1.1. This Privacy and Personal Data Processing Policy of the WorkXplorer Platform (hereinafter — the "Policy") governs the collection, receipt, systematisation, storage, clarification, use, transfer, anonymisation, blocking, deletion, and destruction of personal data, as well as the measures to ensure their confidentiality and security when using the website, application programming interfaces, mobile, and other digital services operating under the WorkXplorer designation (hereinafter collectively — the "Platform").
1.2. This Policy has been developed in accordance with the legislation of the Republic of Uzbekistan, including the Law of the Republic of Uzbekistan No. ЗРУ-547 dated 2 July 2019 "On Personal Data", as well as other applicable regulatory legal acts of the Republic of Uzbekistan in the field of personal data, informatisation, and information protection.
1.3. The personal data controller is WorkXplorer Limited Liability Company, TIN: 311888470, email address: [email protected] (hereinafter — the "Operator").
1.4. This Policy applies to personal data of candidates, job seekers, students, graduates, employer representatives, partner organisation representatives, Platform visitors, and other individuals whose personal data are processed by the Operator in connection with providing access to the Platform and its functionality.
1.5. Use of the Platform, account registration, authorisation, profile completion, resume uploading, application submission, vacancy creation, submission of requests via feedback forms, registration for a WorkXplorer Event, confirmation of participation in it, completion of registration or access control at such an event, and any other actions in the Platform interface or within a WorkXplorer Event shall constitute the User's acknowledgement of this Policy. Consent to the processing of personal data is expressed through a separate affirmative action of the User, including ticking the relevant box, clicking a confirmation button, signing an electronic or paper consent form, or performing another action expressly designated as an expression of consent.
1.6. Any person who disagrees with this Policy is obliged to refrain from using the Platform and from providing their personal data through the Platform.
2.1. For the purposes of this Policy, terms are used in the meaning established by the legislation of the Republic of Uzbekistan.
2.2. Personal data means any information relating to a directly or indirectly identified individual or enabling their identification.
2.3. Processing of personal data means any action or set of actions performed with personal data using automated means or without such means, including collection, recording, systematisation, accumulation, storage, clarification, updating, modification, extraction, use, transfer, provision of access, anonymisation, blocking, deletion, and destruction.
2.4. User means any individual using the Platform as a candidate, employer representative, partner representative, or Platform visitor.
2.5. A WorkXplorer Event means an event organised, co-organised or supported by the Operator, or held with its participation, in person, remotely or in a hybrid format, including career days and months, job fairs, presentations, meetings, interviews, tests, master classes, competitions, webinars and other career, educational or recruitment events.
2.6. Interaction data means information about the User's actions on the Platform and within WorkXplorer Events, including their requests, answers, messages, applications, choices, ratings, results of tests and assignments, feedback, actions with vacancies and profiles, as well as their interactions with the Operator, employers, educational institutions, partners and other participants.
3.1. Personal data is processed by the Operator on the principles of lawfulness, fairness, good faith, limitation of processing to specific pre-determined and lawful purposes, data minimisation, compliance of the volume and nature of processed data with the stated processing purposes, and ensuring accuracy, sufficiency, and relevance of data.
3.2. The Operator processes personal data on the basis of: (a) consent of the personal data subject; (b) necessity to conclude and perform agreements; (c) necessity to fulfil obligations imposed by the legislation of the Republic of Uzbekistan; (d) other grounds provided for by law.
3.3. The Operator processes personal data using automated means, without such means, or by mixed methods.
3.4. The Operator does not make decisions affecting the rights and legitimate interests of the personal data subject solely on the basis of automated processing, unless directly provided for by law and agreed with the subject.
4.1. In respect of candidates, job seekers, students, and graduates: last name, first name, patronymic; gender; date of birth; phone number; email address; information on place of study, specialisation, academic performance, and educational achievements; information on professional experience, skills, certificates, portfolio, and letters of recommendation; data from resumes, cover letters, questionnaires, test assignments, and career survey results; employment and occupation preferences.
4.2. In respect of employer representatives, partners, and other organisations: last name, first name, patronymic; job title; place of work; phone number; email address; information about the company and the representative's authority; correspondence, enquiries, applications, and vacancy information.
4.3. In respect of all Users: IP address, browser, operating system, device model information, device identifiers, date and time of access, geographic and network attributes, cookies, server log data, and information about interface actions.
4.4. The Operator does not intentionally collect special categories of personal data unless directly required by the Platform's functionality, legislation, or a separately expressed consent.
