Privacy policy

I. Who is responsible for the processing of your data?

The person responsible for the processing of your personal data is The Finder Company, S.L.
(hereinafter, ‘FINDR’) with registered office at Paseo Pintor Rosales 56, 28008,
Madrid, Spain.
If you have any questions about the processing of your personal data, you can contact us by sending us your request
contact us by sending your request by e-mail to the address dpo@findrapp.es .

II. For what purposes and on what grounds do we process your data?

Findr will process your personal data in accordance with the following purposes
below:
(i) Management and registration for Findr services.
Your personal data will be processed in order to manage your registration with Findr as well as to provide you with
the service by which you can view and analyse job opportunities or, in the case of being a Findr partner company, the
Findr’s partner company, the publication of job opportunities and the analysis of the
compatibility analysis of Findr users. Within our services, there is the need to
the need to contact the user in order to provide you with information about job opportunities that fit your needs.
information regarding job opportunities that match your profile.
In the case of professional company profiles, contact details will be processed for the purpose of
processed in order to manage the registration and services of the application.
In order to have a greater protection of personal data, the initiation of conversations regarding job
of conversations regarding job opportunities between users and companies will take place in our
companies will take place in our application environment.
Category of personal data processed: the information contained in your LinkedIn profile.
LinkedIn profile, including but not limited to: first name, surname, email, telephone number, information about your work experience, information about your
work experience, information about your education, skills, a photograph, your city or location and the
city or location and any validations you have in your profile. Additionally and if you wish
you can enter additional information that will allow you to make the most of our services.
the performance of our services. Likewise, we remind you not to publish or
add personal data that you do not want to be made public.
Basis of legitimacy: the basis that legitimises the processing of your personal data is
the performance of the contract entered into between you and the data controller at the time of accepting
our terms and conditions and those of LinkedIn. We remind you that, in addition to the
other rights granted to you by data protection law, you may at any time also request not to be subject to the processing of your personal data.
you may also at any time request not to be subject to automated individual decision-making, including the
automated decisions, including profiling, to request human intervention in automated decision
in automated decision-making, express your point of view, resolve any doubts about it, or contest
any concerns or challenge them in accordance with the provisions set out in section ‘What are your rights when you provide us with information about you?
‘What are your rights when you provide us with your personal information?
in this Privacy Policy.

(ii) User service
If you request information and/or send us queries, suggestions, complaints, claims or incidences through any of the channels that FINDR offers,
claims or incidents through any of the channels that FINDR makes available for this purpose (specific form, telephone or email), your personal
(specific form, telephone or email) your personal data will be processed to manage and attend your request by email or email.
will be processed in order to manage and attend to your request by email or phone call depending on the
telephone call depending on the means used by you to send us your request.
Category of personal data processed: name, surname, email address, telephone number, and
any other information you voluntarily provide in your request.
Basis of legitimacy: the basis that legitimises the processing of your personal data is
consent. Without the personal data indicated above, your request could not be

(iii) Commercial actions
If you consent, we will process your personal data in order to manage commercial actions, including the
commercial actions, including sending you commercial communications about products, services and promotions that may be
services and promotions that may be related to our FINDR application,
including personalised and prior profiling, by any means, including electronic means, which may include newsletters
including electronic means, which may include newsletters, discounts, promotions, relevant information or
relevant information or commercial information about its activities, events, products and services related to the
services related to the HR and Recruitment sector.
Category of personal data processed: e-mail address, telephone number and postal address will be processed.
telephone number and postal address will be processed for sending commercial communications.
commercial communications. The personalisation parameters (demographic criteria, operational information and inferred socio-economic
information and inferred socio-economic parameters) will be processed so that you will only receive communications
receive communications with commercial information that we consider most appropriate to your
your profile.
Basis of legitimacy: this processing will only be carried out if you provide your express
your express voluntary consent by ticking the box provided for this purpose in the different
for this purpose in the different forms of this app. We remind you that, in addition to the
other rights granted to you by data protection regulations, at any time you may also withdraw your consent and request
you can also withdraw your consent at any time and request to unsubscribe from the sending of commercial
communications, request not to be the subject of automated individual decisions, including the
automated decisions, including profiling, request human intervention in automated decision-making, including profiling, and request human intervention in automated decision-making, including profiling.
automated decision making, express your point of view, resolve any doubts or challenge your
any concerns or object in accordance with the provisions set out in the section ‘What are your rights when we use your personal data?
What are your rights when you provide us with your personal information?
included in this Privacy Policy.

