Effective date: 14-10-2022
We are OSINT Central. This document explain the policy regarding personal data.
We respect your privacy and private life, but sometimes we need your personal data. We consider personal data to be any information relating to an identified or identifiable person, in conformity with the General Data Protection Regulation (the GDPR).
We may modify this policy without notifying you, so please check back often for updates.
To make these terms a little easier to understand, we capitalize certain terms and capitalizing them means they have a special meaning. Terms are defined throughout the Terms of Service, mainly in the User Agreement (look for quotation marks and bold font).
Table of Contents
- Are you under the age of 18?
- Processing of personal data
- Who is the controller of your personal data?
- What information is collected?
- On which legal basis and for which purpose(s) do we collect?
- Are you obliged to share your Personal Information with us?
- How long do we store your Personal Information?
- With whom do we share your Personal Information?
- Your rights
- How do we secure your Personal Information?
Are you under the age of 18?
If you are younger than 18 years old, you need permission from your parents or legal guardian to use our Service.
Processing of personal data
In order to provide you with our Services, we process your personal data.
Who is the controller of your personal data?
We have posted a Data Processing Agreement (”DPA”) to streamline compliance with the General Data Protection Regulation (“GDPR”).
This DPA governs the relationship between the Customer (as defined in the DPA) acting as a data controller or processor, as applicable, of personal data under European Data Protection Legislation; and OSINT Central (acting as a data processor or subprocessor, as applicable).
Unless otherwise agreed to in writing by you and us, to the extent we process any EU personal data for you as a controller (as defined by the General Data Protection Regulation (EU) 2016/679) in your role as a Customer, the Data Processing Agreement applies.
What information is collected?
Information you provide
- Personal Information: While using the Service (whether as a Sponsor or Researcher or Agency), we may require or otherwise collect information that identifies you as a specific individual and can be used to contact or identify you (“Personal Information”). Examples of Personal Information include your name, email address, company address, billing address, and phone number.
- Payment Information: If you use the Service to make or receive payments, we will also collect certain payment information, such as credit card or other financial account information, and billing address.
- Identity Verification: We may collect Personal Information, such as your date of birth or taxpayer identification number, to validate your identity or as may be required by law, such as to complete tax filings. We may request documents to verify this information, such as a copy of your government-issued identification or photo or a billing statement.
- Biometric Identifiers or Service Interaction Information: We may collect Personal Information to verify your identity and to detect fraud, identity theft, or other misuse of your account through facial recognition and other technologies.This might be a photograph of your face, a selfie, or data about your interactions with the Service. We may request documents to verify this information, such as a copy of your government-issued ID. From time to time, we may require you to take and submit another or updated image of your face for comparison to your government-issued ID. The biometric identifiers or information collected are used only to verify your identity and platform security and use integrity purposes.
- General Audience Service: The Service is general audience and intended for users 18 and older. We do not knowingly collect Personal Information from anyone younger than age 18. If we become aware that a child younger than 18 has provided us with Personal Information, we will use commercially reasonable efforts to delete such information from our files. If you are the parent or legal guardian of a child younger than age 18 and believe that we have collected Personal Information from your child, please contact us at: firstname.lastname@example.org.
- Combination of Personal and Non-Identifying Information: Sometimes when non-identifying information is combined, it can identify an individual. For example, if a birthdate is combined with a first name, it might identify a person even if the birthday or first name alone could not. But the same pieces of information are considered Non-Identifying Information when they are taken alone or combined only with other non-identifying information (for example, your viewing preferences). We may combine your Personal Information with Non-Identifying Information, but we will treat the combined information as Personal Information.
- Collection of Third Party Personal Information: We collect the following personal information from you about your contacts or friends: First name, last name, and email address when you provide it to us for the purpose of adding your contacts to a message room.
Information received from third parties
We also may receive information about you from third parties. For example, we may supplement the information we collect with outside records or third parties may provide information at your request (such as if you choose to sign in with a third-party service).
Information Collected Automatically
Like other online companies, we receive technical information when you use our Services. We use these technologies to analyze how people use the Service, to improve how our Site functions, to save your log-in information for future sessions, and to serve you with advertisements that may interest you.