4.5. When the User takes part in WorkXplorer Events, the Operator may process information about registration, the fact, time and format of participation, sessions and activities attended, questions and answers, results of tests, assignments, interviews and surveys, materials received, feedback, communications and interactions with participants, employers, educational institutions, partners and representatives of the Operator, as well as information obtained through registration forms, QR codes, electronic passes, badges and other means of recording participation.
4.6. Where the relevant consent has been given, the Operator may take photographs and make video and audio recordings of WorkXplorer Events and process the image, voice, speeches and other materials featuring the User. The publication of such materials and their use for informational, reporting, educational or promotional purposes are governed by the consent given by the User and by the legislation of the Republic of Uzbekistan.
5.1. The Operator obtains personal data directly from the personal data subject upon registration, authorisation, profile completion, uploading of documents, completion of surveys and tests, applications to vacancies, and use of Platform services.
5.2. Where provided for by the Platform's functionality, the Operator may obtain personal data from employers, educational organisations, partners, and referees where lawful grounds exist. Where a partnership agreement with an educational institution is in place, the Operator is entitled to receive information on students' and graduates' academic performance, attendance, fields of study, and other academic data to the extent provided for by the relevant agreement.
5.3. Technical data and information about Platform use may be collected automatically by means of software and hardware tools, event logs, metrics systems, third-party analytics services, cookies, and other similar technologies.
5.4. Data related to WorkXplorer Events may be obtained directly from the User; from the organisers, co-organisers, employers, educational institutions and partners of the event; and through registration, access control, survey and testing systems, as well as photo, video and audio recording where the applicable consent has been given.
6.1. The Operator processes personal data for the purposes of: (a) identifying the User and creating an account; (b) providing access to the Platform and its functionality; (c) creating and updating the User's profile; (d) assisting with career guidance, career navigation and the selection of vacancies, internships and other career opportunities; (e) enabling employers and partners to search for and communicate with candidates; (f) organising, holding and supporting WorkXplorer Events, registering and recording participants, analysing participation and results, preparing reports and subsequent interaction with participants; (g) sending service and informational messages; (h) handling enquiries and complaints; (i) ensuring information security; (j) maintaining analytics and improving services; (k) applying artificial intelligence technologies in accordance with Section 13 of this Policy; (l) fulfilling the requirements of the legislation of the Republic of Uzbekistan.
6.2. The Operator may not use personal data for purposes incompatible with those specified in clause 6.1 of this Policy.
7.1. By posting personal data on the Platform, the User acknowledges and agrees that such information may be accessible to employers, partners, and other persons within the visibility settings and Platform functionality.
7.2. The Operator is entitled to transfer personal data to employers and their authorised representatives for the purposes of reviewing a candidacy, recruitment, internships, and other career development opportunities.
7.3. The Operator is entitled to provide personal data to contractors and service providers engaged to ensure Platform operation, subject to their maintaining confidentiality and applying appropriate protective measures.
7.4. Personal data may be provided to public authorities, courts, and law enforcement bodies in the cases provided for by the legislation of the Republic of Uzbekistan.
7.5. The Operator is not a party to relations between a candidate and an employer and is not responsible for the lawfulness of further processing by third parties that have received data on lawful grounds.
7.6. To provide features based on artificial intelligence, the Operator may entrust the processing of the necessary scope of data to providers of cloud and AI services, including Anthropic, Google and other providers engaged by the Operator. Such persons process the data on behalf of the Operator to generate results, ensure security, provide technical support and operate the relevant services, unless otherwise separately agreed with the User.
7.7. Before transferring data to AI service providers, the Operator removes the User's direct identifiers from the transferred data set, including their surname, first name, patronymic, phone number, email address, residential address and other contact details. AI providers receive only the content necessary to perform a specific function, in pseudonymised form and without the possibility of directly identifying the User from the transferred data set.
8.1. The Operator ensures the storage and processing of personal data in accordance with localisation requirements of the legislation of the Republic of Uzbekistan where such requirements are applicable.
8.2. Cross-border transfer of personal data is permitted only where lawful grounds exist and in compliance with the requirements of the legislation of the Republic of Uzbekistan.
8.3. The Operator shall carry out registration of personal data databases with the State Register in cases provided for by the legislation of the Republic of Uzbekistan.
8.4. Providers of cloud and AI services may be located and process data outside the Republic of Uzbekistan. Data is transferred to such providers only where there is an applicable legal basis, in compliance with the requirements for the cross-border transfer and storage of personal data, and with contractual, organisational and technical safeguards in place.
9.1. Personal data is processed and retained for the period necessary to achieve the processing purposes, for the duration of the User's account, or for the period provided for by the legislation of the Republic of Uzbekistan.
