Stint’s Privacy Policy

Last updated: November 2022

Stinter User Privacy Notice

At Stint, we value your data and hold it in the highest regard. This Privacy Notice outlines what types of data we collect from you, how we use it, who we share it with, and how long we keep it for. If you have any questions about this Privacy Notice or any other matter relating to how Stint uses your personal data, feel free to email our data protection officer at dataprotection@stint.co.

Who we are

Stint Ltd, a company registered in England under number 11022621, with its registered office at The Retreat, 406 Roding Lane South, Woodford Green, Essex, England, IG8 8EY, is the data controller. Stinter or you). Personal data, personal information means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymous data).

For definitions used in this privacy notice, see the Stint Terms and Conditions.

Personal data Stint collects on Stinter

Information you provide. This may include:

• User profile: for a Stinter to create an account on Stint we require they input details about themselves. This includes your name, email address, mobile phone number, date of birth, work experience (if any), details of work experience, profile picture, payment information (including bank account details and national insurance number), student loan information (where applicable) and password. This information is used to create your Stint profile and allow you to sign up for Stints.
• Emergency information: emergency contact name and emergency contact phone number is processed in the unlikely event a Stinter is involved in an emergency while on a stint.
• Right to work and employment information: by law we need to verify your right to work in the UK, we therefore require that you provide us a copy of your passport (if British) or BRP card and Home Office share code; we also need you date of birth and national insurance number as required by HMRC.
• Payment information: your time spent on Stints and the rate at which you agreed the Stint, your payslips and bank details so that we can pay you for your Stints.
• Stint preferences: this includes information you provide on your future availability to do Stints including the dates and times of day you want to do Stints, and areas you aren’t willing or able to work in as a Stinter (e.g. not working with alcohol or in heavy lifting).
• User content: this includes your answer to questions we may ask you, such as ‘How did you hear about Stint?’ or your comments on Business Users.

Information created when using our App. This may include:

• Marketing data: your preferences in receiving marketing from us, and our third parties. We may also use our correspondence with you to generate information on how you respond to email, phone, messaging, social media, text and post campaigns.
• Communication data: we communicate with Stinter on the phone, by email and on WhatsApp. We keep a record of this correspondence.
• Location information: depending on your device permissions Stint may collect your precise or approximate location. We collect this information when the Stint App is running in the foreground or background of your device. You can still use the Stint App without enabling location tracking but this may hinder our ability to match you to stints that are within a reasonable distance to your location or to verify that you are on a way to a Stint you signed up for, in which case the Stint may be reassigned.
• Device information: we may collect data on the device you use to access the Stint App such as your battery level and device motion information.

Information provided by other sources. This may include:

• Verification meeting feedback: this may include a comment on your work experience and English-speaking ability.
• Business User feedback on your Stint performance: this includes an overall rating out of 5; category ratings out of 5 on your personality, attitude, presentablity, English-speaking ability, uniform and lateness; bad ratings tags on lateness, uniform, skills and attitude, and comments made by Businesses on your performance.

More sensitive data:

• Health problems: we ask you to provide us with information on any health issues that may hinder your ability to do certain Stints so we can assign you to Stints suited to you. For example, allergies, physical injuries or disabilities.

We also collect, use and share Aggregated Data such as statistical or demographic data for any purpose. Aggregated Data could be derived from your personal data but is not considered personal data in law as this data will not directly or indirectly reveal your identity. For example, we may aggregate your Device Data to calculate the percentage of users accessing a specific feature of our Website. However, if we combine or connect Aggregated Data with your Personal Data so that it can directly or indirectly identify you, we treat the combined data as Personal Data which will be used in accordance with this Privacy Policy.

If you fail to provide Personal Data

Where we need to collect Personal Data by law, or under the terms of a contract we have with you, and you fail to provide that data when requested, we may not be able to perform the contract we have or are trying to enter into with you (for example, to provide you the Services). In this case, we may may not be able to allow you to attend a Stint. If you do not want us to process your Personal Data in the way set out in this Privacy Policy, you should not use our App.

