Participants Privacy Notice (hereinafter referred as the “Notice”)

RWS as controller provides you with this Notice to inform you of RWS’s practices regarding the processing of your Personal Data. Please read this Notice carefully as it contains detailed information about the processing of your Personal Data, including your rights.

For all the work done on Google Selfie Project the payment will be done by the company who onboarded you to the project and NOT by RWS Group. 

1              Objective and Scope

In the context of your relationship with RWS, RWS (serving in a capacity of the Data Controller) will process Personal Data about you in both digital and electronic format.

In particular circumstances, RWS may not be solely but jointly responsible with other RWS subsidiaries and affiliates for the lawfulness of the processing of your Personal Data; we will provide you with an additional complementary notice in those cases.

For definition of certain terms used in this Notice, please refer to Appendix 1. This Notice may be complemented by additional notices and policies.

2              Source of the Personal Data

Personal Data Provided by You: RWS collects Personal Data directly from you. RWS may, for example, ask you for information in the beginning of your relationship with RWS, e.g. upon a video call with you. You may also provide new, or updated or corrected data to RWS from time-to-time.

To assist us in complying with our obligation to maintain Personal Data accurate you should immediately notify the  Data Privacy Officer (privacy@rws.com) in writing of any changes to your Personal Data.

Where you have notified the Data Privacy Officer (privacy@rws.com) or we otherwise become aware of an inaccuracy in your information we will take steps to ensure that Personal Data is erased or rectified without delay.

3              Categories of Personal Data Processed, Purposes and Legal Bases for RWS’s Processing of Personal Data

RWS Processes the below categories of Personal Data for the following Purposes, based on the Legal Basis listed hereof.

3.1               Creating a pool of participants for RWS’s client project and verification of their personal identification and age 

The Categories of Personal Data that RWS Processes about you for this purpose, are the following:

›        Identification and contact data, nationality, date of birth, gender.

RWS uses the below as a basis for the above Personal Data processing:

›        Consent, or

›        Performance of contract with you, whether verbal or in writing.

For Personal Data received directly from you we predominantly use consent. The relevant consent form is provided to you via Google form and forms Appendix 2 to this Privacy Notice.

The provision of the Personal Data in this Article 3.1 is voluntary and you are not obliged to provide the Personal Data. If you do not provide the Personal Data, you will not be able to participate in RWS’s client project relating to use of your Personal Data for which condition of being at least 18 years of age and of a legal age in your jurisdiction is necessary to be fulfilled.

4              Personal Data Retention

RWS retains your Personal Data for the period necessary to fulfil the purposes set out in this Notice or as required by applicable law, and, when the purposes are fulfilled, will delete or anonymize the Personal Data.

It is our general policy to retain certain Personal Data of for the duration of a contractual relationship between you and RWS, and/or 10 (ten) years in case of a pending or threatening dispute, but in no event for longer than strictly necessary. For more detailed overview of retention periods, see RWS’s Personal Data Retention Directive, which is available here. You may also ask the Data Privacy Officer (privacy@rws.com) for a copy of the Personal Data Retention Directive if you cannot access the link.

5              Automated Decision-Making

RWS does not Process your Personal Data by automated decision-making, including profiling.

6              Disclosure of Personal Data

Personal Data of Participant may be shared with other RWS branches, subsidiaries, affiliates and holding companies (i.e. intragroup) or with third parties where appropriate or relevant for the same purpose as described above.

6.1               Intra-Group

RWS will need to share Personal Data of Participant with its branches, subsidiaries, affiliates and holding companies, depending on the purposes of the data processing described in Section 3 of this Notice, including staff members from the Data Privacy Officer (privacy@rws.com) in accordance with Section 7.1.

6.2               Third Parties

We may also share Personal Data with suppliers that are engaged to perform services or functions on behalf of RWS and under its instructions, for example, to provide payroll or benefit services, to provide cloud services which may be located also outside of EEA, lookup and communication services, survey tools, etc. In all such cases, RWS will put in place appropriate contracts with these parties to ensure that they only process Personal Data in accordance with our instructions and in order to provide these services and protect the integrity and confidentiality of the Personal Data.

For the purposes set out in Section 3 of this Notice, RWS may share information about your age (the fact that you are being at least 18 years of age and of a legal age in your jurisdiction) and your email address with RWS client.

