(updated on May 20, 2021)
UBS processes the Data:
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:
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:
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 email@example.com
AMENDMENTS AND EFFECTIVE DATE
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