We and our third party service providers, including analytics and third party content providers, may automatically collect certain information from you whenever you access or interact with the Service. This information may include, among other information, the browser and operating system you are using, the URL or advertisement that referred you to the Service, the search terms you entered into a search engine that led you to the Service, areas within the Service that you visited, which links you clicked on, which pages or content you viewed and for how long, other similar information and statistics about your interactions, such as content response times, download errors and length of visits to certain pages and other information commonly shared when browsers communicate with websites. We may combine this automatically collected log information with other information we collect about you. We do this to improve services we offer you, and to improve marketing, analytics, and site functionality.
The information we collect also includes the Internet Protocol (“IP”) address or other unique device identifier (“Device Identifier”) for any device (computer, mobile phone, tablet, etc.) used to access the Service. A Device Identifier is a number that is automatically assigned or connected to the device you use to access the Service, and our servers identify your device by its Device Identifier. Some mobile service providers may also provide us or our third party service providers with information regarding the physical location of the device used to access the Service.
Cookies: Like many websites, we and our marketing partners, affiliates, analytics, and service providers use “cookies” to collect information. We try to not use or only to use anonymous cookies wherever possible.
Web Beacons: We and our marketing partners, affiliates, analytics, and service providers may also employ software technology known as “web beacons” and/or “tracking tags” to help us keep track of what content on our Service is effective and to serve relevant advertising to you. Web beacons are small graphics with a unique identifier that may be invisible to you, and which are used to track the online activity of Internet users. Web beacons are embedded in the web pages you review or email messages you receive. Web beacons or similar technologies may be used for a number of purposes, including, without limitation, to count visitors to our Service, to monitor how our Users navigate the Service, to count how many emails that were sent were actually opened, or to count how many particular articles or links were actually viewed.
Embedded Scripts: We and our marketing partners, affiliates, analytics, and service providers may also employ software technology known as an Embedded Script. An Embedded Script is programming code that is designed to collect information about your interactions with the Service, such as the links you click on. The code is temporarily downloaded onto your computer or other device and is deactivated or deleted when you disconnect from the Service.
In addition, we and our marketing partners, affiliates, analytics, and service providers may use a variety of other technologies (such as tags) that collect similar information for security and fraud detection purposes and we may use third parties to perform these services on our behalf.
Researchers may create a profile, with certain or all information publicly available. Sponsors and Agencies may also create organization profiles.
You may have the opportunity to create a profile, which consists of information about you, and may include Personal Information, photographs, examples of your work, information on work previously performed via the Service and outside the Service, skills, tests taken, test scores, earnings information, feedback/rating information and other information, including your username (“Profile”).
The information in your Profile may be visible to all our Users and the general public subject to the privacy choices you make within your Profile. If you choose to make your profile publicly visible, your profile will be visible to the entire Internet, including sponsors, researchers, visitors, and search engines such as Google and Bing, and may appear on our partners' sites.
You may edit certain information in your Profile via your account and may choose to limit who is able to view certain content you post to your Profile. Sponsors and Agencies of associated individual users or companies may also have the opportunity to create an organization Profile. If, in any case, you believe that an unauthorized profile has been created about you, you can request for it to be removed by contacting us at email@example.com.
We place a premium on trust in our Service, so we may take steps to verify your identity.
Before a Researcher or Sponsor can complete registration on the Service, or at any time thereafter, we may request or re-request identity verification. Without limiting the manner in which we request identity verification, we may require Researchers or Sponsors to participate in a video call after submitting their government issued ID to enable us to confirm that the Researcher or Sponsor is indeed the individual in the ID or the organization represented. We may record such video calls and take screenshots of the user during the call. We may use the information obtained from Identity Verification for purposes of verifying your identity, enforcing our Terms of Service and other agreements, and preventing fraud.
Researchers, Agencies, and Sponsors may communicate with each other through the Service. For example, Researchers, Agencies, and Sponsors may wish to discuss Sponsor needs and Researcher applications. If you communicate with an Agency or Sponsor, that Agency or Sponsor will also be a “data controller” with respect to such communications.
We may offer public forums or blogs. If you participate, your comments and questions will be publicly displayed.
The Service may provide you the opportunity to participate and post content publicly in forums, on blogs, through interactive features on OSINT Central and through other communication functionality (“Community Forums”).
You may choose, through such features or otherwise, to submit or post questions, comments, or other content (collectively, “User Forum Content”). Please note that certain information, such as your name and Profile may be publicly displayed on the Service along with your User Forum Content. Please note that your use of Community Forums is subject to the our Forum Rules and our Terms of Service.
