Privacy Policy
Last revised: 8 February 2024This privacy policy serves as a transparent and comprehensive guide to how Fill You In handles the personal data of our clients, collaborators, and website users. Aligned with GDPR regulations in Europe and the DPDP Act in India, our commitment is to ensure the utmost privacy and security of your information. By detailing our data processing practices, rights of data subjects, and the measures in place to protect your data, we aim to provide clarity and confidence in our approach to privacy. This policy reflects our dedication to building sustainable, long-lasting relationships based on trust and responsible data management. Additionally, it is important to note that access to personal data is restricted solely to individuals authorized to do so, ensuring stringent control over data access and reinforcing our commitment to data security and privacy.
Scope of Application
This Privacy Policy applies to the following individuals:
- Visitors of the Site with whom Fill You In does not have a contractual relationship
- Clients who use our Services, including client UBOs or representatives
- Independent Contractors who use our Services
- Fill You In community platform users
- Suppliers who provide products or services to Fill You In
- Candidates
- Prospects
- Participants of webinars, conferences, trade events, surveys, etc.
By using our site and/or our services as well as engaging with Fill You In in any way, you agree to the collection and use of your information in accordance with this Privacy Policy.
Information Collection
Fill You In collects and stores certain information about you. This information can be used on its own or in combination with other information to identify you (“Personal Information”). Below is a list of types of Personal Information that we may collect and use about you.| Categories of Personal Information | Description |
| Contact | Information we use to contact you including physical addresses, e-mail addresses, and phone numbers |
| Identification | Information we use to identify you including full name, government ID, passport, DoB, and selfie |
| Contractual | Information about the products or services we provide to you |
| Locational | Information we get about where you are, including country and IP address. This may come from your mobile phone or the place where you connect a computer to the internet. It may also include locations where you used your card. |
| Usage | Information about the usage of our Services and Site including metadata |
| Technical | Information on the devices and technology you use including IP address, login data, browser type and version, timezone, operating system, browser type |
| Communications | Information from communications between us including any personal data you may share with us in your messages, communication metadata |
| Professional | Information about professional career and educational background including current and old job positions, degrees, qualifications |
| Public and third-party records | Information about you that is in public records and information about you that is publicly available on the internet. We also collect information about you which we receive from other companies, such as (without limitation) credit reference or fraud protection agencies (see below for more information). |
| Consents | Any permissions, consents or preferences that you give us |
| Fill You In Community Platform Content | The Fill You In Community allows you to post or transmit comments, computer files, messages, and other materials. This content may include personal data |
| Other Information | Any other information you choose to provide to us through all available channels, participating in user/customer surveys or otherwise visiting and interacting with our site and/or services. |
Sources of Your Personal Information
We may collect personal information about you or your businesses from any of these sources:- Directly for you when you use our Services, complete a contact form, request marketing communications, participate in surveys or contact us.
- Fill You In collects profile and usage data when you interact with our Site and/or Services, including, without limitation, your security details, app or your web browser settings, marketing choices and data from the devices you use to connect to our platform so we can provide you with our products or services.
- We also collect information through the use of cookies and other internet tracking software while you are using our website or mobile apps as described in detail in our Cookie Policy.
- From third parties:
- Companies, business partners or individuals that introduce you to us
- Business partners, service providers, sub-contractors, advertising networks, analytics providers, search information providers, fraud protection services, Payment Service Providers (PSPs) who help us authenticate your identity, improve the quality of our Services, promote our Services and protect our business. We may also receive Personal Information about you from providers that help prevent, detect and prosecute unlawful acts, money laundering, and fraudulent behavior.
- Social networks and other technology providers (for instance, when you click on one of our Facebook or Google adverts)
- Public information sources such as (without limitation) national company registries
- Market researchers
- Government, law enforcement agencies, authorities and regulatory bodies
Information Use
Below is a list of the ways that we may use your Personal Information together with the legal basis of processing, where applicable under data protection law.
Purposes for which we use your Personal Information | Legal basis | Our reasons |
Management of the contractual relationship with you to provide you with our Services |
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Improving our business by
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| Our legitimate interest is centered around enhancing the quality of our Services, optimizing operational efficiency, and maintaining a competitive edge in the market |
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Secure access to our Services, including but not limited to performing the necessary identification and verification of our users prior to granting access to our Services |
Our legitimate interest is to safeguard access to our Services to authorized only users who have gone through identification and verification processes. |
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Marketing and events-related communications, including but not limited to inviting you to participate in events, surveys or otherwise communicating with you for marketing purposes to promote our Services |
Our legitimate interest is to tailor our marketing communications to the preferences and interests of our audience and provide a personalized and engaging experience for our customers |
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Recruitment |
Our legitimate interest is to assess candidates’ qualifications and suitability for available positions and to maintain a pool of potential candidates for future opportunities |
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Protect the security or integrity of us, our Site and our Services |
Our legitimate interest is to maintain the reliability and availability of our services by detecting and preventing security threats, fraud, money laundering and other crime, unauthorized access, risk and other activities that could harm our business, Site, or Services.
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Communicate with you about our Site and Services, such as to notify of changes and updates and to provide you with customer support and troubleshooting |
Our legitimate interest is grounded in our commitment to delivering a seamless and informative user experience and to provide assistance when needed |
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To manage our business operations including but not limited to delivering |
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Fill You In’s products and services, making and managing payments, managing fees and charges due on user accounts and debt collection | Our legitimate interests to manage our business operations efficiently, deliver our products and services, and ensure the financial stability of our company |
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Meet our legal, regulatory, and tax reporting obligations |
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To provide and maintain the Fill You In Community Platform |
Our legitimate interest to ensure that the online platform operates smoothly and effectively to provide the services or features it offers to users |
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Aggregating pseudonymised personal data and reporting anonymised salary data for the purpose of compensation benchmarking in various industries and geographies as well as for academic research purposes |
Our legitimate interest in making informed decisions about compensation strategies, remain competitive, and attract and retain talent as well as benefiting society by advancing the knowledge in fields related to compensation, labor markets, and HR practice |
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In cases where we need to process personal data for the performance of the contract with you or as required by law and you refuse to provide your information, we may not be able to perform the contract with you and consequently, we may not be able to provide certain services to you.
Communications
We may contact you with newsletters and other marketing information that may be of interest to you. You may opt out of receiving any, or all, of these marketing communications from us by following the unsubscribe link or instructions provided in any email we send or by contacting us. Please note that we may still send you transactional or administrative messages related to the Service even after you have opted out of receiving marketing communications.
Information Sharing with Third Parties
We will only share your information with the third parties listed below for the purposes described above in the “Information Use” Section unless otherwise noted at the point of collection:
- Our clients to whom you provide your services
- Trusted third-party agents, partners, suppliers, and service providers who assist us in providing the Services to you and are only permitted to use your information according to the purposes specified in their agreement with us. These third parties include website hosts, data hosts, cloud software providers, IT providers, identification verification providers, customer support providers, payment processors, financial institutions, financial advisors, legal advisors, auditors, and insurance companies. These partners are required under law and contract to keep your Personal Information confidential
- Government or public agencies, law enforcement authorities, regulators or any other entity having appropriate legal authority for receipt of you Personal Information, if required or permitted by law or legal process or if we believe that such action is necessary to comply with the law, to protect the security or integrity of our business, our Site and/or Services and to protect the safety of the users of our Services or the public
- We may disclose your Personal Information to a third party who acquires any part of our business, whether such acquisition is by way of merger, consolidation, divestiture, spin-off, or purchase of all or a substantial portion of our assets
- We may share de-identified Personal Information with academic institutions to perform research, under controls that are designed to protect your privacy—including requiring such institutions to operate under confidentiality agreements and mandating that published findings contain only de-identified and aggregated data
- From time to time, we may share reports with the public that contain anonymized, aggregate, de-identified information and statistics, and
- We may share Personal Information with our current and future Fill You In affiliates. Our affiliates may use your Personal Information in a manner consistent with this Privacy Policy
- When you provide your consent to us to share your information
Retention of your personal information
We will retain your personal data only for as long as necessary to fulfill the purposes for which it was collected, consistent with applicable law. This retention period allows us to comply with our legal obligations, resolve disputes, enforce our agreements and study customer data as part of our own research. We will not retain your data for longer than is necessary to fulfill the purpose for which it is being processed.
To determine the appropriate retention period, we take into consideration the amount, nature, and sensitivity of the personal data, as well as the purposes for which we process it. We also assess whether we can achieve those purposes through other means.
Security
The security of your Personal Information is important to us. We implement suitable measures to safeguard the information you entrust to us, preventing its loss, misuse, unauthorized access or disclosure, alteration, and destruction, addressing threats from both external and internal sources. Furthermore, we restrict access to your personal data to individuals such as employees, agents, contractors, and other third parties, but only those who require such access for legitimate business purposes. These authorized individuals will process your personal data solely based on our explicit instructions and are bound by a confidentiality obligation.
Please be aware that no method of transmission over the internet, or method of electronic storage is 100% secure and we are unable to guarantee the absolute security of the Personal Information we have collected from you. Therefore, you are also a key stakeholder in making sure that your Personal Information is protected. If you become aware of any breach of security or privacy, please contact us immediately at dpo@fillyou.
International Transfer
Information collected while you use the Site and/or Service, including your Personal Information, may be transferred to — and maintained on — computers located outside of your state, province, country or other governmental jurisdiction where the data protection laws may differ from those of your jurisdiction.
If you are located outside the Netherlands and choose to provide information to us, please note that we will transfer the information, including your Personal Information, to the Netherlands and process it there. By utilizing our Sites and/or services, you authorize the international transfer of your data, to the United States, where we are based, and to other locations where we and/or our service providers operate. Note that the Deel Platform is maintained and owned by Deel Inc., a United States entity, however Deel stores all Deel Platform data in Ireland (EU) only.
Link to other sites
Our Site may contain links to other sites that are not operated by us. If you click on a third-party link, you will be directed to that third-party’s site. We strongly advise you to review the Privacy Policy of every site you visit. We have no control over, and assume no responsibility for the content, privacy policies or practices of any third-party sites or services.
Children’s privacy
We do not knowingly collect Personal Information from children under the age of 18. Our Site and Services are not addressed to minors. If you are a parent or guardian and you learn that your children have provided us with Personal Information, please contact us. If we become aware that we have collected Personal Information from a child under the age of 18 without verifiable parental consent, we will take steps to remove that information from our servers.
Your rights
Under applicable privacy regulation, you may have some or all of the following rights in respect of your Personal Information:
- to obtain a copy of your Personal Information together with information about how your Personal Information is processed;
- to rectify inaccurate Personal Information;
- to erase your Personal Information in limited circumstances where it is no longer necessary in relation to the purposes for which it was collected or processed;
- to restrict processing of your Personal Information
- to object to the processing of your Personal Information where we’re relying on a legitimate interest;
- to object to decisions that are based solely on automated processing or profiling;
- to obtain a portable copy of your Personal Information, or to have a copy transferred to a third party controller; or
- to withdraw your consent, at any time, where you may have provided it for the collection, processing and transfer of your Personal Information for a specific purpose;
In addition to the above, you have the right to lodge a complaint with a supervisory authority for data protection.
To exercise these rights you may contact us either by emailing dpo@fillyou.in.com.
We may ask you for additional data to confirm your identity and for security purposes, before disclosing the information requested to you. If you would like to submit a request on behalf of another individual, you may do so by providing proof of authorization by the individual to submit such a request on their behalf. We reserve the right to charge a fee where permitted by law. We may also decline to process requests that jeopardize the privacy of others, are excessive, or would cause us to take any action that is not permissible under applicable laws. Additionally, as permitted by applicable laws, we may need to retain certain Personal Information for a limited period of time for record-keeping, accounting and fraud prevention purposes. Please note also that you may be able to exercise some of these rights without our intervention. For example, if you are a registered Fill You In platform user, you can access and update your personal data.
Legal Basis for Processing Personal Data
Consent
Consent serves as a lawful basis for processing personal data when the data subject willingly grants permission for specific processing activities. In the context of Fill You In’s operations, consent is obtained through clear and transparent communication, ensuring individuals understand the purpose, scope, and consequences of data processing.
Fill You In takes a meticulous approach to obtaining consent, utilizing intelligible language that avoids ambiguity. Consent forms are presented in an easily accessible manner, separate from other terms and conditions. The information provided outlines the specific processing activities, and individuals are empowered to grant or deny consent without facing adverse consequences.
Individuals retain the right to withdraw their consent at any time. Clear and straightforward mechanisms are in place to facilitate withdrawal, and Fill You In promptly ceases processing activities upon receipt of such withdrawal. Withdrawal does not affect the lawfulness of processing based on consent before its withdrawal.
Legitimate Interest
Legitimate interest provides a legal basis for processing personal data when it is deemed necessary for the legitimate interests pursued by Fill You In or a third party, except where overridden by the interests, rights, or freedoms of the data subject.
Fill You In maintains transparency by communicating the legitimate interests pursued and the rationale behind data processing. Individuals are informed about their right to object, and mechanisms are in place to address objections promptly. When processing involves sensitive data, additional safeguards are implemented to protect privacy.
Performance of contract
Processing personal data is grounded in the necessity for the performance of a contract when it is required to fulfill contractual obligations or to take pre-contractual steps at the request of the data subject.
Fill You In ensures that processing activities are directly related to the performance of a contract. Data collected is limited to what is necessary for the execution of contractual obligations, and any additional processing beyond the contract’s scope requires a separate legal basis.
To uphold the principle of data minimization, Fill You In only processes personal data essential for fulfilling contractual commitments. Unnecessary data is not collected, ensuring a focused and proportionate approach to data processing in alignment with contractual requirements.
Changes to this Privacy Policy
This Privacy Policy is effective as of the “LAST REVISED” date specified at the top of this Privacy Policy and will remain in effect except with respect to any changes in its provisions in the future, which will be in effect immediately after being posted on this page.
We reserve the right to update or change our Privacy Policy at any time and you should check this Privacy Policy periodically. Your continued use of the Service after we post any modifications to the Privacy Policy on this page will constitute your acknowledgment of the modifications and your consent to abide and be bound by the modified Privacy Policy.
Questions or concerns regarding the Privacy Policy
If you have any inquiries or concerns regarding the privacy of your data when utilizing our services, including requests to modify, delete, or access your information, we encourage you to contact our dedicated Data Protection Officer (DPO) at dpo@fillyou.in. Your privacy is of utmost importance to us, and our DPO is ready to assist you with any questions or requests you may have related to the handling of your personal data.