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Privacy Policy

Wazafk Privacy Policy

This Privacy Policy ("Policy") outlines the manner in which [Company Name] (hereinafter referred to as "the Company," "we," "our," or "us") collects, processes, stores, and protects the personal data of users ("Users," "Freelancers," "Clients," or "you") in compliance with Lebanese Law No. 81 of 2018 on Electronic Transactions and Personal Data, along with applicable international data protection standards. By accessing or using the Platform, you agree to the collection, processing, and storage of your personal data in accordance with this Policy. The Company is committed to maintaining the confidentiality and integrity of your personal information and ensuring that all processing activities are performed lawfully and transparently.

1. Introduction 1.1 Company Information

Wazafk ("we," "our," or "us") is a Lebanese-based company operating an online platform that connects Freelancers with Clients, enabling the offering and acquisition of services. Our Platform, consisting of a website and mobile application, facilitates the formation of service contracts between Users and provides support in resolving disputes via a secure escrow payment service. As a company committed to ensuring the privacy and security of personal data, we are dedicated to upholding the highest standards of data protection. This Privacy Policy outlines our practices in relation to the collection, processing, and protection of your personal information.

1.2 Purpose of the Privacy Policy

The primary purpose of this Privacy Policy is to inform Users about how their personal data is collected, utilized, stored, and safeguarded when interacting with our Platform. By accessing or using the Platform, you acknowledge and consent to the collection and processing of your personal data as described in this Policy. The Company seeks to ensure that all data processing activities comply with applicable legal requirements, including Lebanese Law No. 81 of 2018 on Electronic Transactions and Personal Data, and international data protection standards.

1.3 Scope of Application

This Privacy Policy applies to all Users of Wazafk Platform, including Freelancers and Clients, who access our services through the website, mobile application, or any other medium provided by the Company. It covers all interactions on the Platform, including but not limited to the formation of service contracts, management of payments, and dispute resolution facilitated by the escrow payment service. This Policy governs all aspects of personal data processing within the context of our services.

2. Definitions

For the purposes of this Privacy Policy, the following terms have the meanings outlined below:

  • Personal Data: Any information that relates to an identified or identifiable individual, including, but not limited to, names, contact details, financial information, professional data, usage data, and payment information. Personal data encompasses any information that can be used to identify an individual directly or indirectly, whether through specific data elements or in combination with other information.
  • Processing: Any operation or set of operations performed on personal data, including but not limited to collection, storage, usage, modification, sharing, or deletion of such data. Processing refers to the entire lifecycle of personal data as it is handled by the Company in the course of providing services to Users.
  • Service Contracts: Agreements entered into between Clients and Freelancers through the Wazafk Platform for the provision of services. These contracts outline the terms and conditions under which services are delivered, and they may include details about project deliverables, timelines, compensation, and other relevant provisions.
  • Freelancer: An individual or business entity that seeks to offers services through the Wazafk Platform, which may include professional, project-based, or other freelance work. Freelancers utilize the Platform to advertise their services and engage with Clients seeking such services.
  • Client: An individual or business entity that seeks to hire Freelancers for services through the Wazafk Platform. Clients post job offers, review Freelancer profiles, and enter into Service Contracts for the provision of services.
  • Escrow Service: A secure payment service provided by Wazafk that holds funds in escrow until the completion of contractual obligations between Freelancers and Clients. This service ensures that both parties fulfill their respective responsibilities under the Service Contract before the release of funds. 3. Legal Framework3.1 Compliance with Lebanese Law Wazafk operates in strict adherence to Lebanese Law No. 81 of 2018 on Electronic Transactions and Personal Data (the "Data Protection Law"), which governs the collection, processing, and storage of personal data within Lebanon. This law is designed to safeguard individuals' privacy and ensure the secure handling of personal information in the digital economy, providing robust protections for Users' personal data. By complying with this law, Wazafk ensures that all data processing activities are conducted in a lawful, transparent, and accountable manner, in line with the statutory requirements set forth under Lebanese data protection regulations.