We display personal testimonials of satisfied customers on our Service, in addition to other endorsements. With your consent we may post your testimonial along with your name. If you wish to update or delete your testimonial, you can contact us.
Job Listings Through the Service
If you choose to publish a job listing via the Service as a Sponsor, the contents of such listing will be viewable publicly, unless you designate the listing as only viewable through the Service or as private using the settings available on the applicable website. Job listings can include information such as budget, location, history of work listing(s) by the Sponsor, the names of other Researchers performing work for the Sponsor, Sponsor feedback and rating information and timing of project performance.
We collect public and private feedback from our Users about their experience with other Users of our Service. Please note that any public feedback that you provide via the Service about your experience with other Users of our Service or that is provided about you by other Users is publicly viewable via the Service.
Any private feedback that you provide via the Service about your experience with other Users of our Service or that is provided about you by other Users will not be publicly viewable via the Service.
We also collect feedback from Users about our Service. We use this information to respond to your inquiries, improve the Service and how our Site functions, and develop new products and features.
Email to Friends and Referral Program
We may let you send job postings to friends via email. We may also offers the ability to send friends emails about providing or purchasing services through the Service. You should only provide us contact information from individuals who are familiar to you and with their consent. If you choose to use either feature, your friend’s email address will be used to send the requested posting and your email address will be used to copy you on the message to your friend or to send the message on your behalf. We store this information for the sole purpose of sending this one-time email and tracking the success of our referral program.
Social Networking Services
You may register for an account directly with our Site, or potentially through a social networking service. If you register with a social networking service (or later link your account to one), we will collect certain information about you from that social networking service, and what we collect depends on your privacy settings with that social networking service. The Service may also allow you to “like” or share content with social networking services.
You may register to join the Service directly via the Service or potentially by logging into your account with a third party social networking service (“SNS”) via our Service (e.g., LinkedIn, Github and other third party services that let you sign in using your existing credentials with those services).
If you choose to register via an SNS, or to later link your account with the Service to your account with an SNS, we will use the Personal Information you have provided to the SNS (such as your name, email address, gender and other information you make publicly available via the SNS) to create your account. Note that the information we collect from and through an SNS may depend on the privacy settings you have set with the SNS and the permissions you grant to us in connection with linking your account with the Service to your account with an SNS. Other than what we may share with the SNS as described below, the Personal Information an SNS has about you is obtained by the SNS independent of our Service, and we are not responsible for it.
Our Service also may permit additional interactions between it and a third party website, service, or other content provider, such as enabling you to “like” or share content to a third party SNS. If you choose to “like” or share content, or to otherwise share information from or via our Service with a third party site or service, that information may be publicly displayed, and the third party may have access to information about you and your use of our Service (and we may have access to information about you from that third party). These features may collect your IP address, which page you are visiting on our site, and may set a cookie to enable the feature to function properly. Your interactions with third parties through an SNS or similar features are governed by the respective privacy policies of those third parties.
You represent that you are entitled to use your SNS account for the purposes described herein without breach by you of any of the terms and conditions that govern the SNS, and without obligating us to pay any fees or making us subject to any usage limitations imposed by such SNS.
You can disable the link between your OSINT Central account and your SNS account at any time through the “Settings” section of our Service. Please note that your relationship with any SNS is governed solely by your agreement(s) with such SNS. If your SNS account terminates, then functions enabled through the link between your OSINT Central account and your SNS account will terminate as well.
On which legal basis and for which purpose(s) do we collect?
We need some of your Personal Information in order for you to use our Services.
We are allowed to process your Personal Information, because we comply with the Relevant Legislation. We lawfully process your Personal Information because:
- Processing Personal Information is necessary in order to perform our contract or agreement with you; Much of our processing of Personal Information is to meet our contractual obligations to our investors, or to take steps at Users' request in anticipation of entering into a contract with them.
- We have to comply with a legal obligation; we need to use and disclose Personal Information in certain ways to comply with our legal obligations.
- We have legitimate interests to process your Personal Information, where we have considered these are not overridden by your rights. In many cases, we handle Personal Information on the grounds that it furthers our legitimate interests in commercial activities, such as the following, in ways that are not overridden by the interests or fundamental rights and freedoms of the affected individuals:
- Providing our Site and Service.
