I. OBJECTIVE, SCOPE AND APPLICABILITY
- Multiplier Technologies Pte. Ltd. and its affiliates worldwide (hereinafter collectively referred to as the “Company”, “We”, “Us”, “Our”) is dedicated to protecting and respecting the individual’s legal rights of privacy while collecting, storing, using and transmitting the Personal Data (as defined below).
- Your actions of accessing and / or using the Platform, the Services and/or communicating any information in a manner explained in this Policy will mean that You have understood that the Company will collect and use Your Personal Data as described in this Policy and You expressly consent to the terms of this Policy. This Policy should be read in conjunction and together with the terms of services and other policies as may be available on the Platform (collectively the “Terms of Service”). Please read this Policy and in the event You do not agree to the terms or policies specified herein, please discontinue the usage of the Platform and the Services.
- In relation to the users who are based in EU, the Company complies with the General Data Protection Regulation (EU) 2016/679 (hereinafter the “GDPR”), which sets guidelines for the collection and processing of the personal data from individuals. We have therefore established and created this Policy to inform You about the type of the Personal Data we collect from You, how We use it and Your rights with respect to such data.
- Further, We may engage third parties who will be working with or for the Company, and who have or may have access to the Personal Data to perform their functions, but may not use it for other purposes. The Company may act as a data processor or a data controller depending on the Service being provided and the amount of control the Company has over the purpose(s) and means of the data processing.
- Please note that any Personal Data provided to the Company by Our clients or any other third party is collected by the clients and third parties under their respective privacy policies. This Policy does not govern any other information or communications that may have been collected by such parties.
- You agree that the Company reserves the right to take any legal or other action against You including the right to deny the usage rights to the Platform and the Services and referral to the appropriate authorities.
- For the purpose of this Policy, the term “Personal Data” refers any information relating to an identified or identifiable individual and includes the information that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer or household.
II. CATEGORIES OF THE PERSONAL DATA COLLECTED
1. Depending upon the Services You avail and the manner You interact with Us, We may use and collect the Personal Data. The following categories of the Personal Data is collected by Us to provide better services and offerings to You.
- Contact Information: This category includes data such as name, age, gender, email address, password, country, city, contact number.
- Unique identifiers: This category includes data such as customer number, account number, subscription number, rewards program number), system identifiers (including username or online credentials), device advertisers, trade names and logo, advertising IDs and IP address.
- Government-issued identification information numbers: This category includes data such as social security number, driver’s license number, and passport number. Further, we may collect any Personal Data that would be required by the Company to ensure compliance with any applicable laws.
- Financial information: data such as bank account number and details and payment card information are collected by the Company for processing payments.
- Payroll Data: data such as salaries, wages, bonuses, withheld taxes etc. of the employees and contractors on our platform.
- Transaction and Commercial Information: This category includes data such as customer account information, qualification data, purchase history and related records (returns, product service records, records of payments, credits etc.), records related to downloads and purchases of products and applications, non-biometric data collected for consumer authentication (passwords, account security questions), customer service records.
- Inferred Information derived from other information listed in this section: We create inferred and derived data elements by analysing our relationship and transactional information.
- Online & Technical Information, including internet or other electronic network activity information: This category includes data such as IP address, MAC address, SSIDs or other device identifiers or persistent identifiers, online user ID, encrypted password, device characteristics (such as browser information), web server logs, application logs, browsing data, viewing data, website and app usage, cookies, web beacons, clear gifs and pixel tags.
- Other Information: We may collect Your information such as name, age, contact details, preferences, etc. through surveys and forms, when You choose to participate in these surveys etc. When You communicate with or use the Platform to communicate with other users (such as partners) on our platform, We collect information about Your communication and any information You choose to provide.
- Permissible information: To the extent permitted by law, the Company may record and monitor Your communications with Us to ensure compliance with our legal and regulatory obligations and our internal policies. This may include communications through telephone, by email, via the contact form, via a link contained in an email sent by us or via some other electronic message offered to you, via the chat function, web care, surveys or (panel) surveys, the (mobile) website, if you sign up for newsletters or via social media. This may also include recording of telephone conversations.