From time to time and for the purposes set out in Section 3 of this Notice, RWS may also disclose your Personal Data to its auditors, lawyers, consultants, law enforcement and public authorities.

RWS does not sell, rent or lease your Personal Data to third parties.

7              International Transfers of Personal Data

7.1               Intra-Group

Due to the global nature of our operations, some of the Personal Data recipients (mentioned in Section 6) may be located in countries outside the European Economic Area (EEA), which do not provide an adequate level of data protection. International transfers will be to countries where RWS branches, subsidiaries, affiliates and holding companies have offices, including Argentina, Canada, China, Germany, Hungary, Ireland, Japan, the United Kingdom and the USA. The transfer of your Personal Data outside the EEA takes place on the basis of our Intra-Group Data Sharing Agreement, which is based on the standard data protection clauses adopted by the European Commission and in accordance with applicable law.

7.2               Third Parties

Some of the third parties with whom we share Personal Data are also located outside the EEA. Certain third countries, such as Argentina, Canada or Japan, have been officially recognized by the European Commission as providing an adequate level of protection. Transfers to third parties located in other third countries outside the EEA take place using an acceptable data transfer mechanism, such as the EU approved Standard Contractual Clauses, Binding Corporate Rules, approved Codes of Conduct and certifications etc. or in exceptional circumstances on the basis of permissible statutory derogations.

Please contact Global Supply team (contact details in Section 9 below), if you want to receive further information or, where available, a copy of the relevant data transfer mechanism.

8              Your Data Protection Rights

Under the conditions set by applicable data protection laws, you may exercise the following rights regarding your Personal Data (see also Section 9 on how to exercise those rights):

8.1               Access

You have the right to obtain from us confirmation if Personal Data is being processed, the purpose of processing, the categories of data, the legal basis of the processing, information on recipients of the data and the non-EU countries in which they are located, the safeguards put in place for the transfer of data to non-EU countries, storage period of data or criteria to determine it, further information on your rights, our processing activities, sources of information and the significant and envisaged consequences of processing.

8.2               Rectification

You have the right to request the rectification of inaccurate Personal Data and to have incomplete data completed.

8.3               Objection

You have the right to object to the processing of your Personal Data for compelling and legitimate reasons relating to your particular situation, except in cases where legal provisions expressly provide for that processing. In addition, you have the right to object where your Personal Data are processed for direct marketing purposes.

8.4               Portability

You may receive your Personal Data that you have provided to us, in a structured, commonly used and machine-readable format and have the right to transmit it to other data controllers without hindrance. This right only exists if the processing is based on your consent or a contract and the processing is carried out by automated means.

8.5               Restriction

You may request to restrict processing of your Personal Data if (i) you contest the accuracy of it – for a period we need to verify your request; (ii) the processing is unlawful and you oppose the erasure of it and request restriction instead; (iii) we no longer need it, but you tell us you need it to establish, exercise or defend a legal claim; or (iv) you object to processing based on public or legitimate interest – for a period we need to verify your request.

8.6               Erasure

You may request to erase your personal data if it is no longer necessary for the purposes for which we have collected it, you have withdrawn your consent and no other legal ground for the processing exists, you objected and no overriding legitimate grounds for the processing exist, processing is unlawful, or erasure is required to comply with a legal obligation.

8.7               Right to lodge a complaint

You also have the right to lodge a complaint with a supervisory authority, in particular in EU Member State of your residence, place of employment, or the location where the issue that is the subject of the complaint occurred.

For the Czech Republic, please see contact details below:

Address:

Personal Data Protection Office

Pplk. Sochora 27

170 00 Prague 7

Czech Republic

Email: posta@uoou.cz

8.8               Right to refuse or withdraw consent

Please note that in case we ask for your consent to processing, you are free to refuse to give consent and you can withdraw your consent at any time without any adverse negative consequences. The lawfulness of any processing of your Personal Data that occurred prior to the withdrawal of your consent will not be affected.

9              Contact Details

RWS’s contact details:

Address:

Moravia IT s.r.o.

Vlněna 526/1,

Postal Code 602 00,

Brno, Czech Republic

E-mail address: Global.Supply@rws.com

If you wish to exercise any of the afore-mentioned rights (see Section 8) or if you have any questions regarding this Notice, please direct your request to the Data Privacy Officer:

Moravia IT s.r.o.

Data Privacy Officer

privacy@rws.com

+420-545552133

Vlněna 526/1,

Postal Code 602 00,

Brno, Czech Republic

10           Updates to this Notice

RWS may update this Notice from time to time. The new version will be effective as from the date indicated in that updated Notice, ensuring that individuals receive sufficient advance notice and draw their attention to any significant changes.

Appendix 1

Definitions

Controller

means the natural or legal person, public authority, agency or other body which, alone or jointly with others, determines the purposes and means of the processing of Personal Data.

Data Protection Laws

means the GDPR and the relevant national implementing legislation.

GDPR

means the Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 on the protection of natural persons with regard to the processing of personal data and on the free movement of such data, and repealing Directive 95/46/EC (General Data Protection Regulation) (Text with EEA relevance).

RWS’s client project

Video Verification Research organized by RWS’s client based on separate agreement between Participant and RWS’s client.

Participant

means a natural person that voluntarily participates/intends to participate in RWS’s client project.

Personal Data

means any information relating to an identified or identifiable natural person (“data subject”); an identifiable person is one who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, identification number, location data, an online identifier or to one or more factors specific of the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person.

Processing

means any operation or set of operations performed on Personal Data or on sets of personal data, whether or not by automated means (e.g., computers), such as collection, recording, organization, structuring, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, alignment or combination, restriction, erasure or destruction.

RWS

means the Moravia IT s.r.o., with its seat at Vlněna 526/1, Trnitá, Postal Code 602 00, Brno Czech Republic, Registration number: 032 51 853, registered in the Commercial Register led by the Regional Court in Brno, Part C, Entry 88437 and its branches, subsidiaries, affiliates and holding companies.

Special Categories of Personal Data

means Personal Data revealing racial or ethnic origin, political opinions, religious or philosophical beliefs, or trade union membership, genetic data, biometric data (for the purpose of uniquely identifying a natural person), data concerning health or data concerning a natural person's sex life or sexual orientation.

Appendix 2

CONSENT WITH PROCESSING OF PERSONAL DATA

1.              I hereby grant my consent to

Moravia IT s.r.o., a limited liability company established and existing under the laws

of the Czech Republic, with its registered seat at Vlněna 526/1, Trnitá, ZIP Code 602 00, Brno,

the Czech Republic, Corporate Identification Number 03251853, registered in the Commercial Register maintained by the Regional Court in Brno, Part C, Entry 88437 (“RWS”),

with processing of the following personal data:

-          identification and contact details (my first name and surname, email address, date of birth (age), my nationality, my gender);

(the “Personal Data”).

And to share my email address and fact that I am of legal age with RWS’ client.

2.              I grant this consent for the purpose of my Personal Data being processed by RWS in order to verify that I am at least 18 years of age (legal age). The legal age is a necessary condition for participation in the study/project Video Verification Research organized by RWS’s client based on separate agreement between Participant and RWS’s client. I acknowledge that Personal Data will be collected directly from me via video call where I will display my date of birth in an identification document to an RWS vendor manager.

3.              I understand the processing of the Personal Data is governed by the Participant Privacy Notice which is available to me online and which includes information relevant to the Personal

Data processing such as RWS contact details, recipients, data transfers and detailed information about my rights.

4.              Notwithstanding article 3 above, I understand that, in connection with processing by RWS of any of the Personal Data, I may:

(a)             request access to the Personal Data;

(b)             request explanation in respect of processing of the Personal Data;

(c)              request rectification, completion, restriction of processing or erasure of the Personal Data;

(d)             request to receive a copy Personal Data or have it ported to another controller;

(e)             object to processing of Personal Data; and/or

(f)               lodge a complaint with the supervisory data processing authority.

5.              I confirm I understand granting of this consent with processing of Personal Data is voluntary.

6.              I confirm I understand that I may withdraw my consent at any time.

7.              I confirm I understand the withdrawal of the consent shall not affect the lawfulness of personal data processing based on consent before it has been withdrawn.

8.              I hereby confirm that I have read, understood and agree to the Notice as outlined above.

 It can be “RWS’s” or “RWS’ ” but it should be consistent throughout the document

 I put “the” here because it sound especially weird without it, but I am honestly not 100% if it is needed as it may be a legal language thing

 I changed this around a little because “of them” at the end sounded really weird

 Normally I’d be tempted to write The Participant, but I believe in Legal language “the” is ommited