You may also choose not to provide us with any optional personal data (marked as non-mandatory where applicable). However, please note that doing so might prevent you from fully using our App and provide you with the best user experience when using it.

How Stint uses your personal data

Stint uses the personal data of Stinter for purposes including:

We will only use your personal data when the law allows us to. Most commonly, we will use your personal data in the following circumstances:

• where we need to perform the contract we are about to enter into or have entered into with you;
• where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interest;
• where we need to comply with a legal obligation;
• where we may rely on legitimate interest;
• where it is in your vital interest or
• where you have provided consent.

Purposes for which we will use your Personal Data

We have set out below, in a table format, a description of all the ways we plan to use your personal data, and which of the legal bases we rely on to do so. We have also identified what our legitimate interests are where appropriate.

Note that we may process your personal data for more than one lawful ground depending on the specific purpose for which we are using your data. Please contact us if you need details about the specific legal ground we are relying on to process your personal data where more than one ground has been set out in the table below.

Purpose/Activity	Type of data	Lawful basis for processing including basis of legitimate interest
To register you as a new Stinter and update your account, verifying your identity and right to work in the UK.	User profile Emergency information Right to work information Communication Data	Performance of a contract with you
To match you with and offer you Stints that match with your personal experience and abilities, and enable communications with you about your Stint	User profile Stint preferences Location information Verification meeting feedback Business User feedback Health problems Communication Data	Performance of a contract with you Necessary to comply with a legal obligation
To pay your salary, and make payments to HMRC	Right to work and employment information Payment information	Necessary to comply with a legal obligation
To optimise our service, encourage improvement in your performance, as grounds for deactivating Stinter with ratings below a certain minimum where Stint’s reputation in the eyes of Business Users is in jeopardy, and enhance the pricing and matching of Stinters with Business Users	User profile Buiness User feedback Communication Data	Necessary for our legitimate interests (to ensure Stint’s reputation is not damaged and avoid loss of Business Users and optimise our service)
To assist you when you contact our customer support services, including to direct your questions to the appropriate customer support person, to investigate and address your concerns, and to monitor and improve our customer support responses.	User profile Right to work and employment information Payment information Stint preferences Communication Data	Performance of a contract with you Necessary to comply with a legal obligation Necessary for our legitimate interests (to help Stinters use our App)
To keep our Stinters and Business Users safe and secure by: tracking your location before a stint to ensure you are not lost or require assistance with travel and ensure you arrive promptly to your Stint; processing your name and profile picture so the Business whose stint you are attending knows the identity of the Stinter prior to your arrival; inform the Business User of any health issues that they must be made aware of in order to keep you safe and allow you to perform the Stint; and informing your emergency contact in the event you are injured during a Stint	User profile Emergency information Communication data Location information Device information Health problems	Performance of a contract with you Necessary to comply with a legal obligation Necessary for our legitimate interest (to ensure that the right Stinter attends the Stint, and timely arrives at the Stint location) Vital interest
To manage our relationship with you which will include: Notifying you about any changes to our Terms or this Privacy Policy; Notifying you about changes to our App Respond to any questions or issues you may have Asking you to leave a review or take a survey	User profile User content Profile Marketing data Communication Data	Performance of a contract with you Necessary to comply with a legal obligation Necessary for our legitimate interests (to keep our records updated and to study how our Stinters use our App)
To enable you to complete a survey	User profile User content Marketing data Communication Data	Performance of a contract with you Necessary for our legitimate interests (to study how our Stinters use our App, to develop them and grow our business)
To administer and protect our business and our App, and use data analytics to improve our App (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data), and for research and marketing purposes	User Profile Contact Device information	Necessary for our legitimate interests (for running our business, provision of administration and IT services, network security, to prevent fraud, to analyse usage trends to improve the user experience and enhance the safety and security of our services) Necessary to comply with a legal obligation
To deliver relevant marketing content and make suggestions and recommendations to you about goods or services that may be of interest to you, including products, services, promotions, studies, surveys, news, updates, and events and serve you relevant ads and content about our services and those of our business partners.	User profile User content Marketing data Device information	Consent Where applicable, necessary for our legitimate interests (to study how our Stinters use our App, to develop it, to grow our business and to inform our marketing strategy)
To deal with any hearings, termination and disputes, including in relation to: gathering evidence for possible grievance or disciplinary hearings in relation to Stinters; making decision about your continued use of the Stint App; the termination of your use of the App accordance with the Stint Terms; dealing with legal disputes, claims or other legal or administrative or regulatory actions or investigations involving Stinters, or other employees, workers and contractors of Stint, or any Business User (including in relation to health and safety or compliance with any other laws).	User profile Right to work and employment information Payment information Location information Device information Health problems Stint preferences Communication data Location information Verification meeting feedback Business user feedback on your Stint performance Health problems	Performance of a contract with you Necessary to comply with a legal obligation Necessary for our legitimate interests (to ensure Stinters that could create a reputational risk for Stint)

