Introduction
We have recently made updates to our Privacy Policy to increase transparency and comply with the EU’s regulation. EveryMatrix Group is committed to safeguarding your privacy, and your data privacy and communication preferences are top priority for us. We will always treat your information with the utmost care and respect.
EveryMatrix Group takes the privacy of its clients and visitors seriously into account. The purpose behind this policy (the ‘Privacy Policy’) is to inform you of how the EveryMatrix Group protects the privacy of your communications and collects, processes, uses and stores your Personal Data as well as the rights you have with regard to your access to and use of this Website as well as other services provided by us (hereinafter the “Services”).
The “Data Controller” is the company that determines the purposes and means of the processing of personal data under this Privacy Policy.
EveryMatrix Software Limited, EveryMatrix Development, EveryMatrix SRL, EveryMatrix Limited and EveryMatrix N.V. act jointly in their capacity of data controllers in terms of the EU Regulation 2016/679, determining the purposes and means of the processing of your personal data.
Please see Section 9 for contact details of the Data Controllers.
By using and/or visiting any section of this website as well as agreeing to use our Services, you agree to be bound by the Privacy Policy.
Information we collect
When you contact us through the form for General Enquiries or Sales Enquiries, we ask you to fill the contact form with your name, email, phone number, Skype ID. We process this data for the purpose of providing you a support and information service and in order to maintain accurate records of the information that we have received from you, given our legitimate interest in conducting our business and improving the Website and our users’ experience, and in some cases in order to take the first step for entering into a contract with you.
When you apply for a job through the application form in our career section, we collect the data you provide us with by submitting this form (your name, e-mail address, telephone number, Skype id) and further documentation that you may be asked to provide during the recruitment process. This information is necessary to carry out the recruitment process in order to take steps to possibly enter into a contract.
When you approach us or have been approached by us either as our partner or client with regards to the provision of our Services as well as services provided to us by you, and upon entering into contract with us, you shall be prompted to provide us KYC data (by filling in the applicable form(s). In this instance we collect data you have provided us with, by submitting the applicable forms, and such data may include:
- personal details of directors
- personal details of UBO’s
- account signatory personal details (if applicable).
- Additional information such as personal information on PEPs.
Any additional information as may be set out in the respective form(s), or privacy notices that will be issued and provided to you.
How we use the information we collect
Personal Data necessary for the navigation and use of our Website as well as for the provision of our Services, is collected and processed by us pursuant to Article 6(1)(b) of the GDPR (‘Performance of Contract’) for the following purposes:
- Carrying out KYC checks and procedures
- Development and introduction of new services, utilities and offerings;
- Detection, investigation and prevention of fraudulent transactions and other illegal activities and protection of your rights and rights of EveryMatrix Group;
We may process Personal Data only with your lawful consent pursuant to Article 6(1)(a) for the following purposes:
- For the purposes of commercial communication, marketing and advertising of our services or third-party services via e-mail, internet, mail, social media and / or any other appropriate communication channels as set out in a notice when requesting such consent.
- For the purposes of processing sensitive data during the recruitment process (if and when applicable)
You have the right to withdraw your consent at any time in writing to our contact details mentioned in this Policy. Withdrawal of your consent does not affect the lawfulness of the treatment of your data prior to its revocation. Your consent is also revoked in the same manner as provided.
We may process Personal Data wherever it is necessary to comply with a legal obligation to which we as Controller are subjected to.
We may process Personal Data in our legitimate interest for the following purposes:
- Collection, processing and performing statistical and other research and analysis of information for enhancement of the Website and the services;
- Administration and development of the Website and our Services;
- Enhancement of user experience, including the provision of personalized Services and improvement of the Website and the Services;
- To contact you in relation to our products or services, industry events where you can meet us, EveryMatrix hosted events invitations that you may be interested in from time to time.
- Carry out certain profiling of you and your activity on the Website in order to personalise, measure, and improve the marketing of our products and to send you more relevant marketing communications related to our products and services.
- For the purposes of processing employment applications and conducting the recruitment process.
You can always opt-out of receiving marketing communications from us by following the unsubscribe instructions included in each of our marketing communications.
Principles of Data Processing
We fully respect your fundamental rights and render protection of your privacy a priority of EveryMatrix Group. In this context, when processing your Personal Data, we follow the following basic principles:
We submit your Personal Data only to legitimate processing, and we maintain full transparency vis-à-vis the way we handle your Personal Data.
We collect and process your Personal Data only for specified, explicit, and legitimate purposes as outlined in the Privacy Policy, and we do not process it further in a manner incompatible with these purposes.
