(updated on May 20, 2021) 

This Privacy Policy (Policy) aims to give freelancers (“freelancer”, “you”, “your”) the information on how UNIVERSAL BUSINESS SOLUTIONS (“UBS”, “we”, “us”, “our”) processes their personal data (Data), its legal status and other conditions.

UBS processes the Data:

  • for the finding of best candidates, as well as conclusion, performance and termination of the Freelancer Contract (Contract);
  • in order to comply with legal obligations (taxes, auditors, accounting, KYC/ AML etc.) and requirements of state authorities;
  • in order to establish, exercise and/ or protect legal claims of UBS and/ or third parties (UBS employees, partners etc.),

hereinafter referred to as “Purpose” or “Purposes” respectively.

Also freelancers may be subject to our partners’ and service providers’ policies and procedures. In such cases freelancers must communicate with the current partner or service provider regarding their data processing rules, this Policy does not apply in such cases.

If freelancers register for any event, which is not covered with Purposes, this Policy does not apply.

Communication among freelancers, except for the performance of Contract, must be treated as data processing for personal needs. In such cases each freelancer is responsible for timely data removal, as well as applying other necessary precautions.

UBS is committed to comply with confidentiality rules set in the Contract. Additionally:

  • We will not process the Data outside the Purposes.
  • By default, we are processing only Data, which:
    • Is necessary to achieve the current Purpose.
    • Is accurate and, where necessary, kept up to date.
  • Upon achievement of a Purpose we apply one of the following steps (data retention) :
    •  unlink the Data from freelancer’s person (anonymisation); or
    • delete the Data; or
    • limit access to the Data, if other Purposes is still active (for example, if the Contract was terminated, but governing law still requires us to store the Data for taxation reasons or maximum survival period for legal claims is not expired yet).
  • When data is being processed for statistical and analytical purposes, we are applying additional safeguards preventing any undue impact on your person.

Each freelancer is a separate business project. UBS treats freelancers as independent contractors – legal persons. The term Data within this Policy means  “personal data which concerns legal persons” (B2B relationships) and necessary to achieve Purposes set above. As a result, UBS uses best practices originated from provisions of data protection laws and guides, at the same time UBS as a party in B2B relationships may derogate from those laws and guides.

What data does UBS collect about freenalcers? 

We are collecting different Data categories (identification data, personal credentials, financial data, experiences, skills, results of assessments of services provided under the Contract etc.). If freelancers submit requests or complaints we might collect extra data to manage these processes.

We might collect information regarding your CV (work experience, language knowledge etc.) submitted during the application process. At the time of Contract conclusion, performance or termination we might also collect and share with partners technical data (log files, internal URLs, usernames, internal IDs etc.)  to manage accesses, resolve bugs/ errors, ensure secure communications and confidentiality regime, as well as to prevent/ respond to security incidents.

Who is responsible for your data protection? 

UBS is responsible for your Data in accordance with Contract provisions. Our service providers and partners are liable, where the Data falls under their policies and procedures or where they have acted outside or contrary to lawful instructions of UBS.

If you are providing Data of other freelancers or candidates (Referrals), you shall be solely liable for obtaining documented permission from them or using other legal basis for their data processing (e.g. contract, power of attorney etc.).

If You Fail to Provide Personal Data

Where UBS collects personal data to comply with legal obligations or under the terms of a Contract, and you fail to provide the Data when requested, we may not be able to perform the Contract or to enter into with you. In this case, we may have to terminate negotiations/ conclusion and/ or performance of the Contract, but we will notify you if this is the case at the time.

Disclosure after collecting 

Generally, we do not share the Data with third parties, except minimally necessary information shared with:

  • our corporate clients, so you are able to provide services requested by them;
  • our service providers and suppliers;
  • our corporate affiliates (in case of change of control of UBS ownership);
  • other business partners (e.g. to conduct a survey);
  • public (in cases, when you authorized (also orally) us to publish it on our website or social media).
  • state authorities and agencies upon their lawful request.

Security Measures

Considering the state of art and costs of implementation, the scope of Purposes, UBS ensures and permanently improves security measures to protect the Data from the accidental or unlawful destruction, loss, alteration, disclosure or access to the Data.

To achieve the high security level, we are performing necessary organizational and technical measures.

Requests and complaints 

The scope of your rights is set in the Contract. You can also submit a request or complaint regarding Data. We will reply to the request  to the extent of our capacity. Usually, we reply within 30 days. Any complaints must be resolved in accordance with Contract provisions. Pre-contractual and post-termination relationships must be resolved in accordance with survived provisions of the Contract, as well as complaints must be subject to the governing law set in the Contract.

In case, your requests are manifestly unfounded or excessive, UBS might refuse to act on the request or charge some fee.

In case we have reasonable doubts concerning your identity (also identity of an authorized representative) we may request for additional information necessary to confirm the identity.


In cases You have any questions regarding Data processing, please contact us as


UBS might amend this Policy from time to time.

Amendments shall enter into force on the Effective Date.

Actual version of the Policy is published on our website.

The Effective Date of the Policy: May 20, 2021

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