We at NuLink Network Foundation Ltd. (“we”, “us”) are committed to protecting and respecting your privacy. This policy describes how we collect and use personal data about the users (“Users”) of our service muchskills (the “Service”). This privacy policy also describes your rights regarding your personal data.

The Service is owned and provided by us, why we are responsible for the processing of your personal data as described herein, as a data controller (as defined in the The Personal Data Protection Act, the “PDPA”). Please do not hesitate to reach out to us if you have any questions or comments regarding your personal data or this privacy policy. You can also reach us by sending an email to privacy@nulink.org, Attention: Privacy.

Please note that the Service is not directed to individuals under the age of 18, and we request that such individuals do not create an account or provide us personal data through the Service.

Furthermore, when we refer to Clients in this privacy policy we are referring to companies and any representative of a company who is authorized to use the Service on behalf of the company. Clients can either be your employer, a recruiting company or a third party invited to the Service by your employer.

1. Personal data that we process, how we do it and our legal grounds for processing it

We process your personal data for the following purposes and based on the following legal basis:

Applicable to all Users:

• To set up and register your account. Your username and e-mail address will be processed to provide you with the Service and enabling you to have an account. Furthermore, you will have the opportunity to connect your Google-account to the Service and thereby import information about you from your Google-account, provide us with your profile picture and other information you voluntarily fill in the profile. As this processing is necessary for us to provide the Service to you, we base this processing on fulfilment of the agreement we have entered into with you, i.e. the Terms of Use.
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  Please note that if you connect your Google-account to the Service Google may access your account in the Service to:

1. improve features and do more for you on Google services, and
2. let you use third-party features from within Google services. For example, you can link apps to Google Assistant to help you get things done, like add items to your to-do list on a productivity app.
   To read more about how to manage third-party sites or apps you have linked with Google, and how Google uses data you can read here.

• To enable you as a professional to create a profile on your skills and job focus. This entails processing the personal data you provide regarding your soft skills, job focus and software skills as well as career goals and opportunities you are looking for and any other information provided in the free-text fields in the Service. This information is either provided by you in the Service or imported by you from third party sources such as LinkedIn.
  
  This processing is one of the core functions of the Service and necessary for us to fulfil the agreement we have entered into regarding our provision of the Service, i.e. the Terms of Use.

• To match professionals with Clients – by enabling Clients to find the right people, with the right set of skills. This entails processing of the personal data a professional has entered into their profile and making it searchable for Clients that have been allowed access, by the professional, to the profile. The Service enables Clients to search for and find the right professional with the right skills for roles and teams within or outside their organization.
  
  The consequences of this processing, and matching procedure, are that you either will or will not become eligible for roles, positions and teams based on the skills you have entered into your profile – as you will only appear in a search if your profile matches the skills the company is looking for.
  
  This processing is one of the core functions of the Service and necessary for us to fulfil the agreement that we have entered into regarding our provision of the Service, i.e. the Terms of Use.
  
  If you have any questions regarding how your skills are being presented and the matching that happens within the Service, please do not hesitate to contact us!

• To help you develop and enhance your skills and focus. This we do by showing you personalized content such as articles, based on the skills, job focus and goals you have entered into your profile. This processing is based on our legitimate interest in being able to improve our Service with functions that enable you to develop and enhance your skills.

• To provide a tool for project managing. We process your personal data as needed for us to be able to provide you with a tool for project managing.  This processing is one of the core functions of the Service and necessary for us to fulfil the agreement that we have entered into regarding our provision of the Service, i.e. the Terms of Use.

• To communicate with you. Your contact information will be used to send you reminders, confirmations, application messages and other relevant information about the Service. This processing may be necessary to fulfil the Terms of Use and to provide you with the Service (e.g. send important administrative messages required) or otherwise be necessary for our legitimate interests, such as our interest to enhance and maximize your use of the Service and to communicate effectively with you.

