Our privacy policy

Protecting your data and information

We ask that you read this privacy notice carefully as it contains important information on who we are, how and why we collect, store, use and share personal information, your rights in relation to your personal information and on how to contact us and supervisory authorities in the event you have a complaint.

Summary:

We use your data to provide our services to you (if you are a client) or receive services from you (if you are a virtual assistant freelancer, to improve our service or our dealings with freelancers, and to meet and enforce our legal obligations).

We delete your data when it is no longer needed for these things. Generally, we do not give your information to third parties, but there are some exceptions where we use external service providers to power our operations – some of these are outside Europe.

We are happy to answer your questions about any of this – email us at gdpr@timeetc.com.

Who we are

Time etc USA Limited (trading as 'Time Etc') collects, uses and is responsible for certain personal information about you. When we do so we are regulated under the General Data Protection Regulation which applies across the European Union (including in the United Kingdom) and we are responsible as 'controller' of that personal information for the purposes of those laws.

This Privacy Notice is directed to you if you are a virtual assistant freelancer providing services to Time Etc, or a client using the Time Etc service.

The personal information we collect and use

Information collected by us – if you are (or apply to be) a virtual assistant freelancer

We collect the following personal information when you provide it to us. References to the basis of processing (e.g. "Basis: Legitimate Interest") are a reference to the article of the General Data

Protection Regulation under which we undertake the processing in question. More information is provided on the different bases for processing here.

- Information you provide when you apply to register as a freelancer, or enquire about registering. We use this to facilitate your providing services to us, including listing a profile for viewing by clients, verifying your identity and your eligibility to provide services to us, selecting which briefs might be suitable for you, communicating those briefs to you, paying you, and communicating with you in relation to your providing services to us. We also use it to combine it with other freelancers' data in order to carry out statistical research and improve the way we run our service, including improving the way we match freelancers to briefs. Basis: Performance of Contract; Legitimate Interest.

- Further information you provide to us in 'on-boarding' emails and phone calls with you following your having submitted your profile information. We use this in the same way - to facilitate your providing us with your services and for statistical purposes. Basis: Performance of Contract; Legitimate Interest.

- Communications you send and receive in the course of processing briefs. We use this to provide our service to our clients. Basis: Legitimate Interest; Performance of Contract.

-Your preferences as to whether we contact you with briefs, or promotional with information about Time Etc. We use this to make sure we don't send you anything you have asked not to receive. Legal basis: Consent; Legitimate Interest

- Any feedback you give us regarding your experience with Time Etc. We use this to help us improve the service. Basis: Legitimate Interest.

We also receive feedback from clients on their experience in working with you. We use that to help us decide how we use your services, and which briefs you might be suited for and not suited for. Basis: Performance of Contract; Legitimate Interest.

- We will use your information in the event that we need to enforce our freelancer terms of service. Basis: Legitimate Interest.

We may also need to process your data for compliance with a legal obligation to which we are subject.

Information collected by us – if you are a client of Time Etc

We collect the following personal information when you provide it to us. References to the basis of processing (e.g. "Basis: Legitimate Interest") are a reference to the article of the General Data

Protection Regulation under which we undertake the processing in question. More information is provided on the different bases for processing here.

- Information you provide when signing up for our service, or enquire about registering for our service. We use this to help us provide you with the service, including to receive details of briefs from you, to allocate briefs to one of the network of freelance virtual assistants we work with, communicating with you in relation to our providing services to you, and to receive payment from you. We also use it to provide you with more information about the Time Etc service. We also use it to combine it with other clients' data in order to carry out statistical research and improve the way we run our service, including improving the way we match freelancers to briefs. Basis: Performance of Contract; Legitimate Interest.

- Further information you provide to us in 'on-boarding' emails and phone calls with you following your having submitted your information. We use this for the same purposes as above. Basis: Performance of Contract; Legitimate Interest.

- Instructions you provide to us as the nature of a brief you ask us to have carried out by a freelancer virtual assistant. We use this to match you and put you in contact with a freelancer. Basis: Performance of Contract.

- Communications you send and receive in the course of liaising with freelance virtual assistant in the course of their processing your briefs. We use this to provide our service to you. Basis: Legitimate interests; Performance of contract.

- Any payment data you provide to us which may contain personal data (for example, on a payment card). We use this for the purposes of arranging payment for the service. Basis: Performance of Contract.