- Detecting security incidents, protecting against malicious, deceptive, fraudulent or illegal activity, and prosecuting those responsible for that activity.
- Measuring interest and engagement in our Services.
- Short-term, transient use, such as contextual customization of ads.
- Improving, upgrading or enhancing our Services.
- Developing new products and services.
- Ensuring internal quality control and safety.
- Authenticating and verifying individual identities.
- Debugging to identify and repair errors with our Services.
- Auditing relating to interactions, transactions and other compliance activities.
- Enforcing our agreements and policies.
- Analyzing and improving our business.
- Communications, including marketing and responding to your inquiries about our services.
- Addressing information security needs and protecting our Users, OSINT Central, and others.
- Managing legal issues.
We make sure that the processing of your Personal Information is adequate, relevant and limited to what is necessary in relation to the purpose for which the Data is processed.
We shall only use your Personal Information for the purpose of providing our Services or for compatible purposes. By doing so, we will not use your Personal Information in an unexpected manner.
Are you obliged to share your Personal Information with us?
You do not have a statutory obligation to provide us with any information.
In some cases, the processing of your Personal Information is necessary. This is relevant, for example, when we have to process your Personal Information in order to oblige to a contract with you or to provide our Service to you. Without your Personal Information, we cannot provide our Service to you.
How long do we store your Personal Information?
We shall not store your Personal Information longer than the period in which we need them for the aforementioned purposes. We delete the Personal Information after we no longer need them for the purpose we process them for.
Unless you request that we delete certain information (see "Your Rights" below), we retain government-issued identification documents you submit to verify your identity for 40 days, selfies you submit to verify your identity for 180 days, a copy of the headshot image from your identity document for 5 years, and other information we collect for at least 5 years. Your information may persist in copies made for backup and business continuity purposes for additional time. If you choose to provide us with Personal Information, we encourage you to routinely update the data to ensure that we have accurate and up-to-date information about you.
With whom do we share your Personal Information?
We may share information about you to provide the Services, for legal and investigative purposes, in connection with sweepstakes and promotions, or if we are part of a merger or acquisition. We may also share non-identifying information with third parties. You have choices as to whether we share your personal information with third parties for their own marketing purposes.
Information about Researchers Shared with Sponsors: We share information regarding Researchers who have entered into a contract with a Sponsor, including information in work history, with Sponsors and Agencies.
Note that if a Researcher is suspended from our Service, we may share that information with Sponsors for whom that Researcher has worked or submitted proposals for work. We may also share information with Agencies to whom Researchers are associated for a particular contract.
If you choose to view a job post or submit an application for a job as a Researcher via the Service, we may share relevant information with the applicable Sponsor(s), including, but not limited to, the information contained in your Researcher Profile.
Information about Sponsors and Agencies Shared with Researchers: If you have entered into a research contract, we may provide him/her with your name, company address, billing address, or tax ID or VAT number in order to complete the transaction or to facilitate the resolution of a claim or dispute. The user receiving your information is not allowed to use it for purposes unrelated to the transaction, such as to contact you for marketing purposes, unless you have expressly consented to it.
Service Providers: We may employ third party companies and individuals to facilitate our Service, to provide the Service on our behalf, to perform Service-related services (e.g., without limitation, maintenance services, database management, web analytics and online advertising, payment processing, fraud detection and improvement of our features) or to assist us in analyzing how our Service is used. These third parties may have access to your Personal Information in order to perform these tasks on our behalf.
We are not responsible for the privacy policies and practices of third parties, and, if you later decide that you no longer want to receive communications from a third party, you will need to contact that third party directly. You also may request, sometimes through your use of an SNS or similar interactive feature or third party application, that we share information about you with a third party and we will typically do so under those circumstances.
Legal and Investigative Purposes: We will share information with government agencies as required by law in response to lawful requests by public authorities, including to meet national security or law enforcement requirements and, including without limitation, in connection with reporting earnings.
We cooperate with government and law enforcement officials and private parties to enforce and comply with the law.
We will disclose information about you to government or law enforcement officials or private parties as we, in our sole discretion, believe necessary or appropriate to respond to claims and legal process (including but not limited to subpoenas), or, at the request of governmental authorities or other third parties conducting an investigation where we determine in our sole discretion the disclosure is necessary to:
- protect the property and rights of OSINT Central or a third party;
- protect the safety of the public or any person; or
- prevent or stop activity we may consider to be, or pose a risk of being, illegal, fraudulent, unethical or legally actionable activity.
