Privacy Policy Europe
Effective date: [DD Month YYYY]
Last updated: [DD Month YYYY]
SEO Interaction (“SEO Interaction”, “we”, “us” or “our”) respects your privacy and is committed to protecting your personal data.
This Privacy Policy explains how we collect, use, disclose, retain and protect personal data when you visit or use our website, platform, applications and related services (together, the Service). It also explains the choices and rights available to you.
This Privacy Policy is intended to comply, where applicable, with Regulation (EU) 2016/679 (the EU GDPR), the EU ePrivacy Directive and its national implementing laws, the GDPR as incorporated into United Kingdom law (the UK GDPR), the UK Data Protection Act 2018, and the Swiss Federal Act on Data Protection (FADP). References to the “GDPR” mean the EU GDPR or UK GDPR, as applicable.
This Privacy Policy is information about our processing activities. It is not a contract, and use of the Service does not constitute consent to every processing activity described below. Where we rely on consent, we will request it separately and you may withdraw it at any time.
Controller and contact details
The controller responsible for the processing described in this Privacy Policy is:
Legal entity: [FULL LEGAL NAME OF THE ENTITY OPERATING SEO INTERACTION]
Trading name: SEO Interaction
Registered address: [FULL POSTAL ADDRESS, COUNTRY]
Company/registration number: [NUMBER, IF APPLICABLE]
Privacy email: privacy@seointeraction.eu
Website: https://www.seointeraction.eu
Data Protection Officer: [NAME OR “Not appointed because SEO Interaction is not required to appoint one”]
DPO contact: [DPO EMAIL, IF APPLICABLE]
If the controller is not established in the European Economic Area (EEA) but is subject to the EU GDPR, its representative under Article 27 EU GDPR is:
EEA representative: [LEGAL NAME, POSTAL ADDRESS AND EMAIL]
If the controller is not established in the United Kingdom but is subject to the UK GDPR, its UK representative is:
UK representative: [LEGAL NAME, POSTAL ADDRESS AND EMAIL]
Scope of the Service
SEO Interaction is a professional marketplace and networking platform that helps SEO professionals find jobs and projects, showcase expertise, offer services and connect with employers, agencies and clients.
This Privacy Policy applies when SEO Interaction acts as a controller. Employers, agencies, clients, payment providers, authentication providers and other users may process personal data for their own purposes as independent controllers. Their processing is governed by their own privacy notices.
Personal data we collect
Data you provide
Depending on how you use the Service, we may collect:
- Account and identity data: name, email address, username, password hash, account identifiers, country or general location, preferred language and authentication information.
- Professional profile data: professional title, biography, photograph, CV or résumé, employment and education history, skills, certifications, portfolio materials, availability, rates, social-media links and website URLs.
- Marketplace data: job posts, service listings, applications, proposals, contracts, project details, reviews, ratings and transaction-related records.
- Communications data: messages exchanged through the Service and communications with our support, trust and safety or privacy teams.
- Payment and billing data: billing name and address, tax information, transaction amount, currency, status and payment-provider reference. Payment providers process full card or bank credentials; we do not store complete payment-card details unless expressly stated at the point of collection.
- Preference and consent data: marketing preferences, cookie choices and records of consent or withdrawal.
- Verification and safety data: information submitted to verify an account, investigate fraud, enforce our terms or resolve a dispute.
Please do not include special-category data—such as health information, biometric data used for identification, political opinions, religious beliefs, trade-union membership or information about sexual life or orientation—in your profile, CV, portfolio or messages unless it is necessary and you have a lawful reason to disclose it. If we intentionally process special-category data, we will identify an appropriate condition under Article 9 GDPR and provide any additional information required by law.
Data collected automatically
When you access or use the Service, we may collect:
- Device and network data: IP address, device type, browser, operating system, language, time zone, approximate location derived from IP address and device identifiers.
- Usage data: pages viewed, searches, clicks, referring pages, features used, session times and interaction data.
- Technical and diagnostic data: server logs, authentication events, error reports, performance data and security events.
- Cookie and similar-technology data: identifiers and information described in Section 9 and in our [Cookie Policy — INSERT LINK].
Data received from third parties
We may receive personal data from:
- authentication providers, such as Google or LinkedIn, when you choose to connect an account;
- employers, agencies, clients and other users who interact with you or submit information about a transaction;
- payment and fraud-prevention providers;
- analytics, advertising and marketing providers, where permitted by law and subject to your choices;
- publicly accessible professional sources, where collection and further use are lawful; and
- service providers that help us operate, secure and support the Service.
