Prohood

Company Website

Privacy Policy

Effective date: 29 Mar 2025

RESPONSIBLE

Responsible for the collection, processing and use of your personal data within the meaning of Art. 4 No. 7 GDPR data protection laws is –

Vitalii Kozlo, a self-employed individual,

Ukraine, Kyiv, str. Borschahivska, building 148

Website: https://prohood.org

Email: [email protected]

hereinafter – “Prohood”, (“Site”).

If you wish to object to the collection, processing or use of your data by us in accordance with these data protection regulations as a whole or for individual measures, you can address us your objection. Also, you can save and print out this Privacy Policy at any time.

GENERAL CONDITIONS

At Prohood (“We,” “Us,” and “Our”) we pay attention to the safety our Users (“You,” and “Your”), as well as the security of private information. The Privacy Policy section here is destined to give You an overview of the information we need from you and about how it is protected from illegal use. We urge Our Users to study the following Privacy Policy section before they pass on to the cooperation with Us.

You accept the following information about the Privacy Policy, as well as the Terms of Service. If You need additional information about the Privacy Policy issues, find Our contact information on the Website and get in touch.

All personal data is collected and processed in compliance with the applicable data protection regulations of the General Data Protection Regulation (GDPR) as well as UK GDPR and FADP. Your acceptance of the Privacy Policy will become a legal basis for Us in case any inconveniences occur. We need certain types of information, which will be sufficient and in line with the Terms of Service.

CHILDREN’S PRIVACY

Our Service does not address anyone under the age of 18 without a parent/guardian consent.

We do not knowingly collect information from children under the age of 16 and discourage the use of Prohood by users under this age (enjoy childhood, study interesting school subjects, you’ll have enough of profession-related learning in the future).

If you are under the age of 18 but not less than the age of 16, most likely, you will need to ask your parent/legal guardian to set up an account on Prohood that you may use under their supervision (in some circumstances you may have a legal capacity to enter into contracts of this nature starting from the age of 16. If this is the case, we do not need to rely on a parent’s or guardian’s consent as a legal basis for processing your information).

If You are a parent or guardian

To authorize your child to use Prohood, You must send to Us an email with an attached signed PDF consent letter. If You are aware that your child has provided Us with Personal Data, please contact Us. If We become aware that We have collected Personal Data from anyone under the age of 18 without verification of parental/guardian consent, We take steps to remove that information.

PROHOOD LEGAL BASES FOR COLLECTING AND PROCESSING YOUR DATA

Prohood processes your personal data only when we have lawful bases. Specifically, Prohood processes your personal data if:

  • processing is based on the consent you have given. As such our newsletters, collection, analysis and publication of user feedback and reviews, your participation in our events, webinars, beta tests, and placement of different types of cookies is based on your consent;
  • processing is necessary to provide our services to you according to our Terms of Service which constitute a contract between you and us as regards to information services of Prohood;
  • processing is necessary for the purposes of our legitimate interests. Those legitimate interests may include but are not limited to:
    • the assessment of Prohood’s business efficiency by analyzing the Site’s traffic and financial performance indicators;
    • promotion of Prohood through social media networks, affiliates, such as bloggers or influencers; this in particular concerns the right of Prohood to use the user’s name, blurred profile picture and other details for promotional purposes pursuant to the Terms of Service;
    • performance of the contracts with Prohood business customers (Recruiters);
    • user session control and fraud prevention, ensuring the appropriate protection of personal data;
    • Recruiter verification;
  • where necessary, compliance with applicable legislation (e.g., data subject request processing, verification of a consent letter from a parent/guardian);
  • in exceptional cases, to protect your vital interests or vital interests of another natural person; or for the performance of a task carried out in the public interest.

TYPES OF INFORMATION WE COLLECT

Limited use of the Site is always possible without the necessity to register an account. In this case we do not collect your first name and email address unless you contact Us.

Personal Data

If you choose to register an account with us, at a minimum, you will need to provide us with the following personal details:

  • First name
  • Email address

Without creating an account you will not be able to use all of our Services.

