Privacy Policy
Version Update: 28/05/2022
DataMix Europe OÜ created this policy in line with its commitment to your privacy as a website user of
https://www.canary.consulting/ (and any related site or mobile device application designated by us), as may be
updated by us from time to time(“Users”) and/or a person with whom we cooperate, including our clients, business
partners, their representatives and Alpha Specialists (henceforth referred to as “You” and “Yours”). Unless
specifically referred to a given category of data subjects, the below provisions apply to all of them. For the
terms of this policy, DataMix Europe OÜ with its registered office at F. R. Kreutzwaldi tn 4-7 Kesklinna
linnaosa, Tallinn Harju maakond 10120 is a controller of data collected in connection with our website and our
business. The terms “we”, “us”, “our” refer to DataMix Europe OÜ (henceforth referred to as “Canary
Consulting”). If you have any questions regarding the processing of your personal data please contact us at:
office@datamix.space.
Terms Used in the Policy
GDPR – Refers to the European Parliament and Council Regulation (EU) 2016/679 of 27 April 2016 on the
protection of natural persons with regard to the processing of personal data and on the free movement of such
data (a general data protection regulation).
Personal Data − Refers to any information relating to an identified or identifiable natural person. An
identifiable natural person is one who can be identified, directly or indirectly, in particular by reference to
an identifier such as a name, an email address or a telephone number of the person and other data when combined
with the above.
Sensitive Personal Data – Special categories of Personal Data mentioned in Art. 9 of the GDPR and
Personal Data mentioned in Art. 10 of the GDPR include: racial or ethnic origin, political opinions, religious
or philosophical beliefs, trade union membership, criminal convictions and offences or related security
measures, genetic data, biometric data for the purpose of uniquely identifying a person, health, sex life or
sexual orientation.
Processing – Refers to any operation or set of operations which is performed on Personal Data or on sets
of Personal Data, by automated means or otherwise, such as: collection, recording, organization, structuring,
storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or
otherwise making available, alignment or combination, restriction, erasure or destruction.
Online Services – Refers to all of the services made available to You by us or our affiliates via our
Websites or the DataMix mobile device applications, including in particular the application program interface,
DataMix’s content, our users pool database, your Account and any other service provided by us under our separate
Terms of Use.
Purposes & Legal Basis of Processing
We process Personal Data in order to:
- Execute the agreement concluded by You as our business partner, Contractor, client or in order to undertake
actions on your request before the conclusion of the agreement with regards to the processing of Your data as
a sole entrepreneur or Your company’s representatives authorized to conclude the agreement with us (Art. 6.1.b
of the GDPR) and to make cooperation/execution of the agreement easier with regards to the processing of your
contact persons’/representatives’ personal data (Art. 6.1.f of the GDPR).
- Provide responses to your inquiries sent through the website contact form, e-mail or phone. In such a case the
legal basis for the processing of your Personal Data is our legitimate interest in contacting You in reference
to Your inquiry (Art. 6.1.f of the GDPR).
- Send direct marketing information (including the Canary Consulting newsletter) to users, clients and business
partners (Businesses, Contractors), via e-mail addresses they provide on the legal basis of their consent
(Art. 6.1.a of the GDPR) and in case we have already a relevant relation with You, based on our legitimate
interest (Art. 6.1.f of the GDPR). In cases where we will do marketing profiling, we shall process Your
Personal Data based on Your consent, if required. (Art. 6.1.a of the GDPR). Consent/s for sending marketing
information in accordance with Art. 10 of the act on rendering services by electronic means and / or Art. 172
of Polish Telecommunications Act, is expressed by You independently and separately.
- Organize competitions by Canary Consulting, conferences or events. Your Personal Data will be processed only
if You have registered as a participant. The legal basis for the organization of competitions is consent (Art.
6.1.a of the GDPR).
- Organize and conduct open and dedicated training sessions. In the case of training sessions, the legal basis
for the processing of Personal Data is an agreement for the provision of training services conducted with
Canary Consulting by sending electronically the respective order form (Art. 6.1.b of the GDPR).
If You are a Contractor whose services may be needed by Businesses, the processing of Your Personal Data will
take place mostly as a result of Canary Consulting’s cooperation with our Businesses users. In such a case we
will process Your Personal Data in order to:
- Pursue our business, i.e. connect You with enterprise clients by matching projects suitable to Your level of
professional experience and sending Your Personal Data to clients on this basis; by managing the relationship
with You to enable You, as an Contractor, to participate in Businesses’ projects. In such a case the legal
basis for the processing of Your Personal Data is our legitimate interest in (Art. 6.1.f of the GDPR).
- We may, in random cases process Your Personal Data as an Contractor within the assessment of the effectiveness
of the measurement tools we use such as tests, games and, questionnaires for the purpose of verifying their
effectiveness. The legal basis of the processing will be our legitimate interest (Art. 6.1.f of the GDPR).
- If you decide to use Canary Consulting Online Services, we will process Your Personal Data for the purpose of
entering into an agreement concerning the provision of our Online Services, including the registration as
defined in the Terms of Use for those Online Services. In such cases the legal basis for the processing of
Your Personal Data is entering into a contract with You concerning the provision of Online Services (Art.
6.1.b of the GDPR).
