Last Updated: 17-Aug-2023
Depending on Data Subject category and country of residence this Policy may from time to time be supplemented by additional policies issued by us and other parties which will be notified to you separately. For example, Personal Data about Employees and Contractors hired by any of our local legal entities can be co-controlled by these local entities and, where required by law, an additional policy will be notified to you in case the local entities engage in Personal Data processing not covered in this Policy.
We commit ourselves to the highest standard for data protection and privacy. Due to our global footprint, we are subject to several data protection regulations and as a guiding principle, we apply the strictest regulation to protect your data and privacy globally. This results in a broad set of rights and choices made available to you.
The terms “Personal Data”, “Data Processing”, “Data Subject”, “Data Controller” and “Data Processor” have the same meaning as under Regulation (EU) 2016/679 - the General Data Protection Regulation (“GDPR”).
THE PERSONAL DATA, PERSONAL INFORMATION, SENSITIVE PERSONAL INFORMATION WE COLLECT
Sensitive personal information is a specific subset of personal information that includes certain government identifiers (such as social security numbers); an account log-in, financial account, debit card, or credit card number with any required security code, password, or credentials allowing access to an account; precise geolocation; contents of mail, email, and text messages; genetic data; biometric information processed to identify a consumer; information concerning a consumer’s health, sex life, or sexual orientation; or information about racial or ethnic origin, religious or philosophical beliefs, or union membership.
Personal Data means any information relating to an identified or identifiable natural person (‘data subject’); an identifiable natural person is one who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person.
We collect and maintain different types of personal data/information that you provide to us on a voluntary basis. This may include:
- Contact information that facilitates communication - contact and identification information, such as your real name, alias, unique personal identifier, postal address, telephone number, email address, signature or other similar identifiers, and client / employment information;
- Location information - IP address, postal address
- internet or other electronic network activity information, including, but not limited to, information regarding your interaction with the Site;
- product and service related information concerning the products and services that we provide to you or programs that we offer;
- Identifying information - any other information that identifies, relates to, describes, is capable of being associated with, or could reasonably be linked, directly or indirectly, with you or your household - Depending on the Data Subject - Name, government-issued ID, profile picture, birthdate;
- Financial Information that identifies an individual’s financial account or about an individual’s remuneration - for parties with whom we do business, credit, and financial information such as your payment methods and preferences, and billing and credit history, where applicable, bank accounts, salary benefits;
- business relationship information, including information related to your agreements, preferences, advisors and decision-makers, feed-back and information requested by or provided to you;
- Professional information about educational or professional career – Role
- Emergency contact information - Name, surname and contact details of emergency contact
- Social information about social status - Marital status and number of dependants
- Special category data – sensitive data such as Biometric data in the form of face scans for our identity verification process (KYB, KYC and KYE), Health data - e.g. disability, pregnancy, absence due to sickness, etc.
If you email us a question or request, we may use your email address to process your request and respond to your question, which may involve collecting any personal information that you choose to provide to us in your email.
We may also collect market-related information, which may include personal information, concerning market trends and activities impacting our business. This information may include contract terms, financial information and other information for the purpose of market analysis, resource planning, financial advisory services and strategic planning. We may also collect information related to our media, investor and public relations activities and information related to our interactions with financial, resource planning, regulatory and other analysts and advisors
THE PERSONAL INFORMATION WE COLLECT FROM THIRD PARTIES
HOW WE COLLECT AND USE PERSONAL DATA / INFORMATION
We collect personal data/information from you when:
- you browse pages of our website
- you receive an email from us
- you select someone to be hired on your behalf
- you engage in a meeting with our team
- you participate in our promoted events
- you create an account in our platform
- you allow our partners to share your data
You give us personal data/information when:
- you participate in our promoted programs or giveaways
- you to subscribe to our blog/mailing list
- you opt-in for marketing messages
- you select someone to be hired on your behalf
- you engage in a meeting with our team
- you participate in our promoted events
- you create an account in our platform
This personal data/information is used to enable us to manage, maintain, and develop our business and operations, including:
- to establish, maintain and manage our relationship with you so that we may provide you with, products and services that have been requested;
- to perform services on behalf of you or your clients, including maintaining or servicing accounts, providing customer service, processing or fulfilling orders and transactions, and processing payments;
- to be able to review the products and services that we provide to you so that we may understand your requirements for our products and services and so that we may work to improve our products and services;
- to administer or otherwise carry out our obligations in relation to any agreement you or your clients have with us;
- to protect us against error, breach of contract, negligence, fraud, theft, illegal activity and damage to our goods and property;
- to alert you to updated information and to share with you transaction updates, other new products and services from us, or third-parties,
- to forward promotional materials to you, where you have consented to receive such information;
- to complete a transaction or service requested by you or your clients;
- to respond to inquiries or requests submitted by you or your clients;
- to ensure the Sites are relevant to your needs;
- to detect security incidents, protecting against malicious, deceptive, fraudulent, or illegal activity, and prosecuting those responsible for that activity;
- to debug to identify and repair errors that impair existing intended functionality;
- to undertake internal research for technological development;
- to help us create and publish content most relevant to you;
- to further any commercial purposes, including any purpose to advance your interests, or provide products, goods, information, or services, or enabling or effecting, directly or indirectly, a commercial transaction;
- to enable us to comply with applicable law or regulatory requirements; and
- any other reasonable purpose in connection with the business and services.
We may use your personal information without your knowledge or consent where we are permitted or required by applicable law or regulatory requirements to do so.
What is “lawful basis”?
Under the GDPR, we need to have a lawful basis to legally process your Personal Data. For the described Data Processing, we rely on the following legal grounds:
- Consent: (Art. 6(1)(a) GDPR) when we rely on this basis we only process Personal Data about you for the specific purposes you expressly authorise. You can withdraw your consent whenever you wish.
- Performance of a contract: (Art. 6(1)(b) GDPR) when we rely on this basis the Data Processing is necessary for the performance of a contract with you or to take steps at your request before entering into such a contract.
- Compliance with a legal obligation: (Art. 6(1)(c) GDPR) when we rely on this basis we are obliged to process the relevant Personal Data to comply with our legal obligations.
- Legitimate interests: (Art. 6(1)(f) GDPR) when we rely on this basis we process Personal Data as necessary in pursuit of our own, our business partners’, or your legitimate interests. When we do this we must ensure that the interests we pursue do not override your fundamental rights and freedoms.
- Substantial public interest: (Art. 9(2)(g) GDPR) when we rely on this basis we do it to prevent harm, fraud, money laundering, terrorist financing, child labour and to enable trust safety and compliance.
Your personal data/information may be used and disclosed:
- as permitted or required by applicable law or regulatory requirements;
- to meet national security or law enforcement requirements.
- to comply with valid legal processes such as search warrants, subpoenas or court orders;
- as part of our regular reporting activities;
- to protect our rights and property;
- where the personal information is publicly available;
- during emergency situations or where necessary to protect the safety of a person or group of persons to investigate fraud, or respond to a government request; or
- for any additional purposes for which we have obtained your consent.
We may disclose your personal data/information without your knowledge or consent where we are permitted or required by applicable law or regulatory requirements to do so.
We may share your personal data/information with our employees, contractors, consultants, affiliates and other parties who require such information to assist us with managing our relationship with you. Additionally, we may share your data/information with service providers in connection with commercial purposes that advance your interests, language and cultural training and other ancillary services as you may have opted for.
When you visit our Site, we may automatically collect website use information, such as information about your operating system, browser type, domain name, your access times, the website that referred you to us, the Web pages you request, and the date and time of those requests. We use this information only to monitor our Site’s performance and improve our Site’s content and structure.
SOCIAL MEDIA WIDGETS
Our Site may include social media features, such as the Facebook Like button, and Widgets, such as the “Share This” button or interactive mini-programs that run on our Site. These features may collect your Internet protocol address, which page you are visiting on our Sites, and may set a cookie to enable the feature to function properly. Social media features and Widgets are either hosted by a third party or hosted directly on our Site. Your interactions with these features are governed by the privacy statement of the company providing it.