9.2. Upon achievement of the processing purposes or withdrawal of consent, personal data shall be deleted, destroyed, or anonymised, unless otherwise provided for by legislation or another lawful ground.
9.3. Certain data may be retained after account deletion as part of backups, event logs, and mandatory documentation within the periods established by the legislation of the Republic of Uzbekistan.
10.1. The personal data subject is entitled to: (a) receive information about the purposes and legal grounds for the processing of their personal data; (b) demand correction, blocking, or deletion of inaccurate or unlawfully obtained data; (c) withdraw previously given consent to processing; (d) submit requests and complaints to the Operator; (e) protect their rights by other means provided for by the legislation of the Republic of Uzbekistan.
10.2. To exercise these rights, the subject shall submit a request to the Operator at [email protected] or by postal address of the Operator. A response shall be provided within a reasonable period.
10.3. Withdrawal of consent does not affect the lawfulness of processing carried out prior to its receipt by the Operator, and does not prevent processing on other lawful grounds.
11.1. The Operator takes necessary legal, organisational, and technical measures to protect personal data from unlawful processing, unauthorised access, destruction, alteration, blocking, distribution, and other unlawful actions.
11.2. Such measures include restricting access to personal data, implementing internal regulations, using identification and authentication tools, maintaining event logs, backing up data, protecting data transmission channels, and anti-virus protection.
11.3. Persons who have obtained access to personal data in connection with the performance of obligations to the Operator are required to maintain confidentiality in accordance with the legislation of the Republic of Uzbekistan.
12.1. The Platform may use cookies, pixels, tags, event logs, and other similar technologies to ensure the proper functioning of services, save user preferences, analyse traffic, and improve Platform quality.
12.2. The User may restrict the use of cookies through their browser or device settings. This may affect the availability or correct operation of certain Platform features.
13.1. The Operator may use artificial intelligence technologies to analyse the User's profile, resume, skills, competencies, preferences, answers, results of tests and assignments, data on participation in WorkXplorer Events and interaction data.
13.2. The purposes of such processing are to generate career recommendations and a career track, analyse skills and potential, select vacancies, internships, events and educational opportunities, match candidate profiles with employers' requirements, prepare analytics, summaries and suggestions, support Users, detect errors and abuse, and improve the quality and security of the Platform.
13.3. To perform certain AI functions, the User's pseudonymised data may be transferred to the AI service providers specified in clause 7.6 of this Policy. The surname, first name, patronymic, phone number, email address and other direct identifiers and contact details are not transferred to such providers. The Operator uses contractual terms, plans and technical settings under which the relevant provider is not granted the right to use the data received to train its models for its own purposes, except where the User has given separate explicit consent to this.
13.4. To develop, test, configure, evaluate and improve WorkXplorer's own algorithms, models and AI mechanisms, the Operator may use anonymised and aggregated data derived from Users' data and their interactions. Identifiable personal data may be used to train models only with the User's separate explicit consent or on another legal basis.
13.5. Results generated using artificial intelligence are advisory and probabilistic in nature. The Operator does not make legally significant decisions affecting the rights and legitimate interests of the User solely on the basis of such results, unless this is expressly permitted by law and agreed with the User in the prescribed form.
13.6. The User may contact the Operator for information on the processing of their personal data using artificial intelligence, request that the source data be corrected, or challenge the result of automated processing in the cases and in the manner provided for by the legislation of the Republic of Uzbekistan.
14.1. Where the Platform's functionality involves interaction with persons under the age of eighteen, the processing of their personal data is carried out in accordance with the requirements of the legislation of the Republic of Uzbekistan.
14.2. Where the provision of consent to the processing of a minor's personal data legally requires the participation of their legal representative, such consent shall be provided in the prescribed manner.
15.1. The Operator is entitled to make amendments to this Policy unilaterally in order to bring it into compliance with changes to legislation, Platform functionality, or other material circumstances.
15.2. The new version of the Policy shall take effect from the moment of its publication on the Platform.
15.3. Continued use of the Platform after the publication of a new version shall constitute the User's acknowledgement of such version. If the changes provide for new purposes, methods or scope of processing for which consent is required by law, the Operator obtains such consent separately.
16.1. This Policy shall be published on the Platform and made permanently accessible to Users.
16.2. In all matters not regulated by this Policy, the parties shall be governed by the legislation of the Republic of Uzbekistan and other user documents of the Platform.
16.3. This Policy is drafted in Russian. Where a translation is available, the Russian-language version shall prevail unless otherwise established by the Operator.