Usage Data

Some Usage Data is collected automatically when using the Site. It’s a part of regular browser communications over the internet and you can not limit the collection of it. For example, Your Device’s IP address, browser type and version, the pages of our Site that You visit, the time and date of Your visit.

Detailed usage data is collected only with your consent to the statistics cookies (consult the “Cookies” clause). It includes but is not limited to unique device identifiers, operating system version, browser language, screen resolution.

Cookies

We use Cookies (identifiers), small text files placed on Your Device. Some of them we must use, another are optional but help us improve our services.

Cookies can be “Persistent” or “Session” Cookies. Persistent Cookies remain on Your personal computer or mobile device when You go offline, while Session Cookies are deleted as soon as You close Your web browser.

We use both Session and Persistent Cookies for the purposes set out below:

  • Necessary CookiesType: Session CookiesAdministered by: UsPurpose: These Cookies are essential to provide You with services available through the Website and to enable You to use some of its features. They help to authenticate users and prevent fraudulent use of user accounts. Without these Cookies, the services that You have asked for cannot be provided, and We only use these Cookies to provide You with those services. You can not opt out of them.
  • Cookies Policy / Notice Acceptance CookiesType: Persistent CookiesAdministered by: UsPurpose: These Cookies identify if users have accepted the use of certain types of cookies on the Website. You can not opt out of them.
  • Functionality Preferences CookiesType: Persistent CookiesAdministered by: UsPurpose: These Cookies allow us to remember choices You make when You use the Website, such as remembering your dark/light theme preference. The purpose of these Cookies is to provide You with a more personal experience and to avoid You having to re-enter your preferences every time You use the Website.
  • Statistics Cookies Type: Persistent Cookies Administered by: Us ****Purpose: These cookies collect information that can help us understand how our websites are being used. This information can also be used to measure effectiveness in our marketing campaigns. You can opt out of them but we use a privacy-respecting analytics tool called “Matomo” and these cookies will help us improve the user experience of the Site and prevent wasting money by investing in the wrong marketing channels that bring few or no users.
  • We do not use advertising cookies.

You can always change your cookies preferences by clicking on the following link:

🍪 My Cookie Preferences

DATA OPTIMIZATION AND PERSONAL INFORMATION RENEWAL

The personal information that we collect and store can be accessed by the users and changed when needed. You can do the following to optimize and add new details to Your existing data:

  • Make changes in Your personal information;
  • Delete Your personal information or partially extend it;
  • Contact our Support Team in case if you need help;
  • Subscribe and unsubscribe from Our email notifications.

Note that in case If You unsubscribe from Our marketing offers sent via email, You will still be able to communicate with Our Management for marketing unrelated informational purposes.

PERSONAL INFORMATION USE AND DISCLOSURE

We do not use Your personal information for any other purposes except for the ones mentioned in this section. We do not SELL Your data to third-party companies or people.

We use your personal data to:

  • provide access to our platform and services;
  • process payments and manage subscriptions;
  • improve user experience and effectiveness of our marketing-related work through analytics and tracking*;
  • ensure security and prevent fraud;
  • provide customer support and communication;
  • enable referral programs and marketing campaigns;
  • allow users to request data correction, export and deletion.

*We may scan your data with the analytics tools to find out how to cost-effectively attract new users to the Prohood platform and improve its usability, and not to track individual Users.

Your information might be SHARED with 3rd party Service Providers

We may employ third party companies and individuals to facilitate our Service (“Service Providers”), provide Service on our behalf, perform Service-related services or assist us in analysing how our Service is used. These third parties have access to your Personal Data only to perform these tasks on our behalf and are obligated not to disclose or use it for any other purpose.

Categories of Service Providers that we use and that have access to your Personal Data:

  • email marketing provider;
  • email forwarding service provider;
  • network services provider (e.g. DNS, web application firewall);
  • payment processors.

Note that our Analytics tool provider (Matomo) does not have access to your data because we self-host their platform on our own server. This ensures complete control over data we collect from you and how it is used.