CONSENT AND OPT-OUT
It is important to us that we collect, use or disclose your personal data/information where we have your consent to do so. Depending on the sensitivity of the personal data/information, your consent may be implied, deemed (using an opt-out mechanism) or express. Express consent can be given orally, electronically or in writing. Implied consent is consent that can reasonably be inferred from your action or inaction. For example, when you enter into an agreement with us, we will assume your consent to the collection, use and disclosure of your personal information for purposes related to the performance of that agreement and for any other purposes identified at the relevant time.
From time to time, we communicate via email with users who request information. For example, we may use your email address to confirm a request you have made, to send you information about changes to our products and services, and to send notices and other disclosures as required by law. If you do not wish to receive email communications from us, you may change or withdraw your consent at any time by changing your preferences through the user dashboard if you are a registered user or via Contact form if you are not a registered user.
LINKS TO OTHER WEBSITES
Our Sites may offer links to other websites that may be subject to less stringent privacy standards. If you visit one of these linked websites, you are then subject to the privacy policies and other policies of such website and are no longer protected by our policies.
We are not responsible for, or able to monitor or control, the policies and practices of other companies, including with respect to their collection, use or disclosure or your personal information. You should review the privacy policies of these websites before providing them with personal information.
No data transmissions over the Internet can be guaranteed to be 100% secure. Consequently, we cannot ensure or warrant the security of any information you transmit to us and you understand that any information that you transfer to us is done at your own risk.
Once we receive your transmission, we make reasonable efforts to maintain physical, technical and procedural safeguards that are appropriate to the sensitivity of the personal information in question. We use firewalls to protect your information from unauthorized access, disclosure, alteration, or destruction. However, please note that this is not a guarantee that such information may not be accessed, disclosed, altered or destroyed by breach of such firewalls and secure server software, over which breach we may have limited or no control.
In addition, although we obligate third parties who support our Sites and their related offers or other programs to use any personal information only for the purpose of performing their work, we do not control such third parties’ websites or other security measures.
If we learn of a security system breach, we may attempt to notify you electronically so that you can take appropriate protective steps. By using these Sites or providing personal information to us, you agree that we can communicate with you electronically regarding security, privacy and administrative issues relating to your use of these Sites.
We may post a notice on our Sites if a security breach occurs.
We may also send an email to you at the email address you have provided to us in these circumstances.
Depending on where you live, you may have a legal right to receive notice of a security breach in writing.
UPDATING OR ACCESSING YOUR PERSONAL DATA/INFORMATION
Upon request, we will provide you with information about whether we hold any of your personal information. If you wish to obtain access to the personal information that we maintain about you, or to correct, amend, update or delete such information, please raise a request through the user dashboard if you are a registered user or via Contact form if you are not a registered user. Before responding to your request, we may ask you to verify your identity and to provide further details about your request. We will endeavour to respond within an appropriate timeframe and, in any event, within any timeframe required by law.
Your right to access the personal data/information that we hold about you is not absolute. There may be instances where applicable law or regulatory requirements may allow or require us to refuse to provide some or all of the personal information that we hold about you.
In addition, the personal data/information may have been destroyed or erased in accordance with our record retention obligations and practices. In the event, we cannot provide you with access to your personal information, we will inform you of the reasons why, subject to any legal or regulatory restrictions. In some circumstances, we may not agree with your request to change your personal data/information and will instead append an alternative text to the record in question.
RIGHTS UNDER APPLICABLE LEGISLATIONS
Based on your applicable jurisdiction, you may have certain specific rights. Please note that these rights are not absolute and certain exemptions may apply to specific requests that you may submit to us. These rights may include the following:
CALIFORNIA CONSUMER PRIVACY ACT
Under the California Consumer Privacy Act, California residents have the right to:
Request that a business delete any personal information about the consumer which the business has collected from the consumer.
Request that a business that collects personal information about the consumer disclose to the consumer, free of charge, the following:
- The categories of personal information that it has collected about that consumer.
- The categories of sources from which the personal information is collected.
- The business or commercial purpose for collecting or selling personal information.
- The categories of third parties with whom the business shares personal information.
- The specific pieces of personal information it has collected about that consumer.
Request that a business that sells the consumer’s personal information, or that discloses it for a business purpose disclose, free of charge, to the consumer:
- The categories of personal information that the business collected about the consumer.
- The categories of personal information that the business sold about the consumer and the categories of third parties to whom the personal was sold, by category or categories of personal information for each third party to whom the personal information was sold.
- The categories of personal information that the business disclosed about the consumer for a business purpose.
Direct a business that sells personal information about the consumer to third parties not to sell the consumer’s personal information.
Purposes and Legal Bases for Processing Personal Information
We collect your personal data/information to provide our products and services to you; otherwise, we may not be able to process the transactions you request. We will only process your personal information when we have a lawful basis for doing so. We will collect and process your personal information as necessary for the performance of a contract to which you are a party or because we have another legitimate interest in doing so relating to our business purposes arising from your relationship with us. We may also seek your prior consent or rely on some other lawful basis to process your personal information.
Our legitimate interests include but are not limited to:
- Provide you with the products and services you request, view, engage with, or purchase;
- Communicate with you regarding your account or transactions with us; and
- Operate, understand, optimize, develop, or improve our sites, applications, products, services, and operations.
Rights of Users Located in the EU
If you use this website and are located in the EU, EAA, or Switzerland, you are entitled by law to access, correct, amend, or delete personal information about you that we hold. A summary listing these rights appears below. Please note that these rights are not absolute and certain exemptions may apply to specific requests that you may submit to us.
- The right to access - You have the right to ask us for copies of your personal information. When making a request, please provide an accurate description of the personal information to which you want access. Where requests are repetitive or manifestly unfounded or excessive, we may charge a reasonable fee based on administrative cost.
- The right to rectification - You have the right to ask us to rectify information you think is inaccurate. You also have the right to ask us to complete information you think is incomplete.
- The right to erasure - You have the right to ask us to erase your personal information in certain circumstances, including your personal information to be erased to comply with a legal obligation under applicable law.
- The right to restrict processing - You have the right to ask us to restrict the processing of your personal information in certain circumstances, including: (i) when the accuracy of the personal information is brought into question, or (ii) when we no longer need the personal information for purposes of the processing, but require such personal information for the establishment, exercise, or defense of a legal claim.
- The right to data portability - You have the right to ask that we transfer the personal information you gave us from one organization to another or give it to you.
- The right to lodge a complaint with the supervisory authority - If you believe your rights under the applicable legislation have been violated, and if that legislation gives you the right to file a complaint with your supervisory authority.
- The right to withdraw consent - If we obtain your written consent to collect and process your personal information, you can subsequently withdraw such consent as to any further processing of information.
- Automated decision-making - To the extent that we engage in decision-making based solely on automated processing, including profiling, which produces legal effects concerning you or which significantly affects you, you have the right not to be subject to such decision-making.
You may submit a request through the user dashboard if you are a registered user or via Contact form if you are not a registered user if you wish to exercise any such right as applicable.
For your protection, we may need to verify your identity before responding to your request. Please be prepared to provide us with your address, phone number, email address. We will match the personal information that you provide to us with personal information that we already maintain about you in order to verify your identity. We may also need to contact you to confirm your request.
We may not be able to honor each request that we receive, but if we are unable to do so, we will respond to let you know our reasons. We will not discriminate against you if you choose to exercise any of your rights as described in this section.
Right to Object to Processing
You have the right to object to the processing of your personal information that is based on legitimate interests. If you make such an objection, we will cease to process the personal information unless we can demonstrate compelling legitimate grounds for the processing which override your interests, rights and freedoms, or we can demonstrate the processing is for the establishment, exercise, or defense of legal claims. You can object to the processing of your personal information by contacting us.
Cross-Border Transfers of Personal Information
The laws in the transferring jurisdiction may not be the same as those in your location. Please reach out to us if you have any questions regarding this.
Retention of Your Personal Information
We will retain your personal information until the personal information is no longer necessary to accomplish the purpose for which it was provided. We may retain your personal information for longer periods for specific purposes to the extent that we are obliged to do so in accordance with applicable laws and regulations, to protect you, other people, and us from fraud, abuse, unauthorized access, as necessary to protect our legal rights, or for certain business requirements.
GOVERNING LAW / VENUE / FORUM