[ 01 ]Introduction

This Privacy Policy describes how AFFPRO LTD, a legal entity registered under the laws of the United Kingdom, Company Registration Number 14947392, registered address: Suite 118, 4 Montpelier Street, London, SW7 1EE ("Company", "We", "Us" or "Our"), collects, uses and manages information obtained through its website https://affpro.com ("Website").

We respect your privacy and are committed to processing your data in accordance with applicable data protection legislation, including the EU GDPR and the UK Data Protection Act 2018.

By accessing or using Our Service, You confirm that You have read, understood and agreed to the terms of this Privacy Policy. If You do not agree with this Policy, please refrain from using our Website and Services. Continued use of the Service after any updates will constitute acceptance of the changes.

[ 02 ]Definitions

The following definitions apply throughout this Privacy Policy:

• "Account" means a unique account created for You to access our Service or parts of it.

• "Affiliate" means a legal entity that controls, is controlled by, or is under common control with a party, where "control" means ownership of 50% or more of the shares, equity interest or other securities entitled to vote for election of directors or other managing authority.

• "Personal Data" means any information that relates to an identified or identifiable individual.

• "Usage Data" means non-identifiable technical data collected automatically during use of the Website.

• "Cookies" are small files that are placed on Your computer, mobile device or any other device by a website, containing details of Your browsing history on that website, among many other uses.

• "Device" means any device that can access the Service, such as a computer, a mobile phone or a digital tablet.

• "Service" refers to the Website.

• "Service Provider" means any natural or legal person who processes data on behalf of the Company. This refers to third-party companies or individuals engaged by the Company to facilitate the Service, to provide the Service on behalf of the Company, to perform services related to the Service, or to assist the Company in analyzing how the Service is used.

• "Data Controller" refers to AFFPRO LTD, which determines the purposes and means of the processing of Personal Data.

• "You" or "User" means the individual or legal entity accessing or using the Website.

[ 03 ]Data Collection

We collect only a limited amount of data from users, depending on their interaction with the Website. Specifically:

[ 04 ]Personal Data

While using Our Service, We may ask You to provide Us with certain personally identifiable information that can be used to contact or identify You. Personally identifiable information may include, but is not limited to:

• Email address.

• First and last name.

• Phone number.

• CV/Resume.

• Usage Data.

• Login credentials (e.g., username and password for accessing a personal dashboard).

We may collect Personal Data when You:

• Provide information through contact forms or lead generation forms (first and last name, email, phone number).

• Apply for a position through a job application form (e.g., CV, name, contact information).

• Register for or log in to a personal dashboard on the Website.

[ 05 ]Usage Data

Usage Data is collected automatically when using the Service.

Usage Data may include information such as Your Device's Internet Protocol address (e.g., IP address), browser type, browser version, the pages of our Service that You visit, the time and date of Your visit, the time spent on those pages, unique device identifiers and other diagnostic data.

When You access the Service through a mobile device, We may automatically collect certain information, including, but not limited to, the type of mobile device You use, Your mobile device's unique identifier, the IP address of Your mobile device, Your mobile operating system, the type of mobile Internet browser You use, unique device identifiers and other diagnostic data.

We may also collect information that Your browser sends whenever You visit our Service or when You access the Service through a mobile device.

This data is non-identifiable and is used solely for Website performance and analytics.

[ 06 ]Use of Personal Data

We process the limited Personal Data that we collect for the following purposes:

• To respond to inquiries submitted through the Website;

• To review applications submitted for recruitment purposes;

• To analyze usage of the Website and improve user experience;

• To fulfill legal obligations, where applicable.

• We do not use Personal Data for direct marketing purposes or profiling.

[ 07 ]Cookies and Tracking Technologies

The Website uses cookies and similar technologies to collect analytical data.

[ 08 ]Types of Cookies Used

• Strictly Necessary Cookies – Ensure the core functionality and security of the website.

• Analytical Cookies – Allow Us to understand Website traffic (e.g., through Google Analytics or similar tools).

• Functional Cookies – Help provide enhanced functionality and personalization of the Website.

[ 09 ]User Control

Users are presented with a cookie consent banner on their first visit. Users are given the option to consent to or decline the use of non-essential cookies.

