Privacy Policy

Introduction

At Wirbi S.A.C. (“Wirbi”, “we”), we are committed to protecting your personal data in accordance with the EU General Data Protection Regulation (GDPR). This Policy explains how we collect, use, share, and safeguard personal data.

By using our services or providing personal data, you acknowledge this Policy and the processing described herein.

1. Information We Collect

1.1 Information you provide directly

• Contact details: full name, email, phone number, postal address
• Professional information: CV, work experience, technical skills, certifications
• Company information: legal name, tax ID, billing/registered address
• Payment information: details required to process transactions

1.2 Information collected automatically

• IP address and approximate geolocation
• Browser and device information
• Pages visited and time spent
• Access date and time

1.3 Information from third parties

We may receive information from third parties such as professional references, job platforms, or professional social networks.

2. Purposes and Legal Bases

We process personal data for the following purposes and legal bases:

• To provide staff augmentation, recruitment, and software development services (performance of a contract or steps prior to entering into a contract)
• To assess candidates for job opportunities (legitimate interests and/or contractual necessity)
• To communicate with you about our services (legitimate interests; consent where required)
• To process payments and manage invoicing (contract/legal obligation)
• To comply with legal and contractual obligations (legal obligation)
• To improve our services and user experience (legitimate interests)
• To send marketing communications (consent; you may withdraw at any time)
• To prevent fraud and ensure security (legitimate interests)

3. Sharing Personal Data

3.1 Clients and business partners

For recruitment and staff augmentation, we may share relevant candidate data with client organisations.

3.2 Service providers (processors)

We engage trusted providers (e.g., hosting, analytics, communications) under written data processing agreements and confidentiality.

3.3 Legal and regulatory

We may disclose data where required by applicable law, regulation, or legal process, or to protect our rights.

4. Data Security

We implement appropriate technical and organisational measures to protect personal data against unauthorised access, loss, or alteration, proportionate to risk.

Measures include:

• Encryption in transit and at rest
• Role-based access controls
• Continuous security monitoring
• Regular staff training on data protection
• Periodic audits and testing

5. Your GDPR Rights

Subject to conditions and applicable law, you have the right to:

• Access your personal data
• Rectify inaccurate or incomplete data
• Request erasure (right to be forgotten)
• Restrict processing
• Object to processing (including for direct marketing)
• Data portability (receive your data in a structured, commonly used, machine-readable format)
• Withdraw consent at any time without affecting prior processing

To exercise your rights, contact: privacy@wirbi.com. We will respond within one month, extendable where permitted by GDPR.

6. Cookies and Similar Technologies

We use cookies and similar technologies to:

• Remember user preferences
• Analyse website usage and performance
• Personalise content and advertising
• Enhance security

You can manage cookie preferences via your browser settings and, where available, our cookie banner.

7. Data Retention

We retain personal data only for as long as necessary for the purposes described, or as required by law. We delete or anonymise data when no longer needed.

Criteria considered:

• Duration of our relationship with you
• Legal/regulatory requirements
• Applicable limitation periods
• Business and record-keeping needs

8. International Data Transfers

Where personal data is transferred outside the EEA/UK, we ensure adequate protection through mechanisms such as adequacy decisions, Standard Contractual Clauses (SCCs), or Binding Corporate Rules, as appropriate.

9. Children

Our services are not directed to individuals under 18. Where consent is relied upon, Member States may set the age of digital consent between 13 and 16; we do not knowingly process children’s data. If we become aware, we will erase it promptly.

10. Changes to this Policy

We may update this Policy to reflect legal or operational changes. We will post the updated version with a new “Last updated” date.

If you have any questions, comments, or concerns about this Privacy Policy or our privacy practices, please contact: