NextDot Single Membered S.A. (hereinafter referred to as “NextDot” or “we”) respects your privacy and is committed to ensure protection of your personal data, in accordance with the Reg. (EU) 2016/679, as in force and any other data protection law applicable within the EU.

This Privacy Policy describes how we collect and process your personal data when you use our website, application(s) and services (hereinafter referred to as “Services”).

By creating an account with NextDot and use any of our Services, you agree to this Privacy, which is effective as of April 1st 2024.

• Definitions

  • Controller: The natural or legal person, public authority, agency or other body which, alone or jointly with others, determines the purposes and means of the processing of personal data.

  • Personal Data: any information relating to an identified or identifiable natural person (“Data Subject”), which information is subject to GDPR or the law of non-EU EEA countries that have formally adopted the GDPR; 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 identification number, location data, an online identifier or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person.

  • Data Subject: is the identified or identifiable natural person the Personal Data is relating to.

  • Process or Processing: means an operation or set of operations which is performed on Personal Data or on sets of Personal Data, 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.

  • Processor: means a natural or legal person, public authority, agency or other body which processes Personal Data on behalf of the Controller.

  • Sub-processor: means a natural or legal person, public authority, agency or other body or any subcontractor engaged by the Processor for the Processing of Personal Data on behalf of the Controller.

  • Personal Data Breach: means a suspected or actual breach of security leading to the accidental or unlawful destruction, loss, alteration, unauthorized disclosure of, or access to, Personal Data transmitted, stored or otherwise processed.

  • Terms of use: The agreement between NextDot and any user of our Services, which provides for the rights and obligations of each party

  • Service(s): means all the services provided by NextDot, as described in our Terms of Use.

  • User: Any person who has an active account with NextDot and uses part or all of NextDot’s Services.

  • Organization: Any third party who is represented by an administrator or administrators in the NextDot network and is the owner of a specific professional project, which its employees and/or contractors, who are also users of the Services, undertake to complete (hereinafter referred as “Dot”), as further described in our Terms of use.

• Identity of the data controller

  Next Dot is the Controller of personal data for any user of our Services, (i.e. any person who creates a profile and uses our Services, any visitor of our website etc.)

  Any Organization who uses our Services is also a data controller of the personal data of the users, who work as employees and/or contractors within this Organization. The collection and processing of your personal data will be also subject to the Privacy Policy of the respective Organization.

• Personal Data we collect

  We collect personal data of users of our Services, as described below:

  • Personal data provided by you as a user

    • Upon creating an account with us and start using your NextDot profile, we collect and process the following categories of Personal Data that you may provide on your profile:

      Personal Information: Name, Surname, Email Address, Contact Information, Location, Profile Picture, Username, Password, URL

      Professional Information: Current job title, Employer, Work experience, Skills, Place of Work, Academic background, Skills performance (numeric KPI, where “KPI” stands for key performance indicator, i.e. a quantifiable number or value that gives insight into how effectively you can achieve identified objectives), Skills growth (numeric KPI),

    • Upon giving feedback to other users:

      Feedback giver data: Name, Surname, Profile picture, Data regarding the content of your posts and comments as a feedback giver, Date of feedback, Your skills

      Your personal data as a feedback giver will appear on the profile of other users, only upon your consent, the consent of the user who receives the feedback and the consent of the Organization, as described below under article 3(b). You can choose the type of visibility of your data as feedback giver in your Settings. If the type of your consent does not match the consent type of the Organization or the consent type of the user who receives the feedback, the most restrictive type will apply.

      We may use data regarding the content of your feedback as training data for our AI machine learning models, only upon your consent. You will have the option to opt-out at any time through your Settings.

    • Upon using our Services:

      Billing Information: Payment details, Back account information, Tax ID number

      Network activity Information: Browsing history, search history, information about your network and device (e.g., IP address, proxy server, operating system, web browser and add-ons, device identifier and features, cookie IDs and/or ISP, or your mobile carrier). We will ask you to opt-in before we use GPS or other tools to identify your precise location.

