right to restrict our use of your personal data.
• Protest: You may protest to our use of your personal data.
• Data portability: You can request that we transfer your personal data to you, if certain conditions for data portability is met.

To exercise your rights, we ask you to send us an email privacy@folq.com.

If you believe that our processing is not in accordance with the Personal Data Act, you can complain to the local Data Protection Authority.