Privacy Policy Updated: 01 Feb 2023 This Privacy Policy explains how and why 32links collects, uses, and shares personal information when you interact with or use our Site or Service. It also includes any information Upwork collects offline in connection with the Service, which we may combine with information from the Site and Service. By reading this Privacy Policy, you will understand your privacy rights and choices. When we say 32links, we mean Sellers Review sp. z o.o., and any of its affiliates, including Sellers Review sp. z o.o. When we say “Site”, we mean https://32links.com/ and when we say “Service”, we mean the Site plus any websites, features, applications, widgets, or online services owned or controlled by 32links and that post a link to this Privacy Policy. Accessibility: This Privacy Policy uses industry-standard technologie. If you wish to print this policy, please do so from your web browser or by saving the page as a PDF. . TABLE OF CONTENTS INFORMATION COLLECTION USE OF INFORMATION DATA RETENTION INFORMATION SHARING AND DISCLOSURE YOUR CHOICES AND RIGHTS SECURITY CROSS-BORDER DATA TRANSFERS LINKS TO OTHER SITES CHANGES TO THIS POLICY CONTACT US 1. INFORMATION COLLECTION Users of the Service may be Clients, Freelancers, or Agencies, or Site Visitors (as each is defined in the User Agreement). a. Information You Provide to Us When you use the Service, you may provide us with information about you. This may include your name and contact information, financial information to make or receive payment for services obtained through the 32links , or information to help us fill out tax forms. When you use the Service, we may also collect information related to your use of the Service and aggregate this with information about other users. This helps us improve our Services for you. Agencies may also provide us with information about Freelancers associated with the Agency. Depending upon our relationship with you, we may collect the following categories and types of personal information from and about you: Categories of Personal Information We Collect Types of Personal Information Collected Categories of Sources of Personal Information Business Purpose for Collection of Personal Information Identifiers Name, Email Address, Social Media Account Information, Profile Data, IP Address Directly from You or Your use of the Service; Cookies and Other Tracking Technologies; Third Parties (such as affiliates, agents, service providers and other users) Providing and Improving the Service, Identification, Communications, Marketing/Advertising, Security, Legal, Compliance and Regulatory Obligations. Sensitive Personal Information Social Security Number, Driver’s License, State Identification or Passport Number Directly from You Verify your identity and to detect fraud, identity theft, or other misuse of your account. Commercial Information Transaction Data Directly from You or Your use of the Service; Third Parties (such as affiliates, agents, service providers and other users) Providing and Improving the Service, Identification, Communications, Marketing/Advertising, Security, Legal, Compliance and Regulatory Obligations. Financial Data Credit card or other financial account information, and billing address Directly from You or Your use of the Service; Third Parties (such as affiliates, agents, service providers and other users) Providing and Improving the Service, Identification, Communications, Marketing/Advertising, Security, Legal, Compliance and Regulatory Obligations. Internet or Other Network or Device Activities Unique device and app identifiers, browsing history or other usage data, , the browser and operating system you are using, the URL or advertisement that referred you to the Service, the search terms you entered into a search engine that led you to the Service, areas within the Service that you visited, which links you clicked on, which pages or content you viewed and for how long, other similar information and statistics about your interactions, such as content response times, download errors and length of visits to certain pages and other information commonly shared when browsers communicate with websites Directly from You or Your use of the Service; Cookies and Other Tracking Technologies; Third Parties (such as affiliates, agents, service providers and other users) Providing and Improving the Service, Identification, Communications, Marketing/Advertising, Security, Legal, Compliance and Regulatory Obligations. Geolocation Information Your Location Directly from You or Your use of the Service; Cookies and Other Tracking Technologies; Third Parties (such as affiliates, agents, service providers and other users) Providing and Improving the Service, Identification, Communications, Marketing/Advertising, Security, Legal, Compliance and Regulatory Obligations. Sensory Information Audio recordings if you call our customer service. Directly from You or Your use of the Service; Third Parties (such as affiliates, agents, service providers and other users) Providing and Improving the Service, Identification, Communications, Marketing/Advertising, Security, Legal, Compliance and Regulatory Obligations. Other information that identifies or can be reasonably associated with you User-generated content, (e.g., community posts, feedback and job postings), photographs, examples of your work, information on work previously performed via the Service and outside the Service and earnings information. Directly from You or Your use of the Service; Third Parties (such as affiliates, agents, service providers and other users) Providing and Improving the Service, Identification, Communications, Marketing/Advertising, Security, Legal, Compliance and Regulatory Obligations. b. Non-Identifying Information Non-Identifying Information/Usernames: We also may collect other information, such as zip