- Collection of anonymized data: We may also collect and/or generate anonymized and aggregated information from Your use of the Platform. The anonymized or aggregated information is not Personal Data since We are not able to re-identify You using any means available to Us from that anonymized or aggregated information. The anonymized and aggregated information is used for a variety of functions, including to help Us identify and remediate any bugs, and to improve the performance of Our Platform. We may share this information with third parties for Our or their purposes in an anonymized or aggregated form that is designed to prevent anyone from identifying You.
III. PURPOSE FOR THE COLLECTION OF PERSONAL DATA
1. Our use of Your Personal Data shall depend on the purpose for which You have interacted with Us. Below is the list of purposes for which We may process Your Personal Data:
- Creation of Your account and sending You the agreements or other promotional materials;
- Facilitation of payment, in connection with chargeable Services or your employment/engagement with the client, as the case may be;
- Automated processing in order to provide Our Services;
- Enhancing and optimizing Our Services and improving the users experience and the quality of Our Services and Platform;
- Handling of complaints, questions, disputes and participation in social media;
- Acceptance and issuing of offers to current and potential clients and performance of contracts with the Company.
2. Further, We may also use the Personal Data for the purpose of the following:
- Analysing market trend and/or conducting research;
- Communicating marketing or promotional information about Our products and Services, which could be done directly, but also for instance via social media campaigns on Facebook, for example, and/or search engines like Google. Preventing, detecting, investigating and taking action against crimes, any other illegal activities, suspected fraud, or violations of Company’s Terms of Service in any jurisdiction;
- Establishing, exercising or defending legal rights in connection with legal proceedings and seeking professional or legal advice in relation to such legal proceedings;
- Complying with any applicable law, regulation, legal process or enforceable governmental request.
3. We generally collect the Personal Data to provide the Services requested by You or to fulfill Your request. Where additional, optional information is sought, You will be notified of this at the point of collection. Further, We process the Personal Data, so long as We have a ground under the law to do so. Accordingly, We process the Personal Data based on one of the following conditions:
- Performance of a contract: Herein, We process the Personal Data as it is necessary in order to fulfil Our obligations set forth under a contract or for the performance of Our agreement with You;
- Legal obligation: Herein, We process the Personal Data in order to comply with a legal obligation, such as keeping records for tax purposes or providing information to a public body or law enforcement agency;
- Legitimate interests: Herein, We process Your Personal Data information where it is in Our legitimate interest in running a lawful business. We will only rely on such a ground where an assessment has been performed balancing the interests and rights involved and the necessity of the processing in order to provide our Services, products and features to You. Few examples of Our legitimate interests are: (i) to offer information and/or services to individuals who visit the Platform or (ii) to prevent fraud or criminal activity and to safeguard our IT systems etc;
- Your consent: In some cases, we will ask You for Your specific permission to process Your Personal Data and we will only process Your Personal Data in this way if you agree to us doing so. You may withdraw your consent at any time by requesting Us at email@example.com.
4. To the extent permissible under the applicable law, We may use and disclose any non-personal data (data which is does not contain any information that can be used to identify natural person) for any purpose, any non-personal data. However, in the event We combine any non-personal data with Personal Data, then We will only use and disclose such combined information for the purposes described above while it is so combined.
IV. SHARING OF THE PERSONAL DATA
- We do not rent, share, list or sell the Personal Data with any third parties, except as necessary for our legitimate professional and business needs, to carry out Your requests, and/or as required or permitted by an applicable law. The Personal Data may be shared with the third parties only if it is for the purposes identified above or in the event You consent for the sharing of such Personal Data. Proper assurances will be obtained for the third parties that they will comply with the rules or policies specified under this Policy and subsequently notify the Company if it makes a determination it can no longer meet this obligation. We will take all the reasonable steps to prevent or stop unauthorized use or disclosure of the Personal Data by the third parties.