- Your preferences as to whether we contact you with briefs, or promotional with information about Time Etc. We use this to make sure we don't send you anything you have asked not to receive. Legal basis: Consent; Legitimate Interest

- Any feedback you give us regarding the Time Etc service. We use this to help us improve the service. Basis: Legitimate Interest.

We also receive feedback from one or more freelance virtual assistants on their experience in working with you. We use this to help us decide how we match freelancers to your briefs, and which briefs you might be suited for and not suited for. We will also use it in the event that we need to enforce our terms of service. Basis: Performance of Contract; Legitimate Interest.

Additionally, we will also use your information in the event that we need to enforce our client terms of service. Basis: Legitimate Interest.

We may also need to process your data for compliance with a legal obligation to which we are subject.

Information collected by us – if you sign up for our newsletter

We collect your name and email address when you sign up to receive our newsletter. We use this to send you the newsletter. Basis: consent.

Information collected from other sources

We also obtain personal information from other sources as follows:

- If you apply to be a freelancer, where you provide a link to your LinkedIn profile, website, social media account or other place which contains information about you, we will obtain information from that source. Basis: Legitimate Interest.

- If you are a client or wish to be a client, where you provide a link to your LinkedIn profile, website, social media account or other place which contains information about you, we will obtain information from that source. Basis: Legitimate Interest.

- We use cookies to track activity our websites. For more details, please see our Cookies Policy. Basis: Consent; legitimate interest.

- If you apply to be a freelancer, as part of our onboarding process we run checks to see if you have a criminal record. Basis: Consent; legitimate interest.

- We obtain feedback from freelancers about clients, and vice versa. We use this to improve how we match freelancers and clients, and to improve our service. Basis: legitimate interest.

Who we share your personal information with

We routinely share your personal information with a range of third party service providers who help us provide, analyse and promote the Time Etc services and engage with freelancers. For a list of our third party providers, please see this page. Some of those third party recipients may be based outside the European Economic Area — for further information including on how we safeguard your personal data when this occurs, see 'Transfer of your information out of the EEA'.

If you are a freelancer, we will share information (including your name, email address, profile data, ratings, and the skills you have notified to us) with a client in respect of whose brief we have asked you to provide us with your services.

If you are a client, we will share relevant information about you from your Time etc client account (including your name, email address, profile, biography) and the nature of your brief with a freelancer we think is suitable for your brief.

We will share personal information with law enforcement or other authorities if required by applicable law.

We will not share your personal information with any other third party.

Whether information has to be provided by you, and if so why

The provision of all the information we obtain from you is necessary in order for us to provide you with the service (if you are a client) or for you to provide services to us (if you are a freelancer). Without it, we'd be unable to maintain a Time Etc account about you, and without that we can't do business with you.

How long your personal information will be kept

- Data about clients: we will keep this for the duration of your relationship with us, then 5 years.

- Data about freelancer virtual assistants: we will keep this for the duration of your relationship with us, then 5 years.

- Data about applicant freelancers who do not become freelancers: 2 years

- Messages sent using our Time Etc messaging service: 5 years

- Name and email addresses for those who send us an enquiry (but are neither a client nor a freelancer): we will keep this for 2 years following your last interaction with us.

- Name and email addresses for those who sign up to our newsletter (but are neither a client nor a freelancer): we will keep this for 2 years following your last interaction with us.

- Cookie data: Cookies are deleted after a maximum of 365 days.

Transfer of your information out of the EEA

We may transfer your personal information to the following third party service providers, which are located outside the European Economic Area (EEA). We do this to help us provide and promote the Time Etc service and to help us engage with freelancer virtual assistants:

Google, USA - for the purposes of analytics and documents. Basis: EU-US Privacy Shield certification,.

Amazon Web Services, USA - for the purposes of hosting and file storage. Basis: EU-US Privacy Shield certification.

Freshdesk, USA - for the purposes of providing you with a help desk facility to contact us. Basis: EU-US Privacy Shield certification.

Microsoft, USA - the the purpose of email. Basis: EU-US Privacy Shield certification.

Inspectlet, USA - for the purpose of user experience monitoring. Basis: Model clauses in contract.

Stripe, USA - for the purpose of payment processing. Basis: EU-US Privacy Shield certification.

Paypal, USA - for the purpose of payment processing. Basis: EU-US Privacy Shield certification.

Slack, USA - for the purpose of internal team communication. Basis: EU-US Privacy Shield certification.