3.2 Compliance with International Standards

In addition to meeting the requirements of Lebanese data protection law, Wazafk is also committed to adhering to internationally recognized data protection frameworks, including the General Data Protection Regulation (GDPR). This commitment ensures that personal data is handled in a secure and lawful manner, regardless of geographic location, and extends privacy protections across borders. By aligning with international standards such as the GDPR, Wazafk aims to provide Users with confidence in the security and privacy of their personal information, reflecting a global best-practice approach to data protection.

4. Types of Data Collected

Wazafk collects and processes various categories of personal data to provide its services through the Platform. These include:

  • Personal Identification Information: This includes identifiable data necessary to create, manage, and maintain your account on the Platform, such as your full name, date of birth, contact information (e.g., residential address, email address, telephone number), and other personal identifiers. This information is essential for verifying user identity, facilitating communication, and ensuring that the services provided are customized to meet the individual needs and preferences of each user.
  • Professional Information: For Freelancers, this encompasses data related to your professional background, including but not limited to skills, qualifications, portfolio, work experience, and any other details you provide in relation to the services you offer. For Clients, this includes information regarding your needs, projects, and any relevant professional context.
  • Payment Information: This includes financial data such as credit card information, billing address, and transaction history, which are required for processing payments, receiving payments, and fulfilling the obligations under Service Contracts.
  • Usage Data and Analytics: This involves data regarding how you interact with the Platform, such as your IP address, browser type, login history, pages viewed, time spent on the Platform, and other behavioral data to help improve user experience, track usage patterns, and enhance the services provided.
  • Location Data: If applicable, location-based data may be collected when using the Platform. This helps in providing location-specific features, personalizing services, and enhancing the overall user experience by tailoring the services to your geographical preferences.

5. Purpose of Data Collection and Processing

Wazafk collects and processes personal data for several key purposes essential to the functioning of the Platform and the provision of its services:

  • Account Creation and Management: To facilitate the creation, management, and maintenance of user accounts on the Platform, enabling both Freelancers and Clients to access and utilize the services effectively.
  • Facilitating Service Contracts: To enable connections and interactions between Clients and Freelancers, facilitating the formation, communication, and management of Service Contracts, including the secure processing of payments via the escrow service.
  • Payment Processing: To securely process payments made by Clients to Freelancers and vice versa, ensuring the smooth and secure transfer of funds for services rendered.
  • Dispute Resolution: To assist in the resolution of any disputes arising from Service Contracts, using the secure escrow service as a means of holding funds and ensuring both parties fulfill their contractual obligations.
  • Service Improvement and Personalization: To enhance the functionality, performance, and overall user experience of the Platform, including developing new features and tailoring content and services based on user feedback, behavior, and usage patterns.
  • Legal and Regulatory Compliance: To comply with applicable legal and regulatory requirements, including those related to tax reporting, anti-money laundering, and other local and international legal obligations, particularly under Lebanese Law No. 81 of 2018 on Electronic Transactions and Personal Data.

6. Legal Basis for Processing

Wazafk processes personal data in accordance with the following legal bases, ensuring compliance with applicable data protection laws and the smooth operation of the Platform:

  • Consent: When required, Wazafk obtains explicit consent from users for specific processing activities, such as marketing communications, promotional offers, and other non-essential services. Users have the right to withdraw their consent at any time.
  • Contractual Necessity: Data processing is essential for the performance of a contract between Wazafk and the user. This includes processing personal data to facilitate the creation, management, and execution of Service Contracts between Freelancers and Clients, ensuring the fulfillment of all terms and conditions.
  • Legitimate Interests: Wazafk processes personal data based on its legitimate interests, including the improvement and operation of the Platform, enhancing security measures,ensuring smooth communication, providing customer support services, and developing features that benefit users.

• Legal Obligations: Wazafk processes personal data as necessary to comply with legal obligations, including but not limited to tax reporting, fraud prevention, regulatory requirements, and adherence to the Lebanese Data Protection Law (No. 81 of 2018) and other relevant legislation.