When we obtain personal data from a source other than you, we will provide the information required by Article 14 GDPR within the applicable period, unless a lawful exception applies.
How and why we use personal data
We use personal data only when we have a valid legal basis. The activities below describe our expected processing. SEO Interaction must confirm that they accurately reflect its actual practices before publishing this Privacy Policy.
| Purpose | Typical data | Legal basis under the GDPR |
|---|---|---|
| Create and manage accounts; authenticate users; provide core platform features | Account, identity, profile, device and authentication data | Performance of a contract; steps requested before entering a contract |
| Publish profiles, listings and portfolio materials according to your settings | Profile and marketplace data | Performance of a contract; consent where required for optional publication or indexing |
| Facilitate applications, proposals, messaging, transactions, reviews and ratings | Profile, marketplace, communications and transaction data | Performance of a contract; legitimate interests in operating a trustworthy professional marketplace |
| Process payments, invoices, refunds and tax records | Identity, billing and transaction data | Performance of a contract; compliance with legal obligations; legitimate interests in accounting and payment administration |
| Provide support and respond to enquiries | Account, communications and technical data | Performance of a contract; legitimate interests in supporting users and resolving issues |
| Operate, maintain, troubleshoot and improve the Service | Usage, technical, diagnostic and feedback data | Legitimate interests in maintaining and improving the Service; consent where required for non-essential analytics technologies |
| Personalise, rank and recommend jobs, professionals, services or content | Profile, marketplace and usage data | Legitimate interests in making the Service relevant; consent where required by applicable law |
| Prevent fraud, spam, abuse and security incidents; enforce our terms | Account, verification, communications, device, usage and security data | Legitimate interests in protecting users and the Service; compliance with legal obligations; establishment, exercise or defence of legal claims |
| Send essential service messages | Account and communications data | Performance of a contract; compliance with legal obligations |
| Send newsletters, promotions and other direct marketing | Contact, preference and interaction data | Consent where required; otherwise legitimate interests, subject to your right to object and applicable electronic-marketing law |
| Comply with law, respond to lawful requests and resolve disputes | Relevant account, transaction, communications and security data | Compliance with legal obligations; legitimate interests in protecting legal rights; establishment, exercise or defence of legal claims |
| Manage corporate transactions, such as a merger, financing or sale | Relevant account, commercial and operational data | Legitimate interests in managing our business; compliance with legal obligations |
Where we rely on legitimate interests, we consider whether the processing is necessary and balance our interests against your rights and reasonable expectations. You may request further information about this assessment and may object to processing based on legitimate interests as described in Section 12.
Where we rely on consent, you may refuse or withdraw it without affecting the lawfulness of processing carried out before withdrawal. Refusing consent will not affect core functions unless the relevant processing is necessary to provide a feature you requested.
If we intend to use personal data for a materially different purpose, we will assess whether the new purpose is compatible with the original purpose and provide additional notice or obtain consent where required.
Public profiles, search engines and other users
The Service is designed to enable professional visibility and interaction. Depending on your settings, information in your profile may be visible to employers, recruiters, clients, other registered users or the general public. Public information may include your name, professional title, photograph, biography, skills, portfolio items, listings, reviews and ratings.
If public-profile indexing is enabled, search engines may index public pages. Copies or cached versions may remain visible for a period after you change your settings or delete information. We will take reasonable steps required by law in response to a valid erasure request, but we do not control independent search engines or third parties that previously obtained public information.
Before publishing information, review your privacy and visibility settings. Do not make personal data public unless you want it to be publicly accessible.
When you apply for a job, submit a proposal, enter a transaction or send a message, we share the information necessary for that interaction with the relevant user. Recipients may act as independent controllers and are responsible for their own use of the information.
Automated processing and recommendations
We may use automated systems to rank, match or recommend profiles, jobs, services or content using factors such as stated skills, professional experience, location, preferences, activity and relevance to a search.
[CONFIRM BEFORE PUBLICATION:] These recommendation activities do not produce legal effects or similarly significant effects and are not used to make decisions based solely on automated processing within Article 22 GDPR.