Sentry, USA - for the purpose of bug tracking. Basis: EU-US Privacy Shield certification.

Typeform, USA - for the purpose of recording your responses to questions. Basis: Model clauses in contract.

Such countries do not have the same data protection laws as the United Kingdom and EEA. Whilst the European Commission has not given a formal decision that those countries provide an adequate level of data protection similar to those which apply in the United Kingdom and EEA, any transfer of your personal information will be subject to appropriate safeguards as permitted under the General Data

Protection Regulation that are designed to help safeguard your privacy rights and give you remedies in the unlikely event of a misuse of your personal information. To obtain a copy of the relevant safeguards please contact us at gdpr@timeetc.com

We will not otherwise transfer your personal data outside of the United Kingdom or EEA.

Your rights

Under the General Data Protection Regulation you have a number of important rights free of charge. In summary, those include rights to:

- access to your personal information and to certain other supplementary information that this Privacy Notice is already designed to address

- require us to correct any mistakes in your information which we hold

- require the erasure of personal information concerning you in certain situations

- receive the personal information concerning you which you have provided to us, in a structured, commonly used and machine-readable format and have the right to transmit those data to a third party in certain situations

- object at any time to processing of personal information concerning you for direct marketing

- object to decisions being taken by automated means which produce legal effects concerning you or similarly significantly affect you

- object in certain other situations to our continued processing of your personal information

- otherwise restrict our processing of your personal information in certain circumstances

For further information on each of those rights, including the circumstances in which they apply, see the Guidance from the UK Information Commissioner's Office (ICO) on individuals rights under the

General Data Protection Regulation.

If you would like to exercise any of those rights, please:

- email us at gdpr@timeetc.com

- let us have enough information to identify you,

- let us have proof of your identity and address (a copy of your driving licence or passport and a recent utility or credit card bill), and

- let us know the information to which your request relates, including any account or reference numbers, if you have them.

If you would like to unsubscribe from any email newsletter you can also click on the 'unsubscribe' button at the bottom of the email.

Keeping your personal information secure

We have appropriate security measures in place to prevent personal information from being accidentally lost, or used or accessed in an unauthorised way. We limit access to your personal information to those who have a genuine business need to know it. Those processing your information will do so only in an authorised manner and are subject to a duty of confidentiality.

We also have procedures in place to deal with any suspected data security breach. We will notify you and any applicable regulator of a suspected data security breach where we are legally required to do so.

If you want detailed information from Get Safe Online on how to protect your information and your computers and devices against fraud, identity theft, viruses and many other online problems, please visit www.getsafeonline.org. Get Safe Online is supported by HM Government and leading businesses.

How to complain

We hope that we can resolve any query or concern you raise about our use of your information.

The General Data Protection Regulation also gives you the right to lodge a complaint with a supervisory authority, in particular in the European Union (or European Economic Area) state where you work, normally live or where any alleged infringement of data protection laws occurred. The supervisory authority in the UK is the Information Commissioner who may be contacted at https://ico.org.uk/concerns/ or telephone: 0303 123 1113.

Changes to this privacy notice

This privacy notice was published on Friday 8th May 2018 and last updated on Friday 8th May 2018.

We may change this privacy notice from time to time, when we do in any way that affects you significantly we will inform you.

How to contact us

Please contact us if you have any questions about this privacy notice or the information we hold about you.

If you wish to contact us please send an email to gdpr@timeetc.com, or write to us at Lyndon House, 58-62 Hagley Road, Birmingham, B16 8PE, UK.

Legal Bases for Processing

In the section of this notice which sets out what data we collect and how we use it, we refer to different legal bases for processing. Further details on each of those are set out here.

Legitimate Interest means the interest of our business in conducting and managing our business to enable us to give you the best service and the best and most secure experience. We make sure we consider and balance any potential impact on you (both positive and negative) and your rights before we process your personal data for our legitimate interests. We do not use your personal data for activities where our interests are overridden by the impact on you (unless we have your consent or are otherwise required or permitted to by law). You can obtain further information about how we assess our legitimate interests against any potential impact on you in respect of specific activities by contacting us.

Performance of Contract means processing your data where it is necessary for the performance of a contract between us and you or to take steps at your request before entering into such a contract. Comply with a legal or regulatory obligation means processing your personal data where it is necessary for compliance with a legal or regulatory obligation that we are subject to.