  • Personal data provided by you and other users

    We also collect and process your personal data and the data of other users, that are provided upon your consent and the consent of other users of our Services, as described below:

    Dots Data: Organization name where you work, Dot title, Dot description, Dot media, Dot duration, Skills progression within the Dot, Feedback AI summary regarding the Dot directed to you (without the name of the feedback giver)

    The above data would be visible on your profile for other users to see, only upon your consent along with the consent of the Organization (as represented by an administrator), in one of the three ways from which you and the Organization can choose through your Settings:

    • Private: Your personal data will remain private and will be available only to the Organization and only during your tenure within the Organization. Your personal data might also be visible to any user who is an employee of the Organization, upon decision of the administrator of the Organization. Following the completion of your tenure, the Organization will have access to your personal data only upon your consent, which will be requested each time.

    • Restricted access: Your personal data will be shared only with Organizations and users that choose to share their own data.

    • Public: Your data will be public and visible to any user of NextDot network.

    In case your choice and the Organization’s choice differ, the most restrictive type of visibility will apply.

    Both you and the organization will be able to change your consent at any time through you Settings.

    Feedback data: In case you receive feedback regarding your performance progress on a specific Dot coordinated by an Organization, we may collect, and process data provided by other uses as feedback givers about you, i.e. feedback content, date of the feedback etc.

    The above data would be visible on your profile for other users to see, only upon your consent along with the consent of the Organization (as represented by an administrator) and the consent of the feedback giver, in one of the three ways from which you, the Organization and feedback giver can choose in your Settings:

    • Private: Your personal data will remain private, and will be available only to the Organization and the feedback giver only during your tenure within the Organization and during the tenure of the feedback giver, when the latter is an employee of the same Organization. Your personal data might also be visible to any user who is an employee of the Organization, upon decision of the administrator of the Organization. Following the completion of your tenure, the Organization will have access to data only upon your consent and the consent of the feedback giver.

    • Restricted access: Your data will be shared only with Organizations and other users that choose to share their own data.

    • Public: Your data will be public and visible to any user of the platform.

    In case your choice, the Organization’s choice and/or the feedback giver’s choice differ, the most restrictive type of visibility will apply.

    All the above persons, i.e. you, the Organization and the feedback giver, will be able to change your consent at any time.

    Other data: Content including your data, i.e. name, surname, skills, job title, which may be provided by other users in their posts and comments.

    In case you reveal, in any manner, sensitive data through your profile, you give your consent to the processing thereof by NextDot.

• Lawful Basis for Processing

  We will only collect and process your personal data only upon a lawful basis, in accordance with the General Data Protection Regulation (“GDPR”).

  In general, we collect and process your personal data, based on one of the following lawful bases:

  Consent: To process your personal data as described above, we rely on your consent. You can withdraw your consent anytime through your Settings, as described above, or by contacting us directly. Your withdrawal of consent to process certain personal data about you may limit our ability to provide benefits and services to you and does not affect the lawfulness of our processing activities based on your consent before its withdrawal.

  Legal obligation: We may collect and process your personal data only if we are required by law to do so. We may disclose your personal data where such disclosure is necessary for the establishment, exercise or defense of our legal claims, whether in court proceedings or/ and in out-of-court procedure.

  Legitimate interest: We may collect and process your personal data based on our legitimate interests or the legitimate interests of third parties (e.g. our affiliates), provided that our interest in processing does not outweigh your interests as data subject. These interests include commercial interests and/or the interests of our network of users.

• Lawful Basis for Processing

  How we use your personal data will depend on which Services you choose to use, how you use those Services and the choices you make in your Settings. We may use your data for the following purposes:

  • Provision of our services (i.e. to ensure that you as user can have full access to our Services)

  • Improvement and development of our Services (i.e., to improve the quality of our services)

  • Personalization of your experience: We use data to make the content of our Services more relevant and useful to you and provide you with a better, more personalized experience.

  • Statistics: We may collect and use your data to generate statistics about the users of our Services (i.e., profession, skills growth etc.).

  • Security purposes: We use your data for security purposes or to prevent possible fraud, criminal activity or other violations and ensure safety of our users.

  • Other legitimate interests: We may use your information when necessary for our legitimate interests, provided that such interests are not overridden by your interests, rights and freedoms in relation to your personal data.

• Third parties with whom we may share your personal data

  We may disclose your data to following third parties, pursuant to this Privacy Policy:

  Affiliates: We may share your personal data with our affiliates to provide and develop our Services.

  Service providers: We may share your personal data with third parties service providers that perform certain services on our behalf. These services may include hosting and maintaining our website, marketing our services and other related services. Service providers may have access to personal data needed to perform their functions and are not allowed to share or use such information for any other purposes. In any case, we will share only the minimum amount of personal data with these service providers that is needed for the performance of their tasks. These service providers are also subject to written declarations of confidentiality and secrecy and present adequate assurances for the safety of your personal data.

  Other users/ Organizations: Subject to your settings, your personal data will be visible to other users, only if you consent to the disclosure of your data in your Settings

  Public Authorities: We may disclose your data to competent public authorities when we are required to do so by applicable law or a judicial proceeding, court order or legal process or when it is necessary to comply with our legal obligations, or when we must take other action regarding illegal activity, suspected fraud or other wrongdoing.

• Rights of data subject

  • Right of access

    You can ask us whether we are processing your personal data. You may also access the personal data we maintain about you.

  • Right to rectification

    You can review and update any inaccurate personal data. You may also ask for any addition or correction to incomplete personal data.

  • Right to erasure (“right to be forgotten”)

    You can ask us to erase any of your personal data that is no longer necessary in relation to the purposes for which they were collected or in cases where you have withdrawn your consent.

  • Right to withdraw your consent

    You can withdraw your consent at any time. The withdrawal of consent will not affect the lawfulness of processing based on consent before its withdrawal.

  • Right to restriction of processing

    You can ask us to restrict the use of your personal data if such use is unlawful, or you deem that we no longer need your personal data for the above purposes.

  • Right to data portability

    You have the right to receive your personal data, which you have provided to us, in a structured, commonly used and machine-readable format and you can ask us to transmit this data to another controller without hindrance from us.

  • Right to object

    You have the right to object, on any legitimate grounds, at any time to processing of your personal data.

  To exercise your rights, you can contact us by any means of communication. We will consider and process your request within a reasonable period of time.

• Security measures

  We take appropriate organizational and technical measures to ensure that your personal data is secure. We have an internal policy to deal with any security breach of our website, while we have installed software protection tools, such as encryption, firewall etc., to protect your data from the risk of unfair processing as well as any loss, damage or destruction thereof.

• Cross-Border Data Transfers /Transfer of data out of the European Economic Area (EEA)

  We may transfer and process your personal data in third countries, outside the European Economic Area (EEA).

  Any transfer of your personal data by us to third countries will take place only to countries which have data protection laws that provide an adequate level of protection within the meaning of EU Data Protection Law.

  To the extent that international data transfers take place, we will seek and obtain assurances that any information we may transfer is safeguarded adequately and in accordance with this Privacy Policy.

• Duration of processing of your data

  We will retain your personal data only as long as necessary for the purposes of the processing thereof in accordance with this Privacy Policy.

  In general, we retain your data for as long as you have an active account with us and remain a user of the NextDot network. Even if you do not use our Services for a long period of time (i.e. a year or more), we will retain your personal data in our records, unless you decide to permanently close your account.

  If you decide to permanently close your account, your personal data will cease to be visible to other users in the NextDot network within 24 hours and we will delete your personal data from our records within thirty (30) days from the date of permanent closure of your account. We may retain your personal data even after you have closed your account only, if reasonably necessary, indicatively and not restrictively, to comply with our legal obligations, to prevent security breach, to represent ourselves before Courts or public authorities.

  In cases where your personal data is collected by other users of the network (i.e. posts of other users), we may continue to use this data only in an aggregated or anonymized form to ensure appropriate delivery of our Services, (i.e. feedback content published by another user).

  Any information you have shared with other users of the network through chatrooms will remain visible even after you close your account or delete the information from your own profile or the chatroom. Please keep in mind that we have no control over data that other users might have copied and kept a record of.

• Aggregate Data

  We may use anonymised and/or aggregate data collected through your use of our Services for statistical purposes, for improvement of our Services or to conduct research or for any other legitimate purpose. Anonymised and/or Aggregate Data is not considered personal data.

• Third party websites

  Our website may, from time to time, contain links to and from the websites of our partner, advertisers and affiliates. If you follow a link to any of these websites, please note that these websites have their own privacy policies and terms of use and that we do not accept any responsibility or liability for these policies and terms of use. Please check these policies before you submit any of your personal data to these websites.

• Changes in our Privacy Policy

  We reserve the right to modify this Privacy Policy at any time. Any changes we may make to our Policy in the future will be notified and made available to you through our website or by other means. Your continued use of our Services shall be deemed your acceptance of this Privacy Policy, as updated and in force.

• Contact

  In case you have any questions regarding this Privacy Policy, please contact us directly through the platform or otherwise at dpo@nextdot.team.