1.1. If you do not agree with the terms of this Policy, please do not use the website and Platform.

1.2. This Policy shall not apply to Platform, mobile applications or services of third-party developers, providers, advertisers or sponsors and social media, services that might be available through or integrated with the Platform, including links thereto (Third-Party Services). For example, when effecting a payment, you may be redirected to the payment system’s website and in such cases, the processing of data is beyond the control of Restaff. Such Third-Party Services act as independent data controllers guided by their own policies, we therefore recommend that you make yourself aware of them. We shall not bear any responsibility for privacy policy of such Third-Party Services and you shall use these services at your own risk.

1.3. We aim to protect and respect your privacy. We shall be considered the data controller as we determine the method, approach, criteria, and purpose of processing personal data. This Policy complies with the Federal Decree Law No. 45 of 2021 (PDPL), regarding the Protection of Personal Data, It further complies with all other applicable laws and aims to ensure due protection and care relating to the processing of your personal data pursuant to PDPL.

2.1. Restaff may collect, use, store and process any personal data that helps to identify you, as well as any other information (including anonymized) that is not directly related to personal data such as device specifications, connection details, error reports and interface interaction methods (Other Data).

2.2. Restaff obtains and processes the data for the following purposes:

2.2.1. The data to be provided for the purpose of registration:
In order to be granted access to the closed sections of the Platform, the information as below shall be required:

• Phone number.

2.2.1.1. When you register or log into your account on the Platform, the information as below shall be required:

• Full name;
• Passport data or ID number;
• Company name;
• Company TIN or registration number;
• Authenticated customer identifier;
• Type of the used device;
• IP address;
• Geo-location details, including region, country, state and city;
• Type of the browser used;
• Identifiers  associated with your device.

2.2.1.2. To setup dual authentication, the information as below shall be required:

• Phone number;
• Email.

2.2.2. The data indicating your access path:

• Address of the web-page which you used to access our Platform.

2.2.3. The data we collect for analytics of customer behavior:
We may collect technical information on your use of the Platform through tracking and analytic technologies.

• Number of visits to the Platform;
• Pages you access;
• Traffic data;
• Time and duration of communication session.

2.2.4. The data that you provide to us when contacting support:
Any contact information provided by you or requested by us.

• Full name;
• Passport data or ID number;
• Phone number.

2.2.5. The data you provide to us at subscription to our newsletters:

• Your email address;
• Your name.

2.2.6. The Data required for calculations.
When you pay or receive payment:

• Full name;
• Mobile number;
• Tax number;
• Платежные реквизиты.

Should you have any concerns regarding the use of certain billing information, please refer to the Privacy Policy of the chosen payment system.

2.3. If you refuse to provide Restaff with certain personal data, you will not be able to access the Platform, including, contact Restaff by using certain methods, sign up / authorize as a Customer of the Platform, activate or use certain functionality of the Platform (for example, receive payments) or receive certain information about Restaff products.

2.4. Subject to your separate consent or where expressly permitted by applicable laws regulating electronic newsletters, Restaff may send you promotional emails about products and services offered by Restaff. In this event we may also use the information collected from you to customize our promotional emails, as well as to track whether you open the emails we send you and which links you are clicking on.
You may at any time cancel or withdraw your consent to receiving promotional emails by clicking the “Unsubscribe” link that is included in each promotional email.

2.5. Restaff may allow advertisers to show their advertisements directly to you on the Platform. While providing such advertisements directly to you, advertisers may place their own cookies on your computer and use their own web beacons and other technologies enabling them to track the effectiveness of advertisements, as well as to collect and track such information as demographical data, likely interests, aggregated information and actions that help them to personalize advertisements delivered to you. Restaff shall not provide any information that could enable us to identify you without your consent. However, if you react to advertisements targeted at a particular audience (for instance, males aged between 20 and 25 who took part in certain campaigns), the advertiser may conclude that you belong to its target audience. This Policy does not cover any actions of such advertisers. Before responding to an advertisement, you should get familiarized with the respective privacy policy of such advertisers.

2.6. When providing us with third-party personal data, you shall warrant that you have obtained the respective party’s consent to providing their personal data to Restaff (for example, by sending invitations to join the Platform).

3.1. Cookies are small-sized text files stored in the customer browser that save customer interface settings. We use cookies and other tools such as web beacons (electronic images that are used to track the number of visits to a certain page without collecting any personal data that could enable us to identify your personality) as well as tracking pixels. These data help us to operate the Platform, personalize and optimize your browsing experience on Platform pages, direct you via the links, improve functionality of the Platform, provide you support and conduct monitoring and analytics.

3.2. We may use all of, or several types of the below cookies on our Platform:

• Necessary cookies. These are cookies that are required for certain parts of our Platform to function properly. They allow you to navigate through our Platform, help us to recognize you on the Platform and thereby enable the requested access to be provided.
• Functional cookies. These help us to customize the content of our Platform to your preferences. They remember your preferences, language and country from which you visited our Platform. The information collected by these cookies can be anonymous and they cannot track your activity on other websites. Such cookies help Restaff to provide you with information regarding whether you have given your express consent to the use of cookies pursuant with applicable law.
• Performance cookies. These files collect information on how you use our Platform, thus helping us to improve such functions as navigation and help us in resolving technical issues or errors. For example, we use performance cookies to understand how you access our Platform, whether you surf and use our Platform and identify areas that would benefit from improvement.
• Targeting cookies. These files collect information about your browsing habits to enable us to show you more relevant content. They are also used to limit certain content, as well as to measure the effectiveness of marketing campaigns. Such cookies are usually deployed by Third-Party Services.

3.3. Restaff employs technologies of some Third-Party Services to enhance interaction with customers including for the Platform’s modules deployed on the website: Facebook Analytics services (Privacy Policy: https://www.facebook.com/about/privacy). This enables the Platform to track how many customers visit the Platform’s respective pages, analyze customer behavior on the Platform and provide access to certain functions of the Platform. Such Third-Party Services shall be liable for cookies they install on your device. All Third-Party Services receive data in an encrypted format. Data available to Third-Party Services does not allow identifying you.

3.4. Opting out of cookies.
3.4.1. You can manage your cookies using browser settings. You can set up your browser to prevent cookies from being stored or to send a notification every time it is attempted to set up cookies. You may disable cookies altogether by ticking the respective boxes in the browser. You should however be aware that if you clear the cookies, all of your preference settings will be lost (such as your browser settings for interacting with the website), including your cookie opt-out preference. Blocking cookies may also affect your interactions with the interface and the customer accaunt, and you may lose the ability to access certain parts of the Platform.

3.4.2. The links below provide information on how to manage and block cookies in your browser:

• Internet Explorer: https://support.microsoft.com/en-us/help/17442/windows-internet-explorer-delete-manage-cookies#

• Firefox: https://support.mozilla.org/en-US/kb/enable-and-disable-cookies-website-preferences

• Chrome: https://support.google.com/chrome/answer/95647?hl=en

• Safari: https://support.apple.com/kb/PH19214?locale=en_GB

• Opera: https://blogs.opera.com/news/2015/08/how-to-manage-cookies-in-opera/

3.4.3. You can find more information on how to refuse cookies using this link http://www.youronlinechoices.eu. If you want to learn more about cookie files or how to manage, disable or delete cookies, please refer to the detailed guidelines at https://www.aboutcookies.org. Furthermore, certain third-party advertisement networks, including Google, enable customers to opt out of cookies or manage cookies settings. To learn more about this option with Google, visit https://adssettings.google.com/u/0/authenticated?hl=en. Google Analytics allows customers to opt out from its service, for details please see the link https://tools.google.com/dlpage/gaoptout?hl=en.

3.4.4. We would recommend that you consider the possibility of having cookies placed on your device, as once you disable cookies from our Platform, you will not be able to use certain features of the Platform, in particular those needed to personalize your experience.

3.5. By using the Platform you provide Restaff with your consent to uploading cookies onto your device (generating cookies using the Platform) as described above. Also, by using the Platform you consent to your customer information being handled in accordance with this Policy. If you are located in the EEA, you will also be requested to provide your express and explicit consent to the collection, processing and transmission of your personal data using cookies and similar technologies.

