Privacy statement
25 november 2024
We recognise that your privacy is very important and take it seriously. This Privacy & Cookies Policy describes the policies and procedures of WHO KNOWS GINNY on the collection, use and disclosure of your information when you use the services, websites, and applications offered by WHO KNOWS GINNY (the "Services") and tells you about your privacy rights and how the law protects you. By using the Services, you consent to our use of your information in accordance with this Privacy & Cookies Policy. We will not use or share your personal information with anyone except as described in this Privacy & Cookies Policy. Capitalised terms that are not defined in this Privacy & Cookies Policy have the meaning given them in our Terms of Service.
This Privacy & Cookies Policy is intended to meet our duties of transparency under relevant law, including the General Data Protection Regulation ("GDPR"). We will post any modifications or changes to this Privacy & Cookies Policy on this page and then update the effective date displayed at the top of this page.
This Privacy & Cookies Policy is intended to meet our duties of transparency under relevant law, including the General Data Protection Regulation ("GDPR"). We will post any modifications or changes to this Privacy & Cookies Policy on this page and then update the effective date displayed at the top of this page.
Who we are and how to contact us
Who we are. WHO KNOWS GINNY B.V. (doing business as WHO KNOWS GINNY) is the Controller (for the purposes of the GDPR) of your Personal Data (referred to as either "WHO KNOWS GINNY", "we", "us" or "our" in this Privacy & Cookies Policy). Our address is Prinsengracht 769, 1017 JZ, Amsterdam, the Netherlands. How to contact us. If you have any questions about our practices or this Privacy & Cookies Policy, please contact us at hello@whoknowsginny.com.
Your rights relating to your Personal Data
You have the right under this Privacy and Cookies Policy, and by law in certain jurisdictions, to:
Request access to your Personal Data. If you are in certain jurisdictions, this enables you to receive a copy of the Personal Data we hold about you and to check that we are lawfully processing it.
Request correction of the Personal Data that we hold about you. This enables you to have any incomplete or inaccurate information we hold about you corrected.
Request erasure of your Personal Data. This enables you to ask us to delete or remove Personal Data where there is no good reason for us continuing to process it. You also have the right if you are within the EU to ask us to delete or remove your Personal Data where you have exercised your right to object to processing (see below).
Object to processing of your Personal Data. This right exists where we are relying on a legitimate interest as the legal basis for our processing and there is something about your particular situation, which makes you want to object to the processing of your Personal Data on this ground. You also have the right to object where we are processing your Personal Data for direct marketing purposes.
Request the restriction of processing of your Personal Data. This enables you to ask us to suspend the processing of Personal Data about you in certain scenarios. For example, if you want us to establish its accuracy or the reason for processing it.
Request the transfer of your Personal Data. If you are in certain jurisdictions, we will provide to you, or a third party you have chosen, your Personal Data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.
Withdraw consent. This right only exists where we are relying on consent to process your Personal Data ("Consent Withdrawal"). If you withdraw your consent, we may not be able to provide you with access to certain specific functionalities of our Site. We will advise you if this is the case at the time you withdraw your consent.
How to exercise your rights. If you want to exercise any of the rights described above, please contact us by sending an email to hello@whoknowsginny.com.
Typically, you will not have to pay a fee to access your Personal Data (or to exercise any of the other rights). However, except in relation to Consent Withdrawal, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive, or, we may 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 four weeks. Occasionally it may take us longer than this time window if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.
Request access to your Personal Data. If you are in certain jurisdictions, this enables you to receive a copy of the Personal Data we hold about you and to check that we are lawfully processing it.
Request correction of the Personal Data that we hold about you. This enables you to have any incomplete or inaccurate information we hold about you corrected.
Request erasure of your Personal Data. This enables you to ask us to delete or remove Personal Data where there is no good reason for us continuing to process it. You also have the right if you are within the EU to ask us to delete or remove your Personal Data where you have exercised your right to object to processing (see below).
Object to processing of your Personal Data. This right exists where we are relying on a legitimate interest as the legal basis for our processing and there is something about your particular situation, which makes you want to object to the processing of your Personal Data on this ground. You also have the right to object where we are processing your Personal Data for direct marketing purposes.
Request the restriction of processing of your Personal Data. This enables you to ask us to suspend the processing of Personal Data about you in certain scenarios. For example, if you want us to establish its accuracy or the reason for processing it.
Request the transfer of your Personal Data. If you are in certain jurisdictions, we will provide to you, or a third party you have chosen, your Personal Data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.