In this Privacy Policy

• Legitimate Interest means the interest of our business in conducting and managing our business to enable us to give you the best service and the best and most secure experience. We make sure we consider and balance any potential impact on you (both positive and negative) and your rights before we process your personal data for our legitimate interests. We do not use your personal data for activities where our interests are overridden by the impact on you (unless we have your consent or are otherwise required or permitted to by law). You can obtain further information about how we assess our legitimate interests against any potential impact on you in respect of specific activities by contacting us.
• Performance of Contract means processing your data where it is necessary for the performance of a contract to which you are a party or to take steps at your request before entering into such a contract.
• Comply with a legal obligation means processing your personal data where it is necessary for compliance with a legal obligation that we are subject to.
• Vital Interest means processing your personal data where it is necessary in case something happens which puts you in serious physical danger.

Marketing

Stint may also use the information to promote and serve you relevant ads and content about our services where you have signed up to become a Stinter. You may receive some of these communications based on you profile as a Stinter. This information will be processed on legitimate interest.

Upon creation of your account with Stint, you will be asked for your consent to provide you with marketing emails or other form of communication about our services, our partners, charities we work with, events happening around you, etc.

You may unsubscribe from any of the above communications at any time.

Change of purpose

We will only use your personal data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If you wish to get an explanation as to how the processing for the new purpose is compatible with the original purpose, please contact us.

If we need to use your personal data for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so.

Please note that we may process your personal data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.

Sharing your data

Stint may share the data we collect:

• With Business Users of Stint: Business Users need to know – for security and operational reasons – who is coming to their Stint. We therefore share a limited version of your profile with Business Users when you are matched to their Stint posting. This limited profile includes your name, profile picture, and overall rating.
• With third party services providers: Stint will share personal information with third parties where required by law, where it is necessary to administer the contract between us and you or where we have another legitimate interest in doing so.

We share personal data with third parties as follows:

• With our payroll service providers, including Virtual Business Source (PayPlus at https://payplus.co.uk) ;
• With our database service providers, including Firebase (https://firebase.com) and Salesforce (https://salesforce.com);
• With our instant messaging and customer service messaging providers, including WhatsApp (https://www.whatsapp.com) and Zendesk (https://zendesk.co.uk/);
• With our web hosting providers, including AWS (https://aws.amazon.com) and Google Cloud;
• With our email and file sharing applications and providers, including Gsuite, Sendgrid;
• With our HR management software providers, including Bamboo HR (https://bamboohr.com);
• With out calendar and booking providers, including Calendly (https://calendly.com) – we also use Zapier (https://zapier.com) to share data stored in Calendly with Google Sheets;
• With other suppliers. We may, for example, engage a supplier to carry out administrative and operational work in support of our relationship with Stinters; and
• With other entities in our group of companies part of our regular business operations and reporting activities on company performance, in the context of a business reorganisation, sale of all or part of our business, or group restructuring exercise, for system maintenance support and hosting data.

