Global Privacy Policy

Effective date: October 1, 2024
Last revised: October 27, 2024

Greystones Retail SL, a company based in Madrid, Spain, (“Inevista,” “us,” “we,” or “our”) operates the www.inevista.com website (the “Site”) and provides global mobility services and related offerings (the “Services”), which are available through the Site.

Inevista has developed a global privacy program under which we offer the same high standards of privacy protection regardless of where you are in the world. When we refer to Inevista, we mean the Inevista entity with which you have an agreement, if applicable.

This Privacy Policy informs you of how information about you is collected, used, and disclosed by us.

This Privacy Policy forms part of our Inevista Platform Terms of Service. Unless otherwise defined in this Privacy Policy, capitalized terms used in this Privacy Policy have the same meanings as in our Terms of Service.

Scope of Application

This Privacy Policy applies to the following individuals:

Visitors of the Site with whom Inevista does not have a contractual relationship
Clients who use our Services, including client representatives
Suppliers who provide products or services to Inevista
Candidates applying for roles or engaging with us
Prospects and participants in webinars, conferences, trade events, surveys, etc.

By using our Site and/or our Services, as well as engaging with Inevista in any way, you agree to the collection and use of your information in accordance with this Privacy Policy.

Information Collection

Inevista collects and stores certain information about you. This information can be used on its own or in combination with other information to identify you (“Personal Information”). Below is a list of types of Personal Information that we may collect and use about you.

Categories of Personal Information

Category	Description
Contact	Information we use to contact you, including physical addresses, email addresses, and phone numbers.
Identification	Information we use to identify you, including full name, government ID, passport, date of birth, and selfie.
Financial	Information about an individual’s financial account, including bank account details and payment card details.
Transactional	Information about the transactions you carry out and payments to and from your accounts with us, including amounts and dates.
Contractual	Information about the products or services we provide to you.
Locational	Information we get about where you are, including country and IP address. This may come from your mobile phone or the place where you connect a computer to the internet. It may also include locations where you used your card.
Usage	Information about the usage of our Services and Site, including metadata.
Technical	Information on the devices and technology you use, including IP address, login data, browser type and version, timezone, operating system.
Communications	Information from communications between us, including any personal data you may share with us in your messages and communication metadata.
Professional	Information about your professional career and educational background, including current and past job positions, degrees, and qualifications.
Public and Third-Party Records	Information about you that is in public records and publicly available online. We may also collect information about you from other companies, such as credit reference or fraud protection agencies.
Consents	Any permissions, consents, or preferences that you give us.
Community Platform Content	The Inevista platform allows you to post or transmit comments, computer files, messages, and other materials. This content may include personal data.
Biometric Data	To automatically verify your identity and prevent fraud, we may use your biometric data. Specifically, we may collect a photo of you (a selfie) along with government-issued identification. Using facial recognition technology, the information from your photo is matched against the information on your identification document.
Other Information	Any other information you choose to provide to us through all available channels, participating in user/customer surveys, or otherwise visiting and interacting with our Site and/or Services.

For the avoidance of doubt, Personal Information shall not include any personal information that has been anonymized, where identifiable data is destroyed.

Inevista may also collect and use non-Personal Information to analyze the effectiveness of our Services and improve them. We may collect non-Personal Information through the Services, the Site, and through cookies.

Sources of Your Personal Information

We may collect Personal Information about you or your businesses from any of these sources:

Directly from you when you use our Services, complete a contact form, request marketing communications, participate in surveys, or contact us.
Inevista collects profile and usage data when you interact with our Site and/or Services, including, without limitation, your security details, app or your web browser settings, marketing choices, and data from the devices you use to connect to our platform so we can provide you with our products or services.
We also collect information through the use of cookies and other internet tracking software while you are using our website or mobile apps, as described in detail in our Cookie Policy.

From third parties:

Companies, business partners, or individuals that introduce you to us.
Business partners, service providers, sub-contractors, advertising networks, analytics providers, search information providers, fraud protection services, Payment Service Providers (PSPs) who help us authenticate your identity, improve the quality of our Services, promote our Services, and protect our business. We may also receive Personal Information about you from providers that help prevent, detect, and prosecute unlawful acts, money laundering, and fraudulent behavior.
Social networks and other technology providers (for instance, when you click on one of our Facebook or Google ads).
Public information sources such as (without limitation) national company registries.
Market researchers.
Government, law enforcement agencies, authorities, and regulatory bodies.

Cookie Use

Please refer to our Cookie Policy for more information.

Information Use

Below is a list of the ways that we may use your Personal Information, together with the legal basis of processing, where applicable under data protection law.