Withdraw consent. This right only exists where we are relying on consent to process your Personal Data ("Consent Withdrawal"). If you withdraw your consent, we may not be able to provide you with access to certain specific functionalities of our Site. We will advise you if this is the case at the time you withdraw your consent.
How to exercise your rights. If you want to exercise any of the rights described above, please contact us by sending an email to hello@whoknowsginny.com.
Typically, you will not have to pay a fee to access your Personal Data (or to exercise any of the other rights). However, except in relation to Consent Withdrawal, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive, or, we may 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 four weeks. Occasionally it may take us longer than this time window if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.
Complaints
If you would like to submit a complaint regarding this Privacy Policy or our practices in relation to your Personal Data, please contact us at: hello@whoknowsginny.com.
We will reply to your complaint as soon as we can.
If you feel that your complaint has not been adequately resolved, please note that if you are in the EU the GDPR gives you the right to contact your local data protection supervisory authority.
We will reply to your complaint as soon as we can.
If you feel that your complaint has not been adequately resolved, please note that if you are in the EU the GDPR gives you the right to contact your local data protection supervisory authority.
Marketing communications preferences
You can ask us to stop sending you marketing messages or modify your email preferences at any time through any of the following methods:
Where you opt out of receiving these marketing messages, this will not apply to Personal Data provided to us as a result of emails relating to existing or pending hires, purchases or investments using the Services or consent to direct marketing communications.
- by following the opt-out links on any marketing message sent to you; or
- by contacting us at any time sending an email to hello@whoknowsginny.com
Where you opt out of receiving these marketing messages, this will not apply to Personal Data provided to us as a result of emails relating to existing or pending hires, purchases or investments using the Services or consent to direct marketing communications.
What Personal Data we collect
WHO KNOWS GINNY uses Personal Data we collect to provide the Services, personalise content, remember information to help you efficiently access your account, analyse how the Services are used, diagnose service or technical problems, maintain security, monitor aggregate metrics such as total number of visitors, traffic, and demographic patterns, and track user content and users as necessary to comply with the applicable laws.
Information You Directly Provide to Us. There are many occasions when you provide information that may enable us to identify you personally ("Personal Data") while using the Services.
Personal Data from Third Party Sources. In addition to the Personal Data that we collect directly from you, we may also collect certain of your Personal Data from third party sources, some of which may not be publicly available.
Aggregated Data. We may also collect, use and share "Aggregated Data" such as statistical or demographic data for any purpose. Aggregated Data may be derived from your Personal Data, but once in aggregated form it will not constitute Personal Data for the purposes of the GDPR as this data does not directly or indirectly reveal your identity. However, if we combine or connect Aggregated Data with your Personal Data so that it can directly or indirectly identify you, we treat the combined data as Personal Data which will be used in accordance with this Privacy & Cookies Policy.
Google API Policy. If you choose to connect any of our Services with Google Gmail, WHO KNOWS GINNY’s use and transfer of information received from Google APIs to any other app will adhere to Google API Services User Data Policy, including the Limited Use requirements.
Information You Directly Provide to Us. There are many occasions when you provide information that may enable us to identify you personally ("Personal Data") while using the Services.
Personal Data from Third Party Sources. In addition to the Personal Data that we collect directly from you, we may also collect certain of your Personal Data from third party sources, some of which may not be publicly available.
Aggregated Data. We may also collect, use and share "Aggregated Data" such as statistical or demographic data for any purpose. Aggregated Data may be derived from your Personal Data, but once in aggregated form it will not constitute Personal Data for the purposes of the GDPR as this data does not directly or indirectly reveal your identity. However, if we combine or connect Aggregated Data with your Personal Data so that it can directly or indirectly identify you, we treat the combined data as Personal Data which will be used in accordance with this Privacy & Cookies Policy.
Google API Policy. If you choose to connect any of our Services with Google Gmail, WHO KNOWS GINNY’s use and transfer of information received from Google APIs to any other app will adhere to Google API Services User Data Policy, including the Limited Use requirements.
How we use your Personal Data and why
We generally use Personal Data for the following:
- to deliver and improve our Services;
- to manage your account and provide you with customer support;
- to perform research and analysis about your use of the Services;
- to develop, display, and track Content and advertising tailored to your interests on the Services and other sites, including, potentially, providing our advertisements to you when you visit other sites; website or mobile application analytics;
- to diagnose or fix technology problems; to automatically update the Services on your device;
- to verify your identify and prevent fraud or other unauthorised or illegal activity;
- to enforce or exercise any rights in our Terms of Service;
We may also use your Personal Data for purposes of verifying your identity generally for use of the WHO KNOWS GINNY platform.
