Publication date: April 24, 2022

This Privacy Policy together with our Terms of use applicable to you and any additional provisions that may be incorporated by reference into the terms apply to your use of our Platform “Kwikwins” accessible from https://kwikwins.io/ (“Website”) and any of the services accessible through the Website (collectively referred to as “Kwikwins”).

This Privacy Policy sets out the basis which we apply to process any Personal Data we collect from you, or that you provide to us. Please read this Policy carefully to understand our practices regarding your Personal Data and how we will process it. One of our main priorities is the privacy of our users.
IF YOU DO NOT AGREE WITH THIS PRIVACY POLICY IN GENERAL OR WITH ANY PART OF IT, YOU SHOULD NOT USE OUR WEBSITE.

If you have additional questions or require more information about our Privacy Policy, do not hesitate to contact us. This Privacy Policy applies only to our online activities and is valid for visitors to our Website with regards to the information that they share on Kwikwins and/or Kwikwins collects. This Policy is not applicable to any information collected offline or via channels other than this Website.

IMPORTANT DATA AND WHO WE ARE
1. General information
1.1 Kwikwins Ltd is the data controller and is responsible for your Personal Data (collectively referred to as “Company”, “we”, “us” or “our”). Our full details are:
Full name of legal entity: Kwikwins Ltd
Postal address: 71-75 Shelton Street, Covent Garden, London, the United Kingdom of Great Britain and Northern Ireland, WC2H 9JQ
Email address

Information we collect
2. Registration and verification
2.1 When you register to use Kwikwins by establishing an account, we will collect following personally identifiable information (“Personal Data”):
− full name (patronymic name if applicable);
− alias, username;
− your employer's name;
− password;
− phone number;
− email;
− area of your expertise;
− degree certificate or diploma;
− copies of government-issued identification;
− profile picture;
− financial information (account name, banking information, including bank account and payment card details, billing details);
− tax ID or VAT number;
− IP address, geolocation, browser type/version, and operating system.
2.2 Depending on your goals, you may add more information about yourself, for example, professional information, information on your education, etc. We may also retain any messages you send through the Kwikwins, customer service correspondence, and may collect information you provide in any content you post at Kwikwins.
2.3 In order to keep your Personal Data accurate and complete, you can log in to review and update your account information, including contact and billing information, via your account settings page.
2.4 We collect Personal Data for the following purposes:
− authenticate your access to an account;
− respond to your requests, for example to contact you about a question you submitted to our customer service team;
− provide the functionality of Kwikwins, including, but not limited to, connecting the Clients and the Kwikers, posting information regarding the Bundle, Project and administering your account. We collect information about the Kwiker's work/services on the Project for the Client and can transfer it to the Client;
− to inform you about changes in your services, our service offering and other important service-related notices;
− protect our rights and interests as well as the rights and interests of our users and any other person;
− сarry out any actions for which we have received your consent;
− perform research and analysis about your use of, or interest in, our products, services, or content, or products, services or content offered by others;
− to comply with applicable legal or regulatory obligations, including complying with requests from law enforcement or other governmental authorities, or in legal proceedings involving Kwikwins;
− fulfill our contractual obligations;
− communicate with you, either directly or through one of our partners, including for customer service, to provide you with updates and other information relating to the Website, and for marketing and promotional purposes;
− initiate a payment, add value to an account, or pay a bill;
− prevent and investigate fraudulent or other criminal activity.
2.5 We may take steps to verify your identity. Before a Kwiker can complete registration at Kwikwins, or at any time thereafter, we may request or re-request identity verification. Without limiting the manner in which we request identify verification, we may require the Kwiker to provide the scan copies of his/her document on academic degree and qualification and to participate in a video call after submitting their government issued ID to enable us to confirm that the Kwiker is indeed the individual in the ID. We may record such video calls and take screenshots of the user during the call for verification purposes. The Company may use the information obtained from identity verification for purposes of verifying your identity, enforcing our Terms of use and other agreements, and preventing fraud.

3. When you use Kwikwins
3.1 When you use Kwikwins, we will collect following Personal Data:
− records of products or services purchased;
− information associated with the transaction such as amount sent or requested;
− financial identifier (i.e., account name, banking information, including bank account and payment card details).
3.2 We may require you to provide us with additional Personal Data as you use Kwikwins and the Website.
3.3 We will process your Personal Data legally and fairly and not use it outside the purposes of which we have informed you, including selling it individually or in the aggregate for commercial use.
3.4 We retain Personal Data in an identifiable format for the least amount of time necessary to fulfil our legal or regulatory obligations and for our business purposes. We may retain Personal Data for longer periods than required by law if it is in our legitimate business interests and is not directly prohibited by the applicable law. If your account is deleted, we may take steps to mask Personal Data and other Data, but we reserve our right to retain and access the data for so long as required to comply with applicable laws. We will continue to use and disclose such Personal Data in accordance with this Policy.
3.5 We also collect, use and share aggregated data such as statistical or demographic data for any purpose (“Aggregated Data”). Aggregated Data could be derived from your Personal Data but is not considered personal data in law as this data will not directly or indirectly reveal your identity. For example, we may aggregate your usage data to calculate the percentage of users accessing a specific software feature. However, if we combine or connect Aggregated Data with your Personal Data so that it can directly or indirectly identify you, we treat the combined data as Personal Data which will be used in accordance with this Policy.
3.6 We do not collect any special categories of Personal Data about you (this includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, data about your health data).