4.1. Restaff uses personal data in strict compliance with the applicable law and for the purposes for which it is collected.

4.2. Personal data may be used by Restaff for the following purposes:

• to discharge the mutual obligations arising between Restaff and yourself (customer) under agreements for the use of the Platform agreed by the parties to ensure you gain full access to the entire functionality of Platform, among other  - to process your requests to support, provide you with services as well as enhance the Platform and your customer experience;
• to comply with all relevant laws such as tax law, etc;
• to protect the legitimate interests of Restaff and/or third parties, with the exception of where these interests are overridden by your prevailing legitimate interests and rights (when investigating copyright infringement, fraud or other bad faith conduct);
• to discharge our obligations based on your separate consent.

4.3. When processing personal data for the purposes specified in clause 4.2 of this Policy, Restaff relies on the existence of a reasonable, legitimate interest. 

5.1. We will only store your data for as long as is necessary in relation to the purposes for which it was collected and processed or (provided that the applicable law stipulates a longer storage period) — during the period as required by law. Upon expiry of this period your personal data shall be deleted, blocked or anonymized, as specified by the applicable law.
Including without limitation:

• If you close your account all of your personal data will be marked for deletion, unless a longer retention period is necessary due to legal or other prevailing lawful requirements;
• In certain cases, where it is necessary to confirm the existence of concluded deals, signed documents and payments made.;
• Please note that Restaff is obliged to retain certain transaction data for up to ten (10) years as set out in the applicable commercial and tax regulations;
• In the event that you withdraw your consent to the processing of your personal data we shall delete your personal data without undue delay to the extent that the collection and processing of personal data are based on the consent withdrawn;
• In the event that you exercise your right to object to the processing of your personal data, we shall consider your objection and without undue delay delete your personal data processed for the purpose objected to, unless there are other legal grounds for processing and retaining of this data or unless it shall be retained under the applicable law.

5.2. Regardless of customer’s request to delete their data, Restaff may retain the data provided that it is deemed necessary for legitimate business interests, discharging obligations and resolving disputes.

5.3. Once the purposes of processing are achieved or in the event there is no longer a necessity for achieving these purposes, the data shall be destructed or anonymized.

5.4. customer content and information that you post in chats is saved for indefinite period of time. Should you wish that we delete your account or any of your posted customer content, please contact us using any of the methods set out in the “Contact Information” section.

6.1. Restaff shall keep confidential and not disclose any customer information to third parties without your consent, except for the cases stipulated in this Policy or by the applicable law and to the extent necessary for disclosure.

6.2. Personal data may be disclosed in the circumstances described below:

• When we are instructed to do so by customer. In particular, customer’s instruction shall mean, without limitation, when you decide to to sign up / authorize on the Platform via social media or express a wish to link your account with a third-party Platform account. In the event that the linking of accounts requires your personal data to be transferred from Restaff to a third party, you shall be given prior notice and an opportunity to provide your consent for the linking of your accounts and transferring your personal data. The use of your personal data by a third party shall be governed by the privacy policy of this respective third party, which you are recommended to read carefully before linking the accounts. Besides that, we use third-party providers for making payments, emailing and hosting on the website. In the event that you decide to use this service, we shall provide the third party with your personal data to the extent necessary to render you this service. Such third parties may not use your personal data for any other purposes. If you are not willing to have your personal data disclosed to any third party, you may refuse from consenting to disclosing your personal data by way of not using this particular service;
• To other customers and partners of Restaff (access to your accaunt’s data, including your name and surname, as well as to passport data, if you have expressed a desire to enter into legal relations with such customer on the Platform or requested access to the services of Restaff Partners;
• To providers of additional services. For example, payment systems, services that provide support to customers, monitor their activity, as well as network services providers who deliver digital content requested by you and game servers in connection with the Platform. Such providers shall use personal data in strict compliance with and for the purposes specified in this Policy;
• To comply with the applicable law. For example, data may be disclosed upon the request of a competent authority;
• To affiliated parties of Restaff, in order to meet the obligations to customer and to the extent required for this purpose;
• To prevent illegal activities, protect the rights and to ensure the security of Restaff and other parties and to defend against claims and lawsuits;
• When data is transferred as a part of Restaff’s reorganization, as well as when entering into agreements for the transferring of rights within contracts. In this case Restaff may disclose data to a party acquiring the rights under such contracts, as well as to a party formed as a result of the reorganization;
• Generalized, aggregated and non-personalized data. Restaff may disclose non-personalized statistical data, such as the most frequently used features of the Platform; 
• In other cases subject to customer’s consent.