Internal and Business Transfers: We may share information, including Personal Information, with any current or future subsidiaries or affiliates, primarily for business and operational purposes, including activities such as IT management, for them to provide services to you, or support and supplement the Services we provide.
We may sell, transfer, or otherwise share some or all of our assets, including your Personal Information, in connection with a merger, acquisition, reorganization or sale of assets (including, in each case, as part of the due-diligence process with any potential acquiring entity) or in the event of bankruptcy.
Sweepstakes, Contests, and Promotions: We may offer sweepstakes, contests, and other promotions (any, a “Promotion”) that may require registration.
By participating in a Promotion, you are agreeing to the official rules that govern that Promotion, which may contain specific requirements of you, including, except where prohibited by law, allowing the sponsor(s) of the Promotion to use your name, voice, likeness, or other indicia of persona in advertising or marketing associated with the Promotion.
If you choose to enter a Promotion, your Personal Information may be disclosed to third parties or the public in connection with the administration of such Promotion, including, without limitation, in connection with winner selection, prize fulfillment, and as required by law or permitted by the Promotion’s official rules, such as on a winner’s list.
You have the following rights:
- You can request access to your Personal Information;
- You can request us to correct, limit or delete your Personal Information. In the event of fraud, non-payment or other wrongful acts, we can store some of your Personal Information in a register or on a blacklist;
- You can request a copy of your Personal Information. We can provide this copy to third parties at your request, so you do not have to do so yourself;
- You can object to the processing of your Personal Information;
- You can file a complaint at the Dutch Data Protection Authority (Autoriteit Persoonsgegevens) if you are of the opinion that we wrongfully process your data;
- You can always withdraw your permission to process your Personal Information. From the moment of your withdrawal, we cannot process your Personal Information anymore and features of our Service may become unavailable.
Please see our Privacy Center for more information or to submit a request to us regarding your Personal Information. We use automated means to calculate the Job Success Score of Researchers. If you believe that our services have miscalculated your Job Success Score or you would like to exercise any other rights with regard to your Personal Information, please contact us for assistance. We may be able to assist you by conducting a manual review of your Job Success Score, such as by assessing whether the information you’ve provided us is accurate. While we strongly encourage you to first raise any questions or concerns about your Personal Information directly with us, you have a right to lodge a complaint with the relevant supervisory authority and to seek judicial remedy.
We will use commercially reasonable efforts to honor your requests for deletion; however, certain information will actively persist on the Service even if you close your account, including information in your messages you posted to the Service.
In addition, the rights described above may be limited, for example, if fulfilling your request would reveal personal information about another person, or if you ask us to delete information we are required by law to keep or have compelling legitimate interests in keeping (such as for fraud prevention purposes).
Your Personal Information may remain in our archives and information you update or delete, or information within a closed account, may persist internally for our administrative purposes, to the extent permitted by law.
In addition, we typically will not remove information you posted publicly through or on the Service. Bear in mind that neither you nor we can delete all copies of information that has been previously shared with others on the Service.
How do we secure your Personal Information?
We do our utmost to protect your Personal Information from being lost, destroyed, abused, altered or spread by unauthorized parties.
We take commercially reasonable steps to help protect and secure the information we collect and store about our Users.
For this reason, persons who have nothing to do with your Personal Information, do not have access to them. We ensure this by taking the following measures:
- All access to the Site is encrypted using industry-standard transport layer security technology (“TLS”);
- We also use HTTP strict transport security to add an additional layer of protection for our Users;
- The access to the Personal Information is strictly limited to the employees on a ‘need to know’ basis;
But remember that no method of transmission over the Internet, or method of electronic storage, is 100% secure. Thus, while we strive to protect your Personal Information, we cannot ensure and does not warrant the security of any information you transmit to us.
We shall only process your Personal Information within the European Union. We shall only process your data outside the European Union if that country offers an appropriate level of protection for your Personal Information.
We shall never transfer your Personal Information to other countries or to other parties than those mentioned above.
Phishing websites imitate legitimate websites in order to obtain personal or financial information. Identity theft and the practice currently known as “phishing” are of great concern to us.
If you believe you have received an email or had a similar interaction with a third party pretending to be OSINT Central, please report it.
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