4. How we acquire your data
4.1 Information may come from:
− directly from you (from our communication and/or forms that you filled in);
− from cookies stored in your browser by our Website;
− IP-address;
− from other sources including third parties and publicly available sources.
4.2 We may combine that with information we collect through our services.

5. Consent
5.1 BY SUBMITTING INFORMATION, INCLUDING PERSONAL DATA, YOU ARE EXPRESSLY AND VOLUNTARILY ACCEPTING THE TERMS AND CONDITIONS OF THIS PRIVACY POLICY. YOU HAVE THE RIGHT TO WITHDRAW YOUR CONSENT TO KWIKWINS’S COLLECTION AND USE OF YOUR INFORMATION BY CHANGING YOUR ACCOUNT SETTINGS OR CLOSING YOUR ACCOUNT, BUT YOUR WITHDRAWAL OF CONSENT WILL NOT BE RETROACTIVE.
5.2 You should also be aware that we do not sell, rent your Personal Data or disclose it in exchange for money or other valuable consideration to any third parties and we shall not incorporate such practice in our business, unless providing you with a clear and explicit way to exercise your opt-out right and before introducing appropriate changes to this Policy.
5.3 You consent to transfer your Personal Data to third parties as described in this Privacy Policy, including to carry out your instructions or to provide our services, unless otherwise compelled by law or as necessary to enforce our Terms of Use or to protect the rights or property of the Company or its users or the public. We may provide Aggregated Data about the usage of Kwikwins to third parties for purposes that we deem, in our sole discretion, to be appropriate.
5.4 You consent to the transfer of your Personal Data to Clients or Kwikers from the chosen Bundle for the purpose of concluding a contract between the Client and the Kwikers.
5.5 We will display the Personal Data you select in your profile page and elsewhere on Kwikwins according to the preferences you select in your account settings. This Personal Data will be made available for public viewing to other users.

6. Marketing mailings
6.1 If you provide us with your email address and agree to this Privacy Policy, we and our partners may send you emails regarding the products we offer. You can choose to opt out of receiving email from us at any time. If you wish to opt out with respect to more than one email address, you must provide a separate request for each email address. Every email sent from us will include appropriate unsubscribe instructions. To opt out of all email marketing messages from us, you should follow the instructions provided with each email.
6.2 If you provide us with your telephone number and agree to this Privacy Policy, we and our partners may send you texts regarding or the products we offer. You can choose to opt out of receiving texts from us at any time by emailing us.

TRANSFERRING YOUR DATA
7. Disclosures of your personal data
7.1 To verify your account, we may disclose your Personal Data to third parties such as financial institutions, third party reference agencies and data verification service providers to comply with our legal obligations due to legal, security, and safety purposes. Personal data may be made available to certain types of responsible parties involved in Kwikwins (administration, sales, marketing, legal matters, system administration) or to external parties (e.g., third-party technical service providers, mail carriers, hosting providers, IT-companies, communications agencies).
A list of such parties may be requested from the Company at any time.

7.2 As our business develops, we may sell or buy businesses or assets. In the event of a corporate sale, merger, reorganization, dissolution or similar event, Personal Data may be part of the transferred assets.
7.3 We require our service providers to agree to take reasonable steps to keep the Personal Data that we provide to them secure. We do not authorize them to use or disclose your Personal Data except in connection with providing their services.

8. Third-Party Privacy Policies
8.1 Our Website may contain links to third-party websites and applications. Subject to your opt-out preferences, we may also use third-party advertisers, ad networks, and other advertising, marketing, and promotional companies, to serve advertisements on our Website.
8.2 The Company's Privacy Policy does not apply to other advertisers or websites. We do not endorse these parties, their content, or any products and services they offer, and we are not responsible for the information practices of such third-party websites or applications. Thus, we are advising you to consult the respective Privacy Policies of these third-party ad servers for more detailed information. It may include their practices and instructions about how to opt-out of certain options.
8.3 You can choose to disable cookies through your individual browser options. To know more detailed information about cookie management with specific web browsers, it can be found at the browsers' respective websites.

9. International transfers
We operate all over the world, and therefore we may transfer your data to our counterparties (partners, affiliates etc.) in different countries, including those which are located outside the European Economic Area (EEA). We do all our efforts, including those imposed on us by applicable law, to ensure an adequate level of personal data protection in each case, HOWEVER, we would like you to consider that the countries to which we transfer your data may not have the same data protection laws as your jurisdiction.
To facilitate our global operations, the Company may transfer, store and process your operations with our partners and service providers based outside of the country in which you are based. Laws in those countries may differ from the laws applicable to your country of residence. Where we transfer, store and process your Personal Information outside of the EEA or the UK we will ensure that the appropriate safeguards are in place to ensure an adequate level of protection such as through acceding to the Standard Contractual Clauses. Further details regarding the relevant safeguards can be obtained from us on request.
Therefore, by using the Platform or submitting personal information for any of the above purposes, you acknowledge that your personal information may be transferred or may be stored in the United States of America or other countries outside of the EEA, and the United Kingdom. Such countries may have data protection rules that differ from or are less stringent than those of your country.