• To provide support. Your personal data (e.g. contact information, technical data) may be used to investigate, respond to and resolve complaints and problems with the Service (e.g. bugs). This processing is necessary to provide you with the Service and upholding our obligations towards you as set out in the Terms of Use and for our legitimate interest in the functionality of the Service.

• To conduct user surveys. Your contact information may be used to contact you regarding user surveys. By continuously collecting qualitative feedback from you and other Users, we can gain a deeper understanding of our Users’ problems and needs. We will contact you based on our legitimate interests, such as our interest in developing and improving the Service. Participation in user surveys is however optional any potential personal data provided to us in connection with the answers to the survey will be processed based on your consent.

• To create aggregated data for developing the Service. We use technical data, and other aggregated and non-personal information to develop and improve the Service, including troubleshooting, data analysis, research, statistical purposes and testing (such as beta testing and evaluation of new features). For example, we may collect and evaluate technical data about your use of the Service for analytical purposes, to understand how people use the Service in order to make it more intuitive. The technical data is collected in connection with your use of the Service or your interactions with us.
  
  The processing of converting user activity data to aggregated data is based on our legitimate interest in being able to improve the Service and its features or if it is necessary to enable you to use the Service as intended – based on fulfilment of our agreement with you, i.e. the Terms of Use.

• To fulfil our legal obligations. We are obligated to follow Swedish law. This means that your personal data will be processed to the extent necessary for us to fulfil our legal obligations, for example the Swedish Accounting Act.

• To protect our legitimate business interests and legal rights. We will use information about you where we believe it is necessary for our legitimate interest in being able to protect and enforce our legal rights, interests and the interests of others, for example in connection with legal claims, compliance, regulatory and audit functions. Examples of personal data processed for this purpose is storage of communication with us, as well as invoices and agreements.

• In connection with a merger or acquisition. In connection with, due to strategical or business-oriented reasons, a potential merger, sale of company assets, financing, or acquisition of all or a portion of our business to another company, the personal data we retain about you may be processed, shared or transferred, to parties involved in the process. This processing is based on our legitimate interest of being able to develop our business.

• Concerning sensitive data. We will not ask you to provide us with sensitive personal data about you. If you chose to include such information in the communication with us, we will only process such information to the extent necessary and justified. Be careful about sending sensitive data through non-encrypted email since email communications are not always secure.

• With your consent. Your personal data may be used for other purposes than stated above if you ask us to or you give us your consent. For example, if you are a Client, we might contact you asking for your consent to publish a review by you for the purpose of marketing our services or ask you to perform a survey.

Additional processing that we do in relation to Clients:

• Marketing of our services, products and events. Your contact information will be used to send newsletters, information about our services and products or events to you. This processing is based on our legitimate interest of being able to market our services, as you have shown an interest in our services. Feel free to follow the unsubscribe instructions contained in the email received from us or contact us directly if you no longer want direct marketing from us.

• Administrating our agreements, including billing. Personal data will be processed when we enter into and during the agreements with your company. This is necessary for us to be able to enter into and fulfil the obligations of the agreement with your company and for our legitimate interest to administrate the agreement, e.g. to be able to send invoices with you as reference or to have a contact person in connection with fulfilment of the agreement.

• Identifying you and the company you are working for. If you are a sole trader, we will process your personal identification number as a part of the information we keep about your company and to identify you as the representative of such a company. Since your personal identification number is the same as your company registration number this is necessary for the identification process. If you are not a sole trader but contacts us in the role of representative of a company, we process your company name, job title, workplace and sometimes information regarding your right to represent your company. Such processing is done for our legitimate interest of being able to identify our customers, suppliers and business partners.

2.2

When using the Platform, you will receive a non-exclusive, non-transferable and revocable license to use the Services in accordance with the Agreement. Any use of the Services other than as specifically authorized herein, without the prior written permission from us, is strictly prohibited and will automatically terminate the license granted herein.

• To set up and register your account. Your username and e-mail address will be processed to provide you with the Service and enabling you to have an account. Furthermore, you will have the opportunity to connect your Google-account to the Service and thereby import information about you from your Google-account, provide us with your profile picture and other information you voluntarily fill in the profile. As this processing is necessary for us to provide the Service to you, we base this processing on fulfilment of the agreement we have entered into with you, i.e. the Terms of Use.
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  Please note that if you connect your Google-account to the Service Google may access your account in the Service to:

2. How we gather your personal data

Information you give to us. Most of the information we process about you is received from you, directly and indirectly, when you sign up and use our Service. You can always choose not to provide us with certain information. However, some personal data is necessary in order for us to provide you with the Service. Not providing such personal data may prevent us from providing the Service you expect from us.

Information we collect about you. We may also, responsibly and with your privacy in mind, obtain personal data about you from your employer, the website of your employer, external public sources or providers of contact information for marketing purposes. If you are invited to the Service by a Client, the Client will provide us with your name and e-mail address in order for us to send an invitation to you. We will furthermore automatically receive information and statistics about your use of the Service.

3. How and to whom we share your personal data

Please note, that your profile will never be shown to Clients unless you have actively chosen to reveal your profile or if you join a Client’s team.

We provide you with a Service to, in a more transparent and accurate way, provide information about yourself to maximize your career opportunities. The information we gather will be shared with the following categories of third parties:

• Our employees and consultants. Your personal data will, when appropriate, be shared with some of our employees and consultants. However, we will restrict access to those of our employees and consultants who need it to perform their jobs, for example to provide you with user support. Our employees and consultants are of course subject to strict confidentiality.

• Other Users of the Service including Clients, as you choose. You own your data in the Service and can manage which Users, teams and Clients you choose to disclose your profile to.
  
  Please note, that once you have disclosed your profile to a Client, they will act as a separate data controller for how they use the information you provide them with and if contacting you.

• Google, if you connect your Google-account. When you register your account, you will have the possibility to connect your Google-account to the Service. If you do so, Google may access your account in the Service to:

1. improve features and do more for you on Google services, and
2. let you use third-party features from within Google services. For example, you can link apps to Google Assistant to help you get things done, like add items to your to-do list on a productivity app.

To read more about how to manage third-party sites or apps you have linked with Google, and how Google uses data you can read here.

• Our service providers. We transfer to or share your personal data with our suppliers and subcontractors who help us provide the Service to you or supply other services to us which require the processing of personal data. The services include:

1. providing and facilitating the Service,
2. IT-service for the performance of our Service and services that handle necessary, technical support and maintenance of our IT-solutions. This includes storage of your information by our web host, and
3. analysis of how the Service is used.

We provide personal data to third parties solely for the purpose of delivering our Service and to manage our daily operations including marketing of our services. Our suppliers and subcontractors are not authorized by us to use or disclose your personal data except as necessary to perform services on our behalf or to comply with legal requirements.

• Authorities and other public actors. Sometimes legal obligations may require us to share information about you, for example to respond to lawful requests from law enforcement agencies, regulatory agencies, and other public and government authorities. We may also disclose information if needed to detect and prevent fraud or in connection with a legal process, for example to enforce our agreements or to protect our rights, you or others.

• Merger, acquisition or other business transfer. We may share or transfer your personal data in connection with any merger, sale of company assets, financing, or acquisition of all or a portion of our business to another company.

• Other third parties, when you allow such sharing, for example your employer’s customers.

4. Where we process your personal data

We always strive to process and store your data within the EU/EEA. However, your data may in certain situations be transferred to, and stored at, a destination outside of the EU/EEA territory.

Please note that privacy laws in countries outside of the EU/EEA may not be the same as, and in some cases may be less protective than, privacy laws in your country. However, we always select our service providers carefully and take all the necessary steps to ensure that your personal data is processed with adequate safeguards in place in accordance with the GDPR. These safeguards are either that we sign the EU Commission Standard Contractual Clauses or ensure that the service provider is established in a country which the EU Commission has deemed as having adequate privacy protection or, if the company is established in the United States, certified under Privacy Shield.

Please contact us for more information about the applicable safeguard in a specific case.