6.3. Data that we collect will be stored in the Hong Kong Special Administrative Region. The data of citizens of the countries where legislation allows storage and processing of such data in these countries only shall be stored in accordance with the legislation of such countries. 
If you are located in the European Economic Area (EU) your personal data may be transferred to countries located outside the EU which do not provide a similar or adequate level of protection to that provided by countries in the EU. Such transfers will only be made in accordance with applicable laws including where necessary for us to comply with our contractual obligations with you. We will take all steps reasonably necessary to ensure that any personal data are treated securely and in accordance with this Policy.

6.4. Restaff may transfer data without customer’s instruction to partners (contractors, subcontractors, service providers, etc.) listed in this Policy. To this end, such partners shall ensure that the security level is no less adequate than as is set out in this Policy. All data is provided to partners in an encrypted format, the exception being when your nickname is required for your identification and the linking of your accounts, in which case you will be requested to provide your informed consent to such identification and account linking.

6.5. Our databases are powered by Google Optimize (Privacy Policy: https://policies.google.com/privacy?hl=en). We recommend that you review these Third Party privacy policies and/or terms and conditions of such Third Parties.

6.6. Such partners may receive data in the scope strictly limited to that needed for performing their functions. When we transfer your data to partners outside the Hong Kong Special Administrative Region, we shall conclude  agreements with such partners which include standard data protection clauses adopted by the data protection authority to ensure appropriate security measures to protect your personal data. Should you wish to know more about these precautions, please contact us using any of the methods set out in the "Contact Information" section.

7.1. By using our Platform or visiting our website, you acknowledge the collection and use of your personal data by us as outlined in this Policy. If you do not agree with the use of your personal data as set out in this Policy, or the Terms of Use, please do not use Platform.
Your personal data can be processed without your consent in the following lawful cases:

• the processing is necessary to protect public interest or public health;
• the processing relates to personal data which are made public by the data subject;
• the processing is necessary for the defence of legal claims;
• the processing is necessary for achieving purposes, scientific, historical or statistical research;
• the processing is necessary for the controller to carry out their legal obligations in the fields of recruitment, social security or social protection or in compliance with other laws in the UAE.
• the processing is necessary to protect the interests of the data subject;
• the processing is necessary for the performance of a contract to which the data subject is party.

7.2. Under the Federal Decree Law No. 45 of 2021 (PDPL), you have the right to:

• request for to delete your personal data without undue delay in cases provided by law;
• rectify inaccurate personal data and/or complete incomplete personal data;
• object to decisions made about you based on automated means and obtain human intervention to review decisions made which were based on automated processing;
• be informed about what personal data is being processed and how it is being processed;
• to compel the data controller to restrict, suspend or stop the processing of your personal data;
• obtain your personal data in a machine readable format.

7.3. If you are in an EU Member State, subject to certain limitations and/or restrictions, you have the right under the data protection laws in the EU:

• to obtain a copy of your personal data together with information about how and on what basis that personal data is processed,
• to rectify inaccurate personal data,
• to erase your personal data 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 data where: (a) the accuracy of the personal data is contested, (b) the processing is unlawful but you object to the erasure of the personal data, (c) we no longer require the personal data for the purposes for which it was collected, but it is required for the establishment, exercise or defense of a legal claim,
• to challenge processing which we have justified on the basis of our legitimate interest,
• to object to decisions which are based solely on automated processing or profiling,
• to obtain a portable copy of your personal data, or to have a copy transferred to a third party controller, or
• to obtain a copy of or access to safeguards under which your personal data is transferred outside of the EU.

