Myn Privacy Policy

1. Introduction

This Privacy Policy ("Policy") governs the processing of personal data by Work Perks Group Limited (trading as Myn) and its subsidiaries ("we" or "Myn") through its website www.myn.co.uk, its mobile application (the "App"), and their respective sub-pages (collectively, the "Website").

2. Information to Data Subjects (Articles 13 and 14)

Myn is committed to providing clear and transparent information about its personal data processing practices in accordance with Articles 13 and 14 of the General Data Protection Regulation (GDPR). This information will be provided:

• At the point of data collection: When personal data is collected directly from you, we will provide a concise and easily accessible notice explaining the purposes for processing, legal basis, data retention periods, categories of recipients (if applicable), and your data subject rights (access, rectification, erasure, etc.) and how to exercise them.
• Through this Policy: This comprehensive Policy further details our data handling practices for all personal data collected through the Website.

3. Categories of Personal Data Collected and Processed

We collect and process the following categories of personal data:

• Website Usage Data: Technical information automatically collected during website visits, including date, time, duration, IP address, referring URL, visited subpages, and device details (browser type, operating system). This data is pseudonymous and cannot directly identify individuals.
• Personal Information for App Users: Information requested from App users to facilitate career opportunities and service provision, including:
  • Basic Information: Full name, email address, phone number.
  • Professional Information: Resume, work history, education, skills, certifications, employment authorizations.
  • Optional Information: Date of birth, social security number (where legally permissible), professional references, portfolio platforms (with your permission).
  • Financial Information: Bank account details, salary slips (where necessary for specific services).
  • Application and Interview Data: Applications, search queries, interview recordings (with your consent), feedback from former employers.
• Collected:
  • Full Name
  • E-mail address
  • Telephone number
  • Date of birth
  • Address
  • National Insurance Number
  • Job references
  • Educational Certification
  • Calendar Information, e.g. Availability, Interview Booking, Engagements
  • Interview Data, including Media
  • Bank account details
  • Payroll information
  • Applications & Search Preferences
  • Work Contracts Documentation
  • Other compliance related documentation (e.g., license, right to work);
  • Ratings & Feedback from past Employers

4. Data Sources

To build comprehensive user profiles and enhance service quality, we may combine data from the Website with information obtained from other sources with your consent or as permitted by law, such as:

• Job boards where you have indicated your availability for opportunities.
• References from past employers, with your prior authorization.
• Social media platforms and portfolio platforms, where you have granted access.

5. GDPR - Lawfulness Of Processing

https://gdpr-info.eu/art-6-gdpr/

Personal data is processed for the purpose of operating the platform, as outlined in the Terms of Use, with specified data points deemed vital for operation.

5.1 Purposes of Personal Data Processing

We process personal data for the following purposes:

• Operating the Platform: Providing and maintaining the Website and App functionalities, including user account management, matching job opportunities, and facilitating communication between users.
• Personalisation and Recommendation: Tailoring the user experience by recommending relevant job openings based on your skills and interests.
• Automated Decision-Making: Myn's algorithm generates rankings for suitable applicants based on your profile information, past interactions with Myn, and feedback from former employers. This automated process assists with efficient service delivery and highlighting relevant opportunities. However, final hiring decisions are always made by employers based on their own policies, and you have the right to object to automated processing at any time.
  • We don't use exclusively automated processing to make decisions with significant impact on users without human oversight.
  • Myn's algorithm auto-generates rankings for suitable Applicants per job offer based on:
    • Database information
    • Applicant's past interactions with Myn
    • Feedback from former employers
  • The goal is to enhance user experience by showcasing relevant job offers.
  • Top-ranked Applicants are notified by Myn for potential job matches.
  • Final hiring decisions are made by employers based on their policies.
  • Disagreements should be addressed directly with them.
  • This automated data processing is vital to deliver Myn's services as per our agreement.
  • If you, as a Candidate, oppose this automated data handling, you can't use Myn's services or join its platform.
• Compliance with Legal Obligations: Fulfilling legal requirements, such as tax and labor regulations, and cooperating with law enforcement agencies if necessary.

6. Legal Bases for Processing

We process your personal data based on the following legal grounds:

• Consent: For certain data categories (e.g., social media access, interview recordings), we rely on your freely given consent. You can withdraw your consent at any time.
• Contractual Necessity: To fulfill our contractual obligations to you, such as providing access to the App and matching job opportunities.
• Legitimate Interests: We process data for our legitimate interests, such as improving the Website and App, providing relevant recommendations, and preventing fraud. However, we will always balance your interests and rights with our legitimate interests.