- If You decide to settle an Account with Canary Consulting Online Services, we may process Your Personal Data
in order to manage Your Account and to manage any contacts with You in this scope. The legal basis of the
processing will be our legitimate interest in assigning You to a project (Art. 6.1.f of the GDPR).
The legitimate interest of Canary Consulting is to:
- Contact You to answer Your queries;
- Process a contact persons’ data in order to execute the agreement with our other users;
- Send direct marketing communications to disseminate information about Canary Consulting’s services;
- Manage Your Account on Canary Consulting’s Online Services – to facilitate Your use of these services and to
answer Your queries;
- To simplify the process of evaluating, matching roles and making placements as well as facilitating the
internal management of our relationship with users – in order to more effectively manage the assignment of
Contractors to Businesses projects.
If consent is required for the processing in question, it will be sought from You separately to ensure that it
is freely given and informed. To the extent that Canary Consulting relies on Your consent to process Your
Personal Data, You have the right to withdraw Your consent to such processing at any time. You can do this by
contacting our data protection team at:
office@datamix.space. The withdrawal of Your
consent does not affect the lawfulness of its processing based on consent before its withdrawal.
The Provision of Your Data
Whenever you provide us directly with Your Personal Data, the provision of Your Personal Data, in each case is
voluntary, however without its provision, You won’t be able to receive certain information (e.g. marketing
newsletters) or take part in training, conferences, competitions, events or You won’t be able to settle an
Account with Canary Consulting Online Services as stated in our Terms of Use or we won’t be able to address your
enquiry or to match a project that is suitable for You and as a consequence to be able to recommend Your
services to our Business clients.
Sensitive Personal Data
Canary Consulting does not process Sensitive Personal Data unless:
- The processing is required or permitted by law or;
- Canary Consulting has obtained Your explicit consent, such as for the measurement of Your personal
characteristics, where relying on consent is permitted or appropriate under applicable law.
Your Rights
You may have certain rights in relation to Your Personal Data. Some of these rights only apply in certain
circumstances. If You would like to exercise any of these rights, please contact us at:
office@datamix.space.
- Access: You are entitled to request access to Your Personal Data that we process.
- Correction: You are entitled to ask that any incomplete or inaccurate Personal Data we hold about You
is corrected.
- Erasure: You are entitled to ask us to delete or remove Your Personal Data in certain circumstances.
There are also certain exceptions where we may refuse a request for erasure, for example, where the Personal
Data is still required in relation to the purposes for which it was collected.
- Restriction: In some circumstances, You are entitled to ask us to suspend the processing of some of
Your Personal Data, for example, if You want us to establish its accuracy or the reason for processing it.
- Data Portability: In some circumstances, You may ask us to transfer Your Personal Data to another
party.
- Objection: Where we are processing Your personal data based on our legitimate interests (or those of a
third party), You may object to its processing. However, we may be entitled to continue processing Your
Personal Data if we can demonstrate compelling legitimate grounds for its processing.
- Withdrawing Your Consent: Where Your Personal Data is processed with Your consent, You have the right
to withdraw Your consent at any time. The withdrawal of consent will not affect the lawfulness of its
processing based on consent before its withdrawal.
How Long We Keep Your Personal Data
Canary Consulting retains personal data to meet the purposes for which the data was collected or in order to
ensure compliance with applicable laws or to protect legitimate company interests (e.g. statute of limitations
periods). We will store Your personal data for the purposes of:
- The execution of the agreement throughout the period of our cooperation with You and the lapse of the statute
of limitations period.
- Maintaining Your Account within Canary Consulting Online Services, as stated in our Terms of Use for the
period You use our Online Services and longer, only if and when we are required to do so by law.
- Answering your enquiries – for the time period of our correspondence and longer if justified to ensure we have
an adequate log of our correspondences.
- Sending marketing materials – for the period of sending You our materials up to the period you shall file your
objection to such processing.
- Keeping Your Personal Data, as an user, in our database in order to match projects suitable for Your
professional experience with our Business or your projects with relevant Contractors.
With Whom Do We Share Your Personal Data
Your data provided to us can be disclosed to:
- Our Subcontractors
- Our Business Partners
- Canary Consulting Online Services Users
- Entities authorized by law to obtain Your Personal Data
The Transfer of Personal Data to Third Countries
Canary Consulting does not transfer Your Personal Data to third countries. In case of data transfers to third
parties established outside the EEA or Switzerland; in countries which are not deemed by the European Commission
to provide adequate data protection (non-adequate third countries), Canary Consulting shall rely on transfer
mechanisms in accordance with applicable laws, which includes (1.) the EU “Standard Contractual Clauses”, (2.)
and the Privacy Shield Certification of the third party (if established in the U.S.). When the third party is
established in a country that is deemed by the EU Commission to provide adequate data protection, we rely on the
protections available under local law.
For more information about, or to obtain a copy of specific transfer mechanisms, including information on any of
the existing safeguards implemented by Canary Consulting in case such transfers occurs, please contact
office@datamix.space.
How We Secure Your Personal Data
Canary Consulting maintains appropriate administrative, technical and physical safeguards designed to protect
Your Personal Data against accidental or unlawful destruction, accidental loss, alteration, unauthorized
disclosure or access, use, and all other unlawful forms of processing of personal data in our possession.
Changes to This Privacy Policy
We reserve the right to change this Privacy Policy at any time. When we make material changes to this Privacy
Policy, we will post the changes on our website and update the revision date at the top of the Privacy