If SEO Interaction carries out solely automated decision-making that produces legal or similarly significant effects, this section must instead explain the decision, the principal factors and logic involved, its likely consequences, the applicable legal basis and the right to request human intervention, express a point of view and contest the decision.
How we disclose personal data
We may disclose personal data to:
- Other users: as necessary to display information according to your settings and enable applications, proposals, projects, transactions, messages, reviews and ratings.
- Service providers acting on our instructions: including hosting, cloud infrastructure, database, communications, customer-support, analytics, security, fraud-prevention and professional advisers. They may process personal data only under an appropriate contract and documented instructions, unless they independently act as controllers.
- Payment and authentication providers: when you choose to use their services. These providers may act as independent controllers for some activities.
- Advertising and analytics partners: only as permitted by law and, where required, after you consent. [IDENTIFY THE CATEGORIES AND MATERIAL PARTNERS IN THE COOKIE POLICY OR HERE.]
- Authorities, courts and other parties for legal reasons: when disclosure is required by applicable law or is necessary to protect rights, safety, prevent fraud or establish, exercise or defend legal claims.
- Parties to a corporate transaction: in connection with due diligence, a merger, acquisition, financing, reorganisation, insolvency or sale of all or part of our business, subject to appropriate confidentiality and data-protection safeguards.
We do not sell personal data. [CONFIRM whether any advertising or partner disclosures may constitute a “sale” or “sharing” under non-European laws before retaining this statement.]
International transfers
SEO Interaction operates in [LIST COUNTRIES, INCLUDING CANADA AND/OR THE UNITED STATES IF ACCURATE], and some recipients or service providers may be located outside the country in which you live.
When personal data is transferred from the EEA, United Kingdom or Switzerland to a country that is not recognised as providing an adequate level of protection, we use an approved transfer mechanism as required by applicable law. Depending on the transfer, this may include:
- an adequacy decision adopted by the European Commission, the UK Government or the Swiss Federal Council, as applicable;
- the European Commission’s Standard Contractual Clauses, together with the UK Addendum or Swiss adaptations where required;
- binding corporate rules or another approved safeguard; and
- additional technical, contractual or organisational measures where appropriate.
For transfers to the United States, we may rely on an applicable adequacy framework only where the recipient is validly certified and the framework covers the relevant transfer. Otherwise, we use another lawful safeguard.
You may contact privacy@seointeraction.com to request information about the relevant transfer mechanism and, where available, a copy of the safeguards. Commercially sensitive information may be redacted.
Cookies and similar technologies
We use cookies and similar technologies to operate and secure the Service, remember preferences, measure performance and, if applicable, support analytics and advertising.
Strictly necessary cookies may be used without consent where they are required to transmit communications or provide a service you expressly requested. We will not place or access non-essential analytics, personalisation or advertising cookies on your device until you have given valid consent where applicable.
Our consent interface will allow you to accept or reject non-essential cookies by purpose. You can change or withdraw your choices at any time through [COOKIE SETTINGS LINK OR BUTTON]. Withdrawal must be as easy as giving consent. Refusing non-essential cookies will not prevent access to core Service functions, although some optional features may be less personalised.
Our [Cookie Policy — INSERT LINK] identifies the cookies and similar technologies used, their providers, purposes, duration and whether information is transferred internationally.
Browser controls may also allow you to remove or block cookies, but blocking strictly necessary cookies may prevent parts of the Service from functioning.
Data retention
We retain personal data only for as long as necessary for the purpose for which it was collected, including to provide the Service, comply with legal obligations, resolve disputes and protect against fraud or abuse. We then delete or irreversibly anonymise it, unless the law requires or permits further retention.
SEO Interaction must complete and apply a retention schedule before publishing this Privacy Policy. The following periods are placeholders, not final commitments:
| Data category | Retention period or criterion |
|---|---|
| Account and profile data | While the account is active and for [PERIOD] after closure, unless earlier deletion is required or longer retention is justified |
| Public listings and portfolio content | Until removed by the user or account closure, plus [BACKUP/CACHE PERIOD] |
| Applications, proposals and messages | [PERIOD], taking account of user access, disputes and legal claims |
| Transaction, invoice and tax records | For the period required by applicable accounting and tax law, typically [PERIOD BY JURISDICTION] |
| Support records | [PERIOD] after the matter is closed |
| Security, fraud-prevention and access logs | [PERIOD], extended where needed to investigate an incident or legal claim |
| Cookie consent records | For the life of the consent choice and [PERIOD] thereafter to demonstrate compliance |
| Marketing records and suppression lists | Until consent is withdrawn or you object; minimal suppression data may be retained to honour the opt-out |
| Backups | Deleted or overwritten on a rolling basis within [PERIOD] |
When determining a retention period, we consider the amount, nature and sensitivity of the data, the risk of harm, the relevant purpose, whether it can be achieved by other means and applicable legal requirements.
Security and personal-data breaches
We use appropriate technical and organisational measures designed to protect personal data against accidental or unlawful destruction, loss, alteration, unauthorised disclosure or access. Measures may include access controls, encryption in transit, secure password hashing, logging, backups, vendor controls and security testing, as appropriate to the risk.
No online service can guarantee absolute security. You are responsible for using a strong, unique password and protecting your account credentials. Please notify us promptly at [SECURITY EMAIL OR SUPPORT LINK] if you suspect unauthorised account access.
We assess personal-data breaches and notify the competent supervisory authority and affected individuals when required by applicable law.
Your data-protection rights
Subject to applicable law and any lawful exceptions, you may have the right to:
- receive information about how we process your personal data;
- request access to your personal data and a copy of it;
- request correction of inaccurate or incomplete personal data;
- request erasure of personal data;
- request restriction of processing;
- receive personal data you provided in a structured, commonly used and machine-readable format, and request its transmission to another controller where technically feasible;
- object to processing based on legitimate interests, including profiling based on those interests;
- object at any time to processing for direct marketing, including related profiling;
- withdraw consent at any time, without affecting earlier lawful processing;
- not be subject to a decision based solely on automated processing, including profiling, that produces legal or similarly significant effects, except where permitted by law and accompanied by required safeguards; and
- lodge a complaint with a competent data-protection supervisory authority or seek a judicial remedy.
To exercise a right, email privacy@seointeraction.com or use [PRIVACY REQUEST FORM/ACCOUNT TOOL]. Please describe your request and the account or email address concerned. We may request information reasonably necessary to verify your identity and protect your data.
We will respond without undue delay and normally within one month under the GDPR. That period may be extended by up to two additional months for complex or numerous requests, in which case we will inform you. Requests are generally free of charge, but we may charge a reasonable fee or refuse to act on requests that are manifestly unfounded or excessive, as permitted by law.
You may lodge a complaint with the supervisory authority in the country of your habitual residence, place of work or the place of the alleged infringement. A list of EEA authorities is available from the European Data Protection Board at https://www.edpb.europa.eu/about-edpb/about-edpb/members_en. In the United Kingdom, the supervisory authority is the Information Commissioner’s Office at https://ico.org.uk. In Switzerland, it is the Federal Data Protection and Information Commissioner at https://www.edoeb.admin.ch.
We encourage you to contact us first so we can try to resolve your concern, but you are not required to do so before contacting an authority.
Marketing communications
We send electronic marketing only where permitted by applicable law. Where consent is required, we will obtain it before sending marketing.
You may unsubscribe at any time by using the link in a marketing message, changing your account preferences or contacting privacy@seointeraction.com. Opting out of marketing does not stop essential messages about your account, transactions, security or changes to the Service.
Children
The Service is not directed to, and may not be used by, anyone under 18. We do not knowingly collect personal data from children. If you believe a person under 18 has provided personal data to us, contact privacy@seointeraction.com. We will investigate and delete the data where required.
Third-party links and services
The Service may contain links to or integrations with third-party websites and services. Their privacy practices, content and security are controlled by those third parties, not SEO Interaction. Review their privacy notices before providing personal data or using their services.
Changes to this Privacy Policy
We may update this Privacy Policy to reflect changes to the Service, our practices or applicable law. We will post the revised version and update the “Last updated” date. If a change materially affects your rights or how we use personal data, we will provide prominent notice in advance where required. We will seek new consent if the law requires it; continued use of the Service will not by itself constitute consent to processing that legally requires consent.
Contact us
For questions, complaints or requests relating to privacy or this Privacy Policy, contact:
SEO Interaction / [FULL LEGAL ENTITY NAME]
Postal address: [FULL POSTAL ADDRESS]
Email: privacy@seointeraction.eu
Website: https://www.seointeraction.eu
DPO or privacy lead: [NAME/TITLE AND CONTACT, IF APPLICABLE]