(iv) Sending surveys
If you register and actively participate in our app, FINDR will be able to
send you surveys by electronic means (email, SMS, phone calls) to find out your level of satisfaction
to find out your level of satisfaction, your experience and your possible suggestions about the
suggestions about the functioning of the application, the job opportunities that appear or any other
or other issues that may be useful to FINDR. Your feedback will be used to
improve FINDR’s processes, products and services.
Category of personal data processed: email, telephone, transactional information related to the purchase or
information related to the purchase or booking of products and services, country (in order to ensure that the survey is sent in the
that the survey is sent in the language of the country you have provided during the purchase process to
the purchase process to ensure that it is understood at all times), and
any other non-personal information you provide through the surveys you respond to.
surveys you respond to.
Basis of legitimacy: this processing is necessary for the satisfaction of legitimate interests pursued by FINDRDR
legitimate interests pursued by FINDR in order to know the opinion of its users with respect to the operation and use of the
the functioning and use of the application. FINDR understands that the rights and freedoms of its users and the
rights and freedoms of its users and that there is a balance between the interests of both parties insofar as this
interests of both parties insofar as this processing makes it possible to achieve the intended purpose
(to know the users’ opinion), which is necessary for FINDR to improve its products, services and processes.
to improve FINDR’s products, services and operational processes and for FINDR’s users to
and users obtain an improvement in the quality of their experience. In addition, as a
the volume of users who may access FINDR’s services, we understand that sending surveys by FINDR’s
we understand that sending surveys electronically is necessary for the purpose described above and that there is no other
purpose described and there is no other mechanism to achieve this purpose as effectively.
purpose with the same efficiency. We also understand that our users
may have a reasonable expectation of such processing based on their contractual relationship with us.
based on the contractual relationship they have with FINDR when using the application, on the specific
specific information provided by FINDR during the registration process and that this type of processing is carried out as part of the
processing is carried out as part of a standard and usual practice in the service provider industry.
service provider industry. Furthermore, in order to achieve
In order to achieve this purpose, it is reminded that only strictly necessary personal data of a non-sensitive nature are processed.
of a non-sensitive nature, that no surveys are sent to minors under sixteen (16) years of age.
sixteen (16) years of age and that we only contact our users on an ad hoc basis and for a limited period of time.
limited period of time to our users.
However, you may at any time object to the processing of your personal data or exercise your other rights to
data or exercise your other rights under data protection legislation in accordance with the procedure set out in the
protection in accordance with the procedure described in the section ‘What are your rights when we process your personal data?
section ‘What are your rights when you provide us with your personal information?
included in this Privacy Policy

(v) Market research and analysis
FINDR will proceed to dissociate your personal data provided by you through the forms of the
the application forms for the purpose of making quantitative and qualitative aggregated statistical
quantitative and qualitative aggregate reports to carry out market research and analysis in order to
to enable us to assess our market positioning.
Category of personal data processed: information contained in your LinkedIn profile.
LinkedIn profile, including but not limited to: name, surname, email address, telephone number, information on your work experience, information on your
work experience, information about your education, skills, a photograph, your city or location and the
city or location and any validations you have in your profile. Additionally and if you wish
you can enter additional information that will allow you to make the most of our services.
the performance of our services. Likewise, we remind you not to publish or
add personal data that you do not want to be made public.
Basis of legitimacy: this processing is necessary for the fulfilment of legitimate interests pursued by FINDRDR
legitimate interests pursued by FINDR in order to know and understand the market. FINDR
understands that the rights and freedoms of its users are not undermined and that there is a balance between the interests of both parties.
there is a balance between the interests of both parties (users and FINDR) insofar as the processing is
the purpose for which it is intended (to assess our market position), insofar as this processing allows us to
our market positioning), which is necessary for FINDR to be able to make strategic business decisions and even to
to make strategic business decisions and even improve its products, services and FINDR’s operational
and operational processes of FINDR, which would provide our users with a better quality of experience.
a better quality of experience for our users. In addition, we understand that there is no
other, more modest mechanism to achieve this purpose with the same effectiveness, as only
This is because only basic, non-sensitive and previously anonymised (anonymised) information is used.
dissociated (anonymised) from any personal data that would allow the individual identification of users during the
individual users during the course of this purpose. Likewise,
we understand that our users may have a reasonable expectation regarding the performance of this
this processing based on the contractual relationship they have with FINDR by registering with FINDR.
with FINDR when registering for the application, on the specific information provided by FINDR and that this type of
FINDR, and that this type of processing is carried out as part of a standard and normal practice of the
standard practice in the IT and HR industry.
However, you can at any time object to the processing of your personal data or exercise your other rights
data or exercise the rest of your rights under data protection legislation in accordance with the procedure
protection law in accordance with the procedure described in the section ‘What are your rights when we process your personal data?
section ‘What are your rights when you provide us with your personal data?
included in this Privacy Policy