In respect of each of the purposes for which we use your Personal Data, the GDPR requires us to ensure that we have a legal basis for that use if you are within the EU. The legal bases depend on the Services you use and how you use them. This means we collect and use your Personal Data only where:
- We need it to provide you the Services, including to operate the Services, provide customer support and personalised features and to protect the safety and security of the Services;
- Processing of your Personal Data is necessary for the performance of a contract to which you are a party or to protect your vital interests or that of another person;
- It satisfies a legitimate interest (which is not overridden by your data protection interests), such as for research and development, to market and promote the Services and to protect our legal rights and interests; or
- We need to process your data to comply with a legal or regulatory obligation.
We may also rely on your consent as a legal basis for using your Personal Data where we have expressly sought it for a specific purpose. If we rely on your consent to a use of your Personal Data, you have the right to change your mind at any time but this will not affect any processing that has already taken place.
What happens when you do not provide necessary Personal Data? Where we need to process your Personal Data either to comply with law, or to perform the terms of a contract we have with you and you fail to provide that data when requested, we may not be able to perform the contract we have or are trying to enter into with you (for example, to provide you with the functionalities of the Services). In this case, we may have to stop you from using our Services.
How we use cookies and other tracking or profiling technologies WHO KNOWS GINNY may collect non-personally identifiable information regarding your usage of the Services, including the pages and articles and presentations you viewed, time spent using certain features of the website, demographic data such as server locations, connection speed, and other information that does not identify you. Like most online services, we also use cookies, log files, tracking pixels, web beacons, and other technologies that may collect Personal Data.
Who we share your personal data with
We may share your Personal with third parties in the ways that are described in the table below. We consider this information to be a vital part of our relationship with you.
Service providers. Our service providers provide us support for our Services, including, for example, website and application development, hosting, maintenance, backup, storage, virtual infrastructure, payment processing, analysis, identity verification, background and compliance reviews, fund administration, banking services, and other services for us, which may require them to access or use Personal Data about you.
Professional advisors. Our lawyers, accountants, bankers, auditors and insurers may need to review your personal data to provide consultancy, compliance, banking, legal, insurance, accounting and similar services.
Legal and Taxing Authorities.WHO KNOWS GINNY may disclose your Personal Data if we believe it is reasonably necessary to comply with a law, regulation, order, rule of a self-regulatory organisation or audit or to protect the safety of any person, to address fraud, security or technical issues, or to protect our legal rights, interests and the interests of others, such as, for example, in connection with the acquisition, merger or sale of securities or a business (e.g. due diligence).
Advertisers. Certain users of the Services may have access to your Personal Data for the purpose of enabling them to interact with you and more effectively offer opportunities through the Site that are targeted towards your background and preferences. We may also allow third-parties, including ad servers or ad networks, to serve advertisements on the Site, and such third parties may be provided with access to your Personal Data to provide advertising tailored to your interests.
In addition, Personal Data you choose to add to your profile will be available for public viewing on the Site. If you want your information to remain private, don't make it available to other users on our Site. If you are a Job Seeker, your information will generally be publicly available and Employers may have access to your Personal Data to assist them in discovering, evaluating and tracking communications with prospective candidates.
As we develop our business, we may buy or sell businesses or assets. In the event of a corporate sale, merger, reorganisation, dissolution or similar event, we may also transfer your Personal Data as part of the transferred assets without your consent or notice to you.
We may also share non-Personal Data (such as anonymous usage data, referring/exit pages and URLs, number of clicks, etc.) with interested third parties to help them understand the usage patterns for certain Services or conduct independent research based on such anonymous usage data
If you request that we remove your Personal Data as described in the section “Your rights relating to your Personal Data”, we will convey that request to any third-party with whom we have shared your data. We are not, however, responsible for revising or removing your Personal Data obtained by any third party who has previously been provided your information by us in accordance with this policy or any third party to whom you have provided such information (whether by sharing your login and password, or otherwise).
Service providers. Our service providers provide us support for our Services, including, for example, website and application development, hosting, maintenance, backup, storage, virtual infrastructure, payment processing, analysis, identity verification, background and compliance reviews, fund administration, banking services, and other services for us, which may require them to access or use Personal Data about you.
Professional advisors. Our lawyers, accountants, bankers, auditors and insurers may need to review your personal data to provide consultancy, compliance, banking, legal, insurance, accounting and similar services.