7. Data Sharing and Third-Party Disclosure

Wazafk may share personal data with third parties in the following circumstances, in accordance with applicable data protection laws:

  • Freelancers and Clients: In order to facilitate Service Contracts, information provided by Freelancers and Clients may be shared between the two parties, such as Freelancer profiles, qualifications, and other relevant details necessary for project engagement and communication. This sharing is essential for the performance of the service agreement between the two parties.
  • Third-Party Service Providers: We may disclose personal data to third-party service providers who assist in the operation of the Platform. This includes, but is not limited to, payment processors, cloud storage providers, customer support services, and other partners that ensure the functionality and security of the Platform. These service providers are obligated to protect your personal data and can only use it in accordance with our instructions.
  • Legal Requirements and Law Enforcement: We may disclose personal data to comply with legal obligations or requests from law enforcement authorities, regulators, or other governmental bodies. This includes responding to subpoenas, court orders, or other legal processes, as well as preventing fraud, illegal activities, or in matters concerning public safety or national security. The Company may send marketing communications to users based on their preferences and interests. However, such communications will only occur with the explicit, prior consent of users, in compliance with the provisions of Lebanese Law No. 81 of 2018 and the GDPR. Users may withdraw their consent at any time by using the "unsubscribe" link in marketing emails or by contacting the Company directly. Users' personal data will only be used for marketing purposes as permitted by applicable law and as outlined in this Privacy Policy.

8. Data Retention and Deletion

Wazafk retains personal data for as long as necessary to fulfill the purposes outlined in this Privacy Policy, subject to applicable legal and regulatory obligations.

  • Retention Period: Your personal data will be retained for the duration of your relationship with Wazafk and for a reasonable period thereafter, in order to meet legal, regulatory, and contractual obligations.
  • Account Closure and Data Deletion: You have the right to request the deletion of your account and associated personal data by contacting us. Upon receipt of such a request, we will take reasonable steps to delete or anonymize your data, except where retention is required by law, such as for compliance with financial or legal obligations.

9. User Rights

In accordance with Lebanese Law No. 81 of 2018 on Electronic Transactions and Personal Data, as well as applicable international data protection regulations, Users have the following rights concerning their personal data:

  • Right to Access: You have the right to obtain confirmation as to whether or not we are processing your personal data, and, where that is the case, to request access to such personal data. This right enables you to verify the data we hold about you and to assess its accuracy and lawfulness of processing.
  • Right to Rectification: If you believe that any personal data we hold about you is inaccurate, incomplete, or outdated, you have the right to request the correction or updating of such data. We are committed to ensuring that the personal information we store is accurate, complete, and up-to-date, and we will take all reasonable steps to rectify any inaccuracies as soon as possible.
  • Right to Erasure: In certain circumstances, you have the right to request the deletion or removal of your personal data. This may include situations where the data is no longer necessary for the purposes for which it was collected, if you withdraw your consent (where processing is based on consent), or if you object to processing, and there are no overriding legitimate grounds for continuing the processing. We will assess your request in accordance with applicable laws and our retention policies.
  • Right to Object to Processing: You have the right to object to the processing of your personal data in certain situations where we rely on legitimate interests as the legal basis for processing. This includes situations such as direct marketing, where you may object to the use of your personal data for such purposes at any time. If you object, we will cease processing your personal data for those specific purposes unless we have compelling legitimate grounds that override your interests, rights, and freedoms The Company will respond to such requests in a timely manner, as required by applicable law, and will take appropriate steps to ensure that all personal data is processed in accordance with the statutory provisions governing data protection.

10. Data Security Measures

Wazafk take the security of your personal data seriously and implement appropriate technical and organizational measures to protect it from unauthorized access, loss, misuse, or alteration. These measures include, but are not limited to, encryption of data during transmission and storage, secure access protocols, and robust access controls to ensure that only authorized personnel can access your personal data. Additionally, we conduct regular security assessments and routine audits to evaluate the effectiveness of our security measures and address potential vulnerabilities. These efforts are designed to safeguard the confidentiality, integrity, and availability of your personal data in accordance with applicable data protection laws and best practices.

11. International Data Transfers

In certain circumstances, your personal data may be transferred to or processed in countries outside of Lebanon. We ensure that any such transfers comply with applicable data protection laws, including those that apply to cross-border data transfers, and implement appropriate safeguards to protect your personal data. These safeguards may include the use of Standard Contractual Clauses, Privacy Shield certification, or other legally recognized mechanisms to ensure that your data continues to be protected in accordance with applicable legal standards.