(vi) Dissemination of the content of users who have previously mentioned or tagged FINDR on social networks
mentioned or tagged FINDR on social networks.
If you share content on your social networks and mention FINDR’s user account (e.g. mention us in stories or posts…), we may
FINDR user account (e.g. you mention us in stories or posts…), we may process your
your personal data to promote FINDR’s image on your social media profiles by sharing that
social media profiles by sharing that post where you mention FINDR.
We inform you that we do not control the processing of the personal data of the users of social
users of the social networks where FINDR has a registered account (TikTok,
Instagram and LinkedIn). For more information about how and for which purposes the
social network provider collects and processes personal data, and about users’ rights and options to protect their
rights and options for users to protect their privacy, please refer to the social media provider’s applicable
applicable privacy policies of the social media provider.
Category of personal data processed: user account, image and/or voice of the social network user and/or of those
of the social network user and/or of those third parties that may appear in their
publication.
Basis of legitimacy: this processing will only be carried out if you provide your
your express voluntary consent by replying in the affirmative to the direct message sent from the
direct message sent from FINDR’s social network profile. We remind you that,
in addition to the other rights granted to you by the data protection regulations, you may also withdraw your consent to the
you can also withdraw your consent to our deletion of the publication at any time, either
publication, either in accordance with ‘What are your rights when you provide us with your personal data?
when you provide us with your personal data’ included in this Privacy Policy, or by sending us a direct message
Privacy Policy, or by direct message sent to our profile on the social network where we have shared the content.
where we have shared such content

(vii) Prevention and detection of possible fraudulent activities
Activate the necessary mechanisms in order to prevent and detect misuse of the application or potential fraud related to the
of the application or potential fraud related to the purchase or booking of products and services that could
products and services that could affect FINDR itself or its users. If possible fraudulent
possible fraudulent activities are detected, FINDR may communicate the information to the competent
the competent public authorities so that the appropriate measures can be taken in each case.
in each case.
Category of personal data processed: information contained in your LinkedIn profile.
LinkedIn profile, including but not limited to: first name, surname, email, telephone number, information about your work experience, information about your
work experience, information about your education, skills, a photograph, your city or location and the
city or location and any validations you have in your profile. Additionally and if you wish
you can enter additional information that will allow you to make the most of our services.
the performance of our services. Likewise, we remind you not to publish or
add personal data that you do not want to be made public.
Basis of legitimacy: this processing is necessary for the fulfilment of legitimate interests pursued by FINDRDR
legitimate interests pursued by FINDR. FINDR understands that no rights and freedoms of natural persons are
and freedoms of natural persons and that there is a balance of legitimate interests insofar as this processing allows the
insofar as this processing makes it possible to achieve the purpose pursued (preventing and detecting possible fraudulent activities).
(preventing and detecting possible fraudulent activities) and is beneficial for the users and users of the
users and users of the application, as it allows the necessary measures to be taken to protect them from unlawful activities.
to protect them from unlawful activities such as fraud attempts by third parties, for FINDR itself
third parties, for FINDR itself in order to prevent misuse of the application and its products and services, and for the
products and services, and for society at large to ensure that fraudulent activities are discouraged.
fraudulent activities are discouraged and detected when they occur.