7. Accuracy and Veracity of the Data Provided

• Users undertake to provide personal data which is true and accurate, as well as to notify Myn of any modifications or updates of this data.
• Users are solely responsible for the truthfulness of their personal data.
• Failure to communicate or the incomplete communication of the personal data that is required to formalize the hiring of the Service will imply the impossibility of providing this Service and, thus, when applicable, the termination of the contract.

7.1 Recipients of Personal Data

Myn may allow access to personal data by third parties acting as Processors for service provision. These Processors will follow Myn's instructions and comply with data protection regulations. Subcontracted entities may include:

• Technology service providers
• Payslips service providers
• IT and security service providers
• Marketing-related service providers
• HR service providers
• Business Processing Outsourcing (BPO) providers

8. Transfers of Personal Data

In exceptional cases and with legal basis, Myn may transfer personal data to third parties, including financial and criminal authorities, social security institutions, courts, potential employers, group companies, and independent controllers.

Independent Controllers:

Work Perks 4U Limited (Co. no. 11112634);

Knownetwork Limited (Co. no. 11111234);

Networker Global Limited (Co. no. 11111493);

Advance Wages Ltd (Co. no. 11705946)

8.1 Data Processing outside the EEA

Personal data is not transferred outside the EEA without appropriate security measures, ensuring an adequate level of data protection.

9. Data Retention Periods

We retain your personal data for no longer than necessary for the purposes for which it was collected and processed. The specific retention period will vary depending on the type of data and the purpose for processing. For example, we may retain user account information for a longer period to comply with legal obligations or to resolve potential disputes.

10. Security Measures

Technical and organisational security measures are implemented to protect personal information from unauthorized modification, loss, processing, or access.

11. Data Protection Impact Assessment (DPIA)

Myn acknowledges the importance of conducting Data Protection Impact Assessments (DPIAs) in accordance with Article 35 of the UK GDPR. DPIAs will be carried out when processing operations, particularly the use of new technologies, are likely to result in a high risk to the rights and freedoms of individuals.

12. Consultation with the Information Commissioner

In situations where a DPIA indicates that processing would result in a high risk if mitigating measures are not applied, Myn commits to consulting with the Information Commissioner's Office (ICO) as per the requirements of Article 36 of the UK GDPR.

Such consultations will include providing the ICO with relevant information on the processing activities, the measures proposed to address risks, and any other information requested by the ICO.

13. Exercise of Rights

The User may exercise the following rights regarding data protection before Myn:

• Right of access by the data subject (Art. 15 GDPR) - Check which personal data Myn processes.
• Right to rectification (Art. 16 GDPR) - Modify personal data processed by Myn when they are inaccurate.
• Right to erasure (Art. 17 GDPR) - Request that Myn removes your personal data.
• Right to restriction of processing (Art. 18 GDPR) - Request that Myn limits the processing of your personal data.
• Right to data portability (Art. 20 GDPR) - Request that Myn provides you with information about yourself in a computer format.
• Right to object (Art. 21 GDPR) - Request that Myn does not process your personal data for some specific purposes.
• Right to lodge a complaint with a supervisory authority (Art. 77 GDPR) - If you consider that the processing of your personal data infringes the GDPR, you may lodge a complaint, in particular in the Member State of your habitual residence, place of work or place of the alleged infringement. You may also lodge a complaint with your local supervisory authority.

Furthermore, the Users may also revoke a given consent at any time. However, this revocation is only valid from that moment onwards. Any processing that may have taken place before the revocation remains unaffected.

If the Users wish to exercise their rights as data subjects, they may do so through the platform settings or by editing their Applicant profile. Alternatively, you may also contact the DPO of Myn at privacy@myn.co.uk from the email address associated with the account on which you wish to exercise your rights. In case of sending a request by email, it shall include a copy of your ID or any other equivalent identity document, as well as the minimum content stipulated in the applicable regulations.

If the request does not meet all the specified requirements, Myn may ask for it to be corrected. No consideration for the exercise of any rights will be required. The exercise of rights will be granted unless there is a legal or contractual obligation to retain them.

13.1 Information about Your Right of Objection under Art. 21 GDPR

With regards to the aforementioned right to object to the processing of your personal data at any time for reasons arising from your particular situation; provided that such processing is carried out on the basis of Art. 6 (1) lit. f) GDPR (data processing based on a balancing of interests), if you object, we will no longer process your personal data unless we can demonstrate circumstances that outweigh your interests, rights, and freedoms and therefore justify the processing.

You also have the right to object, at any time and free of charge and without giving any reason, to the processing of your personal data for the purpose of direct marketing, including the creation of a user profile (so-called "profiling"), insofar as it is for the purpose of direct marketing.

Please note that you may not be able to use the services, or only to a limited extent, if you object to the processing of this data. You can submit your objection informally by email to our customer service: privacy@myn.co.uk.