Purposes for which we use your Personal Information | Legal basis

Individuals	Management of the contractual relationship with you to provide you with our Services	Performance of the contract	Compliance with our legal obligations
Clients, Independent Contractors, Suppliers	Improving our business by enhancing services, operations, and developing new ways to meet customer needs	Performance of a contract	Legitimate interest (enhancing service quality, optimizing operations, and maintaining market competitiveness)
Visitors of the Site, Clients, Independent Contractors, Suppliers, Prospects	Secure access to our Services, including identification and verification processes prior to granting access	Performance of the contract	Legitimate interest (safeguarding access to authorized users)
Clients, Independent Contractors	Marketing and events-related communications, including personalized content and advertising campaigns	Consent	Legitimate interest (personalized marketing communications and engagement)
Visitors of the Site, Clients, Independent Contractors, Prospects	Recruitment and assessing candidates’ qualifications for available positions	Performance of the contract	Legitimate interest (assessing candidate suitability for current and future opportunities)
Visitors of the Site, Clients, IndependentContractors, Suppliers, Prospects	Protect the security or integrity of us, our Site, and our Services	Legitimate interest	Legal Obligation
Visitors of the Site, Clients, Independent Contractors, Community Platform Users, Prospects, Participants in webinars, events, surveys	Communication about our Site and Services, including notifying changes, providing customer support	Performance of the contract	Legitimate interest (delivering a seamless and informative user experience)
Clients, Independent Contractors, Suppliers	Manage business operations, payments, and debt collection	Performance of the contract	Legitimate interests (efficient business operations and financial stability)
Clients, Independent Contractors, Suppliers	Meet legal, regulatory, and tax reporting obligations	Legal obligation
Clients, Independent Contractors, Suppliers	Provide and maintain the Inevista Community Platform	Performance of the contract	Legitimate interest (ensuring the platform operates smoothly)
Community Platform Users	Aggregating pseudonymized personal data for compensation benchmarking and academic research	Consent	Performance of a contract

In cases where we need to process personal data for the performance of a contract with you or as required by law and you refuse to provide your information, we may not be able to perform the contract with you and, consequently, we may not be able to provide certain services to you.

Communications

We may contact you with newsletters and other marketing information that may be of interest to you. You may opt out of receiving any, or all, of these marketing communications from us by following the unsubscribe link or instructions provided in any email we send or by contacting us. Please note that we may still send you transactional or administrative messages related to the Service even after you have opted out of receiving marketing communications.

Information Sharing with Third Parties

We will only share your information with the third parties listed below for the purposes described above in the “Information Use” Section unless otherwise noted at the point of collection. We want to assure you that we do not sell or trade any personal information to third parties under any circumstances.

Our clients to whom you provide your services.
Trusted third-party agents, partners, suppliers, and service providers who assist us in providing the Services to you, and are only permitted to use your information according to the purposes specified in their agreement with us. These third parties include website hosts, data hosts, cloud software providers, IT providers, identification verification providers, customer support providers, payment processors, financial institutions, financial advisors, legal advisors, auditors, and insurance companies. These partners are required under law and contract to keep your Personal Information confidential.
Government or public agencies, law enforcement authorities, regulators, or any other entity having appropriate legal authority for receipt of your Personal Information, if required or permitted by law or legal process, or if we believe that such action is necessary to comply with the law, to protect the security or integrity of our business, our Site and/or Services, and to protect the safety of the users of our Services or the public.
We may disclose your Personal Information to a third party who acquires any part of our business, whether such acquisition is by way of merger, consolidation, divestiture, spin-off, or purchase of all or a substantial portion of our assets.
We may share de-identified Personal Information with academic institutions to perform research, under controls that are designed to protect your privacy—including requiring such institutions to operate under confidentiality agreements and mandating that published findings contain only de-identified and aggregated data.
From time to time, we may share reports with the public that contain anonymized, aggregate, de-identified information and statistics.
We may share Personal Information with our current and future Inevista affiliates. Our affiliates may use your Personal Information in a manner consistent with this Privacy Policy.
We may share Personal Information with third-party advertising partners, such as social networks, to perform marketing activities and to deliver targeted advertisements based on your interests.
When you provide your consent to us to share your information.

Retention of Your Personal Information
We will retain your personal data only for as long as necessary to fulfill the purposes for which it was collected, consistent with applicable law. This retention period allows us to comply with our legal obligations, resolve disputes, enforce our agreements, and study customer data as part of our own research. We will not retain your data for longer than is necessary to fulfill the purpose for which it is being processed.
To determine the appropriate retention period, we take into consideration the amount, nature, and sensitivity of the personal data, as well as the purposes for which we process it. We also assess whether we can achieve those purposes through other means. For the data retention period related to the Services provided to you, please refer to the Data Processing Addendum.

Security
The security of your Personal Information is important to us. We implement suitable measures to safeguard the information you entrust to us, preventing its loss, misuse, unauthorized access or disclosure, alteration, and destruction, addressing threats from both external and internal sources. Furthermore, we restrict access to your personal data to individuals such as employees, agents, contractors, and other third parties, but only those who require such access for legitimate business purposes. These authorized individuals will process your personal data solely based on our explicit instructions and are bound by a confidentiality obligation.
If you have selected a password or other login credentials that grant access to the Inevista platform, it is your responsibility to take all reasonable measures to maintain the confidentiality of this information. You should not share your password or login credentials with any other individual.
Please be aware that no method of transmission over the internet, or method of electronic storage is 100% secure and we are unable to guarantee the absolute security of the Personal Information we have collected from you. Therefore, you are also a key stakeholder in making sure that your Personal Information is protected. If you become aware of any breach of security or privacy, please contact us immediately at support@inevista.com.