(viii) Use of cookies and similar technologies
FINDR uses its own and third party cookies and similar technologies throughout this
application page and as a consequence of this, they process, store and share
information and personal data of the users when they browse through the same,
in accordance with the purposes and configuration parameters that are made available to users at all times.
available to users at all times.
You can obtain all the information about the use of cookies and similar technologies that
is carried out through this application page, the processing of personal data resulting from it and the
data processing resulting from it and how to manage the provision of your consent through our
consent through our website.

(ix) Compliance with legal obligations
Personal data will be processed for the purpose of complying with legal obligations applicable
to the Data Controller as a consequence of the relationship with you as a user
and the processing of your personal data in accordance with European Union law and/or the applicable domestic legal
European Union law and/or the applicable domestic legal regime (legal obligations required by tax law, by the
tax law, personal data protection law, commercial law, commercial law, data protection law, data protection law, data protection law, data protection law, data protection law, data protection law, data protection law
commercial law, user and consumer protection law, consumer protection law, information society services law, etc.).
the rules on information society services and electronic commerce,
civil law rules, accounting rules, etc.).
Category of personal data processed: information contained in your LinkedIn profile.
LinkedIn profile, including but not limited to: name, surname, email address, telephone number, information on your work experience, information on your
work experience, information about your education, skills, a photograph, your city or location and the
city or location and any validations you have in your profile. Additionally and if you wish
you can enter additional information that will allow you to make the most of our services.
the performance of our services. Likewise, we remind you not to publish or
add personal data that you do not want to be made public.
Basis of legitimacy: compliance with legal obligations applicable to the Data Controller
under European Union law and/or the applicable domestic legal regime. Without
without your personal data, the Controller would not be able to adequately comply with the above legal
legal obligations indicated or to meet possible legal responsibilities arising from the relationship with the
arising from the relationship with you or from the processing of your personal data.

III. What criteria do we use to determine how long we keep your personal data?

Depending on the purpose for which we process your personal data, the applicable retention criteria will be as follows:

– The data will be stored in accordance with the purpose for which we process it.
The applicable retention criteria are as follows:
– Management and registration of Findr services: for as long as the contractual relationship with you is maintained or you
contractual relationship with you or you request to unsubscribe from the application.
User service: for as long as it is necessary to manage and respond to your request, complaint, incidence or
your request, complaint, incident or claim.
– Commercial actions: we will process your data until you withdraw your consent or you
consent or you inform us of your intention not to continue with the terms and conditions you
terms and conditions accepted at the time of joining Findr.
– Sending surveys: the personal data provided will be kept for a maximum period of 12 months unless you withdraw your consent.
for a maximum period of 12 months unless prior to the expiry of this period you request the
you request the deletion of your personal data or object to this processing, in which case it will no longer be processed.
in which case they will no longer be processed for this purpose.
– Market research and analysis : the information processed for this purpose is disassociated and cannot be
is unlinked and cannot be linked to your other personal information. No
However, if, prior to this separation, you request the deletion of your data or your objection to the
or object to the processing, the data will no longer be processed for this purpose.
this purpose.
– Prevention and detection of possible fraudulent activities: until such time as possible fraudulent activities are
possible fraudulent actions that may be detected are resolved, and thereafter they will be
thereafter, they will be blocked for as long as FINDR can be held legally
FINDR may be held legally liable as a consequence.
– Use of cookies and similar technologies: the information will be processed for as long as the consent given by FINDR
the consent granted by the users for the installation of cookies on their device remains
installation of cookies on their device. If the user does not remove this
consent by means of the mechanisms offered in our (link to our cookie policy), the information will be
cookies policy), the information will be retained for the duration of the period of
validity of the cookies or similar technologies installed on your device.
– Fulfilment of legal obligations: personal data will be kept
blocked for as long as FINDR can be held legally liable for compliance with its legal
compliance with its legal obligations.

