Privacy
privacy policy
OLE Online Services SRL Privacy Policy
The last update was on April 07, 2025. You can access the previous version of this Privacy Policy here .
We care about your privacy and are committed to protecting your personal data. This Privacy Policy informs you about how we handle your personal data, your rights in relation to data privacy and how you are protected by law. Please read this Privacy Policy carefully before using our Services.
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Who are we?
What data do we collect about you?
Do we collect data relating to minors?
What are the reasons for which we process your personal data?
Data processing within the services of the OLE Developer Portal
Data processing within the OLE services "OLE Jobs"
How we will inform you about changes to our Privacy Policy
Your rights
Communication and marketing
To whom do we disclose your data?
International transfers
Where do we store your data and for how long?
Technical and organizational measures and security of processing
Links to third-party websites
Contact details
Data Protection Authority
This Privacy Policy applies to your use of any products, services, content, features, technologies or functions and all websites, mobile applications, mobile sites or other online products or applications offered to you by us (collectively, the "Services").
Who are we?
The main controller of your data for the purposes of our international services is OLE Global BV, a limited liability company with its registered office at 20 Wenlock Road, London, England, N1 7GU . OLE.ad is the parent website service of the tra.co.serv. ltd entity that provides you with our Services in accordance with our Terms and Conditions of Use (hereinafter collectively referred to as "OLE", "we" or "our" in this Privacy Policy). This OLE entity is also considered the data controller for the local services it provides. The relevant contact details can be found under section 15.
The local data controller processing your personal data is: TRA.CO.SERV. LTD, a UK legal entity with its main office in London, tax attribute UK, registered in the Personal Data Processing Register under no. 15839367.
What data do we collect about you?
2.1.1 Data obtained from direct interactions
Registration and other account information
When you register to use our Services, we may collect the following information about you:
if you register directly on our platform, you will be asked to provide your email address;
if you register using your Google account: your first and last name, email address and URL to your Google profile photo;
if you register using your Facebook account: the first and last name that appears on your Facebook account, the email address associated with your Facebook account, your Facebook ID, and the URL to your Facebook profile photo. If you have granted permission to Facebook through its privacy option within the application (which appears just before registering on our Services), we may collect data regarding your gender, age, or email address, depending on the permissions you have granted; and
if you register using your Apple ID: your first and last name and email address; you can decide whether you want to share your email address with us when you sign in to your Apple account.
Depending on the choices you make during authentication for our Services or during the process of contracting our Services, you may choose to provide us with the following additional personal data:
your name;
home address;
mobile phone number;
your payment details, if you wish to use our paid services, as defined in our Terms and Conditions of Use , which, depending on the payment method used, include
your credit and/or debit card details (cardholder name, card expiration date, credit card type, the first and last four digits of your credit card number, and the CVV/CVC code, which is transmitted to the payment processor and is not stored by OLE);
mobile phone number;
email address.
Your Country and Region (County)
Your city or district (for London Municipality).
data relating to studies, professional experience, skills, photos, preferences related to the desired job, as well as any other information included in your CV or submitted directly to your employers through our Services, when you opt to provide us with this data via the "My CV" function within your OLE Account settings to apply for one of the jobs published in the "Jobs" section.
Validity of your OLE account
We validate OLE user accounts using SMS verification to ensure that each account is associated with a real and unique user. This validation process is initiated when you publish your first ad listing on our Services. To validate your OLE account, before publishing your ad listing, we will send you an SMS from a valid mobile phone number provided by you. This process is completely free.
If you do not agree to the validation of your account, it will still remain active and you will be able to use our Services with limited functionality. This limited functionality of an account means that you cannot publish new ad listings and you cannot edit, update, promote, expand, reactivate, deactivate or delete existing ad listings until your account is verified via SMS. You will also not be able to receive or reply to any messages from other users.
If you create multiple OLE accounts using the same mobile number and validate all those accounts through SMS verification, all those accounts will have limited functionality and you will be asked to choose one of them. The account you chose will revert to full functionality and the other accounts will continue to have limited functionality.
Any user can request a maximum of 5 SMS verification codes within 24 hours. Account validation is performed once for each account, until it is successfully verified by the user via SMS.
Once you have validated your OLE account, it will still be associated with the mobile phone number used for SMS verification. If you wish to change the mobile phone number associated with your OLE account, you will need to contact our Customer Support team using the Contact Form .
Communicating via the chat feature within our Services
When you use the chat application to communicate with other users, we collect and process the content and information you choose to provide to us through this feature.
Recording telephone conversations with our customers and sales teams
When you call or opt to be called by one of our customer service representatives or sales team, we record the conversation, subject to your explicit consent, in order to improve our customer interaction practices.
Audio and video recordings for specific studies related to customer interaction
When you expressly agree to participate in customer interaction studies occasionally conducted by OLE, we will record your interaction with our team. For each study conducted by OLE, we will provide you with specific information on how we process your personal data and the purpose for which we do so.
Participation in our user surveys
Occasionally, we will send you our user surveys to measure your overall satisfaction with the quality of the services provided by OLE. In this regard, we will only process your "session long" code (this is a random identification code assigned to you when you download our mobile applications or visit our website).
Furthermore, you may decide to provide us with your contact details, such as your email address and mobile phone number, when we ask you to contact us and invite you to participate in one of our user experiences (UX) or an interview with our team. Please note that the information you provide to us in connection with the questions contained in the questionnaire may occasionally include personal data that you voluntarily provide in your responses.
Rating and feedback
We collect information about the evaluation and feedback you provide to other users following your interaction with them, as well as about the evaluation and feedback you receive from other users, in accordance with the Terms of Use . We do this to measure user satisfaction with the transactional experience and to ensure an optimal and efficient level of communication between users, as well as to verify and prevent inappropriate actions and behaviors in the context of the activity carried out in connection with our Services, this information allowing us to take the necessary and appropriate measures to maintain high standards in the provision of our Services.
2.1.2 Data we collect automatically when you use our Services
When you use our Services, we automatically collect the following information about you:
Information regarding the devices used
We collect specific information about the devices you use, such as the operating system version or unique identifiers. For example, the name of the mobile network you are using, your IP address, the language settings on your device, the make and type of device, the operating system and version of your device, the type and version of your browser, and specific software information, such as fonts, system and browser time zone, or available video and audio formats. If you are logged in, we associate your device identifiers with your OLE account.
Location information
Depending on the permissions granted by your device, if you post any ads through our Services, we automatically collect and process information about your actual location. We use various technologies to determine location, including IP address, GPS, Wi-Fi access points and cell towers. Your location data allows us to see articles from users near you and helps you post ads in the area where you are. If we need your location data, we will first present you with a “pop-up” asking you to decide whether or not to allow us to access your location data from your mobile device. If you do not allow us to access your location data, you will still be able to use our Services but with limited functionality. If you allow us to access your location data location data, you can change this option at any time later by accessing the settings on our website or mobile application and disabling the permissions granted in relation to location sharing. To find out more details about the purposes for which we use your location data and how this data is processed, please see section 4.2 (ii) of this Privacy Policy.
Customer and authentication data
Technical details, including your device's internet protocol (IP) address, time zone and operating system. We will also store your login information (registration date, last password change date, last successful login date), your browser type and version.
Clickstream data
We collect information about your activity on our Services, including the websites from which you accessed our Services, the date and time stamp of each visit, the searches you performed, the ad listings or banner ads you clicked on, your interaction with such ads or ad listings, the length of your visit, and the order in which you viewed content on our Services.
Cookies and similar technologies
We use cookies to manage our users' sessions, store your language preferences, and deliver relevant ads to you. Cookies are small text files that a web server transfers to your computer's hard drive. Cookies may be used to collect the date and time of your visit, your browsing history, your preferences, and your username. You can set your browser to refuse all or some cookies or to alert you when websites set or access cookies. If you disable or reject cookies, please note that some parts of our Services may become inaccessible or may not function properly. For more information about the cookies we use, please see our Cookie Policy and Similar Technologies . In section 10, you will find more information about how we share this information with our analytics providers and advertising partners.
2.1.3 Data from third parties or publicly accessible sources
We receive your personal data from various third parties and publicly available sources, which we may combine with or connect to the personal data we collect from you through our Services. Specifically, this includes the following information:
if you register using your Google account, we receive the email address associated with your Google account (for creating your OLE account and sending you system notifications and marketing messages), your Google ID and your full name (used as your username when you use our Services), as well as the URL to your profile photo (for creating the profile photo on your OLE account);
if you register using your Facebook account: we receive the email address associated with your Facebook account (for the purpose of creating your OLE account and sending you system notifications and marketing messages), as well as information regarding your public profile, including your Facebook ID, first and last name (used as your username when using our Services) and the URL to your Facebook profile photo (for the purpose of creating your profile photo for your OLE account);
certain technical and usage information from analytics service providers, such as Google Analytics 360, for statistical purposes and to analyze the use of our Services, in order to improve our Services and for online marketing (more details regarding this can be found in section 9);
if you decide to store your payment card details with us, we receive the following details about your card from our payment service partners, such as PayU SA: first and last name, card expiry date and the first and last four digits of your card number;
government authorities provide us with your username, phone number and email address when they request OLE to conduct checks or provide these authorities with additional data in the context of fraud prevention activities;
Rating and Feedback: If you act as a seller on our Services, we collect and make available information about the rating and feedback you have received from other users, following your interaction with them, in accordance with the Terms of Use . This is a part of our Services that aims to measure user satisfaction with regard to the transactional experience and ensure an optimal and efficient level of communication between users, as well as verify and prevent inappropriate actions and behavior in the context of the activity carried out on our Services, this information allowing us to take the necessary and appropriate measures to maintain high standards in the provision of our Services.
Do we collect data from minors?
Our services are not directed at children under the age of 16 and we do not knowingly collect data from anyone under the age of 16. If we become aware that a person under the age of 16 has provided us with personal data, we will delete this data without delay.
What are the reasons for which we process your personal data?
We will only use your personal data where the law allows us to do so. Most commonly, we will use your personal data in the following circumstances:
in the situation where we need to execute the contract that we are about to conclude or that we have concluded with you;
when this is necessary in accordance with our legitimate interests and when we consider that our legitimate interests are not overridden by your interests or those of other data subjects or your fundamental rights and freedoms, for example, to improve our Services and to enhance the safety and security of our Services;
when we need to comply with a legal or regulatory obligation.
In certain circumstances, we may also process your personal data based on your consent. In this case, we will inform you of the purpose and category of personal data to be processed at the time we request your consent.
Below we describe why we use your personal data and the legal grounds we rely on when we do so. We have also identified our legitimate interests, where applicable.
To ensure access to and provision of the Services
If you log in using your mobile phone number or email ID, we use your first and last name, mobile phone number and/or email address to identify you as a user and grant you access to our Services.
If you sign in using your Facebook account or Google account or your Apple ID, we use the first and last name and email address associated with that account, as well as the URL to your profile photo (excluding your Apple account) to identify you as a user of our Services and to grant you access to our Services. The above authentication data is also used by us to provide our Services to you in accordance with our Terms of Use .
We use third-party payment service providers to process any payments you make in connection with our Services. Depending on your payment method, you may be asked to provide us with your payment and credit/debit card details, which we will then pass on to the payment service provider for the purpose of processing your payment. We do not store your credit card information unless you choose to save this information to make recurring payments easier without having to re-enter your details each time. In such cases, we only store the cardholder name, card expiration date, card type, and the first and last four digits of your card number. We do not store any credit card verification code values and only transmit such values and your credit card number in an encrypted manner for the purpose of processing your payments to the payment service provider.
We store your data regarding your education, professional experience, skills, photos, preferences related to the desired job, as well as any other information included in your CV or submitted directly to employers through the Services in order to facilitate your direct communication and the transmission of this data to employers who publish job advertisements in the "Jobs" category. The legal basis for this processing is the conclusion and performance of the contract between OLE and you, based on which OLE can provide you with services related to the "Jobs" category.
We process the information mentioned above for the proper execution of our contract with you.
To improve your experience with our Services
We use clickstream data to:
to provide you with personalized content, such as providing more relevant search results when you use our Services; and
determine how much time you spend on our Services and how you navigate our Services to understand your interests and improve our Services based on this data. For example, we may provide you with suggestions about what content you can visit based on the content you have clicked on.
If you decide to provide us with your location data, we use this data for the following purposes:
for compiling anonymous and aggregated information regarding the characteristics and behavior of users of the OLE service, including for the purpose of analyzing, segmenting and developing the activity of anonymous profiles;
to improve the performance of our Services and to personalize the content we send to you. For example, we use location data to display listings of ads that are in your vicinity to improve your shopping experience. In this regard, Google Maps is integrated into our Services. Google Maps is provided by us and Google, acting as independent data controllers. This means that both Google and we are responsible for the processing of your location data in the context of Google Maps. In any case, we will not process your location data for any purposes other than those explained in this Privacy Policy. However, Google may process such location data for its own purposes, as explained in Google's Privacy Policy, which can be found here . Your use of the Google Maps application through our Services is subject to the Google Maps Terms of Service .
Using the contact information in your account, which includes your email address and mobile phone number, we map the different devices (such as desktops, mobile phones, tablets) you use to access our Services. This allows us to associate your activity on our Services across these devices and helps us provide you with a seamless experience, regardless of the device you use.
We use the images you upload, descriptions, and prices you provide in your listings to train machine learning models to personalize search results based on your listing's ranking and user interest, to improve the identification and presentation of items in your listings, improve search functionality, and increase the likelihood of a successful sale. This helps us improve our Services and provide you with an enhanced user experience.
To display and provide you with recommendations about ad listings on our Services that may be of interest to you, we use algorithms that use information about your browsing behavior, items purchased, clickstream data, your user ID, and your location data, if you have given us permission to use it. We use this form of automated decision-making based on our legitimate interest in improving our Services and providing an enhanced user experience by providing more relevant ad listings.
We access and analyze your communications with other users through the chat feature of our Services to improve our products and provide you with an enhanced user experience (e.g., to identify products that are sold and to provide you with only active listings). As a result, we develop and train machine learning models and algorithms to automatically analyze the content of your chat communications. In order to build and train our machine learning models, our machine learning specialists may manually analyze samples of the content of your chat messages. In these circumstances, highly restrictive access rights are granted to selected machine learning specialists who analyze the content of your chat communications. As part of this analysis process, we anonymize the content of your communications to the extent possible by applying a scanning filter to detect and hide personal data, such as names, phone numbers, or email addresses. However, there may still be instances beyond our control where the content of communications could display certain personal data that you have chosen to provide.
Using the “session long” identifier (a random identifier assigned to you when you download our mobile application), we will occasionally send you user surveys designed to determine your level of satisfaction with the quality of our Services. When we send you a survey, we may also ask for your email address or mobile phone number in order to contact you and invite you to participate in user experience (UX) testing or an interview with our team.
To measure the level of user satisfaction related to their trading experience and to ensure an optimal and efficient level of communication between users, as well as to verify and prevent inappropriate actions and behaviors in the context of the activity carried out in connection with our Services, we collect information regarding evaluations and feedback regarding interactions between users in connection with our Services, this information allowing us to take necessary and appropriate measures to maintain high standards in the provision of our Services.
We process the information mentioned above for the proper performance of our contract with you and based on our legitimate interest in improving your experience using our Services.
To ensure the safety and security of the Services
We use your mobile phone number, login details and unique device identification codes for the purposes of administering and protecting our Services (including troubleshooting, data analysis, testing, fraud prevention, system maintenance, support services, reporting and data hosting).
We access and analyze your communications with other users that you have through the chat feature of our Services to verify customer satisfaction, for security reasons, and for fraud prevention purposes (e.g., to block spam or abusive messages that may be sent to you by other users). As a result, we develop and train machine learning models and algorithms to help us automatically detect and prevent inappropriate or fraudulent user behavior. During the analysis and training process, we anonymize the content of chat communications to the extent possible by anonymizing the unique identifiers assigned to users. However, there may still be instances beyond our control where the content of chat communications may reveal certain personal data that you have chosen to provide. Only in limited cases and circumstances do our customer safety and security specialists manually review the content of chat communications, for example, if we have strong indications that lead to suspicions of fraudulent activity. In these situations, extremely strict access rules apply to selected customer safety and security specialists who review the content of chat communications.
To prevent and detect fraud on our Services, we use algorithms capable of recognizing suspicious or fraudulent user behavior based on certain information such as user activity and published content, which may lead us to ban certain user accounts. Automatic banning occurs when there is an extremely high level of certainty that an account or action is fraudulent. Otherwise, an analysis is performed by the human factor, namely by specialists responsible for customer safety and security, based on extremely restrictive access rights. We use this form of automated decision-making based on our legitimate interest in detecting and preventing fraud and maintaining the safety and security of our Services for users. If you believe that your account has been banned unjustifiably, you can contact us via the Contact Form , in which case our team will review the decision to ban your account.
We collect certain information from and about the electronic device you use to access our Services based on our legitimate interest in preventing fraud on our Services. The information we collect includes your user ID (depending on whether you are logged in or not), OLE country domain, IP address, device settings such as language, device make and type, device operating system and version, browser type and version, and specific information about the device software, such as fonts, system and browser time zone, and available video and audio formats. Device information is used to determine whether the same device is used when users interact with our Services. We associate this information with a fraud score for the user, based on which we may ban certain users. For more information on this topic, please see our Cookie and Similar Technologies Policy . If you believe that your account has been unjustly banned, you can contact us via the Contact Form , in which case our team will review the decision regarding the banning of your account.
We process the information mentioned above for the proper performance of our contract with you and based on our legitimate interest in preventing fraud and improving the overall quality and effectiveness of our Services.
To promote and offer you Services that may be of interest to you.
We use your email address and mobile phone number (via SMS) to provide you with suggestions and recommendations regarding our Services that may be of interest to you.
To send you email communications to provide you with suggestions and recommendations regarding ad listings or our Services, we use algorithms that are capable of using information based on your clickstream data. We will always provide you with the opportunity to opt out of such communications by including an unsubscribe link. We use this form of automated decision-making based on our legitimate interest in improving our Services, increasing the number of transactions within our Services, and providing an enhanced user experience by providing more relevant ad listings.
We use clickstream data to monitor and report on the effectiveness of campaign execution for our business partners and for internal business analysis.
If you decide to provide us with your location data, we may use this data to measure and monitor your interactions with third-party advertising banners placed by us within our Services.
We process the information mentioned above based on our legitimate interest in conducting marketing activities to provide you with Services that may be of interest to you. Specifically, you may receive certain marketing communications from us:
through any preferred means of communication, if you have requested such information from us;
by email, regarding similar products and services, if you already use our Services or have purchased some of our products;
by telephone or email, if you provided us with your details when you entered the competition; or
by phone or email, if you have registered for a specific promotion.
You can ask us to stop sending you such marketing communications at any time by clicking on the unsubscribe link in the email message sent to you or by changing the notification settings in your account.
In other situations than those mentioned above, we will use your email address and mobile phone number to send you direct marketing communications (via email, push notifications, SMS or phone calls), if you have given us your consent to do so by checking the relevant box when registering on our Services. You can change your mind at any time and withdraw your consent through your OLE account settings.
If you experience any issues changing your notification settings, please contact us using our Contact Form .
To provide you with quality customer support services
we record your telephone conversations with members of the customer relations team or members of the sales team only subject to your explicit consent;
If you agree to participate in our customer interaction studies occasionally conducted by OLE, we will make a video recording of your interaction with our team in order to improve our Services.
We process the personal data mentioned above for the purpose of in-depth analysis of your interaction with members of our customer relationship team or sales team (as applicable) and to improve the way in which our team members serve customers.
You can withdraw your consent at any time and free of charge by using our Contact Form .
Data processing within the services offered through the OLE Developer Portal
The OLE Developer Portal is a tool aimed at individuals or legal entities who wish to publish their ads through our Services.
For the purpose of providing OLE API services within the OLE Developer Portal, we process the personal data of our users who are software developers or individual contractors/employees of such developers (hereinafter collectively referred to as the “Developer” or “Developers”). In relation to this specific service, we process: the name of the application, the name and surname of the Developer’s contact person, as well as the corresponding telephone number.
The use of the OLE API services requires activation using the details of the OLE account. Each time a new application (“Application”) is added by a Developer, it is necessary to complete a dedicated form and provide us with additional information regarding the Application and the contact person, in accordance with the provisions of the OLE Developer Portal Terms and Conditions . Providing us with the information requested through the form is strictly voluntary, but is nevertheless necessary for the use of the OLE API service. In connection with the use of the OLE API services, we also process data regarding the activity of the Developers within the OLE website.
We process the information mentioned above for the proper execution of the contract you have concluded with us, to improve our Services and based on our legitimate interest in preventing fraud or abuse.
OLE is not responsible for the legality of the processing of users' personal data in connection with the Application added by the Developer. The obligation to provide reliable information regarding the rules for using the Application, the security policy, as well as other information provided for by applicable law, in particular the provisions relating to the protection of personal data, rests with each Developer. OLE imposes as a mandatory rule for Developers the updating and support of the Application, in particular ensuring the security of user data processed through it.
In order to exercise the rights conferred on him/her under the provisions relating to the protection of personal data, any user using the Application must directly contact the Developer or the entity indicated in the corresponding document presenting the rules for using the respective Application.
Data processing within the "OLE Jobs" services
6.1 Processing of personal data in the recruitment process
To facilitate the process of responding to job postings included in the "Jobs" category, we have made it possible for our users to add, store and use their CVs in our Services (hereinafter referred to as "Candidate" or "Candidates", in the plural). Candidates can save their CV during the process of responding to a particular job posting, as well as from their account settings in the Candidate Profile tab - "CV" section (also available through the "Settings - Your CV" tab). An Account can be assigned only one CV file at a time. Changing or adding a CV file during the application submission process to a job posting using the form provided by the Platform will also be reflected in your Account. Depending on the options available on the Platform during the application submission process for a job posting, the CV file may be automatically attached to the application you submit, which will always result from the application submission form on the Platform. You can retain control over whether or not to submit your CV to the Employer even if it is automatically attached to your application in accordance with the terms described in the previous sentence, by unattaching the CV file to a specific application, using the functionality provided in the form.
You can manage your CV saved in your OLE account by adding or deleting certain files in the "Candidate Profile" tab - "CV" section and by using the dedicated button, in the process of submitting an application, using the form. Once your CV is saved in your account, you will not have to attach a separate file every time you respond to a job advertisement.
The CV is visible in your user account until it is removed by the user, not exceeding the time of account deletion.
The CV and any other data provided to the selected employer or stored through the Services will be processed by the employer's account for four (4) months from the moment of their receipt, regardless of whether the user account has been deleted or not. The above does not apply to the Candidate Profile service, within the scope of application referred to in point 1.8. letter b of Annex 1 to our Terms of Use . In this case, the reference to the content of the Candidate form is active as long as this service is activated on the Candidate Account.
When the Candidate submits his/her personal data to an employer, the latter becomes a separate and independent controller of such data for the purposes of recruitment and possibly for other purposes determined by the employer. Thus, the employer may store the Candidate's data outside the employer's account and assign it a separate retention period outside of our Services.
Therefore, OLE, as the controller of personal data, is only responsible for the processing of the Candidate's data as part of the Services.
Within our Services, in the "Candidate Profile" section, you have the opportunity to complete a candidate profile, in which you voluntarily provide personal data, such as: your name, date of birth, contact details, education and professional experience history, as well as your skills and interests.
We store this data to provide you with our Services, at your discretion, until you decide to delete it, but at most until you delete your user account.
When a user:
complete two categories of information under the “Candidate Profile” section, the “Recommended Ads” or “Your New Job” subsections: preferred place to work and preferred profession, and
in case of active use of the Service (including by browsing the content of the ads selected by the user, adding them to favorite ads, viewing the phone number or message box, sending an application, as well as pressing the "Ask a question" button),
we automatically activate the "Recommended Ads" service, as described in articles 8 - 1.11 of Appendix 1 to the Terms and Conditions , through which the user automatically receives a recommendation to display ads compatible with him, which, according to our Services, are most suitable for his profile and preferences.
In case of filling in the preferred location and profession, ads will be recommended based on the data thus provided, and in case of active use of the Service, based on data related to this use.
The "Recommended Ads" service is also made available to visitors to the Services when they actively use the Service.
The “Recommended Ads” Service is based on the automatic analysis and profiling of your personal data provided in the context of using the “Recommended Ads” Service. For this purpose, we will profile your data contained in “Your New Job” and “Recommended Ads” and related to your active use of the Service, until you opt out of this Service or until the Service is terminated in accordance with our Terms and Conditions .
This profiling is necessary to enable us to fulfil our obligations regarding the provision of the “Recommended Ads” service, but will not lead to the automatic generation of decisions that may produce legal effects to your detriment or that may affect you in a similar way. You still have access to the entire catalogue of job advertisements, and the recommendations you receive from us are only suggestions that may be of interest to you. Employers have no influence on the recommendations you receive and are not informed about them.
When you respond to an advertisement in the “Jobs” category through a communication channel or a form implemented by OLE, regardless of the CV, message or Candidate form provided to the employer, you will be asked to provide certain data necessary for the transfer of your application to the employer. You can save this data in your Candidate Account as part of the Candidate form, thus having the possibility of using it for future applications. Providing the above data is necessary to use the “Jobs” category advertisement response service as part of our Services. OLE processes it in this way to provide this service in accordance with our Terms of Use .
6.2 How we transfer your data
Responding to a specific job advertisement in the “Jobs” category involves providing your personal data to the employer, at your request. After sending a response to an advertisement, the employer receives a message which, depending on your choices, settings or the purpose of the selected Service, may contain your personal data (for example, in the form of an attached CV or a link to the Candidate form, in accordance with the Candidate Profile service) and will be able to include your application in its recruitment process. Remember that by making your CV available to the employer, the latter becomes an independent data controller and may process your data outside our Services, in particular outside the rules established by OLE. We encourage you to carefully read the content of the advertisements in the “Jobs” category and the rules for processing personal data indicated by the employers in their privacy statements.
Share your personal data and other information with employers based on your own informed and conscious decision. Before making your data available, you should carefully consider the risks associated with publishing your personal data, in particular your address, contact details or exact location. Such risks could be, for example, the possibility of being identified by other people involved in your recruitment process, partial loss of privacy and, in extreme cases, even identity theft.
How we will inform you about changes to our Privacy Policy
We may change and update this Privacy Policy from time to time. We will notify you of material changes to this Privacy Policy as appropriate under the circumstances and as required by applicable law, e.g., by posting a prominent notice on our Services or by sending you a message through our Services or by sending you an email. If you do not agree with the way we process your personal data and the choices we offer you, you may close your account at any time by accessing your account settings and selecting to delete your account.
The rights you benefit from
In certain circumstances, you have rights under data protection legislation. If you would like to exercise any of the rights listed below, please access your account settings/privacy settings or contact us via the Contact Form :
The right to request access to your personal data (commonly referred to as a “data subject access request”). This gives you the opportunity to receive a copy of the personal data we hold about you and to check whether the processing is carried out by us lawfully.
The right to request rectification of the data we hold about you. This gives you the opportunity to obtain rectification of any incomplete or inaccurate data held by us about you, although a verification of the accuracy of the new data you provide to us may be necessary.
The right to request restriction of processing of your personal data. This gives you the opportunity to request us to suspend the processing of your personal data in the following situations: (a) if you want to establish the accuracy of the data; (b) if you consider that our use of the data is unlawful; (c) if you request us to keep the data even if we no longer need it for the establishment, exercise or defence of legal claims; or (d) if you have objected to our use of your data but we need to verify whether we have overriding legitimate grounds for using it.
The right to request the erasure of your personal data. This gives you the opportunity to request that we delete or remove your personal data where there are no legitimate grounds for us to continue processing it. You also have the right to request that we 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 personal information unlawfully or where we are required to delete your personal data in order to comply with local law. Please note that, in relation to certain purposes, we may be required by law to retain your data. See also section 12.
The right to object to the processing of your personal data where we are relying on a legitimate interest (or the legitimate interests of a third party) and there are certain elements relating to your particular situation which make you want to object to the processing based on this ground because you consider that it impacts on your fundamental rights and freedoms. In some cases, we may be able to demonstrate that we have compelling legitimate grounds for processing your personal information which override your rights and freedoms. You also have the right to object where the processing of your personal data is carried out for direct marketing purposes. You can exercise your right to object in the following ways, depending on the processing activity you want us to stop:
regarding marketing emails, click on the unsubscribe link within our emails;
regarding marketing SMS messages, push notifications or phone calls, changing your notification settings in your account to opt out of them;
regarding cookies, click on the “opt-out” function on our consent management platform, OneTrust, and;
regarding any objection raised against the processing of your data in general, you can contact us via the Contact Form .
The right to request the transfer of your personal data to you or to a third party. We will provide you or a third party of your choice with your personal data in a structured, commonly used, machine-readable and interoperable format. Please note that this right only applies to automated information for which you have initially given us consent to use it or, by using the information, to perform a contract with you.
The right to withdraw your consent at any time for the processing of your personal data. This does not affect the lawfulness of any processing already carried out by us on the basis of your consent given above.
There is usually no fee: You will not have to pay any fee to access your personal data (or to exercise any other right). However, we may charge a reasonable fee if your request is manifestly unfounded, repetitive or excessive. Otherwise, we may refuse to act on your request in such circumstances.
Deadline for providing responses: We try to respond to all legitimate requests within one month. Occasionally, we may need more than one month if your request is particularly complex or if you have submitted multiple requests. In this case, we will notify you and keep you updated.
In addition, you have the right to lodge a complaint with the Data Protection Authority at any time. Its contact details can be found in section 15.
However, before filing a complaint with the Data Protection Authority, we would greatly appreciate the opportunity to first discuss any concerns we may have. To do so, please contact our Privacy Office using the Contact Form .
Communication
We will communicate with you via email, SMS or notification app in connection with our Services, upon validation of your account with us, to inform you if your listings have become active/expired and with other transaction-related messages in connection with our Services. Given that it is imperative for us to send you such transaction-related messages, you may not be able to opt out of such messages.
Who do we share your data with?
We may need to share your personal data with the parties listed below for the purposes specified in section 4 above.
Third-party service providers: We use third-party service providers to help us provide certain aspects of our Services and to maintain and monitor our Services. In this context, your personal data may be shared with the following recipients or categories of recipients:
payment service providers, such as PayU SA , may receive your personal data for the purpose of processing payments that you wish to make through our Services; for making payments on the OLE platform, whether payments are made by card or by payment order, we use the services of PayU SA, a company established and operating in accordance with the laws of Poland, with its registered office at Grunwaldzka no.186, Poznan, 60-166, Poland ("PayU"), the payment processor authorized by OLE to perform these operations in accordance with UK law. You can learn more about our working relationship with PayU related to payment processing in section 11 of the Terms and Conditions of Use .
cloud service providers, such as Amazon Web Services, Inc. (AWS), Google Ireland Limited (Google Cloud), Microsoft Corporation (Microsoft Azure), who may receive certain of your personal data for cloud storage purposes;
third-party providers of integrated tools, such as Google Ireland Limited (Google Maps), who may receive your location data for the purpose of improving the performance of our Services and personalizing the content we deliver to you;
providers of customer support tools, such as Salesforce, Inc. , who may receive certain of your data such as user account details, customer service requests, message content, for the purpose of communicating with and providing customer support, as well as data regarding your quality as a potential customer, used by our sales team;
marketing communications service providers, such as White Image Loyalty SRL or Lion Communication Services SA , who may receive certain of your data for the purpose of organizing and conducting marketing communication campaigns;
providers of user survey services, such as Reveal Marketing Research SRL , who may receive certain data about you such as contact details for the purpose of participating in surveys on how the services offered by OLE are used
These third party service providers may be located within or outside the EEA.
We conduct checks on our third-party service providers and require them to respect the security of your personal data and to process it in accordance with the law. We do not allow them to use your personal data for their own purposes and we allow them to process this data only for the specified purposes and in accordance with our instructions.
Advertising and Analytics Providers: In order to improve our Services, we will occasionally share your personal information with analytics providers, such as Google Analytics 360, who (i) help us analyze how people use our Services in order to improve our Services, and (ii) support us in connection with our online marketing and interest-based advertising activities. For the most part, we share your personal information with them in a non-identifiable form for the purposes of monitoring and reporting on the effectiveness of our campaigns for our business partners and for internal business analysis. Typically, such information will include a cookie ID, an IP address (shortened), the referring URL, and information about your browser and device. By analyzing your behavior By using cookies to better understand how you use our Services and improve our product, we can serve you more relevant OLE ads when you visit other websites. For advertising purposes, we partner with advertising service providers that are organized under the Interactive Advertising Bureau (IAB) and are listed here: https://iabeurope.eu/vendor-list/ . We may share your cookie ID (first- and third-party cookies) with our advertising partners to allow us to serve you more relevant third-party ads on our Services based on your browsing behavior outside of our Services. To control and manage your ad settings, you can access your settings via a link in the footer of our website. For further details regarding advertising and analytics service providers, please see our Cookie and Similar Technologies Policy .
OLE Group Companies: We will occasionally share your personal information with other “OLE Group Companies”, meaning entities or subsidiaries controlled directly or indirectly by OLE Global BV in which OLE Global BV holds more than 50% of the voting rights or has the right to control the entity (together referred to as the “OLE Group”). The OLE Group is made up of entities and subsidiaries located around the world. Many of these subsidiaries provide a wide variety of Classified Services in many countries. You can see all of our Classified Brands under which we provide our Services at https://www.ole.ad . In relation to certain business operations, we leverage our global expertise by using shared resources across different subsidiaries to provide you with the best possible Services, which includes aspects of product improvement, customer support, security and safety, and activities related to the collection of business intelligence. This means that we may need to share your personal data within the OLE Group Companies, which are located both inside and outside the European Economic Area (“EEA”).
Any sharing of personal data between OLE Group Companies will always be subject to the safeguards set out in Section 11 , which we have expressly stated in an internal data transfer agreement between all OLE Group Companies. This agreement clearly defines the rights and obligations of all OLE Group Companies to ensure appropriate technical and organisational measures to protect your personal data.
Mergers and Acquisitions: If our business or assets (or a portion thereof) are reorganized, sold, transferred, or merged with another business, your personal data will be disclosed and transferred to the new owners of the business. In such situations, we will take all steps required by law, which may include notifying you and giving you the opportunity to decide whether or not you wish to continue to use our Services.
Law enforcement, regulatory and other authorities: We may disclose your personal data to law enforcement, regulatory, public government bodies and other relevant third parties for the purpose of complying with any legal or regulatory requirements.
Publicly Available Information: When you post an item for sale using our Services, you may want to make certain personal information visible to other OLE users. This may include your first and last name, email address, location, and contact number. Some information, such as your rating and feedback from other users, may be disclosed publicly when you post an ad, automatically. We also make your rating and feedback, along with your username, available to users you have rated. Please be aware that any information you provide to other users may be shared by them with others at any time, so please exercise caution in this regard.
Publicly available information on other OLE sites: When your ad is relevant to other platforms managed and developed by OLE, such as our website www.autovit.com ("Autovit") or the website www.storia.ro ("Storia") and you decide to make your personal data visible to other OLE users, this personal data, such as your name or account number (depending on your privacy settings), the content of the ad and your mobile phone number (if you decide to make it public) will be automatically displayed on these platforms, including on Autovit or Storia.
Legal entity customers operating within our Services as employers: for the provision of our Services relating to the "Jobs" category and for facilitating the submission of your CV directly through our Services. When you wish to apply for a job posted on OLE Jobs, we will transmit to employers data relating to your education, professional experience, skills, photos, preferences related to the desired job, as well as any other information included in your CV or submitted directly by you to employers through the use of our Services.
International transfers
Whenever we transfer your personal data outside the EEA, we ensure that it is afforded a similar level of protection by implementing at least one of the following safeguards:
We will only transfer personal data to those countries that have been deemed to provide an adequate level of protection for personal data by the European Commission. For further details, see European Commission: Adequacy of the level of protection of personal data in third countries .
In cases where we use certain service providers, we may use specific contracts approved by the European Commission, which ensure the same level of protection for personal data as it enjoys in Europe. For further details, see European Commission: Model contracts for the transfer of personal data to third countries .
You can receive a copy of the relevant protection measures that have been implemented by contacting us via the Contact Form .
Where do we store your data and for how long?
The data we collect about you will be stored and processed within and outside the EEA on secure servers to provide you with the best possible user experience, for example, to quickly create a website or mobile application. Data for OLE EEA users is stored on cloud servers provided by Amazon Web Services, Inc., which is located in Dublin, Ireland.
We will retain your personal data only for as long as necessary to fulfill the purposes for which we collected it, including for the purpose of meeting any legal, tax, accounting or reporting requirements.
In order to determine the appropriate retention period for personal data, we take into account the volume, nature and sensitive nature of the personal data, the potential risk of harm caused by the unauthorized use or disclosure of your personal data, the purpose for which we process your personal data and whether we can achieve these purposes by other means, as well as the applicable legal requirements.
We retain the personal data associated with your account for as long as you are registered as a user or until you delete your account, in which case we will ensure that your data is deleted without undue delay and as soon as technically feasible. Depending on the Service you use and the systems in which your data is stored, data deletion may take up to 3 months from the date of your request. During this period, any access to your data will be restricted or blocked immediately.
If there is no activity in your account for a period of more than 36 months, we will close your account in accordance with our Terms of Use and delete all personal data stored in your account, meaning that you will no longer be able to access and use this account. However, we will not close your account or delete your data if you have any open transactions in progress or are entitled to a refund of funds credited to your account by you or us. Before closing your account, we will notify you, giving you the opportunity to keep your account active, for example by logging into that account.
When you close your account, we may retain certain data to the extent necessary to (i) comply with our legal obligations, such as for tax, accounting or audit purposes, or (ii) resolve a complaint or dispute in court or comply with a request from an authority (e.g. in connection with law enforcement). We will only retain that data that is relevant for such purposes and will delete that data upon expiry of the applicable or statutory retention period or upon the fulfillment of the legal purpose.
In order to ensure customer safety and security and prevent fraud, we may retain certain data related to your closed account, such as your ad listings, IP address, moderation information, and user experience, for a maximum period of 14 months from the date of account closure.
Personal data related to cookies is stored for the period corresponding to the life cycle of the respective cookie type or until it is deleted by you. You can learn more about this topic by consulting our Policy on Cookies and Similar Technologies .
If you have any questions regarding the retention period of your data, please contact us via the Contact Form .
Technical and organizational measures and security of processing
All information we receive about you is stored on secure servers and we have implemented technical and organizational measures that are appropriate and necessary to protect your personal data. OLE constantly evaluates the security of its network and the adequacy of its internal information security program, which is designed to (a) help us secure your data against any accidental or unlawful loss, access or disclosure, (b) identify reasonably foreseeable risks related to the security of the OLE network, and (c) minimize security risks, including through risk assessments and periodic testing. In addition, we ensure that all payment data is encrypted using SSL technology.
Please note that, despite the measures we have implemented to protect your data, data transfers over the internet or other open networks are never completely secure and there is a risk that your personal data may be accessed by unauthorized third parties.
Links to third-party websites
Our Services may contain links to third-party websites or applications. If you click on one of these links, please note that each will have its own privacy policy. We do not control these websites/applications and are not responsible for their policies. When you leave our Services, we encourage you to review the privacy notice of each website you visit.
Contact details
For any additional information or to exercise your rights, please check your account/privacy settings or contact our Data Protection Office using the Contact Form or through the Help Center .
If you wish to contact us to request information regarding the processing of your personal data, you can send a letter to the following address: OLE London UK.
Data Protection Authority
With regard to complaints regarding data protection, you can contact the Data Protection Authority. You can exercise this right by contacting the authority at your place of residence or work or at the address of the data controller.
As regards UK, the competent Data Protection Authority is: National Data Protection Authority UK.
With regard to cross-border data processing, our main supervisory authority is the Dutch Data Protection Authority in the Netherlands, with the following details:
