Privacy Notice

The Privacy Notice referenced on this page explains that we are committed to protecting and respecting your privacy.

This privacy notice (and all other policies referenced) explains what kind of information we collect about you, how we use that information, the legal basis for the use of that information, and to whom we provide that information. It also indicates your rights and obligations regarding your information and who you can contact for detailed information or questions.

Please read this Privacy Notice carefully before using the site. By using our site, you indicate that you agree to this Privacy Notice and that you agree to abide by this notice.

The last update was on May 11, 2023, Friday.

1. PARTIES COVERED AND SUBJECTS COVERED BY THIS PRIVACY NOTICE

This privacy notice specifies how we will collect, handle, store and protect information about you when serving you or our customers or when performing other activities that are part of the operation of our business.

This privacy notice also contains information about when we share your personal information with other members of our group and with other third parties (e.g. parties who perform due diligence activities on our behalf).

In this privacy notice, your information is sometimes referred to as “personal data” or “personal information”. In some cases, we may collectively refer to the handling, collection, protection and storage of your personal information as “processing” of such personal information.

2. CHILDREN

We acknowledge the importance of protecting children’s privacy. Our website is not designed or intended for children. We do not have a policy to deliberately collect or store information about children.

3. PERSONAL INFORMATION WE COLLECT

We may collect and process personal data about you because you provide it to us, other people provide that data to us (such as third party service providers who assist us in the conduct of our business), or the data is publicly available.

The personal data we collect or obtain may include: your name, age, date of birth, gender, e-mail address, home address, country of residence, lifestyle and social circumstances (e.g. your hobbies), your educational and professional information (e.g. the institution you work for, your title and education information), your IP address, your browser type and language, access hours, complaint details, information about how you use our products and services, details about how you want to interact with us, and other similar details.

That you inform us by filling out the forms on our website. This may include information made available at the time you register, subscribe, post to our services, send messages and post on our applications, comment, pay or receive payments through a User Account, or request other services.

Details of the transaction and service you provide through our website.

We may ask you for information (whether or not a formal dispute has arisen) when you report a problem or concern, or receive a complaint or question about you.

We may keep a record of correspondence between you and us.

Although you are not required to answer, we may ask you to complete surveys that we use for research purposes.

Details of messages you send and receive using our apps, including but not limited to whether you send or receive a message, the content of that message. Messages are not private and confidential.

We may collect and process personal data about you from the following sources:

1. We may collect or obtain personal data from you because we observe or derive data about you from the projects you undertake or the way you interact with us or others. For example, we (or our service providers) may use cookies (text files stored in a user’s browser) and Web beacons that collect personal data to improve your experience when you use our website and to enable it to function effectively. Additional information on how we use cookies and other tracking technologies and how you can control them can be found in our Cookie Policy.
2. Sometimes we add information from third parties to the information you provide. For example, from credit reference agencies, search information providers or other companies (according to privacy policies and applicable law) and other accounts that are under your control (in whole or in part) with us.
3. Where any third party, such as a service provider, provides us with personal data about you, we take steps to ensure that the third party complies with the third party’s personal information privacy laws and regulations associated with that information; and this includes, e.g. the third party notifying you of the collection (and other matters) and obtaining the necessary consent (if relevant) for us to process that information as described in this privacy notice. We may use your personal data to collect feedback regarding your experience on our platform. This helps us grow our business by collecting useful information from our end user.

4. USE OF PERSONAL DATA

We shall use your personal data to fulfill your requests and shall only ask for data that is adequate, relevant and not disproportionate for the purposes stated. If for any reason we send you information, this information may be sent by e-mail or mail. When we ask you for your personal data, this request is based on the following purposes:

1. We may occasionally contact you to notify you of new products and services we are to offer;
2. We may send you regular information on topics that we think will be of interest to you;
3. We may send you requested information regarding our products and services;
4. We may use your personal data for marketing and market research;
5. We may use your personal data internally to provide you with the services offered by us on this website, to administer this website, and to improve our services;
6. We may use your personal data to manage your information and make it available to third party service providers (e.g. due diligence service providers or to support our information technology) and our affiliates;
7. If you choose to do so, we may use your personal data to enable you to participate in interactive features of our service;
8. We may use your personal data to notify you of changes to our services, terms and conditions, policies or website;
9. We may use your personal data to manage risk or to investigate, detect, prevent and/or rectify fraud, suspected fraud or other potentially illegal or prohibited activities;
10. We may use it in accordance with applicable legal or regulatory requirements or to respond to requests and notifications from competent authorities (including courts and boards);
11. We may use your personal data for the services we receive from professional consultants such as lawyers, accountants and advisers;
12. We may use your personal data to protect our rights, the rights of our customers, or the rights of our affiliates.

None of the information we request from you is mandatory. However, we may not be able to identify, protect, or return your money or assets if such information is not provided to us.

5. LEGAL REASONS FOR THE PROCESSING OF PERSONAL INFORMATION

We cannot process personal information unless we have a valid legal justification. Therefore, we shall only process your personal information for the above-mentioned purposes for the following reasons:

1. our legitimate interests in the performance of activities that form part of the conduct of our business;
2. our legitimate interests in the lawful and effective conduct of our business unless your interests or fundamental rights and freedoms outweigh our interests;
3. legal and regulatory obligations to which we are subject, such as keeping records for tax reasons or providing information to a government agency or law enforcement agency; or
4. information necessary to carry out activities that form part of the conduct of our business (e.g. that the processing is necessary to fulfill our contractual obligations to you).

Examples of the above-mentioned legitimate interests are as follows:

1. taking advantage of low-cost services (e.g. we may choose to use certain IT platforms offered by suppliers);
2. verifying the accuracy of information provided by a third party;
3. preventing fraud or criminal activity;
4. protecting the security of our IT systems, architecture and networks, physical facilities; and
5. the freedom to conduct our business and the exercise of our rights under Articles 16 and 17 of the Charter of Fundamental Rights, including our right to property.

If we process your sensitive personal data for one of the above-mentioned purposes, we shall do the processing for the following reasons: (i) that we are required by law to process that data in order to comply with our “know your customer” and “anti-money laundering” obligations (or other legal obligations imposed on us); (ii) the processing is necessary to fulfill our obligations under employment, social security or social protection law; (iii) the processing is necessary for the establishment, exercise or defense of legal claims; or (iv) that you have made the data public.

6. UNSUBSRIPTION

From time to time, we may share relevant information with you by e-mail or mail, in order to provide you with other similar products and services that may be of interest to you. If you do not want to receive e-mails or mails from us for these purposes, or if you wish to unsubscribe from our e-mailing list, you can choose the “unsubscribe” option from the marketing e-mails we have sent to you or contact us.

7. ANONYMOUS DATA COLLECTED FROM THIS WEBSITE

In addition to the information collected as described above, we use technology to collect anonymous information about the use of our website. For example, our web server automatically records which pages our visitors view, their IP addresses, and which web browsers our visitors use. This technology does not personally identify you, it only allows the compilation of statistics on our visitors and use of our website.

Our website contains hyperlinks to other pages on our website. We may use technology to track how often these links are used and which pages of our website are viewed by visitors. To point out again, this technology does not personally identify you, it only allows us to compile statistics on our visitors’ use of these hyperlinks.

8. LINKS TO OTHER WEBSITES

This website may contain hyperlinks to websites not operated by us. These hyperlinks are provided for your reference and convenience only and do not imply any endorsement of the activities of third party websites or any affiliation with their operators. We do not control these websites and are not responsible for their data or privacy practices. We recommend that you review the privacy policy posted on each site you visit before using the site or providing any personal data about yourself.

9. COOKIES

In order to collect anonymous data described in the previous paragraph, we may use temporary “cookies” and similar technologies (web beacon, pixel, advertisement tags and device identifiers) that remain in your browser’s cookies folder for a certain period of time to recognize you and/or your device(s). For example, we use Google Analytics to receive and analyze visitor information such as browser usage and new visitor numbers. We use this information to generate reports and to assist us in improving the website. Cookies collect information anonymously, including the number of visitors to the website and blog, from where visitors have come the website, and the pages visitors have visited. Please note that the names of cookies, pixels and other technologies may change over time.

Cookies by themselves cannot be used to identify the user. A “cookie” is a small piece of information sent to your browser and stored on your computer’s hard drive. Cookies do not harm your computer. You can set your browser to notify you when you receive a cookie. This way, you can decide whether to accept the cookie or not. We also use your IP address to diagnose problems with our server and to administer our website. An IP address is a numerical code that allows you to identify your computer on a network or, in this case, the Internet. Your IP address is also used to collect broad demographic information. Cookies are useful because they allow a website to recognize a user’s device, preferences, and generally improve your online experience.

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10. SOCIAL MEDIA

Our website may contain plugins and other features that integrate third party social media platforms to improve the services we offer and make them more interesting to you as a user. You will be able to enable these plugins and features. If you do so, the third party companies operating these platforms will be able to identify you, identify how you use this website, and thus associate and store this information with your social media profile. Please review the data protection policies of social media platforms to find out what they do with your personal data. If you enable this plugin and other features, you do so at your own risk, as we have no influence on the data collection and processing, and we are not aware of the exact size, purpose and retention periods of the said data collection.

11. DISCLOSURE OF YOUR PERSONAL DATA

In connection with one or more of the purposes set out in the “Use of Personal Data” section above, we may disclose details about you to the following parties: any third parties that provide services to us and/or our affiliates, such as our affiliates, lawyers, competent authorities (including courts and supervisory or other authorities), your consultants or your employer, if any, any credit reference agencies or other organizations that help us make decisions and reduce cases of fraud, and other third parties who reasonably need access to personal data about you for one or more of the purposes set out in the “Use of Personal Data” section above.

In case you choose to link your account on our website to your Facebook or LinkedIn account, we may share, disclose and transfer your personal data to Facebook or LinkedIn, as the case may be. This permission will be requested when you login your accounts. If you have given this permission, you can disable this function at any time by changing Facebook, LinkedIn or our account settings (as applicable).

Where appropriate, we contractually oblige the third party to take adequate measures to protect the data and comply with applicable laws before personal data is disclosed to any third party.

If you give your consent, we may share your personal data with other companies within our group of companies; and these companies may also contact you about their products or services that may be of interest to you.

Please note that some recipients of your personal data mentioned above may be located in countries outside the EU, of which laws may not provide the same level of data protection. Those countries currently include India and the USA. In this case, we shall ensure that adequate safeguards are in place to protect your personal data in accordance with our legal obligations. In order to provide this level of protection for your personal data, we conclude a data transfer agreement with the recipient based on standard contractual clauses approved by the European Commission. A copy of these articles is available upon request from us.

12. PROTECTION OF PERSONAL DATA

Any personnel accessing personal information must comply with the internal rules and processes regarding the processing of personal data in order to protect and keep the information confidential.

We have taken adequate technical and organizational measures to protect personal data against unauthorized, accidental or unlawful destruction, loss, tampering, misuse, disclosure or access and any and all other forms of unlawful processing. These security measures have been implemented by taking into account the latest technology, cost of implementation, any risks arising from the processing and nature of personal information, paying particular attention to sensitive information.

Although we use appropriate security measures when we receive your personal data, the transmission of data over the internet (including by e-mail) is never completely secure. We strive to protect personal data, but we cannot guarantee the security of data transmitted to us or that you transfer.

13. HOW LONG DO WE KEEP YOUR INFORMATION?

We shall keep your personal data in our systems for the longest of the following periods: (i) as long as necessary for the relevant activity (usually for 7 years); (ii) any period required by law or regulation; or (iii) up to the end of the period during which litigation or investigations relating to our activities may arise.

14. YOUR RIGHTS

You have various rights regarding your personal data. In particular, you have the following rights:

1. to request a copy of the personal data we keep about you;
2. to request the updating of the data we keep about you or to request the correction of personal data that is inaccurate or incomplete according to you;
3. to request the deletion of data we keep about you or to restrict the way we use such personal data;
4. to object to our processing of your personal data;
5. to request us to restrict processing of your personal data; and
6. to request the migration of personal data – to receive the Personal Data you have provided to us in a structured, collaborative and machine-readable format.

If you have any further questions about the exercise of your rights or our use of your personal data, please contact us.

15. RIGHT TO PETITION

If you are dissatisfied with the way we process your personal information or any privacy questions or requests you make to us, you have the right to lodge a complaint with a data protection authority where you live or work or where you believe a problem has arisen with your data. The list of national data protection agencies can be found here.

16. AMENDMENTS TO OUR PRIVACY NOTICE

We may change this Privacy Notice from time to time.

We will change the revision date at the end of this page to notify you that we have made changes to this privacy notice. The newly amended privacy notice shall be effective from the date of that revision. Therefore, we recommend that you review this notice regularly to be aware of how we protect your information.

17. CONTACT

If you have any questions, comments or requests regarding this Privacy Notice, please contact us.