7.4. Individuals in the EU also have the right to lodge a complaint about the processing of their personal data with their local data protection authority. In addition to the above, you have the right to lodge a complaint with a supervisory authority for data protection. You also have the right to withdraw your consent to the processing of your data at any time. We may ask you for additional data to confirm your identity and for security purposes, before disclosing data requested to you. 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 extremely impractical, 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 data for a limited period of time for record-keeping, accounting and fraud prevention purposes.

7.5. We collect, process, use and are responsible for certain personal information about individuals in the EU. When we do so, we are regulated under the General Data Protection Regulation (EU) 2016/679 (GDPR) which applies across the European Union and EEA (including in the UK), and the Data Protection Act 2018 (together with the DPA).

7.6. When transferring data from the European Union, the European Economic Area, and Switzerland, Restaff relies upon a variety of legal mechanisms, including contracts with our customers.

7.7. Restaff commits to cooperate with EU data protection authorities (DPAs) and the Swiss Federal Data Protection and Information Commissioner (FDPIC) and comply with the advice given by such authorities with regard to human resources data transferred from the EU and Switzerland in the context of the employment relationship.

8.1. We do not knowingly collect Personal Information from Children under 16. 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 age 16 without verifiable parental consent, we will take steps to remove that information from our servers.

9.1. If you wish to exercise one of the above mentioned rights, cease marketing communications, and/or raise questions or complaints please contact us at:

Data Protection Officer:
Mikhail Provizion
Al Tayer Building 205, Al Nahda, Sharjah, United Arab Emirates
Tel: +447389065988
E-mail: provizionm@gmail.com
9.2. For individuals residing in the EU please contact our EU Representative with any requests you may have either by emailing admin@restaff.work or addressing it to the Data Privacy Officer.

10.1. You should be aware that absolute security of data transmission through the internet cannot be guaranteed. In order to safeguard your privacy, we use standard physical, electronic and organizational security measures to protect your personal data from loss or theft, as well as from unauthorized access or disclosure. We treat data as an asset that needs to be protected against loss and unauthorized access. We use a variety of security methods to protect such personal data from unauthorized access both internally and externally of Restaff, namely:

• There is a person designated to organize the processing of personal data, whom you can contact using one of the methods set out in the “Contact Information” section;
• There are approved local regulations on personal data processing. They establish procedures for the prevention and detection of violations, as well as for remediation of the consequences of such violations;
• Legal, organizational and technical measures are in place to ensure the security of personal data processing, including, where possible, encryption;
• Periodic checks are conducted to assess the conditions of personal data processing;
• Restaff employees who are directly involved in the processing of personal data are familiarized with the provisions of the applicable law on personal data, including personal data protection requirements and in-house documents relating to personal data processing.

10.2. Restaff cannot guarantee that data is securely protected from intrusion whilst transmitted over the internet or when stored. To this end, Restaff uses data pseudonymization and encryption, whenever possible. If you are concerned that your privacy might have been compromised, please contact us using one of the methods set out in the “Contact Information” section.

10.3. Restaff cannot guarantee the security of personal data where this is beyond the control of Restaff. This includes, but is not limited to, your account access data, while you shall be responsible for maintaining the confidentiality of this data. You shall not disclose this data to third parties, and Restaff recommends that you take appropriate measures to ensure the confidentiality of this data.

11.1. Restaff may change this Policy at any time to incorporate changes in legislation and business processes. The revision date shall be indicated in the left-hand corner under the name of this Policy. All updates and amendments shall take effect forthwith upon notice, which we may give you by any means, including but not limited to placement of the Policy on the Platform and website https://restaff.tech/policy, to notifications in your personal account, push notifications as well as other notification methods.

11.2. Restaff recommends that you read this Policy as often as is practicable to be aware of changes that may affect you. In the case that you disagree with the changes made to this Policy, you shall delete your account and stop using the Platform.

11.3. Your continued use of the Platform after any change introduced to this Policy shall constitute your acceptance of such changes.