FYLLED PRIVACY POLICY

1. INTRODUCTION

FULFYLLED STAFFING SOLUTIONS LIMITED its Nominees, Affiliates or Associated Entities(“Company,” “we,” “us,” or “our”) operates FYLLED (the “Platform”), an online platform that connects individuals seeking employment, work, contracts, assignments, or other professional opportunities with employers, recruiters, businesses, organizations, and other persons seeking workers or professional services.

This Privacy Policy explains how we collect, use, store, protect, disclose, and otherwise process personal information when you:

visit or use our website;
create an account;
register as a job seeker, worker, employer, recruiter, or other user;
create or upload a profile, résumé, CV, portfolio, application, or other professional information;
search or apply for employment or work opportunities;
post or advertise employment or work opportunities;
communicate with other users or with us;
purchase subscriptions, memberships, products, or services;
make or receive payments through the Platform;
participate in surveys, promotions, events, or other Platform activities; or
otherwise interact with us.

This Privacy Policy applies to all users of the Platform, including free users, paid subscribers, job seekers, workers, employers, recruiters, organizations, and other visitors.

By using the Platform, you acknowledge that you have read this Privacy Policy. Where applicable law requires consent, we will obtain your consent before processing your personal information on the basis of consent.

2. OUR COMMITMENT TO PRIVACY

We recognize that your personal information is important.

We are committed to processing personal information fairly, lawfully, transparently, securely, and only for legitimate purposes.

Where Jamaican law applies, we intend to process personal information in accordance with the Jamaica Data Protection Act, 2020 and applicable regulations and requirements.

We seek to ensure that personal information is:

processed fairly and lawfully;
collected for specified and legitimate purposes;
limited to information reasonably necessary for those purposes;
accurate and kept up to date where necessary;
retained only for as long as reasonably necessary;
processed in accordance with applicable data-subject rights;
protected through appropriate technical and organizational safeguards; and
transferred internationally only in accordance with applicable legal requirements.

3. WHO IS RESPONSIBLE FOR YOUR PERSONAL INFORMATION?

The data controller responsible for personal information processed through the Platform is:

Legal Name: FULFYLLED STAFFING SOLUTIONS LIMITED Trading Name: FYLLED Address: Aboukir, Cave Valley PO, St. Ann Email: fylledofficial@gmail.com Telephone: 876-331-6714

Where we appoint a Data Protection Officer or other privacy representative, their contact details will be published here:

Data Protection Officer: Kemesha Johnson Email: kemesha.johnson10@gmail.com

4. INFORMATION WE COLLECT

Depending on how you use the Platform, we may collect different categories of information.

4.1 Identity Information

This may include:

full name;
date of birth or age, where necessary;
gender, where voluntarily provided and relevant;
photograph or profile image;
username;
account identification information;
government-issued identification information where legitimately required; and
other information necessary to verify identity.

We will not request government identification unless there is a legitimate reason for doing so.

4.2 Contact Information

We may collect:

email address;
telephone/mobile number;
mailing address;
residential address;
business address;
emergency or alternative contact information where legitimately required; and
communication preferences.

4.3 Employment and Professional Information

For job seekers and workers, this may include:

résumé/CV;
education;
qualifications;
professional certifications;
licenses;
employment history;
job titles;
skills;
professional experience;
work preferences;
availability;
desired compensation;
preferred work location;
remote-work preferences;
references;
portfolios;
professional profiles;
languages;
professional memberships;
work samples; and
information contained in applications submitted through the Platform.

For employers and recruiters, this may include:

company name;
business information;
industry;
company address;
authorized representative information;
job descriptions;
hiring requirements;
recruitment information; and
information necessary to verify an employer or recruitment account.

5. SENSITIVE PERSONAL INFORMATION

Some information may be considered sensitive personal information under applicable law.

Depending on the services offered by the Platform, this could include information relating to matters such as:

health or disability;
biometric information;
racial or ethnic origin;
religious beliefs;
political opinions;
criminal convictions;
government identification;
financial information; or
other categories recognized as sensitive under applicable law.

We will seek to avoid collecting sensitive information unless it is reasonably necessary for a legitimate purpose and permitted by applicable law.

Where applicable law requires a higher level of protection or explicit consent, we will apply the appropriate safeguards.

Users should not upload sensitive personal information to their public profile unless the Platform specifically requests or permits such information for a legitimate purpose.

6. INFORMATION ABOUT JOB SEEKERS AND WORKERS

If you register as a job seeker or worker, we may process your information to:

create and maintain your professional profile;
identify potentially relevant employment opportunities;
match you with employers or opportunities;
allow employers or recruiters to review information you make available;
process job applications;
communicate with you regarding opportunities;
provide career-related services;
improve matching and search functionality;
provide paid employment-related services; and
administer your account.

