Privacy Policy“TalentPay” OÜ, a company incorporated and established
under the laws of Estonia, with registration code 16776932, registered at Roseni 13,
Central City, Tallinn, Harju County, 10111(“TalentPay” hereinafter), accessible from https://talentpay.io/ (referred
to as “Website”) one of our main priorities is the privacy of our visitors and users. This
Privacy Policy describes how TalentPay (referred to as “we”, “our” hereinafter) collects,
stores, uses, and discloses your Personal Data in accordance with the applicable law. The most relevant
version of Privacy Policy is on our website at this
link.
“Personal
Data” means any information relating to an identified or identifiable individual, including “Personal
Information” under the General Data Protection Regulation (2016/679) (“GDPR”).
This Privacy
Policy applies to all visitors, users, and others who access our products (collectively referred to as “Services”)
and governs the information you provide to or share with TalentPay, taking into account different
provisions depending on how you interact with the Website.
1. ConsentPlease
read this Privacy Policy carefully before using the Website. Your access to and use of the Services is
conditioned on your acceptance of and compliance with this Privacy Policy.
For users who visit the Website
for informational purposes (without registration):
By accessing our Website, you agree to the
use of Сookies as described in this Privacy Policy. No Personal Data is collected or processed
unless you register or interact with specific features of the Website that require such data. If you do
not agree with the use of Сookies, you may manage your Сookie preferences through your
browser settings. Your use of the Website signifies your acceptance of the use of Сookies in
accordance with this Privacy Policy.
For users who register on the Website:
By accessing our
Services, including registration, you expressly consent to the collection and processing of your Personal
Data as described in this Privacy Policy. This consent is provided by actively confirming it during
registration (by checking the checkbox). You may withdraw your consent at any time by contacting us.
Withdrawal of consent will not affect the lawfulness of processing based on consent before its
withdrawal.
2. The categories of Personal Data we collecta. Information
you give to TalentPay
Information that TalentPay receives from your use of our
Services
In order to provide you with access to and use of our Services, we collect and process the
following categories of Personal Data that you provide to us during registration or in the
course of using the Services:
• Full name (first name and last name)
• Phone number
• Email address
• Bank
statement confirming the existence of a bank account
• Bank account details (including
account number and name of the bank)
• Tax Residency Certificate (TRC)
• Actual residential address
• Identification
numbers
• Passport details
• Diploma
• Residence permit
• Insurance
certificate
• Marriage certificate
• Children's birth certificate
• Employment
record book
• Name change certificate
• Professional skills, descriptions of completed
work
• Cookies.
This information is necessary to verify your identity, ensure compliance with
applicable legal and regulatory requirements, and to facilitate the secure and lawful provision of our
Services. The processing of this data is based on Article 6(1)(b) and 6(1)(c) of the GDPR, as it is
necessary for the performance of a contract and for compliance with legal obligations to which we are
subject.
Information for Providing our Services
When you use our Services, you may
provide us with certain information that may qualify as Personal Data under applicable data protection laws,
including GDPR. This information may be provided during registration, communication with our support team,
filling out forms, uploading documents, or using other functionalities within the Services.
We
emphasize that you are solely responsible for the content of the information you choose to provide to us.
Please do not submit any Personal Data that is not necessary for the use of our Services.
Please note
that by submitting any such information, you acknowledge that you understand the purpose of its
processing, and you confirm that you have the authority to provide this data, especially in cases where it
concerns third parties (e.g., in corporate or joint use scenarios).
If you have any doubts about
which data is necessary or appropriate to submit, we encourage you to contact our support team before
sharing any sensitive information.
We may collect and process marketing and communications data such
as your preferences in relation to receiving marketing information from us. This also applies to the
way we communicate with you when you give us your Personal Data by filling in forms corresponding
with us by e-mail, or otherwise when you request marketing materials. We may also ask you to subscribe
to receive newsletters. We will only process your data for the purposes in this Privacy Policy if
we are allowed to do so under applicable law (because you consented to it or otherwise).
Information
that TalentPay receives from your use of our Services
TalentPay uses Сookies and
similar technologies to provide, improve, secure, and promote its Services.
What are
Cookies?
A Сookie is a small piece of information that is downloaded to your computer or
mobile device, enabling certain functions. Cookies make it easier and more convenient to use websites and
applications and provide a more personalized user experience.
TalentPay uses both first-party
and third-party Сookies.
We use Google Analytics to gather overall Website statistics and
track performance over time. Before using the Website, please review Google Analytics'
privacy
policy. If you wish to stop your data from being used by Google Analytics, you can easily opt out by
following
this link.
In
addition to Сookies, we use or plan to use similar technologies, such as integration with electronic
document management systems, Singnow, and API integrations.
- Pixel tags – snippets of
code from third-party companies embedded in websites and emails.
