• DATA COLLECTION

Users of the Service may be Freelancers or Site Visitors 

Data You Provide to Us

To use our Services, you will be required to provide us with data about yourself. This includes your name, email address, phone number, photo, video, and other data provided by you by filling out our forms. We will also collect data about your contacts such as names, email addresses, and phone numbers in instances where you wish to refer someone else to our Services or for background verifications. Other data that we collect helps us improve our services.

• Personal Data: For the purposes of identifying you, we will collect personal data such as your name, email address, home address, and phone number.
• Service Integrity Data: For the purposes of detecting identity theft, fraud, and/or other misuses of personal data, we will collect a photo of your face, a video of you, and government-issued clearances.
• Identity Verification: For the purposes of verifying your identity, we will collect photos (scanned or taken) of any government-issued identification cards including but not limited to: passports, driver's licenses, etc. The government ID that you provide will verify personal data provided by you such as your name, address, and date of birth. We may also require you to provide a copy of a billing statement for the same purpose.
• General Service: Your date of birth will be collected along with your government-issued identification card to make sure that you are aged 18 or over. 
• Collection of Third-Party Data: For the purposes of referrals and background checks, we may collect your contacts’ data such as name, email address, and phone number.

The data collected from you is not mandatory. You may refuse to provide data to us, however, failure to provide these necessary data will hinder our ability to offer our services to you.

Automatic Data

We may automatically collect certain data from you as you use our website by using cookies and similar technologies. Please see our cookie policy for more details about this.

We may receive data from third parties such as analytics providers such as Google based outside the EU, advertising networks such as Facebook based outside the EU, such as search information providers such as Google based outside the EU, and providers of technical, payment, and delivery services, such as data brokers or aggregators.

We may also receive data from publicly available sources such as Companies House and the Electoral Register based inside the EU.

User Registration

You may be required to register with the Site. You agree to keep your password confidential and will be responsible for all use of your account and password. We reserve the right to remove, reclaim, or change a username you select if we determine, in our sole discretion, that such username is inappropriate, obscene, or otherwise objectionable.

The data that you provide us may be featured in your profile such as but not limited to name, work history, certifications, etc. The data in your profile is for public view with the sole purpose of making it visible to clients to fulfill our purpose of getting you hired.

At any point in time that you choose to opt out of this registration and profile, you may contact legal@bottleneck.online for our team to remove your profile from our database.

If you believe that an unauthorized profile was created using your data with the purpose of fraud or identity theft, you can request immediate removal of the said profile by contacting us at legal@bottleneck.online.

Identity Verification

Integrity is integral for us to provide services to you and our clients. Hence, we place importance on verifying your identity. Processes are in place for verifying your identity. Data you provide such as but not limited to a government-issued identification card, name, phone number, photo, video, etc. will be used for this purpose. Our team also conducts interviews and background checks with your references or contacts your previous employers to safeguard the integrity of the Services that we provide you and our clients.

Your Contact’s Data

By providing your contact’s data such as but not limited to names, phone numbers, email addresses, etc. for purposes of referring and/or conducting background checks, we are under the assumption that you have obtained proper consent from the people who are involved. 

If your data has been provided to us by another user without your consent, you may contact legal@bottleneck.online for immediate removal of your data from our database.

Sensitive Data

We do not collect any Sensitive Data about you. Sensitive data refers to data that includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health, and genetic and biometric data. We do not collect any information about criminal convictions and offenses.

Where we are required to collect personal data by law, or under the terms of the contract between us and you do not provide us with that data when requested, we may not be able to perform the contract (for example, to deliver goods or services to you). If you don’t provide us with the requested data, we may have to cancel a product or service you have ordered but if we do, we will notify you at the time.

We will only use your personal data for a purpose it was collected for or a reasonably compatible purpose if necessary. For more information on this please email us at info@bottleneck.online. In case we need to use your details for an unrelated new purpose we will let you know and explain the legal grounds for processing.

We may process your personal data without your knowledge or consent where this is required or permitted by law.

We do not carry out automated decision-making or any type of automated profiling.

• USE OF DATA

Data collected will be primarily used to provide services to you and our clients, maintain the integrity of our company by preventing fraud and identity theft, and improve our services. Some of the other uses of the data collected are listed below:

• Communication Data includes any communication that you send to us whether that be through the contact form on our website, through email, text, social media messaging, social media posting, or any other communication that you send us. We process this data for the purposes of communicating with you, for record-keeping, and for the establishment, pursuance, or defense of legal claims. Our lawful ground for this processing is our legitimate interests which in this case are to reply to communications sent to us, to keep records, and to establish, pursue or defend legal claims.
• Customer Data includes data relating to any purchases of goods and/or services such as your name, title, billing address, delivery address email address, phone number, and contact details. We process this data to supply services to you and to keep records of such transactions. Our lawful ground for this processing is the performance of a contract between you and us and/or taking steps at your request to enter into such a contract.
• User Data includes data about how you use our website and any online services together with any data that you post for publication on our website or through other online services. We process this data to operate our website and ensure relevant content is provided to you, to ensure the security of our website, to maintain back-ups of our website and/or databases, and to enable publication and administration of our website, and other online services and business. Our lawful ground for this processing is our legitimate interests which in this case are to enable us to properly administer our website and our business.
• Technical Data that includes data about your use of our website and online services such as your IP address, your login data, details about your browser, length of visit to pages on our website, page views and navigation paths, details about the number of times you use our website, time zone settings and other technology on the devices you use to access our website. The source of this data is our analytics tracking system. We process this data to analyze your use of our website and other online services, to administer and protect our business and website, to deliver relevant website content and advertisements to you, and understand the effectiveness of our advertising. Our lawful ground for this processing is our legitimate interests which in this case are to enable us to properly administer our website and our business and grow our business and decide our marketing strategy.
• Marketing Data includes data about your preferences in receiving marketing from us and our third parties and your communication preferences. We process this data to enable you to partake in our promotions such as competitions, prize draws, and free give-aways, to deliver relevant website content and advertisements to you and measure or understand the effectiveness of this advertising. Our lawful ground for this processing is our legitimate interests which in this case are to study how customers use our products/services, to develop them, grow our business, and decide our marketing strategy.
• We may use Customer Data, User Data, Technical Data, and Marketing Data to deliver relevant website content and advertisements to you (including Facebook adverts or other display advertisements) and to measure or understand the effectiveness of the advertising we serve you. Our lawful ground for this processing is legitimate interests which are to grow our business. We may also use such data to send other marketing communications to you. Our lawful ground for this processing is either consent or legitimate interests (to grow our business).

We may have to share your personal data with the parties set out below:

• Clients or affiliates of clients with the intent of getting you hired. 
• Service providers who provide IT and system administration services.
• Professional advisers include lawyers, bankers, auditors, and insurers.
• Government bodies that require us to report processing activities.
• Third parties to whom we sell, transfer, or merge parts of our business or our assets.

We require all third parties to whom we transfer your data to respect the security of your personal data and to treat it in accordance with the law. We only allow such third parties to process your personal data for specified purposes and in accordance with our instructions.

• PUBLIC PROFILE

The data you have provided for the purpose of creating a profile visible to the client is publicly accessible unless otherwise indicated. 

To delete the public profile, contact us at legal@bottleneck.online.

• DATA RETENTION

We will only retain your personal data for as long as necessary to fulfill the purposes we collected it for, including the purposes of satisfying any legal, accounting, or reporting requirements.

When deciding what the correct time is to keep the data we look at its amount, nature and sensitivity, potential risk of harm from unauthorized use or disclosure, the processing purposes if these can be achieved by other means, and legal requirements.

In some circumstances, we may anonymize your personal data for research or statistical purposes in which case we may use this information indefinitely without further notice to you.

In any event that you would like to remove your personal data provided to us, contact us at legal@bottleneck.online for immediate deletion.

•  MARKETING COMMUNICATIONS

Our lawful ground of processing your personal data to send you marketing communications is either your consent or our legitimate interests (namely to grow our business).

Under the Privacy and Electronic Communications Regulations, we may send you marketing communications from us if (i) you made a purchase or asked for information from us about our goods or services or (ii) you agreed to receive marketing communications, and in each case, you have not opted out of receiving such communications since. Under these regulations, if you are a limited company, we may send you marketing emails without your consent. However, you can still opt-out of receiving marketing emails from us at any time.

Before we share your personal data with any third party for their own marketing purposes we will get your express consent.

You can ask us or third parties to stop sending you marketing messages at any time by following the opt-out links on any marketing message sent to you OR by emailing us at info@bottleneck.online at any time.

If you opt out of receiving marketing communications this opt-out does not apply to personal data provided as a result of other transactions, such as purchases, warranty registrations, etc.

• YOUR CHOICES AND RIGHTS

Under data protection laws you have rights in relation to your personal data that include the right to request access, correction, erasure, restriction, transfer, to object to processing, to portability of data and (where the lawful ground of processing is consent) to withdraw consent.

In order to withdraw consent and understand the law, we recommend you contact a knowledgeable lawyer, but you can learn more here: https://privacy.gov.ph/know-your-rights/.

If you wish to exercise any of the rights set out above, please email us at info@bottleneck.online.

You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive, or excessive or refuse to comply with your request in these circumstances.

We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.

We try to respond to all legitimate requests within one month. Occasionally it may take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you.

If you are not happy with any aspect of how we collect and use your data, you have the right to complain to the Federal Trade Commission (FTC), the supervisory authority for data protection issues (https://www.consumer.ftc.gov/blog/2015/08/want-privacy-tell-us-about-it). We should be grateful if you would contact us first if you do have a complaint so that we can try to resolve it for you.

• SECURITY

We have put in place security measures to prevent your data from being accidentally lost, used, or altered. We also allow access to your data visible on your profile publicly for the purposes of providing you and our clients' services. We have procedures in place to deal with any suspected data breach and will notify you and any applicable regulator of a breach if we are legally required to.

• INTERNATIONAL TRANSFERS

Bottleneck Distant Assistants is a US Based company, therefore, data collected is kept in the US.

The European Union’s General Data Protection Regulation (GDPR) takes effect on May 25, 2018. The GDPR requires companies and site owners to be transparent about how they collect, use, and share personal data. It also gives individuals more access and choice when it comes to how their own personal data is collected, used, and shared.

It’s important to understand that while the GDPR is a European regulation, its requirements apply to all sites and online businesses that collect, store, and process personal data about EU residents no matter where the business is located.

You can learn more about the GDPR from the European Commission’s Data Protection page.

We’re committed to supporting site owners around the world in their work to comply with this important law. As part of that effort, we’ve added a number of new privacy features in this release.

Countries outside of the European Economic Area (EEA) do not always offer the same levels of protection to your personal data, so European law has prohibited transfers of personal data outside of the EEA unless the transfer meets certain criteria.

Many of our third-party service providers are based outside the European Economic Area (EEA) so their processing of your personal data will involve a transfer of data outside the EEA.

Whenever we transfer your personal data out of the EEA, we do our best to ensure a similar degree of security of data by ensuring at least one of the following safeguards is in place:

We will only transfer your personal data to countries that the European Commission has approved as providing an adequate level of protection

for personal data by; or

Where we use certain service providers, we may use specific contracts or codes of conduct, or certification mechanisms approved by the

European Commission which gives personal data the same protection it has in Europe; or

If we use US-based providers that are part of EU-US Privacy Shield, we may transfer data to them, as they have equivalent safeguards in place.

If none of the above safeguards is available, we may request your explicit consent to the specific transfer. You will have the right to withdraw this consent at any time.

• LINKS TO OTHER SITES

This website may include links to third-party websites, plug-ins, and applications. 

Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites and are not responsible for their privacy statements. When you leave our website, we encourage you to read the privacy notice of every website you visit.

• COOKIES

You can set your browser to refuse all or some browser cookies or to alert you when websites set or access cookies. If you disable or refuse cookies, please note that some parts of this website may become inaccessible or not function properly.

Third-Party Pixels and Cookies Notwithstanding anything else in this policy, we and/or our partners may use pixels and pixel tags, and place, read or use cookies to collect information from your device and/or Internet browser. These cookies do not contain personally identifiable information, however, it may be possible for our third-party business partners to combine it with other information in order to identify your email address or other personally identifiable information about you.

For example, the cookies may reflect de-identified demographic or other data linked to data you voluntarily have submitted to us, e.g., your email address, which we may share with a data provider solely in hashed, non-human readable form. By using our Service, you agree that we and our third-party partners may store, sell, port, combine with other data, monetize, utilize, and otherwise use either (i) the personally indefinable information about you that we share with them, or (ii) the personally identifiable information they discover and/or identify as described above. Visitors can also express their choices for display advertising, through the following platforms: the Digital Advertising Alliance opt-out platform or the Network Advertising Initiative opt-out platform.

We and/or our partners may also use cookies for delivering personalized advertising emails. These cookies are used to identify the visitors of our advertisers’ websites and send personalized emails based on the visitors’ browsing experience. We and/or our partners use cookies, pixels, and other tracking technology to associate certain Internet-related information about you, such as your Internet Protocol address and what Web browser you are using, with certain of your online behaviors, such as opening emails or browsing websites. Such information is used to customize ads or content and may be shared with our partners.

For more information about the cookies we use, please see our cookie policy.

• CHANGES TO THIS POLICY

Bottleneck Distant Assistants reserves the right to update, modify and make changes to our privacy policy. Should the changes to the policy be substantial, a notice may be sent out informing with the intent of giving you notice.

We may change this Privacy Policy. If we make substantial changes, we will provide notice. Any change made in this policy will be effective immediately.

• CONTACT US

Our full details are:

Full name of legal entity: Bottleneck Distant Assistants

Email address: info@bottleneck.online

Postal address: 2348 E. Seminole St., Springfield, MO 65804.

It is very important that the information we hold about you is accurate and up to date. Please let us know if at any time your personal information changes by emailing us at legal@bottleneck.online.