codes, demographic data, information about your use of the Service, and general project-related data (“Non-Identifying Information”). We may combine information collected from 32links users, whether they are registered or not (“32links Users”). In some cases, we may render Personal Information (generally, email address) into a form of Non-Identifying Information referred to in this Privacy Policy as “Hashed Information.” This is typically accomplished using a mathematical process (commonly known as a hash function) to convert information into a code. The code does not identify you directly, but it may be used to connect your activity and interests. Combination of Personal and Non-Identifying Information: We may combine your Personal Information with Non-Identifying Information, but Upwork will treat the combined information as Personal Information. c. Information Collected Automatically Like other online companies, we receive technical information when you use our Services. We use these technologies to analyze how people use the Service, to improve how our Site functions, to save your log-in information for future sessions, and to serve you with advertisements that may interest you. 32links and its partners use cookies or similar technologies to analyze trends, administer the website, track users’ movement around the website, the desktop app, and the mobile app, and to gather demographic information about our user base as a whole. The technology used to collect information automatically from 32links Users may include cookies, web beacons, and embedded scripts. In addition, we and our marketing partners, affiliates, analytics, and service providers may use a variety of other technologies (such as tags) that collect similar information for security and fraud detection purposes and we may use third parties to perform these services on our behalf. d. Third-Party Analytics Providers, Ad Servers, and Similar Third Parties We may work with advertising agencies and vendors who use technology to help us understand how people use our Site. These vendors may use technologies to serve you advertisements that may interest you. You can choose to opt out of receiving interest-based advertising. 32links works with (or may in the future work with) network advertisers, ad agencies, analytics service providers and other vendors to provide us with information regarding traffic on the Service, including pages viewed and the actions taken when visiting the Service; to serve our advertisements on other websites, within mobile apps and elsewhere online; and to provide us with information regarding the use of the Service and the effectiveness of our advertisements. Our service providers may collect certain information about your visits to and activity on the Service as well as other websites or services, they may set and access their own tracking technologies on your device (including cookies and web beacons), and may use that information to show you targeted advertisements. Some of these parties may collect Personal Information when you visit the Service or other online websites and services. We may also share certain Non-Identifying Information with these parties, including Hashed Information, in connection with the services they provide to us. e. How We Respond to Do Not Track Signals 32links does not respond to Do-Not-Track signals. Please note that your browser setting may allow you to automatically transmit a “Do Not Track” signal to websites and online services you visit. There is no consensus among industry participants as to what “Do Not Track” means in this context. Like many websites and online services, 32links does not alter its practices when it receives a “Do Not Track” signal from a visitor’s browser. To find out more about “Do Not Track,” please visit http://www.allaboutdnt.com. f. Messaging Freelancers, Agencies, and Clients may communicate with each other through the Service. For example, Freelancers, Agencies, and Clients may wish to discuss Client needs and Freelancer work proposals. If you communicate with an Agency or Client, that Agency or Client will also be a “data controller” with respect to such communications. g. Children The Service is general audience and intended for users 18 and older. We do not knowingly collect Personal Information from anyone younger than age 18. If we become aware that a child younger than 18 has provided us with Personal Information, we will use commercially reasonable efforts to delete such information from our files. If you are the parent or legal guardian of a child younger than age 18 and believe that 32links has collected Personal Information from your child, please contact us at: info@32links.com 2. USE OF INFORMATION We use information collected through the Service to provide and improve the Service, process your requests, prevent fraud, provide you with information and advertising that may interest you, comply with the law, and as otherwise permitted with your consent. We Use Information We Collect: To provide and improve the Service, complete your transactions, address your inquiries, process your registration, verify the information you provide is valid, and for compliance and internal business purposes. To contact you with administrative communications and 32links newsletters, marketing or promotional materials (on behalf of 32links or third parties) and other information that may be of interest to you. If you decide at any time that you no longer wish to receive such communications from us, please follow the instructions in the Your Choices and Rights section, below. To tailor content we display to you and offers we may present to you, both on the Service and elsewhere online. To administer and develop our business relationship with you and, if applicable, the corporation or other legal entity you represent. To enforce and comply with the law, including to conduct an investigation, to protect the property and rights of 32links or a third party, to protect the safety of the public or any person, or to prevent or stop activity we may consider to be, or to pose a risk of being, illegal, fraudulent, unethical or legally actionable activity. We may also use Device Identifiers to identify 32links Users. For the purposes disclosed at the time you provide your information, with your consent, and as further described in this Privacy Policy. To Honor Our Contractual Commitments to You. Much of our processing of Personal Information is to meet our contractual obligations to our investors, or to take steps at Users' request in anticipation of entering into a contract with them. For Our Legitimate Interests. In many cases, we handle Personal Information on the grounds that it furthers our legitimate interests in commercial activities, such as the following, in ways that are not overridden by the interests or fundamental rights and freedoms of the affected individuals: Providing our Site and Service. Detecting security incidents, protecting against malicious, deceptive, fraudulent or illegal activity, and prosecuting those responsible for that activity. Measuring interest and engagement in our Services. Short-term, transient use, such as contextual customization of ads. Improving, upgrading or enhancing our Services. Developing new products and services. Ensuring internal quality control and safety. Authenticating and verifying individual identities. Debugging to identify and repair errors with our Services. Auditing relating to interactions, transactions and other compliance activities. Enforcing our agreements and policies. Analyzing and improving our business. Communications, including marketing and responding to your inquiries about our services. Addressing information security needs and protecting our Users, 32links, and others. Managing legal issues. To Comply with Legal Obligations. We need to use and disclose Personal Information in certain ways to comply with our legal obligations. 3. DATA RETENTION We will only retain your personal information for as long as is necessary to fulfill the purposes for which it was collected, including for the purposes of satisfying any legal, regulatory, accounting, or reporting requirements. Unless you request that we delete certain information (see Your Choices and Rights below), we retain government-issued identification documents you submit to verify your identity for 30 days, selfies you submit to verify your identity for 180 days, a copy of the headshot image from your identity document for 3 years, and other information we collect for longer. Your information may persist in copies made for ongoing fraud prevention, backup, and business continuity purposes for additional time. 4. INFORMATION SHARING AND DISCLOSURE We do not sell your personal information as that term is traditionally defined, however, we may use cookies on our Site that are placed by a third party for the purposes of advertising or marketing to you. This may be considered a “sale” of personal information under applicable data protection laws. We may share information about you to provide the Services, for legal and investigative purposes, in connection with sweepstakes and promotions, or if we are part of a merger or acquisition. We may also share non-identifying information with third parties. You have choices as to whether we share your personal information with third parties for their own marketing purposes. We may share aggregated Non-Identifying Information and we may otherwise disclose Non-Identifying Information (including, without limitation, Hashed Information) to third parties. We do not share your Personal Information with third parties for those third parties’ marketing purposes unless we first provide you with the opportunity to opt-in to or opt-out of such sharing. We may also share the information we have collected about you, including Personal Information, as disclosed at the time you provide your information, with your consent, as otherwise described in this Privacy Policy, or in the following circumstances: Service Providers: We may employ third party companies and individuals to facilitate our Service, to provide the Service on our behalf, to perform Service-related services (e.g., without limitation, maintenance services, database management, web analytics and online advertising, payment processing, fraud detection and improvement of 32links features) or to assist us in analyzing how our Service is used. These third parties may have access to your Personal Information in order to perform these tasks on our behalf. What Happens If You Agree to Receive Information from Third Parties or Request that We Share Your Information: You may be presented with an opportunity to receive information and/or marketing offers from one or more third parties. If you agree at that time to have your Personal Information shared, your Personal Information will be disclosed to that third party (or parties) and will be subject to the privacy policy and practices of that third party. We are not responsible for the privacy policies and practices of third parties, and, if you later decide that you no longer want to receive communications from a third party, you will need to contact that third party directly. Legal and Investigative Purposes: 32links will share information with government agencies as required by law in response to lawful requests by public authorities, including to meet national security or law enforcement requirements and, including without limitation, in connection with reporting earnings. We cooperate with government and law enforcement officials and private parties to enforce and comply with the law. We will disclose information about you to government or law enforcement officials or private parties as we, in our sole