You understand that the principal purpose of an employment-matching platform is to facilitate connections between workers and organizations seeking workers.

Accordingly, information that you choose to make available to employers or recruiters may be disclosed to those parties for legitimate recruitment and employment-related purposes.

7. INFORMATION ABOUT EMPLOYERS AND RECRUITERS

If you register as an employer, recruiter, agency, organisation, or other opportunity provider, we may process your information to:

establish and verify your account;
publish job opportunities;
identify suitable workers;
communicate with applicants;
facilitate recruitment;
process payments;
provide recruitment-related services;
prevent fraud or misuse;
administer subscriptions; and
maintain the security and integrity of the Platform.

8. INFORMATION COLLECTED AUTOMATICALLY

When you access or use the Platform, we may automatically collect certain technical information, including:

IP address;
browser type;
device type;
operating system;
device identifiers;
approximate location derived from technical information;
pages visited;
links clicked;
search activity;
date and time of access;
referring website;
session information;
error logs;
interaction with Platform features; and
other technical or usage information.

We use this information to operate, secure, analyze, maintain, and improve the Platform.

9. COOKIES AND SIMILAR TECHNOLOGIES

We may use cookies, pixels, tags, local storage, analytics tools, and similar technologies.

These technologies may help us:

keep you signed in;
remember preferences;
understand how users interact with the Platform;
measure website performance;
prevent fraud;
improve functionality;
personalize certain features; and
understand the effectiveness of marketing.

Where required by applicable law, we will obtain consent before using non-essential cookies or similar technologies.

You may be able to control cookies through your browser or device settings. Disabling certain cookies may affect Platform functionality.

10. HOW WE USE PERSONAL INFORMATION

We may use personal information for the following purposes:

A. Providing the Platform

To:

create accounts;
provide job-matching services;
facilitate applications;
publish job opportunities;
facilitate communications;
provide subscriptions and other services; and
administer user accounts.

B. Matching Users

We may use information such as skills, qualifications, experience, location, availability, work preferences, and job requirements to identify potentially relevant matches.

C. Payments

We may process information necessary to:

purchase subscriptions;
process payments;
issue invoices;
process refunds;
prevent payment fraud; and
maintain financial records.

Payment card information may be processed by third-party payment processors rather than being stored directly by us.

D. Communications

We may send:

account notifications;
service announcements;
security alerts;
application notifications;
job opportunity notifications;
subscription information;
customer service communications; and
marketing communications where permitted by law.

E. Security and Fraud Prevention

We may process information to:

detect fraudulent activity;
prevent abuse;
investigate suspicious activity;
protect accounts;
enforce our Terms of Service; and
protect users and the Platform.

F. Legal Compliance

We may process and disclose information where necessary to comply with:

applicable laws;
regulations;
court orders;
lawful governmental requests;
regulatory requirements; and
legal proceedings.

G. Improving Our Services

We may analyze aggregated or appropriately de-identified information to:

improve matching;
develop new services;
analyze Platform usage;
identify technical problems; and
improve user experience.

11. LEGAL BASES FOR PROCESSING

Depending on the circumstances and applicable law, we may process personal information on one or more of the following grounds:

your consent;
performance of a contract with you;
taking steps at your request before entering into a contract;
compliance with a legal obligation;
protection of your vital interests;
legitimate interests, where permitted by law; or
any other lawful basis recognized by applicable law.

Where we rely on consent, you may withdraw that consent subject to applicable legal limitations and circumstances in which processing may continue on another lawful basis.

12. JOB MATCHING AND AUTOMATED PROCESSING

The Platform may use automated tools, algorithms, search functions, ranking systems, artificial intelligence, machine-learning systems, or other technologies to assist with:

identifying potential job matches;
ranking or filtering opportunities;
identifying potentially relevant candidates;
recommending employment opportunities;
improving search results; and
detecting fraud or misuse.

Automated matching does not necessarily mean that an employment decision is made solely by automated means.

Where applicable law provides you with rights relating to solely automated decision-making, profiling, or similar processing, we will provide the rights and safeguards required by law.

13. WHO MAY RECEIVE YOUR INFORMATION?

We may disclose personal information to appropriate recipients where necessary for the purposes described in this Privacy Policy.

These may include:

Employers and Recruiters

Information that a worker chooses to make available through the Platform may be disclosed to employers, recruiters, or other legitimate opportunity providers.

Workers and Applicants

Information relating to employers and job opportunities may be made available to workers or applicants as necessary to facilitate recruitment.

Service Providers

We may use third-party providers for:

hosting;
cloud storage;
payment processing;
email;
SMS;
customer support;
analytics;
cybersecurity;
identity verification;
fraud prevention;
communications;
software;
data processing; and
other technology services.

These providers may process information only as necessary to provide services to us and subject to appropriate contractual and legal safeguards.

Professional Advisers

We may disclose information to:

lawyers;
accountants;
auditors;
insurers;
consultants; and
other professional advisers.

Government and Regulatory Authorities

We may disclose information where required or permitted by law.

Corporate Transactions

If the Company is involved in a merger, acquisition, restructuring, financing, sale of assets, bankruptcy, or similar transaction, personal information may be transferred as part of that transaction, subject to applicable law.

14. WE DO NOT SELL PERSONAL INFORMATION

We do not sell personal information to third parties for money.

We may, however, disclose information to employers, recruiters, service providers, partners, or other recipients where reasonably necessary to provide the Platform or where permitted by applicable law.

Where a particular activity involves disclosure for direct marketing or another purpose requiring consent, we will obtain the required consent.

15. DIRECT MARKETING

We may send you information about our services, promotions, subscriptions, events, employment-related services, or other offerings where permitted by law.

You may unsubscribe from marketing communications by:

using the unsubscribe mechanism in the communication;
changing your account preferences; or
contacting us at [INSERT PRIVACY EMAIL].

You may continue to receive essential service communications after unsubscribing from marketing.

16. INFORMATION SHARING BETWEEN USERS

The Platform is designed to facilitate interaction between people seeking work and organizations seeking workers.

Therefore, certain information may be visible to other users depending on:

your account type;
your privacy settings;
the service you use;
whether you apply for an opportunity;
whether an employer or recruiter accesses your profile; and
the particular features of the Platform.

You should carefully consider what information you include in a public or searchable profile.

You should not publish passwords, bank account credentials, payment card numbers, government identification numbers, or other highly sensitive information in publicly accessible areas.

17. THIRD-PARTY SERVICES AND WEBSITES

The Platform may contain links to third-party websites, applications, payment services, recruitment services, social media platforms, or other external services.

We are not responsible for the privacy practices of third parties that operate independently from us.

We encourage you to review the privacy policies of third-party services before providing them with personal information.

18. INTERNATIONAL DATA TRANSFERS

Because our Platform may use service providers and technology infrastructure located outside Jamaica, your personal information may be processed or stored in countries other than Jamaica.

Where personal information is transferred outside Jamaica, we will take reasonable steps to ensure that the transfer complies with applicable Jamaican data-protection requirements and that appropriate safeguards are in place.

Where applicable, we may use contractual, technical, organizational, or other legally recognized safeguards.

19. DATA SECURITY

We take reasonable technical and organizational measures designed to protect personal information against:

unauthorized access;
unauthorized disclosure;
alteration;
destruction;
accidental loss;
misuse; and
other unlawful processing.

Security measures may include:

access controls;
authentication;
encryption where appropriate;
secure hosting;
monitoring;
backups;
employee confidentiality obligations;
security testing;
incident response procedures; and
other appropriate technical and organizational measures.

However, no internet-based system can be guaranteed to be completely secure.

You are responsible for protecting your account credentials and should immediately notify us if you believe your account has been compromised.

20. DATA BREACHES

If we become aware of a personal-data breach or other security incident affecting personal information, we will investigate and take appropriate steps to contain, mitigate, remediate, and report the incident as required by applicable law.

Where required, we will notify the Information Commissioner and affected data subjects within the applicable legal timeframe.

21. HOW LONG WE KEEP YOUR INFORMATION

We retain personal information only for as long as reasonably necessary for the purposes for which it was collected, unless a longer retention period is required or permitted by law.

The applicable retention period may depend upon:

the type of information;
the purpose for which it was collected;
whether your account remains active;
contractual obligations;
legal requirements;
tax and accounting requirements;
dispute resolution;
fraud prevention;
security requirements; and
legitimate business requirements.

When information is no longer required, we will take reasonable steps to securely delete, destroy, anonymize, or otherwise dispose of it in accordance with applicable law.

22. ACCOUNT CLOSURE

You may request closure or deletion of your account by contacting us at:

fylledofficial@gmail.com

Closing your account may not result in immediate deletion of all information.

We may retain certain information where necessary to:

comply with legal obligations;
resolve disputes;
enforce agreements;
prevent fraud;
maintain security;
complete financial records; or
comply with other lawful requirements.

23. YOUR PRIVACY RIGHTS

Subject to applicable law and any lawful limitations, you may have rights including:

the right to be informed about the processing of your personal information;
the right to access your personal information;
the right to request correction or rectification of inaccurate information;
the right to request deletion or erasure in appropriate circumstances;
the right to withdraw consent where processing is based on consent;
the right to object to certain processing;
the right to restrict certain processing;
rights relating to direct marketing;
rights relating to certain automated decision-making;
rights relating to transfer of personal information to another data controller where applicable; and
the right to complain to the relevant regulatory authority.

These rights are not absolute and may be subject to exceptions and limitations under applicable law.

24. HOW TO EXERCISE YOUR RIGHTS

To exercise a privacy right, contact us at:

Privacy Email: fylledofficial@gmail.com

Your request should include sufficient information for us to identify you and understand the nature of your request.

We may take reasonable steps to verify your identity before responding to certain requests.

We will respond within the period required by applicable law.

25. COMPLAINTS

If you have concerns about how we process your personal information, we encourage you to contact us first so that we can investigate and attempt to resolve the matter.

Privacy Complaints: fylledofficial@gmail.com

You may also have the right to make a complaint to the Office of the Information Commissioner in Jamaica or another competent regulatory authority, depending on the circumstances.

The Jamaican Office of the Information Commissioner recognizes data-subject rights including the right to be informed, access personal information, request correction, and exercise other rights under the Data Protection Act. (Office of the Information Commissioner⁠)

26. CHILDREN’S PRIVACY

The Platform is intended for persons who are legally capable of entering into the relevant agreements and using employment or professional services.

We do not knowingly collect personal information from children in circumstances where such collection is prohibited by law.

If you believe that a child has provided personal information to us in circumstances where we should not have collected it, please contact us at [INSERT PRIVACY EMAIL].

27. EMPLOYMENT APPLICATIONS

When you apply for a job through the Platform, information contained in your application may be shared with the relevant employer, recruiter, or opportunity provider for recruitment purposes.

Once information has been provided to an employer or recruiter, that organization may process the information under its own privacy policies and legal obligations.

We are not responsible for the independent processing practices of an employer or recruiter acting as a separate data controller.

28. EMPLOYER RESPONSIBILITIES

Employers, recruiters, agencies, and other opportunity providers using the Platform are responsible for ensuring that their collection and use of candidate information complies with applicable privacy, employment, anti-discrimination, and other laws.

Employers must not use information obtained through the Platform for unlawful discrimination, harassment, fraud, identity theft, or any other unlawful purpose.

29. USER RESPONSIBILITIES

You agree to provide information that is accurate and not misleading.

You should promptly update your account when material information changes.

You should not upload or disclose another person’s personal information unless you have a lawful basis and appropriate authority to do so.

You should also protect your login credentials and notify us promptly of suspected unauthorized access.

30. AGGREGATED AND DE-IDENTIFIED INFORMATION

We may create aggregated, statistical, or de-identified information from information collected through the Platform.

Where permitted by law, we may use such information to:

analyze employment trends;
improve matching;
develop products and services;
measure Platform performance;
conduct research;
produce reports; and
understand general user behavior.

We will take reasonable measures designed to prevent such information from being used to identify an individual where it has been de-identified.

31. DATA PROTECTION IMPACT ASSESSMENTS

Where required by applicable law, we may conduct Data Protection Impact Assessments in relation to processing activities that present heightened privacy risks.

This may include processing involving:

large-scale personal information;
sensitive personal information;
automated decision-making;
profiling;
new technologies; or
other processing activities presenting significant risks to individuals.

32. PRIVACY BY DESIGN

We seek to incorporate privacy and data-protection considerations into the design and development of our Platform.

This may include:

limiting the information collected;
restricting access;
applying appropriate security controls;
using privacy-enhancing technologies;
reviewing third-party providers; and
regularly assessing our data-processing practices.

33. CHANGES TO THIS PRIVACY POLICY

We may update this Privacy Policy from time to time.

When we make changes, we may:

update the “Last Updated” date;
post the revised Privacy Policy on the Platform;
provide an account notification;
send an email notice; or
take another step required by applicable law.

Your continued use of the Platform following an effective update may be subject to the revised Privacy Policy, except where applicable law requires your specific consent.

34. CONTACT US

If you have questions, concerns, requests, or complaints relating to this Privacy Policy or our processing of personal information, please contact:

FULFYLLED STAFFING SOLUTIONS LIMITED

Address: Aboukir, Cave Valley PO, St. Ann

Privacy Email: fylledofficial@gmail.com

Telephone: 876-331-6714

Data Protection Officer: Kemesha Johnson

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35. ACKNOWLEDGEMENT

By creating an account or using the Platform, you acknowledge that you have had an opportunity to read this Privacy Policy.

Where applicable law requires consent to a particular processing activity, we will request that consent separately and will not treat your general acceptance of this Privacy Policy as consent to processing that requires separate consent.

Effective Date: 23/09/2026

Last Updated: 22/09/2026