[ 10 ]Data Storage and Retention

We retain Your Personal Data to fulfill our legal, operational, contractual and regulatory obligations. Record-keeping requirements may vary for each type of record, so We ensure that in no case do We retain Your Personal Data longer than necessary. If data is no longer needed, it will be securely deleted or anonymized. All login credentials are securely stored in cloud infrastructure managed by third-party providers such as Google Cloud, used together with the Scaleo platform.

[ 11 ]Data Sharing and Transfer

We do not transfer Your Personal Data to third parties, except in cases expressly set out in this Privacy Policy, namely:

• Compliance with legal obligations. We may disclose Your Personal Data if such disclosure is necessary to comply with applicable law, regulations, legal process or government requests, including, but not limited to, matters of national security or law enforcement. Where permitted by law, We will make reasonable efforts to notify You in advance of such disclosure. We may also share Your Personal Data with regulatory or supervisory authorities, courts, law enforcement agencies, fraud prevention bodies, licensing authorities or other competent third parties, where required by law or necessary to establish, exercise or defend our legal rights. Where possible and appropriate, We will promptly notify You of any such disclosure.

• In an emergency. We may disclose Your Personal Data if We believe it is necessary to prevent imminent and serious harm to the health or safety of any person.

• To enforce our policies and rights. We may disclose Your information if We believe Your actions violate our Terms, internal policies, or otherwise threaten the rights, property or safety of the Company, its users or others.

• With our Affiliates. We may share Your Personal Data with our parent companies, subsidiaries, affiliates or other entities under common ownership or control, solely for purposes consistent with this Privacy Policy.

• Mergers and acquisitions. In the event of a merger, acquisition, reorganization, sale of assets or bankruptcy, Your Personal Data may be transferred to the acquiring or successor entity, subject to the safeguards provided herein.

• With Your consent. We may share Your Personal Data when You explicitly give consent to such sharing or instruct us to do so.

• Third-party service providers. We may share Your Personal Data with trusted third-party service providers who perform services on our behalf and support our business operations, including, but not limited to:

• Cloud hosting and server infrastructure.

• Web and marketing analytics tools (e.g., Google Analytics).

• Email delivery and communication platforms.

• Professional advisors, including legal and regulatory consultants.

We do not sell, rent, or disclose Your Personal Data to third parties for commercial purposes.

[ 12 ]Legal Basis for Processing

• We process Your Personal Data based on one or more of the following legal bases:

• Consent: when You give us explicit permission.

• Contract: when processing is necessary for the performance of a contract with You.

• Legal obligation: when we are legally required to process data.

• Legitimate interests: when it is in our legitimate business interests and is not overridden by Your rights.

[ 13 ]Know Your Rights

In accordance with applicable data protection legislation, You have the following rights:

• You have the right to receive information regarding the purposes of collecting Personal Data, regarding the third parties to whom we disclose Your Personal Data, information regarding the safeguards applied to securely store Your Personal Data, and the period of time for which Personal Data will be retained.

• You also have the right to request the complete deletion of Personal Data relating to You, by sending Us a request via [email protected]. The Company will fulfill Your request within a reasonable period of time. If there is no other lawful basis for retaining and processing Your Personal Data, as provided by Applicable Law, the Company will delete such information. If there is another legal basis for such processing, the Company will notify You within a reasonable period.

• You also have the right to request restriction of the storage and processing of Personal Data, if legal grounds for such requests have arisen or as provided by Applicable Law.

• You have the right to object to the processing of Personal Data relating to You in circumstances provided for by Applicable Law. In the event of such an objection, the Company will refrain from processing Your Personal Data unless there are other legal grounds for continuing the processing.

• You have the right to ask the Company to provide You with a structured list of Personal Data previously provided (and data currently being processed by the Company). You may also ask Us to transfer Your Personal Data to a previously selected third party.

[ 14 ]Data Security

We implement appropriate technical and organizational measures to ensure the security of any data temporarily processed, including encryption, access control and secure deletion procedures.

[ 15 ]Children's Privacy

The Website is not intended for individuals under the age of 16. We do not knowingly collect Personal Data from minors. If You believe that a child has provided Personal Data, please contact Us immediately.

[ 16 ]Contact Us

If You have any questions about this Privacy Policy, please feel free to contact us or email us at: [email protected].