- Integration with electronic
document management systems allows for the exchange of documents and information in digital format. This
speeds up document processing and signing, making them secure and convenient for users.
- Singnow is
an electronic signature platform that helps users sign documents online, ensuring their legal validity and
security.
- API Integrations are used to connect to various external Services and systems. APIs
allow our platforms to exchange data with other software products, enhancing the functionality and
flexibility of our Services.
Note: For simplicity, all these technologies are referred to
as“Cookies” in this document.
How does TalentPay use Cookies?
TalentPay uses
various categories of Cookies to provide Services, protect users, improve Website
functionality, and promote products. Personal Data is stored only for as long as necessary for the
specified purposes.
Strictly Necessary Cookies
These Сookies are essential for the
operation of the Website and Services.
Category |
Purpose |
Data Types |
Retention Period |
Name |
Strictly Necessary |
Ensures the Website functions (authentication, security) |
Authentication data, unique ID |
24 hours |
talentpay_session |
Non-Essential Cookies
These Сookies are not required for the Website’s operation but
are used when interacting with the Website:
Category |
Purpose |
Data Types |
Retention Period |
Third-Party Providers |
Name |
Analytics |
Cookies that help us and our partners understand how the Websites
are used — e.g., through statistics or UI recovery — to improve and personalize
services, identify technical issues. |
Session and user data, encrypted session and analytics data, first
visit timestamp, ad blocker detection, unique visitor ID, session replay and heatmaps,
browser ID for analytics |
From 7 hours to 1 year 5 months |
|
|
Advertising |
Used to understand user interests and promote services based on
collected information |
Ad identifiers, unique user IDs, session data, cross-domain sync
parameters, behavioral data, device technical parameters |
From session (~20 min) to 1 year 2 months |
|
|
Functional |
Helpsremember settings and preferences to improve interaction with
services. |
Help/chat history, email address, Website usage data, unique
IDs |
From session (~20 min) to 1 year |
|
|
Cookie Management
You have the option to manage your Cookie preferences at any time through
your browser settings. By adjusting these settings, you can accept or block Cookies.
Listed below
are the links to the support documents on how to manage and delete cookies from the major web browsers.
Chrome:
https://support.google.com/accounts/answer/32050Safari:
https://support.apple.com/en-in/guide/safari/sfri11471/macFirefox:
https://support.mozilla.org/en-US/kb/clear-cookies-and-site-data-firefox?redirectslug=delete-cookies-remove-info-websites-stored&redirectlocale=en-USInternet
Explorer:
https://support.microsoft.com/en-us/topic/how-to-delete-cookie-files-in-internet-explorer-bca9446f-d873-78de-77ba-d42645fa52fcIf
you are using any other web browser, please visit your browser’s official support documents.
Please
note that refusing Cookies may impact the functionality of certain features of
our Website.
We may use a consent management platform to record your preferences regarding Cookies
and other tracking technologies. Periodically, we may ask for your consent again to ensure that your
settings are up to date and reflect your preferences.
b. Information that TalentPay receives
from third parties
We may also receive information from third parties to add to the information we
receive from you. This is used to help us deliver relevant functionality of our Services to you,
to prevent fraud and/or abuse, and to collect your geolocation for taxation purposes. We may also receive
technical data from analytics providers such as Google Analytics. These third parties may use Cookies,
beacons, tracking pixels, and other tools to collect information about your use of the Services. These
third parties are not controlled directly by us, so we recommend that you check their privacy policies to
understand how they use your data.
3. Personal Data we don’t collect TalentPay does
not intentionally collect any sensitive Personal Data, such as data revealing your racial or ethnic origin,
political opinions, religious or philosophical beliefs, trade union membership, genetic or biometric data
for the purpose of uniquely identifying a natural person, or data concerning your health or sex life or
sexual orientation, as defined under Article 9 of the GDPR and other applicable laws.
You are strongly
advised not to submit any such information when using our Services, unless explicitly requested by TalentPay and
required for a lawful purpose.
If, in exceptional cases, TalentPay reasonably needs to
collect and process such sensitive Personal Data, we will provide you with a clear explanation of the
purpose and lawful basis for such processing, and will request your explicit consent, where required by
applicable data protection law.
TalentPay also implements reasonable measures to detect and
delete any inadvertently collected sensitive Personal Data that is not required for the performance of the
Services.
4. How do we use your information?We process your Personal
Data for the following purposes:
• To operate, improve, develop and provide you with our Services
• To respond to inquiries or comments from you
• To calculate marketing conversion rates
and other elements of advertising performance
• To help tracking and correcting errors
and bugs
• To customize your user experience (for example, by giving you more relevant ads and inform you
about new optionsthat you might be interested in, unless you have told us not to (opt-out))
• To
maintain the integrity and security of the Services
• To create reports, analyses or similar for
the purpose of research and business intelligence and be able to track potential problems, behavior and
trends
• To enforce our terms and conditions, such as our Terms of Use, and this Policy
• To
send you newsletters and promotional notices and offers you have previously agreed
• To keep our
Services fair, investigate and prevent fraud and illegal behavior
• To comply with applicable
law and regulations.