Transfer of Your Personal Data

Your information, including Personal Data, is stored on a rented virtual private server in Switzerland and might be stored and processed in any other location where the parties involved in the processing are located. It means that this information may be transferred to — and maintained on — computers located outside of Your state, province, country or other governmental jurisdiction where the data protection laws may differ than those from Your jurisdiction.

Moderation of user-generated content and recruiter verification are core parts of our service. By creating an account and using our platform, you acknowledge that personal data necessary for moderation and recruiter verification may be processed by our team, including those located in Ukraine.

Transfer of Backups

To ensure the continuity and security of our services, we create regular backups of the site. Some backups include personal information such as your name, email address and other data you provide. Backups may be transferred to and stored in Ukraine, where our operational team is located. The ones that include personal data are encrypted before they are sent to Ukraine. By using our services and agreeing to these Terms, you explicitly consent to this transfer. If you do not agree, don’t create an account. If you want to withdraw your consent for the transfer of backups, delete your account. Your data might not disappear from our systems instantly, please consult the “Storage Time” section to learn more.

Note that Ukraine is still a “non-adequate country” under GDPR. It is in the process of bringing its data protection legislation into compliance with the General Data Protection Regulation. In that respect, a draft Law on Personal Data Protection was registered with the Parliament on 25 October 2022 (“Draft Law № 8153”). It has not been adopted yet, but it is likely to be adopted soon. However, we do not need to wait for a data protection law to force us to responsibly handle your personal data. In particular, we’ve implemented many security measures, consult the “SECURITY AND PRIVACY” section of our Terms of Service to learn more. When it comes to the transfers of backups that contain personal data, backup archives are encrypted and only then are sent via the secure SFTP protocol to Vitalii’s personal devices. Nobody in Ukraine can decrypt them because the decryption key is stored on the server in Switzerland.

We will take all steps reasonably necessary to ensure that Your data is treated securely and in accordance with this Privacy Policy and no transfer of Your Personal Data will take place to an organization or a country unless there are adequate controls in place including the security of Your data and other personal information.

PERSONAL INFORMATION PROTECTION

Consult the “SECURITY AND PRIVACY” section of our Terms of Service to learn more about security measures We have taken. Remember that We are not responsible for the breaches of security caused by Your irresponsible actions or Our service providers.

STORAGE TIME

We only store personal data for as long as is necessary to fulfill the purposes pursued. In some cases, the legislator provides for the storage of personal data, for example in tax or commercial law. In these cases, the data will only be stored by Us for these legal purposes but will not be processed in any other way and deleted after expiry of the legal retention period.

Retention time for backups

The maximum retention time for backups that include personal data is 6 months.

Retention time for detailed usage data

Detailed usage data is collected by statistics cookies. Upon withdrawal of your consent for them, the data will be kept on our server for 6 months at maximum.

Prohood Public Beta Test accounts

If you decide to participate in the Prohood Public Beta Test, you need to create an account. Also, by doing that you agree to be added to an email list so we can notify you when the test begins.

All created accounts will remain active after the completion of the test. To delete all of your data, go to Account — Delete Account.

YOUR RIGHTS AS A DATA SUBJECT

According to the applicable laws, you have various rights regarding your personal data. If you wish to assert these rights, please send your request by email to the address specified in the section on the bottom of this Policy, clearly identifying yourself.

Right to acknowledgement and access

You have the right to receive confirmation from Us at any time as to whether personal data relating to you will be processed. If this is the case, you have the right to request from us free of charge information about the personal data stored about you together with a copy of this data. You can download your data by going to Account — Privacy— Request Data.

If personal data are transferred to a third country or an international organization, you have the right to be informed of the appropriate guarantees in accordance with GDPR protection laws in connection with the transfer.

Right to correction

You have the right to request Us to correct any inaccurate personal data concerning you without delay.

Right for cancellation (“Right for oblivion”)

As a pursuant under GDPR protection laws, you have the right to demand that we delete personal data concerning you without delay, and we are obliged to delete personal data without delay if one of the following reasons applies:

  1. personal data are no longer necessary for the purposes for which they were collected or otherwise processed.
  2. you file an objection to the processing pursuant to GDPR protection laws, and there are no overriding legitimate grounds for the processing, or you file an objection to the processing pursuant under conditions of GDPR protection laws.
  3. you withdraw your consent, on which the processing was based pursuant according to GDPR protection laws, and there is no other legal basis for the processing.
  4. the deletion of personal data is necessary to fulfill a legal obligation under Union law or the law of the Member States to which we are subject.

Right to limitation of processing

You have the right to request Us to restrict processing if one of the following conditions is met:

  1. you dispute the accuracy of your personal data for a period of time that enables us to verify the accuracy of your personal data;
  2. the processing is unlawful, and you have refused to delete the personal data and have instead requested the restriction of the use of the personal data;
  3. We no longer need the personal data for the purposes of processing, but you do need the data to assert, exercise or defend legal claims, or
  4. you have filed an objection against the processing pursuant according to GDPR data protection laws, as long as it is not yet clear whether the justified reasons of our company outweigh yours.

Right to Transferability of Data

You have the right to receive the personal data concerning you that you have provided to us in a structured, current and machine-readable format, and you have the right to transmit this data to another person in charge without our interference, provided that:

  1. processing is based on consent or on a contract pursuant according to conditions of GDPR protection laws, and
  2. processing is carried out using automated methods. When exercising your right to data transferability in accordance with paragraph 1, you have the right to request that the personal data be transferred directly by us to another person responsible, insofar as this is technically feasible.

Right of objection

You have the right to object at any time, for reasons arising from your particular situation, to the processing of personal data concerning you on the basis of GDPR protection laws; this also applies to profiling based on these provisions. We no longer process personal data unless we can prove compelling grounds for processing that outweigh your interests, rights and freedoms, or the processing serves to assert, exercise or defend legal claims.

If We process personal data for direct marketing purposes, you have the right to object at any time to the processing of personal data concerning you for such purpose.

You have the right to object to the processing of personal data concerning you, for scientific or historical research purposes or for statistical purposes in accordance with GDPR protection laws, for reasons arising from your particular situation, unless the processing is necessary to fulfill a task in the public interest.

Automated decisions including profiling

You have the right not to be subject to a decision based exclusively on automated processing – including profiling – that has legal effect against you or significantly impairs you in a similar manner. An automated decision making based on the collected personal data does not take place.

Right to revoke consent under data protection law

You have the right to revoke your consent to the processing of personal data at any time.

Right of appeal to a supervisory authority

You have the right of appeal to a supervisory authority.

In particular, if you have EU/EEA residentship, and have a concern about our practices concerning the processing of Personal Data that we are not able to resolve, you have the right to lodge a complaint with the data protection authority where you reside or in which you work, or in which the alleged infringement occurred, each as applicable, or by contacting the authority for such issues, at https://edpb.europa.eu/about-edpb/about-edpb/members_en.

DATA BREACH NOTIFICATION

In the event of a data breach that poses a risk to user rights and freedoms, we will:

  • notify affected users not later than 72 hours after having become aware of it;
  • inform relevant regulatory authorities, if required;
  • provide details on the breach and mitigation measures;
  • take immediate action to minimize any further risks and secure our systems.

LINKES TO OTHER SITES

Our Service may contain links to other sites that are not operated by us. If you click a third party link, you will be directed to that third party’s site. We strongly advise you to review the Privacy Policy of every site you visit.

We have no control over and assume no responsibility for the content, privacy policies or practices of any third party sites or services.

PRIVACY POLICY POSSIBLE CHANGES

We reserve the right to change the Privacy Policy section and add more information to it. We are not obliged to notify the Users about the changes applied to the current Privacy Policy. It means that the Users are to check this section for themselves to find out more about the way their personal information is protected.

CONTACT US

To contact Us regarding this Privacy Policy or other related Privacy issues, please write to [email protected].