- Further, We may disclose information about You: (i) if we are required to do so by law or legal process, (ii) to law enforcement authorities or other government officials, or (iii) when we believe disclosure is necessary or appropriate to prevent physical harm or financial loss, or in connection with an investigation of suspected or actual fraudulent or illegal activity. We may disclose Personal Data to third party rights owners, or others in the good faith belief that such disclosure is reasonably necessary to: (a) enforce our Terms of Service and this Policy; (b) respond to claims that an advertisement, posting or other content violates the rights of a third party; (c) respond to any authority, having the right to receive such information under law; or (d) protect the rights, property or personal safety of the users or the general public.
- In the event of any proposed or actual reorganization, sale, merger, joint venture, assignment, amalgamation or any other type of acquisition, disposal or financing of all or any portion of the Company or of any Company assets, We may disclose or transfer Your Personal Data to such third party. Should such an event take place, We will endeavor to direct the transferee to use the Personal Data in a manner that is consistent with this Policy.
V. RETENTION AND STORAGE OF THE PERSONAL DATA
- The Personal Data will be retained as long as we have to or keep a record of or need to for the purpose of providing the Services or until You ask Us to delete the Personal Data. Please note that the Personal Data may be held for longer periods where extended retention periods are required by local law, regulation, or professional standards and to establish, exercise or defend our legal rights. If You wish to delete Your Personal Data, You should submit a delete request at firstname.lastname@example.org.
- We may store Your Personal Data using Our own secure on-site servers or other internally hosted technology. Your Personal Data may also be stored by third parties, via cloud services or other technology, with whom the Company has contracted, to support the Company's business operations. These third parties do not use or have access to Your Personal Data other than for cloud storage and retrieval. When we share information with others, we put contractual arrangements and security mechanisms in place as appropriate to protect the information and to comply with our information protection, confidentiality and security standards.
VI. TRANSFER OF PERSONAL DATA ACROSS BORDERS
We are part of a global network of company and in common with other professional service providers, We use third parties located in other countries to help Us run Our business. As a result, the Personal Data may be transferred outside the countries where We and Our clients are located. This includes transfers to countries that may not have laws that provide the same degree of protection for the Personal Data as Your home country. In accordance with applicable legal requirements, We take appropriate measures to facilitate adequate protection for any data so transferred.
VII. CUSTOMER COMMENTS AND CONTENT
Any comment or content uploaded by You on the Platform may be read, collected, or used by the third parties. For any such disclosure of information, the Company will not be held responsible for any reasons. You agree that We cannot guarantee that the third parties will not any copies or use the information in a manner specified herein.
VIII. LINKS TO THIRD PARTY ADVERTISEMNTS OR SITES
- We use reasonable security measures to help protect against the loss, misuse and alteration of the Personal Data under our control. However, despite our best efforts, security cannot be absolutely guaranteed against all threats. To the best of Our ability, the access to Your Personal Data is limited to those who have a need to know. Those individuals who have access to the Personal Data are required to maintain the confidentiality of such data. In addition, please note that emails, messages sent via Your web browser, and other similar means of communication with other users, are not encrypted. Therefore, while We strive to protect Your information, We cannot guarantee its security.
- Please also be aware that We may use third-party cloud service providers that provide hosting, data storage and other services pursuant to standard terms and conditions that may be non-negotiable. These service providers have informed Us or the general public that they apply security measures they consider adequate for the protection of information within their system, or they have a general reputation for applying such measures. However, We will not be liable (to the fullest extent permitted by law) for any damages that may result from the misuse of any information, including Personal Data, by these companies.
X. EXERCISING RIGHTS WITH RESPECT TO PERSONAL DATA
- In the event, We process Your Personal Data, You may avail Yourself the rights explained below. Please note that prior to fulfilling Your request in relation to the rights provided below, we may verify Your identity associated with Our Platform. In case We are unable to verify Your identity, We reserve the right to deny a request. If You authorize someone to make a request on Your behalf, We may also deny Your request if We are unable to verify with You that the individual making the request is authorized to act on Your behalf.
- In the event, We are processing Your Personal Data on behalf of another entity or are acting as a data processor, We will forward Your requests, inquiries or claims concerning these processing activities to the respective data controller the necessary action.
- Your Rights are as follows:
- Please note that in the event We identify that Our system have been hacked or security measures have been breached and Your Personal Data is disclosed, We will notify You as soon as possible but no later than 72 (seventy-two) hours.
- Some Limitations: The rights provided herein are subject to certain limitations as specified in the applicable laws. Any individual requests will be completed within the time allotted by relevant regulations, which starts to run from the point of the Company confirming Your request. To the extent permissible by applicable law and where permitted, We may impose a charge for subsequent requests from the same individual which will be determined by the Company.
XI. CHILDREN UNDER THIRTEEN
We do not collect any data from children under the age of 13 (thirteen). In the event You are under the age of 13 (thirteen), You must ask Your parent or guardian for permission to use the Platform. We attempt to delete any information so received on the Platform, We learn that the Personal Data is the information of a child under 13 (thirteen). If You believe that We might have any Personal Data from a child under 13 (thirteen), please contact Us at email@example.com.
XII. AUTOMATIC PROCESSING OF THE PERSONAL DATA
XIII. COOKIES INFORMATION:
- authenticate the users;
- personalize Your experience;
- analyze which portions of the Platform are visited or used most frequently; and
- measure and optimize advertising and promotional effectiveness.
2. Below is a summary of the categories of cookies collected on Our Platform and how Your consent may impact Your experience of certain features as You navigate those websites
- Strictly necessary cookies: The strictly necessary cookies are essential in order to enable users to browse the Platform and use its features, such as accessing secure areas of the Platform. These cookies must be enabled or the site will not function, and cannot be blocked.
- Performance cookies: The performance cookies are cookies used to gather data to enhance the performance of the Platform. You can manage Your consent for performance cookies using the cookie banner, or by updating Your browser’s settings.
- Functionality cookies: The functionality cookies are used to remember the user selections that change the way the Platform behaves or looks. You may opt-out of these cookies, but it will impact Your experience on the Platform, and You may need to repeat certain selections each time You visit or access the Platform. You can manage Your consent for functionality cookies using the cookie banner, or by updating your browser’s settings.
- Targeting cookies or advertising cookies: The targeting cookies are used to deliver content relevant to Your interests They are also used to limit the number of times You see certain marketing materials, as well as help measure the effectiveness of those marketing materials. If You do not provide consent for targeting cookies, Your computer or internet-enabled device will not be tracked for marketing-related activities.
XIV. THIRD PARTY ANALYTICS
1. We may use third party web analytics services on the Platform. The service providers that administer these services use technologies such as cookies, web server logs and web beacons to collect information (such as IP address) and use that information to help Us analyse how visitors use the Platform. When You access or browse the Platform, a cookie banner will inform you of the use of these analytics technologies. They will only be used if You accept them or if You continue using the Platform. You may change Your cookie settings at any time to accept or refuse these analytics technologies by clicking on the cookie control tool below to adjust Your cookie preferences. Adjusting Your cookie preferences may disable certain functionality on the Platform. You consent to the processing of information about You by these analytics providers in the manner and for the purposes set out in this Policy.
2. At present, We work with the following analytic partners:
- Google Analytics
3. For more information on these third parties, including how to opt out from certain data collection, please visit the sites below. Please be advised that if You opt out of any Services, You may not be able to use the full functionality of the Platform.
XV. POLICY REVIEW
We may modify this Privacy Statement from time to time to reflect our current privacy practices. When we make changes to this statement, we will revise the “updated” date at the top of this page. Any changes to the processing of personal data as described in this Privacy Statement affecting you will be communicated to you through an appropriate channel, depending on how we normally communicate with you.
XVI. PRIVACY CONCERNS
If You are concerned about the handling of your Personal Data, or if You have any complaints or queries related to Your Personal Data or our Policy, please contact Our Privacy Officer (“PO”):
Name: Hiraash Thawfeek
Address: #11-85, CT Hub 2, 338729, Singapore