YOUR LEGAL RIGHTS
10. General rights
10.1 In accordance with applicable law, you may have the right to:
− Access Personal Data about you;
− Request correction of your Personal Data where it is inaccurate, incomplete or outdated;
− Request deletion, anonymization or blocking of your Personal Data;
− Request restriction of or object to our processing of your Personal Data;
− Withdraw your consent to our processing of your Personal Data; 
− Request data portability and receive an electronic copy of Personal Data that you have provided to us;
− Be informed about third parties with which your Personal Data has been shared;
− Request the review of decisions taken exclusively based on automated processing if that could affect data subject rights.

11. Children's Information
11.1 Another part of our priority is adding protection for children while using the Internet. We encourage parents and guardians to observe, participate in, and/or monitor and guide their online activity.
11.2 The Website and Kwikwins are not directed to children under the age of majority, as defined by applicable law in your country of residence.
11.3 Kwikwins is not directed to children under thirteen (13) years of age and we do not knowingly collect Personal Data from children under the age of thirteen (13). If we discover that a child under thirteen (13) has provided us with Personal Data, we will promptly delete such Personal Data from our systems.

COOKIES
12. Cookies and Web Beacons
12.1 Like any other website, the Website uses “cookies”. Cookies are small text files accepted and processed by device that you use to access our Website. They are used to store information including visitors' preferences, and the pages on the Website that the visitor accessed or visited. The information is used to optimize the users' experience by customizing our web page content based on visitors' browser type and/or other information.
12.2 For more general information on cookies, please read "What Are Cookies".
12.3 The following types of cookies are used on the Sites:
− strictly necessary cookies / technical cookies: these cookies are required to run the Website and provide you with the services and may, among other, allow us to identify your hardware and software, including your browser type;
− statistical / analytic cookies: these cookies enable us to recognise users, count the number of users and collect information such as your actions on the Website, including the web pages you visit and the content you retrieve;
− performance cookies: these cookies collect information about how users interact on the Website, enabling us to identify errors and test new functionalities to improve its performance;
− functionality cookies: these cookies enable us to provide specific functionalities in order to improve your experience on the Website, for example by storing your preferences (e.g. language and location);
− (third party) tracking / advertising cookies: these cookies collect information about users, sources of traffic, page visits and advertising displayed to you and followed by you. They enable us to display advertising which may be of interest to you based on collected Personal Data. These cookies are also used for statistical and research purposes.
12.4 Kwikwins only uses the information contained in the cookies for the above purposes, after which the data collected will remain stored on your device for a period that may depend on cookies type, but no longer than necessary to achieve their purpose and will be automatically removed from your system thereafter.
12.5 Personal information collected through cookies placed on your device may be transmitted to and accessed by us or the third parties referred to in this policy. The use of Personal Data outside of Kwikwins for advertising purposes, if any, may be subject to separate policies available on the above third parties’ websites. Kwikwins or those third parties might also provide you with a possibility to opt out of personalized advertising, which shall be subject to laws and regulations applicable to such products, utilities and offerings.
12.6 The first time that you access Kwikwins, your approval for the use of these cookies may be requested. If after you have approved the use of cookies you want to make another choice, you can do this by deleting the cookies stored by your browser (usually via the options in your browser’s Privacy menu – please refer to your browser’s manual or developer’s website). The pop-up requesting your approval may then show up again and you can make a different choice. If you do not consent to the use of cookies, certain features of Kwikwins might become unavailable, which may affect your browsing experience. You may also set up your browser preferences to accept or decline by default all cookies or cookies from specific websites, including Kwikwins.
12.7 Kwikwins may also use web beacons (pixel tags) in order to access the cookies previously placed on your computer for the following purposes:
− to track your actions on the Sites and when using the Kwikwins, by accessing and interacting with the cookies stored on your computer;
− to collect statistical information related to operating the Sites, the Kwikwins or products, utilities, advertisements or other offerings.

GENERAL
13. Changes to the privacy policy 
This Policy may be modified from time to time, thus, check back often. So that you are aware changes have been made, we will adjust the “Last Revised” date or “Date of publication” at the beginning of this document. The new policy may be displayed on-screen, and you may be required to read it to continue your use of Kwikwins. Continued access to our products, services by you will constitute your acceptance of any changes or revisions to this Policy.

14. Compliance with applicable legislation
We are committed to complying with applicable privacy and data protection laws and regulations designed to protect your personal information, including, but not limited to Data Protection Act 2018, Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 (GDPR) and other applicable current or future regional and state privacy and data protection laws and regulations worldwide as they become effective.

15. Questions, problems or complaints
Contact us, if you have any questions, problems or complaints regarding this Policy.
You have the right to lodge a complaint with the Commissioner.