5. How long we keep your personal data

We keep your personal data only as long as necessary to fulfil the purposes for which it was collected. How long depends on the type of information and why we process it. We regularly review our need to keep data, considering applicable legislation.

Your personal data will be stored in the Service for as long as you keep your user account. You can easily, in the Service, request total deletion of all personal data that we process in connection with your account. Upon termination of the account your data might however be stored up until one (1) month after termination due to technical reasons.

We furthermore will save the personal data needed for tax and book-keeping purposes etc.

Personal data processed on the basis of your consent will be deleted when your consent is withdrawn or upon expiry of the purpose for which your consent was given.

Moreover, we store data to the extent we believe it is necessary to protect our legal rights, legitimate interests and the interests of others. Your data may also be stored for a longer period if required by applicable statutory retention periods.

6. Cookies and similar technologies

Like many companies, we use “cookies” and similar technologies (e.g. pixel tags) in the Service. Cookies and similar are used to save your account settings (such as language preferences) and user data (e.g. username, email) and to track your use of the Service, in order to provide you with customer support and to get a better picture on how we can improve Service. Moreover, we use cookies for troubleshooting since cookies enables us to detect bugs and similar in the Service.  

In order to obtain aggregated statistics regarding our users’ activity in the Service we use Google Analytics. All information we receive through the use of these cookies are aggregated and anonymous and will be used to analyze and improve the Service and to develop the products and services we offer. For more information on Google Analytics and personal data protection, please follow this link. If you do not accept cookies for Google Analytics, we will not know when you have used the Service and cannot analyze the performance of the Service. To disable these cookies, please follow this link.

7. Your rights

To exercise the following rights, please contact us at privacy@nulink.org.

• Right to object. You have right to object to processing based on legitimate interest. This means that we may no longer process the personal data unless we can demonstrate compelling legitimate grounds for the processing which override your interests. You can always contact us for more information on the balance test that has been made. Upon an objection we might have to investigate the situation further prior to a decision.
  
  You furthermore have an unconditional right to object to your personal data being processed for direct marketing purposes, including profiling to the extent that it is related to such direct marketing, at any time.

• Right to access your data. You have the right to request a transcript of personal data processed by us, and additional information on how the data have been collected, processed, shared, etc. The first transcript may be requested free of charge, however if you make repeated and unreasonable requests for copies, we might charge you with an administrative fee.

• Right to transfer your data. You have the right to transfer your personal data to another controller under certain conditions.

• Right to rectification. You have the right to correct inaccurate or incomplete information about yourself. We might also update the same information if we consider that it contains factual errors or is out of date.

• Right to erasure (“right to be forgotten”). You have the right to request that we delete personal data about you, for example if the data is no longer necessary in relation to the purposes for which it was collected or otherwise processed, or if there is no legal basis for processing the data. This also applies if you opt out from direct marketing from us. Please note that we might have to decline your request if we are legally obliged to keep the information or if the information is necessary to defend legal claims.
  
  For Users of the Service we have a functionality in your account settings where you can request a total deletion.

• Right to restriction. You are entitled to request that the processing of your personal data should be limited until inaccurate or incomplete information about you has been corrected, or until an objection from you have been handled.

• Right to withdraw your consent. You may at any time withdraw any consent you have given us. However, please note that it will not affect any processing that has already taken place.

• Right to complain. You have the right to lodge a complaint to the Supervisory Authority in the country you live or work in, if you believe that we have not complied with our obligations regarding your personal data.
  
  

Please note that if you request restriction or erasure it might affect our abilities to provide our Service to you. Moreover, legal rights or obligations (such as confidentiality, accounting and tax legislation) may prevent us from disclosing or transfer all or part of your information, or from immediately deleting your information.

8. Changes in this privacy policy

This privacy policy may be updated periodically to reflect changes in our collection and use of your personal data. You will be informed of any significant changes (e.g. by email, in the Service or at our website), but we also recommend that you review this privacy policy from time to time to ensure you are aware of any amendments.

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