We will not use your Personal Data for any other purposes than the
purposes specified in this Policy.
Email and Marketing. In most instances, we give you options with
regard to the Personal Data you provide, including choices with respect to marketing materials. You may
manage your receipt of marketing and non-transactional communications by clicking on the “unsubscribe” link
located at the bottom of marketing emails.
5. Data sharing and
disclosureWe may share your Personal Data with third parties in the following
circumstances, in accordance with applicable law:
• With your consent
• When required
to comply with legal obligations, such as responding to subpoenas or court orders
• With our
service providers who assist us in providing our Services
• In the event of a merger, acquisition,
or sale of our company assets, where your Personal Information may be transferred as part of the
transaction, subject to appropriate protections.
To be able to provide you with the Services and the
best possible experience, we will share your data with other companies and organizations. We will only
do so if our partners can provide the same level of security to keep your data safe as implemented by us and
if our partners can ensure that they comply with applicable law and privacy regulations. We may
share your information with the following partners:
• Developers that develop
our platform
• Market research agencies
• Bank organization
• eSignature platforms
• Companies
and external consultants that help support our platform and Services
• Advertising partners and
attribution platforms to help us understand the effectiveness of our marketing campaigns
• Marketing services partners.
6. Your rightsYou
have the following rights, subject to some limitations, against the respective TalentPay responsible
for the Website you are using:
• To request information about our use of your Personal Data
(e.g., the pieces and categories of Personal Data we have; the categories of sources, purposes for
collection, the third parties to whom we have disclosed Personal Data, and Personal Data we have
disclosed)
• To review and access your Personal Data
• To rectify (correct, update or
modify) the Personal Data we hold about you
• To erase (e.g., delete), de-identify, anonymize or
block your Personal Data
• To restrict our use of your Personal Data
• To receive your
Personal Data in a usable format and transmit it to a third party (also known as the right of data
portability)
• To lodge a complaint with your local data protection authority.
7. Data
retentionWe will only store your information as long as necessary to fulfil the
purposes for which the information is collected and processed or – where the applicable law
provides for longer storage and retention period – for the storage and retention period required
by law. After that your Personal Data will be deleted, blocked or anonymized, as provided by applicable law.
In
particular:
• The time required to fulfill the purposes for which Personal Data is
processed
• The time required to maintain user’s relationships
• The time required to comply
with legal and regulatory retention requirements. In some circumstances, it may become necessary for us to
share your information with government authorities, law enforcement officials, or regulatory bodies as
required by law or for administrative purposes and to the extent that local law allows and/or requires this:
(i)
To comply with applicable law, legal actions or lawful request of state authorities
(ii) To protect our
rights, property or safety, our users or others under the applicable law
(iii) To fulfil our
obligations under our agreement with you
(iv) To check, prevent, and investigate fraud, security, or
technical issues.
8. Data securityWe strive to maintain the highest
standards of security, and TalentPay has put in place robust technical and organizational measures
for the protection of your Personal Data in accordance with the current, general state-of-the-art
technologies, especially to protect the data against loss, falsification, or access by unauthorized third
persons:
• We use reasonable security measures to protect the information we have against loss,
theft and unauthorized use, disclosure or modification
• We continuously analyze and check our
procedures of collection, storage, and use of information including trainings of our staff
• We
use encryption for many of our products.
Please note that although we work hard to protect security of
our Services and Websites, the transmission of information via the Internet is not completely
secure. Although we will do our best to protect your Personal Data, we cannot guarantee the security of
your Personal Data transmitted to our Website; any transmission is at your own risk. Once we have
received your Personal Data, we will use strict procedures and security features to try to prevent
unauthorized access. We also ask you to take every precaution to protect your Personal Data when you
are on the Internet.
9. Children’s Information
TalentPay does not knowingly collect or
process Personal Data from children under the age of 16, unless a lower age limit (not below 13) is provided
by the applicable data protection laws in the user's country of residence, and valid consent is obtained
from the holder of parental responsibility over the child.
If you are a parent or guardian and you
believe that your child has provided us with Personal Data without your consent, please contact us
immediately at finance@talentpay.io. We will take reasonable steps to verify and delete such data from
our records in accordance with applicable data protection laws.
We encourage parents and guardians to
observe, participate in, and monitor their children’s online activity to help
enforce thisPolicy.
10. Contact usIf you have any questions or
concerns about our Privacy Policy, please contact us at:
Telephone:
+37491193416
Email:
finance@talentpay.io