International Transfer

Information collected while you use the Site and/or Service, including your Personal Information, may be transferred to and maintained on servers located outside of your state, province, country, or other governmental jurisdiction where data protection laws may differ from those in your jurisdiction.

If you are located outside of the United States and choose to provide information to us, please note that your information, including your Personal Information, may be transferred to countries outside your own, including the United States, for processing.

We take appropriate measures to ensure that your data is protected when transferred internationally. By using our Sites and/or services, you consent to the transfer and processing of your data in countries outside your country of residence, including to jurisdictions that may not provide the same level of data protection as your jurisdiction.

Third-party Advertising, Links and Content
Our Site may contain links to other sites that are not operated by us. We allow third parties, including advertising networks, and other advertising service providers, to collect information about your online activities through cookies, pixels, local storage, and other technologies. These third parties may use this information to display advertisements on our Sites and elsewhere online tailored to your interests, preferences, and characteristics. We have no control over, and assume no responsibility for the content, privacy policies, or practices of any third-party sites or services. We strongly advise you to review the Privacy Policy of every site you visit.
Some third parties collect information about users of our Sites to provide interest-based advertising on our Sites and elsewhere, including across browsers and devices. These third parties may use the information they collect on our Sites to make predictions about your interests in order to provide you with ads (from us and other companies) across the internet.
For example, we use Meta’s Custom Audience program. This program allows us, among other things, to display personalized advertisements and offers on the Meta platform. This is only if you choose to receive personalized advertisements and offers on the social media platforms, such as Meta. We only provide identifiers to Meta so that Meta can check whether you have an account on one of Meta’s platforms. Meta, in turn, only provides us with aggregated data about the effectiveness of an advertising campaign. This is data that cannot be traced directly back to you. This way, we try to make every effort to keep your personal data secure and confidential. Please check Meta’s privacy policy for more information about how your data is used.
We may participate in similar programs offered by other third parties to display relevant information and personalized advertisements via other channels. These may, for example, include programs offered by other social media platforms, such as LinkedIn, X (formerly Twitter), TikTok, but also search engine platforms, such as Google. Please check the privacy policies of these third parties for more information.
We process this information only with your consent or when it aligns with our legitimate interest in tailoring our marketing communications to better reflect your preferences and interests. Our goal is to provide you with a personalized and engaging customer experience. You have the right to object to the use of your personal data for direct marketing purposes, including targeted advertising, at any time by following the steps in the “Your Rights” section. Also, to opt out of interest-based advertising across browsers and devices from companies that participate in the Digital Advertising Alliance or Network Advertising Initiative opt-out programs, please visit their respective websites.

Children’s Privacy
We do not knowingly collect Personal Information from children under the age of 18. Our Site and Services are not addressed to minors. If you are a parent or guardian and you learn that your children have provided us with Personal Information, please contact us. If we become aware that we have collected Personal Information from a child under the age of 18 without verifiable parental consent, we will take steps to remove that information from our servers.

Your Rights
Under applicable privacy regulation, you may have some or all of the following rights in respect of your Personal Information:

To obtain a copy of your Personal Information together with information about how your Personal Information is processed;
To rectify inaccurate Personal Information;
To erase your Personal Information in limited circumstances where it is no longer necessary in relation to the purposes for which it was collected or processed;
To restrict processing of your Personal Information
To object to the processing of your Personal Information where we’re relying on a legitimate interest;
To object to decisions that are based solely on automated processing or profiling;
To obtain a portable copy of your Personal Information, or to have a copy transferred to a third-party controller; or
To withdraw your consent, at any time, where you may have provided it for the collection, processing, and transfer of your Personal Information for a specific purpose;

In addition to the above, you have the right to lodge a complaint with a supervisory authority for data protection.

To exercise these rights you may contact us either by emailing support@inevista.com

We may ask you for additional data to confirm your identity and for security purposes, before disclosing the information requested to you. If you would like to submit a request on behalf of another individual, you may do so by providing proof of authorization by the individual to submit such a request on their behalf. We reserve the right to charge a fee where permitted by law. We may also decline to process requests that jeopardize the privacy of others, are excessive, or would cause us to take any action that is not permissible under applicable laws. Additionally, as permitted by applicable laws, we may need to retain certain Personal Information for a limited period of time for record-keeping, accounting, and fraud prevention purposes. Please note also that you may be able to exercise some of these rights without our intervention. For example, if you are a registered Inevista platform user, you can access and update your personal data.

Changes To This Privacy Policy
This Privacy Policy is effective as of the “LAST REVISED” date specified at the top of this Privacy Policy and will remain in effect except with respect to any changes in its provisions in the future, which will be in effect immediately after being posted on this page.
We reserve the right to update or change our Privacy Policy at any time and you should check this Privacy Policy periodically. Your continued use of the Service after we post any modifications to the Privacy Policy on this page will constitute your acknowledgment of the modifications and your consent to abide and be bound by the modified Privacy Policy.

Questions or Concerns Regarding the Privacy Policy
If you have questions or concerns regarding privacy using our Service, please contact us at: contact@inevista.com.