European Regional Privacy Notice

1. Data Controller

The entity responsible for processing your personal data:

Ferct (Formerly Skillsuper Limited company), a company registered in the United Kingdom at 27 Old Gloucester Street, London, WC1N 3AX, acts as the data controller.

In this Notice, “Ferct” refers to either Skillsuper Limited Company, as applicable to your location.

2. Legal Bases for Processing Personal Data

Ferct processes your personal data only when there is a lawful basis to do so. Below, we outline the legal bases we rely on, the purposes for processing, and the categories of personal data involved.

2.1 To Perform Our Contract with You

We process personal data when necessary to fulfill our User Agreement with Members. Failure to provide required data may prevent us from entering into or continuing the contract.

• Purpose and Use:
  • Register and manage access to your Ferct account.
  • Provide the Ferct platform in your preferred language.
  • Deliver core Services under the User Agreement.
• Data Processed:
  • Account information: name, email address, login credentials, two-factor authentication details, payment information (for paid Services), subscription details, and preferred language.
  • Usage data: IP address, device ID, user agent, location data, browser type and version, operating system, and online identifiers collected via cookies or similar technologies.

2.2 Consent

We process personal data when you provide consent, which you may withdraw at any time through your settings on the left sidebar or by contacting us. Withdrawal of consent does not affect processing conducted prior to withdrawal.

• Purposes and Uses:
  • Allow Members to build and display profiles visible to connections, networks, Visitors, and on public profiles or third-party applications.
  • Enable two-factor authentication or account recovery.
  • Facilitate connections between Members.
  • Display Member profiles alongside company or interest-related information.
  • Verify Member information (e.g., workplace or educational credentials) for profile badges and security purposes.
  • Enable interaction with platform features, including AI-powered tools.
  • Send marketing communications (e.g., emails or SMS) about products, services, or events.
  • Support opportunity discovery, applications, and selection processes.
  • Use non-essential cookies for analytics, advertising, and user identification.
  • Deliver personalized ads in the EU Countries and the UK based on observed or inferred data or third-party data.
  • Conduct analytics for workforce and salary insights based on Member-provided data.
• Data Processed:
  • Profile data: name, photo, current position, education, location, skills, endorsements, recommendations, and contact details.
  • Two-factor authentication data: phone number.
  • Contact information: email, telephone, direct message handle.
  • Verification data: work or educational institution email, Member ID, hashed identifiers, government-issued ID details.
  • Member-inputted data: learning goals, topics of interest, uploaded CVs.
  • Opportunity-related data: location, opportunity search filters (e.g., industry, experience level), opportunity preferences, CVs, and application details.
  • Usage data: IP address, device ID, user agent, location, browser details, and cookie-based identifiers.
  • Advertising data: inferred location, gender, age range, interests, traits, and activity data (e.g., page visits, ad interactions).
  • Third-party data: hashed contact information, device data, and ad interaction metrics.
  • Demographic data: gender, disability status.

2.3 Legitimate Interests

We process personal data based on legitimate interests, balancing our interests (or those of third parties) against your rights and freedoms. You may object to or request restrictions on such processing.

• Purposes and Uses:
  • Safety and Security:
    • Monitor user activity to detect and prevent security threats, fraud, or violations of our User Agreement (e.g., hacking, fake accounts, or malicious behavior).
    • Verify workplace, educational, or identity information.
    • Share data with Affiliates (e.g., Skillsuper) or other organizations to address threats or fraud.
    • Use AI systems to detect harmful content and improve trust and safety measures.
  • Business Administration:
    • Manage operations, including quality control, reporting, and customer service.
    • Handle corporate transactions (e.g., mergers or acquisitions).
    • Analyze service usage to improve products and customer relationships.
    • Transfer data to data centres of Ferct on Google Cloud and Cloudflare for processing and storage.
  • Personalized Experience:
    • Personalize content and recommendations (e.g., posts, connections, or opportunities) using profiling techniques.
    • Enable customers to search for and contact Members for business or opportunities.
  • Legal Requests and Litigation:
    • Respond to legal requests, subpoenas, or investigations.
    • Defend against claims or protect the security and integrity of our Services.
  • Research and Development:
    • Conduct research to improve products and introduce new features.
    • Generate usage metrics and aggregated insights (e.g., workforce trends or acceptance rates).
    • Invite feedback via surveys to enhance services.
• Legitimate Interests:
  • Ensure platform safety, security, and authenticity.
  • Operate an efficient and high-quality business.
  • Connect professionals to opportunities, enhancing productivity and success.
  • Comply with legal obligations and protect against illegal or harmful activities.
  • Support innovation, economic opportunities, and labor market efficiency.
• Data Processed:
  • Usage data: IP address, device ID, user agent, location, browser details, and cookie-based identifiers.
  • Account information: email, login details, payment, and subscription information.
  • Profile data: name, photo, position, education, location, skills, endorsements, and contact details.
  • Activity data: posts, comments, search history, connections, page visits, ad interactions, and opportunity searches.
  • Support data: information provided via email, tickets, or live chat.
  • Inferences: derived insights about your interests or traits.
  • Demographic data, connections, group memberships, and verification information.

