Privacy Policy

1. Who we are

This website and the related services are operated by On-demand Talent & FoW Company OÜ ("OnDemand Talent Fow", "we", "us" or "our"), a technology-enabled expert network platform that connects companies with experienced industry professionals for on-demand insights and consultations.

For the purposes of the GDPR, On-demand Talent & FoW Company OÜ is the controller of the personal data described in this policy.

• Legal name: On-demand Talent & FoW Company OÜ
• Registered address: Viru väljak 2, 3. korrus, Kesklinna linnaosa, Tallinn 10111, Harju maakond, Estonia
• VAT ID: EE102513181
• Email: info@ondemandtalentfow.com

2. Scope of this policy

This policy applies to personal data relating to:

• visitors to ondemandtalentfow.com (the "Website");
• representatives of our clients and prospective clients ("Clients");
• industry professionals who join our network or are considered for consultations ("Experts");
• users of our software and technology solutions; and
• anyone else who contacts us or whose data we receive in the course of our business, such as suppliers and partners.

Where we process personal data on behalf of a Client as a processor (for example, within software we provide to that Client), the Client's own privacy notice applies and we act on the Client's documented instructions.

3. Personal data we collect

Depending on how you interact with us, we may collect the following categories of personal data:

• Identity and contact data: name, job title, employer, business email address, telephone number and country.
• Professional data (Experts): employment history, areas of expertise, education, qualifications, publicly available professional profiles, and answers to screening questions.
• Engagement data: project briefs, consultation requests, scheduling details, call notes, compliance attestations and feedback.
• Financial data: billing details, invoicing information and, for Experts, payment details needed to pay consultation fees.
• Communications data: the content of messages you send us through the contact form, by email or by other means.
• Technical data: IP address, browser type, device information, and server logs generated when you access the Website.
• Account data: login details and usage information if you use our software or platform.

We collect this data directly from you, from your organisation, from publicly available professional sources (such as professional networking sites and company websites), and automatically when you use the Website. We do not intentionally collect special categories of personal data (such as health data or political opinions) and ask that you do not provide them.

4. Purposes and legal bases

We only process personal data where we have a lawful basis to do so. The table below summarises our main purposes and the legal bases we rely on.

Where we rely on legitimate interests, we have balanced our interests in running and developing our business against your rights and freedoms. Where we rely on consent, you can withdraw it at any time without affecting the lawfulness of processing carried out before withdrawal.

5. Information about experts

As an expert network, identifying suitably qualified professionals is central to our services. If you are an Expert, or a professional we believe may be relevant to a project, please note the following:

• We may compile a professional profile using information you provide and information that is publicly available in a professional context.
• When we first contact you using information from public sources, we will tell you how we obtained your details and give you the opportunity to object or to request deletion.
• We share a summary of your professional background with a Client only in connection with a specific project, and we do not disclose your contact details to Clients without your agreement.
• We will ask you to confirm compliance obligations (such as confidentiality and the absence of conflicts) before each engagement, and we keep a record of these confirmations.

6. Cookies and analytics

The Website is designed to respect your privacy. We do not use advertising or tracking cookies, and fonts and other assets are served from our own domain rather than from third-party providers.

Our hosting provider may automatically record technical data, such as your IP address, browser type and the pages requested, in server logs. These logs are used to deliver the Website securely and reliably and are kept only for a limited period.

If we introduce analytics or other non-essential cookies in the future, we will update this policy and, where required, ask for your consent before setting them.

7. Sharing your data

We do not sell personal data. We may share personal data with:

• Clients, to the extent necessary to propose and deliver expert consultations (for Experts, this is limited to professional information relevant to the project);
• Experts, where limited Client information is required to schedule and conduct a consultation, subject to confidentiality obligations;
• Service providers acting on our behalf, such as hosting, IT, communications, scheduling, payment, accounting and professional advisory providers, under written agreements that require them to protect personal data;
• Authorities, regulators and courts, where we are required to do so by law or to protect our rights, property or safety, or those of others; and
• Successors in connection with a merger, acquisition, reorganisation or sale of all or part of our business, subject to equivalent confidentiality and data protection commitments.

8. International transfers

Our Clients and Experts are located around the world, and some of our service providers may process personal data outside the European Economic Area (EEA). When we transfer personal data outside the EEA, we ensure an adequate level of protection, for example by relying on an adequacy decision of the European Commission or by using the Standard Contractual Clauses approved by the European Commission, together with additional safeguards where appropriate. You can request more information about these safeguards by contacting us.

9. Data retention

We keep personal data only for as long as necessary for the purposes described in this policy, including to meet legal, accounting and reporting requirements. In general:

• enquiries that do not lead to a business relationship are kept for up to 24 months;
• Client and project records are kept for the duration of the relationship and for up to 7 years afterwards, in line with Estonian accounting and limitation periods;
• Expert profiles are kept while the Expert remains part of our network and reviewed periodically, and are deleted on request unless we must retain certain records (such as compliance attestations or payment records) to meet legal obligations; and
• server logs are kept for a short period, normally no longer than 90 days.

10. Security

We use appropriate technical and organisational measures to protect personal data against accidental or unlawful destruction, loss, alteration, unauthorised disclosure or access. These include encryption in transit, access controls based on the principle of least privilege, confidentiality obligations for staff and contractors, and careful selection of service providers. No method of transmission or storage is completely secure, but we work continuously to protect your information.

11. Your rights

Subject to the conditions set out in the GDPR, you have the right to:

• access the personal data we hold about you and receive a copy;
• rectify inaccurate or incomplete personal data;
• erase your personal data ("right to be forgotten");
• restrict the processing of your personal data;
• object to processing based on legitimate interests, including profiling, and to direct marketing at any time;
• data portability, that is, to receive personal data you provided in a structured, machine-readable format; and
• withdraw consent at any time where processing is based on consent.

To exercise any of these rights, please email info@ondemandtalentfow.com. We may need to verify your identity before responding. We will respond within one month, which may be extended by two further months for complex or numerous requests, as permitted by the GDPR.

12. Children

Our services are intended for businesses and professionals. They are not directed at individuals under 18 years of age, and we do not knowingly collect personal data from children.

13. Changes to this policy

We may update this Privacy Policy from time to time to reflect changes in our services, legal requirements or business practices. The "Last updated" date at the top of this page shows when it was last revised. Where changes are significant, we will take reasonable steps to inform you.

14. Contact and complaints

If you have any questions about this Privacy Policy or how we handle personal data, please contact us:

On-demand Talent & FoW Company OÜ
Viru väljak 2, 3. korrus
Kesklinna linnaosa, Tallinn 10111
Harju maakond, Estonia
Email: info@ondemandtalentfow.com

You also have the right to lodge a complaint with a supervisory authority. In Estonia, this is the Data Protection Inspectorate (Andmekaitse Inspektsioon), Tatari 39, 10134 Tallinn, www.aki.ee. You may also contact the supervisory authority in the EU member state where you live or work. We would, however, appreciate the chance to address your concerns first.