12. Cookies and Tracking Technologies

To enhance your experience on the Platform, we use cookies and similar tracking technologies to collect and analyze information about your preferences and user activity. These tools help us understand how you interact with the Platform, personalize content, and improve functionality. Specifically, we use session cookies, persistent cookies, and analytics cookies for various purposes, including remembering your preferences, analyzing site traffic, and improving user experience. By accessing and using the Platform, users consent to the use of cookies as outlined in this Privacy Policy, with the option to withdraw consent at any time by adjusting cookie preferences or contacting the Company directly.

13. Changes to the Privacy Policy

Wazafk reserves the right to update or amend this Privacy Policy as necessary. Any significant changes will be communicated to you by posting the revised Policy on the Platform. In cases where your consent is required, we will request your consent to the changes in accordance with applicable legal requirements. We encourage you to periodically review the Policy to stay informed about how your personal data is being processed and protected.

14. Contact Information

For any questions, concerns, or requests related to this Privacy Policy or the processing of your personal data, please contact us at the following:

Email:[Insert Contact Email]

Phone:[Insert Contact phone]

15. Children's Privacy and Data Protection

The Platform is not intended for, nor do we knowingly collect or process personal data from, individuals under the age of 18. In accordance with applicable data protection laws, including but not limited to Lebanese Law No. 81 of 2018 (the “Data Protection Law”) and the General Data Protection Regulation, the Company does not intentionally collect, store, or process any personal data from individuals who are considered minors under the applicable jurisdiction.

If the Company becomes aware that personal data has been unlawfully collected from a minor, without obtaining valid parental or guardian consent where required, the Company will take immediate action to delete or anonymize such data in accordance with its legal obligations. The Platform requires users to affirm that they are at least 18 years of age, and it is the sole responsibility of the user to ensure that they meet any relevant age restrictions or legal requirements to access and use the Platform.

In the event that the Company discovers that a user is under the age of 18 and has provided personal data without valid consent, the Company reserves the right to suspend or terminate the user’s access to the Platform and remove all relevant personal data from its systems as soon as reasonably possible.

16. Dispute Resolution

In the event of any dispute arising from or related to this Privacy Policy or the processing of your personal data, the dispute will be governed by Lebanese law. Jurisdiction for any legal proceedings shall lie exclusively with the competent courts of Lebanon.

17. Specific Provisions for Freelancers and Clients

Freelancers and Clients (collectively, "Users") acknowledge and agree that the information shared between them through the Platform, including but not limited to profiles, ratings, and reviews, is an integral part of the services provided by the Platform. By using the Platform, both Freelancers and Clients consent to the sharing of such information within the confines of the Platform’s terms and conditions. The exchange of data is conducted solely for the purpose of facilitating potential opportunities, fostering professional relationships, and enhancing the user experience in accordance with the terms of this Privacy Policy. Both parties agree to use the shared information only for the purposes outlined in the Platform's guidelines and to ensure that any data exchanged is used in compliance with applicable data protection laws.

18. Data Protection Impact Assessment

The Company is committed to ensuring the privacy and security of personal data. In accordance with applicable data protection regulations, the Company conducts regular Data Protection Impact Assessments (DPIAs) to evaluate and mitigate potential risks associated with the processing of personal data. These assessments help ensure that our data processing activities are in full compliance with this Privacy Policy, relevant data protection laws, and industry best practices. In the event that a DPIA identifies a high risk to the rights and freedoms of individuals, the Company will take appropriate measures to address and mitigate such risks.

19. Consent Management

The Company obtains explicit consent from Users at the point of data collection, in accordance with applicable data protection regulations. By using the Platform, Users provide consent for the collection, processing, and sharing of their personal data as described in this Privacy Policy. Users have the right to withdraw their consent at any time, with such withdrawal being effective from the point of communication to the Company or through the Platform’s settings interface. The withdrawal of consent will not affect the lawfulness of processing based on consent before its withdrawal. Users may also modify their preferences or exercise their rights related to personal data processing through the Platform's provided tools and settings.

20. Appendices

  • List of Third-Party Service Providers: [Provide names and purposes of third-party providers]
  • Glossary of Technical Terms:
  • Personal Data: Any information relating to an identified or identifiable natural person ("Data Subject"). An individual is considered identifiable if they can be directly or indirectly identified, particularly by reference to an identifier such as a name, identification number, location data, online identifier, or one or more factors specific to the physical, physiological, genetic, mental, economic, cultural, or social identity of that individual.
  • Processing: Any operation or set of operations performed on personal data, whether or not by automated means. This includes, but is not limited to, the 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 of data. "Processing" refers to the entire lifecycle of personal data and is subject to the conditions stipulated under data protection laws.
  • Service Contracts: Legally binding agreements entered into between Freelancers and Clients through the Platform, which define the scope of services to be provided, payment terms, deliverables, deadlines, and other terms and conditions relevant to the professional relationship between the parties. These contracts are central to the operation of the Platform and are executed through the mutual consent of both Freelancers and Clients.
  • Freelancer: An individual or business entity who offers services via the Wazafk Platform, typically on a project-based, contractual basis. Freelancers register on the Platform to advertise their services, engage with potential Clients, and enter into Service Contracts for the provision of their professional services.
  • Client: An individual or business entity that seeks to hire Freelancers for the provision of services through the Wazafk Platform. Clients create job postings, review Freelancer profiles, and enter into Service Contracts for the acquisition of services offered by Freelancers.
  • Escrow Service: A secure third-party payment mechanism employed by Wazafk, which temporarily holds payments made by Clients to Freelancers in a neutral account until the agreed-upon services are completed. The escrow system is designed to ensure both parties fulfill their contractual obligations before funds are released to the Freelancer, offering protection and dispute resolution in the event of conflicts.
  • Platform: The digital platform operated by Wazafk, consisting of the website and mobile application, which facilitates the interaction between Freelancers and Clients, allowing them to form service contracts, exchange information, and process payments securely.
  • Data Subject: An individual whose personal data is being processed. The Data Subject is the natural person to whom the personal data relates. This term encompasses all Users, including Freelancers and Clients, who provide personal data through the Platform.
  • Controller: The natural or legal person, public authority, agency, or other body that, alone or jointly with others, determines the purposes and means of the processing of personal data. In the context of this Privacy Policy, the Company (Wazafk) is the Data Controller for the personal data processed through the Platform.
  • Processor: A third party that processes personal data on behalf of the Data Controller. Processors may assist in the operational aspects of the Platform, such as payment processing, customer support, and hosting, under the instructions of the Data Controller and in compliance with the applicable legal framework.
  • Consent: The freely given, specific, informed, and unambiguous indication of the Data Subject’s wishes by which they, by a statement or a clear affirmative action, signify agreement to the processing of personal data relating to them. Consent must be obtained for specific processing activities and can be withdrawn at any time without affecting the lawfulness of processing based on consent before its withdrawal.
  • Third-Party Service Providers: External vendors or entities with whom the Company shares personal data to facilitate the operation of the Platform, such as payment processors, cloud storage providers, data analytics services, and customer support services. These service providers are required to handle personal data in compliance with applicable data protection laws.
  • Data Protection Impact Assessment (DPIA): A process that helps identify and mitigate risks associated with the processing of personal data. A DPIA is conducted to assess the potential impacts of a processing activity on the rights and freedoms of individuals and to ensure that the processing complies with relevant data protection regulations. DPIAs are a key element in ensuring data protection compliance.
  • Withdrawal of Consent: The act by which a Data Subject retracts or revokes the consent previously provided for the processing of their personal data. Withdrawal of consent does not affect the lawfulness of processing based on consent before its withdrawal.
  • Data Security: The protection of personal data from unauthorized access, disclosure, alteration, destruction, or accidental loss. This includes the implementation of technical and organizational measures such as encryption, secure data storage, and access controls to safeguard the confidentiality and integrity of personal data.
  • Legal Basis for Processing: The foundation upon which the processing of personal data is carried out in accordance with data protection regulations. This includes processing based on consent, contractual necessity, legitimate interests, and compliance with legal obligations. The Company ensures that personal data is processed in accordance with one or more of these legal bases.
  • Cookies and Tracking Technologies: Small text files stored on the user’s device to track, analyze, and personalize the user’s interaction with the Platform. Cookies are used for purposes such as remembering user preferences, analyzing site traffic, and improving functionality. Users have the ability to control or disable cookies through their browser settings, subject to applicable legal requirements.