2.4 Compliance with Legal Obligations

We process personal data to comply with legal obligations, such as responding to valid requests from law enforcement, courts, or regulators, or meeting financial and consumer law requirements.

• Data Processed:
  • Varies based on the legal obligation or request, potentially including any data outlined in this Notice.

2.5 Public Interest

We process personal data when necessary to perform tasks in the public interest, such as protecting individuals from harm.

• Purpose and Use: Detect and combat Child Sexual Abuse Material by analyzing images and videos in Member messages.
• Data Processed: Images and video files in Member messages.

3. Data Sharing with Third Parties

In addition to Section 3 of the Privacy Policy, Ferct may share personal data with the following entities for specific purposes:

• Ferct Developer Programs:
  • Partners in talent, marketing, sales, and learning solutions APIs access limited Member data under partnership agreements.
• Third-Party Service Providers:
  • Providers include Skillsuper (our parent company), cloud services, content delivery networks, telecommunications, maintenance, support, development, market research, anti-fraud services, marketing, analytics, payment processors, auditors, and professional advisors.
• Regulators and Law Enforcement:
  • Data is shared when required by law, as outlined in the “Compliance with Legal Obligations” section.
• Affiliates:
  • Skillsuper: Data is shared to combat fraud, protect site security, and ensure service integrity.
• Other Organizations:
  • Data may be shared to protect the security or integrity of our Services or to safeguard Ferct, Members, Visitors, or others.

4. Data Retention

• General Policy:
  • We retain personal data as long as your account remains active or as needed to provide Services.
  • Data is retained even if you use our Services infrequently (e.g., for opportunity searches every few years) unless you close your account.
  • Certain data (e.g., usage insights) may be retained in depersonalized or aggregated form.
• Account Closure:
  • Closing your account removes your public profile within 72 hours, though search engines may temporarily display cached data.
  • Third parties (e.g., via the Ferct Developer Program) may retain data per their own policies or our agreements.
• Cookie Data:
  • Cookie expiration periods are detailed in our Cookie Table.
  • Data from third-party websites (e.g., via Ferct’s tag) is de-identified after 7 days and deleted after 180 days.
• Extended Retention: Data may be retained longer for reasons such as:
  • Account suspension due to violations of our Professional Community Guidelines.
  • Ongoing or potential legal or regulatory proceedings.
  • Legal requirements (see “Compliance with Legal Obligations”).

Ferct transfers personal data outside the Designated Countries and the UK (e.g., to U.S. servers) using lawful mechanisms.

5. Your Data Rights and Controls

You have several rights and options to control your personal data:

• Accessing Data:
  • Download your data in a structured, readable format via the Data Privacy section of your Member Settings.
• Correcting or Rectifying Data:
  • Update profile information directly in your account settings.
  • Submit a data rectification form for other data corrections.
• Deleting Data:
  • Delete profile data via account settings or submit a Data Deletion request form.
  • Closing your account deletes all personal data.
• Restricting Processing:
  • Adjust Data Privacy or Advertising Data settings.
  • Request restrictions for inaccurate or unlawful processing via the contact form.
• Objecting to Processing:
  • Object to processing based on legitimate or public interest via the Data Processing Objection form.
  • We will review objections, considering legal obligations and compelling interests (e.g., security measures).
  • You can always object to direct marketing, and we will stop using your data for this purpose.
• Data Portability:
  • Download portable data via Member Settings, use our API program (EEA, EU, Switzerland only) or contact us.
• Withdrawing Consent:
  • Withdraw consent via Member settings or by contacting us. Withdrawal does not affect prior processing.

6. Joint Controller Relationship

Ferct acts as a joint controller with organizations administering Ferct Business Pages, sharing Member profile and interaction data.

7. Contacting Your Supervisory Authority

If you have unresolved concerns about our data practices, you may contact the supervisory authority in your jurisdiction.

8. Contact Us

For questions about our practices or to exercise your rights, contact us:

• Online: Use our contact form or live chat (Members only).
• Additional Options: Submit requests via the forms linked above for data rectification, deletion, restriction, or objection.