discretion, believe necessary or appropriate to respond to claims and legal process (including but not limited to subpoenas), or, at the request of governmental authorities or other third parties conducting an investigation where we determine in our sole discretion the disclosure is necessary to (a) protect the property and rights of 32links or a third party, (b) protect the safety of the public or any person, or (c) prevent or stop activity we may consider to be, or pose a risk of being, illegal, fraudulent, unethical or legally actionable activity. Internal and Business Transfers: 32links may share information, including Personal Information, with its parent company Sellers Review sp. z o.o. and any current or future subsidiaries or affiliates, primarily for business and operational purposes, including activities such as IT management, for them to provide services to you, or support and supplement the Services we provide. We may sell, transfer, or otherwise share some or all of our assets, including your Personal Information, in connection with a merger, acquisition, reorganization or sale of assets (including, in each case, as part of the due-diligence process with any potential acquiring entity) or in the event of bankruptcy. Sweepstakes, Contests, and Promotions: We may offer sweepstakes, contests, and other promotions (any, a “Promotion”) that may require registration. 5. YOUR CHOICES AND RIGHTS You may have certain choices and rights associated with your personal information. You may request Sellers Review sp. z o.o. to honor these rights by contacting us, or submitting a request . a. For Individuals Located in the European Economic Area (EEA), United Kingdom (UK) or Switzerland: You have a number of rights under applicable data protection laws in relation to your personal information. Under certain circumstances, you have the right to: Have access to your personal information by submitting a request to us; Have your personal information deleted; Have your personal information corrected if it is wrong; Have the processing of your personal information restricted; Object to further processing of your personal information, including to object to marketing from us; Make a data portability request; Withdraw any consent you have provided to us; Restrict any automatic processing of your personal information; and Complain to the appropriate Supervisory Authority. To exercise any of these rights, please contact us at: info@32links.com b. Notification for users from other countries You may have certain choices and rights related to your personal information that are consistent with the rights and laws of your country and location. c. Appeals Process & Other Concerns If we deny your request in whole or in part, you may have the right to appeal the decision. In such circumstances, we will provide you with information regarding the appeals process. Depending on your location, you may also email legal@32links.com to appeal. 6. SECURITY We take a number of steps to protect your data, but no security is guaranteed. Sellers Review sp. z o.o. takes reasonable steps to help protect and secure the information it collects and stores about Sellers Review sp. z o.o. Users. We maintain reasonable administrative, technical, and physical safeguards designed to protect personal information that we receive against accidental, unlawful, or unauthorized destruction, loss, alteration, access, disclosure or use. 7. CROSS-BORDER DATA TRANSFERS Because we are a Polish company, we process and store your information in Poland and our service providers may process and store it elsewhere. 32links may transfer your personal information to a third party that is located in a jurisdiction other than the one from which we collected your personal information, including to countries that have not been deemed to have an adequate level of protection for the rights and freedoms of data subjects. If we do transfer your personal information to another jurisdiction, we will do so following due diligence and provided that the data recipient is subject to contractual agreements imposing obligations on it to ensure appropriate technical and organizational are implemented and maintained at all times to prevent the unauthorized and unlawful processing of personal information, and the accidental loss or destruction of, or damage to, personal information, consistent with our obligations under applicable data protection laws. 8. LINKS TO OTHER SITES Our Service contains links to other websites. If you choose to click on a third-party link, you will be directed to that third party’s website. The fact that we link to a website is not an endorsement, authorization or representation of our affiliation with that third party, nor is it an endorsement of their privacy or information security policies or practices. We do not exercise control over third party websites. These other websites may place their own cookies or other files on your computer, collect data or solicit Personal Information from you. We encourage you to read the privacy policies or statements of the other websites you visit. 9. CHANGES TO THIS POLICY We may change this Privacy Policy. If we make substantial changes, we will provide notice. This Privacy Policy is effective as of the date stated at the top of this page. 32links may update this Privacy Policy at any time and any changes will be effective upon posting. By accessing or using the Service after we notify you of such changes to this Privacy Policy, you are deemed to have accepted such changes. Please refer back to this Privacy Policy on a regular basis. 10. CONTACT US If you have any questions about this Privacy Policy, please contact us at legal@32links.com, or by mail addressed to Sellers Review sp. z o.o. Ul. Erazma Ciołka, 12, Warszawa, 01-402, Warszawa, Polska. You may also contact us by phone at +48459569381.