Legal and Taxing Authorities.WHO KNOWS GINNY may disclose your Personal Data if we believe it is reasonably necessary to comply with a law, regulation, order, rule of a self-regulatory organisation or audit or to protect the safety of any person, to address fraud, security or technical issues, or to protect our legal rights, interests and the interests of others, such as, for example, in connection with the acquisition, merger or sale of securities or a business (e.g. due diligence).
Advertisers. Certain users of the Services may have access to your Personal Data for the purpose of enabling them to interact with you and more effectively offer opportunities through the Site that are targeted towards your background and preferences. We may also allow third-parties, including ad servers or ad networks, to serve advertisements on the Site, and such third parties may be provided with access to your Personal Data to provide advertising tailored to your interests.
In addition, Personal Data you choose to add to your profile will be available for public viewing on the Site. If you want your information to remain private, don't make it available to other users on our Site. If you are a Job Seeker, your information will generally be publicly available and Employers may have access to your Personal Data to assist them in discovering, evaluating and tracking communications with prospective candidates.
As we develop our business, we may buy or sell businesses or assets. In the event of a corporate sale, merger, reorganisation, dissolution or similar event, we may also transfer your Personal Data as part of the transferred assets without your consent or notice to you.
We may also share non-Personal Data (such as anonymous usage data, referring/exit pages and URLs, number of clicks, etc.) with interested third parties to help them understand the usage patterns for certain Services or conduct independent research based on such anonymous usage data
If you request that we remove your Personal Data as described in the section “Your rights relating to your Personal Data”, we will convey that request to any third-party with whom we have shared your data. We are not, however, responsible for revising or removing your Personal Data obtained by any third party who has previously been provided your information by us in accordance with this policy or any third party to whom you have provided such information (whether by sharing your login and password, or otherwise).
How long we store your Personal Data
We will retain your information for as long as your account is active or it is reasonably needed for the purposes set out in How We Use Your Personal Data and Why unless you request that we remove your Personal Data as described in Your Rights Relating to Your Personal Data. We will only retain your Personal Data for so long as we reasonably need to use it for these purposes unless a longer retention period is required by law (for example for regulatory purposes). This may include keeping your Personal Data after you have deactivated your account for the period of time needed for us to pursue legitimate business interests, conduct audits, comply with (and demonstrate compliance with) legal obligations, resolve disputes and enforce our agreements.
How we protect your Personal Data
WHO KNOWS GINNY uses industry-standard physical, managerial, and technical safeguards to preserve the integrity and security of your personal information. We limit access to your Personal Data to those employees and other staff who have a business need to have such access. All such people are subject to a contractual duty of confidentiality. We periodically review our policies and procedures to evaluate their effectiveness and ensure that they remain up to date. We cannot, however, ensure or warrant the security of any information you transmit to WHO KNOWS GINNY or guarantee that your information on the Services may not be accessed, disclosed, altered, or destroyed by a breach of any of our physical, managerial, or technical safeguards.
We have put in place procedures to respond to any actual or suspected Personal Data breach. In the event that personal information is compromised as a result of such a breach of security, WHO KNOWS GINNY may promptly notify those persons whose personal information has been compromised by posting a notice on the Site, via the functionality of the Services, or by sending an e-mail to you. You may have a legal right to receive this notice in writing.
WHO KNOWS GINNY cannot ensure that your Personal Data will be protected, controlled or otherwise managed pursuant to this Privacy & Cookies Policy if you share your login and password information with any third party, including any third party operating a website or providing other services.
We have put in place procedures to respond to any actual or suspected Personal Data breach. In the event that personal information is compromised as a result of such a breach of security, WHO KNOWS GINNY may promptly notify those persons whose personal information has been compromised by posting a notice on the Site, via the functionality of the Services, or by sending an e-mail to you. You may have a legal right to receive this notice in writing.
WHO KNOWS GINNY cannot ensure that your Personal Data will be protected, controlled or otherwise managed pursuant to this Privacy & Cookies Policy if you share your login and password information with any third party, including any third party operating a website or providing other services.
Changes to our Privacy & Cookies Policy
We reserve the right, in our sole discretion, to change, modify, add, or remove portions of this Privacy & Cookies Policy at any time. Any changes or updates will be effective immediately upon posting to this page. You should review this Privacy & Cookies Policy regularly for changes. You can determine if changes have been made by checking the Effective Date at the top of this page. Your continued use of our Site following the posting of any changes to this Privacy & Cookies Policy means you consent to such changes.
It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during your relationship with us.
It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during your relationship with us.