The suppliers will be subject to contractual and other legal obligations to preserve the confidentiality of data and to respect privacy, and will only have access to the data they need to perform their functions; the relevant suppliers are typically IT suppliers (who provide, host or support our IT systems, including information about Stinters) and back office finance and accounting management providers (who might need to handle details of Stinters in order to process accounts payable and receivable) or our solicitors in order to obtain legal advice.

Some of our suppliers are located outside of the UK and the EEA, this includes our legal advisors and some of our suppliers set out in the list above. Where we do so, we will ensure that such transfer complies with the rules for international transfers under the data protection laws (for example, the country is on the European Commission’s list of adequate countries or there are standard contractual clauses or equivalent in place).

All our supplier and other entities in the group are required to take appropriate security measures to protect personal information in line with our policies. We do not allow our third-party service providers to use personal data other than for specified purposes and in accordance with our instructions.

Retaining and deleting your data

Stint will only retain personal information for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting or reporting requirements. To determine the appropriate retention period for personal data, we consider the amount, nature and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of personal data, the purposes for which we process personal data and whether Stint can achieve those purposes through other means, and the applicable legal requirements.

In some circumstances, Stint may anonymise personal information so that it can no longer be associated with you, in which case Stint may use such information without further notice to you. Once a Stinter is no longer a registered user, Stint will retain and securely destroy personal information in accordance with applicable laws and regulations.

Data security

We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal data on our instructions and they are subject to a duty of confidentiality.

We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.

Automated Decision Making

We use an algorithm to match Stinter with Stints. This algorithm takes into account several parameters, such as the location of the Stinter in relation to the Stint, the Stinter’s availability to perform the Stint, the Stinter’s past working history (if any), the Stinter’s skills, the Stinter’s ranking in the App, a Stinter’s level of education, a Stinter’s willingness/ability to do certain work (e.g. if they are unable to work with alcohol for religious reasons) and other factors. You have the right not to be subject to decisions which are based solely on automated decision making. If you feel you have been treated unfairly you can write to us at dataprotection@stint.co.

Call recordings

We record calls to Stinters for quality and monitoring purposes, which ensures that our staff is properly trained and services are continuously improved. We may also keep calls for longer where the call concerns a complaint of a Stinter, a Business User or Stint, and in order to protect our business’ legitimate interest in the event of a potential or actual claim involving us.

Your rights

Under certain circumstances, by law you have the right to:

• Request access to personal information (commonly known as a “data subject access request”). This enables you to receive a copy of the personal information Stint holds about you and to check that we are lawfully processing it.
• Request correction of the personal information that we hold about you. This enables you to have any incomplete or inaccurate information we hold about you corrected.
• Request erasure of personal information. This enables you to ask us to delete or remove personal information where there is no good reason for us to continue processing it. You also have the right to ask us to delete or remove personal information where you have exercised your right to object to processing (see below).
• Object to the processing of personal information where Stint is relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground. You also have the right to object where we process personal information for direct marketing purposes.
• Request restriction of processing of personal information. This enables you to ask Stint to suspend the processing of personal information about you, for example, if you want Stint to establish its accuracy or the reason for processing it.
• Withdraw consent at any time where we are relying on consent to process your personal data. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain products or services to you. We will advise you if this is the case at the time you withdraw your consent.

Use the form here to make a request and invoke your rights or send an email to dataprotection@stint.co

No fee usually required

You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we could refuse to comply with your request in these circumstances.

What we may need from you

We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.

Time limit to respond

We try to respond to all legitimate requests within one month. Occasionally it could take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.

Changes to this privacy policy

Stint reserves the right to update this privacy policy at any time. We will provide you with the new privacy policy when we make any substantial updates. We may also notify you from time to time about the processing of your personal information through the Stint App or through other means such as email. We encourage you to review this privacy policy regularly for the latest information on our privacy practices.