In any of the above cases, where the personal data are no longer relevant for the purposes for which they were collected or, where
relevant for the purposes for which they were collected or, where applicable, you withdraw your consent or exercise your right to
exercise your right of erasure or objection to the processing indicated, where appropriate, thewhere appropriate, the Controller may keep them duly blocked
(identification and reservation of the personal data, by adopting technical and organisational measures to prevent their
measures to prevent their processing, including their visualisation) in order to make them available, if necessary, to
necessary, make them available to the competent Public Administrations and, in particular, to the competent
the competent supervisory authority in the field of data protection,
Judges, Courts or the Public Prosecutor’s Office during the statute of limitations period for the legal
legal actions that may derive from the relationship maintained with you or from the processing of your personal
processing of your personal data and/or the retention periods provided for by law in accordance with European
legally provided for under European Union law and/or the internal legal system.
Once these periods have elapsed, your personal data will be physically deleted without the possibility of recovery.
without the possibility of recovery.

IV. Who will we share your data with?

Your data will not be shared with third parties at any time. Only if you wish, you can share your contact information through the chat in our application
once the user profile and the company have been connected. However, only if necessary to meet potential legal liabilities
or comply with legal retention periods, your personal data may be
communicated to competent Public Authorities and in particular to the
Control Authority competent in matters of data protection, Judges, Courts or the
Prosecutor’s Office in accordance with European Union Law and/or internal legal regime
In addition, FINDR has suppliers who may also process your personal data to
provide services related to the purposes about which you are being
informed (by way of example and not limitation, companies operating in
the following sectors: information security, management and administration of
user relations (CRM), technology, legal advice, marketing,
customer service, multidisciplinary professional services, IT services,
etc.). These suppliers will only access your personal data to carry out their
services on behalf of and on behalf of FINDR, always following its instructions and
without at any time being able to use said data for their own purposes and/or
unauthorized purposes.

V. Will your data be communicated outside the EU?

Currently, Findr does not process data or transfer data to recipients in
countries outside the EU or the European Economic Area (“EEA”) since all of its suppliers and third-party collaborators are located within the EEA.
If, within the scope of the processing operations described in the section
For what purpose do we process your personal data? of this Privacy Policy, your data is processed in countries outside the EU or EEA for which there is no adequacy decision by the European Commission,
Findr will ensure that your data is treated in accordance with European data protection
standards. To the extent necessary and to ensure the security of data transfers to recipients in countries outside the EU or EEA, we will use international transfer agreements based on the Standard Contractual Clauses or other mechanisms that allow the transfer of data under data protection regulations, including the adoption of appropriate technical and organizational protection measures for the protection of the data transmitted. You can obtain a copy of these guarantees by contacting our data protection officer by email at: dpo@findrapp.es
Certain countries outside the EU have already been officially declared by the EU as countries with an adequate level of data protection similar to that of Europe. This means that, in accordance with the applicable data protection rules, any transfer to these countries does not require independent official approval or separate agreement.

VI. What are your rights when you provide us with your personal data?

You can exercise your right to access, rectification, opposition, limitation, portability
and, where appropriate, not to be subject to automated individual decisions, including
profiling, by sending your request in writing to the email address
dpo@findrapp.es . If there are reasonable doubts about the identity of the owner of the
personal data, a copy of an official document may be requested
(DNI/NIE/Passport) to process the request.
On the other hand, in relation to those treatments that are based on obtaining
your consent, we inform you that, at any time, you can withdraw it or
oppose the treatment through the procedure detailed in the previous paragraph.
In addition, we remind you that, if you have expressly consented to the sending
of communications with commercial information, we also offer you the possibility
of unsubscribing through the means that will be made available to you for this purpose in
each of the commercial communications you may receive.

VII. How have we obtained your personal data?
The personal data processed by FINDR may be obtained in the following
ways:
– they are provided directly by you as the owner of the data through
registration in the Findr application and/or during the relationship maintained with you.
– Our employment marketplace is connected to the LinkedIn API and
therefore, you have accepted in the LinkedIn terms and conditions that
LinkedIn partner companies may access your data under the LinkedIn terms and conditions. In this regard, exceptionally,
we collect data from public LinkedIn profiles and incorporate your data into
our platform (education, work experience, skills, photo, your
city or location and validations).

VIII. Before which authority can you file your claims regarding data protection?
You may file a claim with the Spanish Data Protection Agency to safeguard your rights when you deem it appropriate.

Without prejudice to the above, we recommend that you contact the DPO in advance at the email address dpo@findrapp.es

so that we can assist you with your request and resolve any issues related to the processing of your personal data.

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