Active2me ("active2me" or “we/us”) is committed to protecting the privacy of all users of our Services (“You/r”), as defined in our Terms of Service. This Privacy Policy is part of the Active2me Terms of Service and explains our practices regarding the use of personal data collected and processed through our Services. Defined terms set out herein shall have the same meaning as in the company Terms of Service.
Active2me collects and processes different types of data related to different data subjects: (1) identification, contact data, data about the professional and academic experience of candidates (“Activists”), (2) identification and contact data of the interlocutor of the Employers, data about the company, (3) the email address of Validators and Company Ambassador, (4) the IP address of web users.

This data will be used by us to provide the service that Active2me offers, as well as for the other purposes established below.

We maintain the security and confidentiality of your data in accordance with applicable law.

By completing and submitting your personal data to Active2me, via any online registration or other forms presented on our Services, you declare to have read and accepted the terms of this Policy. Without prejudice to the foregoing, you expressly and unequivocally consent to the collection and processing of your personal data (as identified below) by us in accordance with the indicated purposes and this Policy. You may revoke consent at any time by writing to accompanied with a proof of your identity (copy of ID card or passport).

Please read the text below carefully for the full details of this Privacy Policy.
The entity responsible for your data is ACTIVE TO ME GESTIÓN DE TALENTO, S.L., domiciled at C/ Muntaner 239, ático, 08021, (BARCELONA), SPAIN, having CIF B-67109538. All communications regarding the processing of your personal data shall be directed to our Data Protection Responsible at
2.1 Data collected
a) Activists
We collect and process the following data of people registering in our platform as Activists: 
• Registration (Registration Data).
On registering in our platform, we will collect the following personal data:
o    Email address
o    Password
• Profile (Profile Data).
In order to create a profile as Activist, we collect and process the following data:
o    Profile image, name, surname, location, phone number (optional)
o    CV (academic and professional data, languages spoken) and whether the activist is looking for his / her first professional experience
o    Skills possessed (it is possible to choose among pre-existing skills, or creating new ones)
o    The dream job you would like to do
o    A short description about you
o    Social media accounts
o    Selected and favourite job offers
• Asking for a skill validation (Validation data).
 When you ask for a skill validation, we collect and process:
o    Name and email address of the validator.
b) Employers
If you register as an Employer, we will collect the following data:
•    Registration (Registration Data).
 On registering in our platform, we will collect and process the following personal data:
o    Email address;
o    Password.
•    Profile (Profile Data).
 When creating an Employer profile, we will collect and process the following data:
o    Company name and logo, Tax identification code, company description;
o    Name of the interlocutor of the company, work email, work phone number;
o    If different from the interlocutor, name, email and phone number of the administrator of the profile;
o    Profile image;
o    Link to profiles on LinkedIn, Facebook, Instagram, YouTube, Vimeo.
•    Posting a job (Job Post Data).
 When creating a job post, we will collect and process the following data:
o    Job definition, job description and required skills
o    Name and email address of the Company Ambassador. A Company Ambassador is a person designated by the Company to expand data on the company or on job offers published by the company to any activist who is or may be interested in signing up for it.
c) Validators
If an Activist ask you to validate one or more of his / her skills, you will need to provide us the following information:
o    Email address, password
o    Telephone number (optional)
d) Guest
If an Activist invites you to participate in the Platform, we collect the following personal data provided by the Activist:

Email address
e) Web users
When people access our website without being registered, we will automatically collect the following information:
o    IP address
o    Cookie data

Except when indicated as optional, these data are mandatory and if they are not provided, the profile cannot be created or the action we are required to perform cannot be carried out.

It is important that the personal data we have about you is accurate and current. You are responsible for the accuracy of the information you provide to us and you are expected to update the information you provide to us.
2.2 Data use
We use your personal data to:
•    Create your profile, and manage your privacy option as an Activist (Active, Dormant or Invisible)
•    Facilitate the communication between Employers and Activists, allowing on one side Activists to apply to job offers, and on the other side allow Employers to see Activists’ profile and curriculum vitae from active Activists.
•    Manage the service you are requesting us. If you allow us to send you notifications, we will send you reminders, confirmation of registration to job offers, changes in the status of candidacies, technical notices, updates, security alerts, support messages, among others.
•    Allow both Activists and Employers to use our instant messaging service. Users of our platform can communicate using our messaging service, being themselves fully responsible of the content of the messages.
•    Send messages and/or notification about improvements or new features in our products and services.
•    Give Activists advices based on the skills possessed and the dream job. We will advise Activists about skills they need, courses to follow or job for which they are qualified.
•    Conduct internal analysis in order to improve our services according to the preferences of our Users.
We use the Validators’ data provided by Activists to contact them to confirm or not the competences declared by the Activists. The Activists confirm that they have the consent from Validators to submit their contact information to the Platform and that we can contact them for this limited purpose.
We use the Guest data provided by Users to invite them to participate in the Platform (for example, see a job offer or publish your CV). The Users confirm that they have obtained Guests’ consent to submit their contact information to the Platform and that we can contact them for this limited purpose.
We use the Ambassadors’ data provided by Users to invite them to expand data on the company or on job offers published by the Company to any Activist that is or may be interested in subscribing to it within the Platform. The Users confirm that they have the consent of the Ambassadors to submit their contact information to the Platform and that we can contact them for this limited purpose.
The legal basis of our processing of personal data are the following:

•    For registered users, both Activists and Employers, the processing of data is necessary to provide them with the contracted service and execute the contract in which the users are a party, or to take action when requested before entering into such contract.
•    Registered users also provide us their express consent to process their data, when signing up in the platform accepting this Privacy Policy.
•    Regarding validators’ and ambassadors’ data, our legal basis is our and our Users’ (both activist and companies) legitimate interests in ensuring that all the data is true and accurate (data quality).
•    Regarding the Guest data, our legal basis is the legitimate interest of the company to promote its service among the contacts of its Users, based on the recommendation of the inviting User and with the confirmation of their consent.

In certain circumstances, we may process your data in accordance with this policy to comply with a legal or regulatory obligation to which we are subject.
We give Activists the opportunity to choose whether to show their profile or not, choosing among the following profile privacy setting:
o    Active: the profile is fully visible by Employers. Both the companies and the staff of active2me can access your photo, name, contact information and profile and can contact you. You can request and receive validations about your education, experience and skills.
o    Dormant: Employers do not have access to your profile, photo and any identification or contact data. They will only see the initials of the Activits’ name and surname. You can request and receive validations about your education, experience and skills.
o    Invisible: Employers do not have access to your profile, photo and any identification or contact data. They will only see the initials of the Activits’ name and surname. You cannot request and receive validations about your education, experience and skills.
We treat your personal data confidentially in accordance with the applicable legislation. Unless stated otherwise, your personal data will not be provided to third parties.

For the purpose of providing the Active2me services, Activists authorize Active2me to reveal their personal data of the Active and Dormant Profiles to companies that use the platform (Employers) within the limits of the privacy setting chosen by each Activist.

Active2me may in the future disclose or communicate to third parties certain statistical reports with anonymized data, deriving from data collected from the Platform.

We give access to Users’ personal data to our IT and advisory service providers under contracts for the provision of services in favour of the company. We require that all third parties respect the security of their personal data and process them in accordance with the law. We do not allow our external service providers to use your personal data for their own purposes and we only allow them to process your personal data for specific purposes and in accordance with our instructions.
We use several third-party services to provide our Services, some of which are located in the US, a country that does not provide adequate general guarantees for the protection of personal data (Google). However, these companies are part of the shield of privacy "EU-US Privacy Shield" (that you can check here).
Active2me ensure that, for all companies outside the EEA that are not under the EU_US Privacy Shield, an agreement requiring with the contractual guarantees required by law was signed. You can contact us to consult or obtain a copy of these agreements.
We will retain the personal data submitted through registration and collected during the provision of our services until termination of the Agreement and deactivation of your Account either by you or us. Once such personal data is no longer used for these purposes, they will be blocked (stored securely) for a period of 6 years, for legal or administrative reasons, such as the defence of our responsibility and compliance with mandatory legal obligations, subject to applicable law. Please note that we may keep the statistical data collected from you in an anonymous format for an unlimited time.
We implement security measures and personal data protection schemes as required by law to maintain the confidentiality and integrity of your data and protection against unauthorised access, modification or destruction. 
To provide our skill matching service, as described in our Terms of Service (link), we evaluate certain Activists’ personal aspects related to their professional profile and the skills they possess. We use an algorithm which indicate the percentage of matching of Activists with each job offer. This service falls into the definition of profiling set forth by Art 4 GDPR.

Even though we carry out profiling activities, the result of such activities does not produce any legal effects concerning the Activist or affecting him/her and. Indeed, we provide just an advisory service, and all matches and hierarchy of demand/offers are non-binding and do not exclude either Activist or Employer from access or reviewing the available information on the Platform.

It is up to each Party (Activist and Employer) to decide if the corresponding CV or job offer fits their purpose and required skill set, and – as the case may be - to enter into a separate legal employment relationship, based on interviews and other actions off the platform taken by the Parties.
You have rights under data protection laws in relation to your personal data. Specifically, you have the right to:
• Request access
 to your personal data (commonly known as a "data subject access request"). This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it.
• Request correction
 of the personal data that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.
• Request erasure
 of your personal data. This enables you to ask us to delete or remove personal data where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal data where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your personal data to comply with local law. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.
• Object to processing
 of your personal data where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms. You also have the right to object where we are processing your personal data for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms.
• Request restriction of processing
of your personal data. This enables you to ask us to suspend the processing of your personal data in the following scenarios: (a) if you want us to establish the data's accuracy; (b) where our use of the data is unlawful but you do not want us to erase it; (c) where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims; or (d) you have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.
• Request the transfer
 of your personal data to you or to a third party (right to data portability). We will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.
• Withdraw consent at any time
 where we are relying on consent to process your personal data. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain products or services to you. We will advise you if this is the case at the time you withdraw your consent.
The aforementioned rights may be effective by contacting us at

You also have the right to make any complaint to the competent authority, in this case the Spanish Data Protection Agency (Agencia Española de Protección de Datos), C/. Jorge Juan, 6, 28001 Madrid, Spain. 
We reserve the right to amend the terms of this Privacy Policy and will notify you by providing a clear notice of these changes by email or on our Website, and in this Privacy Policy. If you continue to use our Services after such update, you will be deemed to accept the new terms. If you do not accept the update, please terminate your account or notify us and we will terminate your Account and remove any of your personal data (except as required to be maintained for legal purposes), and you will not be able to continue to use our Services.

Unless a specific local regulation sets forth to the contrary, the Privacy Policy is governed by the laws of Spain.

Version 1: November 7th 2018
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