We process your Personal Data only to the extent that it is appropriate and relevant to the purposes set out herein, while limiting the processing to the measure necessary for these purposes.
We make reasonable efforts with your own assistance to ensure that your processed data is accurate and, where necessary, updated with regards to the purposes of the processing, taking all reasonable steps to immediately delete or correct it in case of inaccuracy.
We keep your Personal Data in a form that allows you to identify yourself only for the time required for the above processing purposes.
We process your Personal Data in a way that guarantees its security by using appropriate technical or organizational measures.
We do not intend to further process your Personal Data for purposes other than the ones for which they are collected.
We hereby inform you that your Personal Data will not be used for automated decision making, including profiling.
Without prejudice to what is stated in the Privacy Policy, we do not disclose and transmit your Personal Data to third parties without your consent, unless permitted by law or by a specific contractual agreement with you.
In general, we comply with all applicable laws and comply with all our statutory obligations, as data controllers of your Personal Data.
Cookies
For information on what cookies are and how we use them please refer to our full Cookie Policy.
Sharing and disclosure
In certain circumstances we may share and disclose your personal data as described below.
The information referred to in 2.2 will not be transmitted to any third party outside our group of companies, except for what provided in 5.1 and 5.5.
Compliance with law, responding to legal requests, preventing harm and protection of our rights
We may disclose your information, including personal information, to courts, law enforcement or governmental authorities, or authorized third parties, if and to the extent we are required or permitted to do so by law or if such disclosure is reasonably necessary: (i) to comply with our legal obligations, (ii) to comply with legal process and to respond to claims asserted against us, (iii) to respond to requests relating to a criminal investigation or alleged or suspected illegal activity or any other activity that may expose us, you, or any other of our users to legal liability.
Third-party service providers
We can use third party service providers to help us provide services related to the Website and the payment services. Service providers may be located inside or outside of the European Economic Area (“EEA”).
These providers have limited access to your information and are contractually bound to protect and to use it on our behalf only for the purposes for which it was disclosed and as well as to provide the same level of data protection and be consistent with this Privacy Policy.
You can always contact us to receive the full list of our service providers which process your data.
Corporate affiliate
We may share your information, including personal information, to any member of our group of companies (this means our subsidiaries, our ultimate holding company and all its subsidiaries) insofar as reasonably necessary for the purposes, and on the legal bases, set out in this policy.
Aggregated data
We may also share aggregated information (information about our users that we combine together so that it no longer identifies or references an individual user) and other anonymized information for regulatory compliance, industry and market analysis, demographic profiling, marketing and advertising, and other business purposes.
Business transfers
If we undertake or are involved in any merger, acquisition, reorganization, sale of assets, bankruptcy, or insolvency event, then we may sell, transfer or share some or all of our assets, including your information in connection with such transaction or in contemplation of such transaction (e.g., due diligence). In this event, we will notify you before your personal information is transferred and becomes subject to a different privacy policy.
Data subject rights
Under the General Data Protection Regulation, you have the right to:
- access your Personal data and information related to its processing and obtain a copy thereof.
- To request for the rectification of any inaccuracies or any missing Personal Data of yours.
- To request for the portability of your personal data to another controller in a structured, commonly used and machine-readable format.
- To request for the restriction of the processing of your Personal Data in cases explicitly provided for by law.
- To object to the processing of your Personal Data in cases explicitly provided for by law.
- To object to a decision taken solely on the basis of automated processing, including profiling, which has impact on you or significantly affects you
You may exercise any of the rights described in this section before your Data Controller by sending an email to dpo@everymatrix.com. Please note that we may ask you to verify your identity before taking further action on your request.
We will respond to any of your requests within one (1) month from their receipt. Upon prior notice, this period may be extended by a further two (2) months if necessary, taking into account the complexity of the request and the number of any other pending requests. In case of rejection of your request, we will provide relevant justification.
Please be aware that whilst we will try to accommodate any request you make in respect of your rights they are not absolute rights. This means that we may have to refuse your request or may only be able to comply with it in part.
Rectification of inaccurate or incomplete information
You have the right to ask us to correct inaccurate or incomplete personal information concerning you.
Data access and portability
You have the right to access your personal data held by us and a right to receive certain personal data in a structured, commonly used, and machine-readable format and/or request us to transmit this information to another service provider (where technically feasible).
Data retention and deletion
We will retain your personal data for the period necessary to perform the contract between you and us and to comply with our legal obligations. Where it is no longer necessary to process your personal data, it will be deleted. Please note, however, that we may be subject to legal and regulatory requirements to keep personal data for a longer period.
You have the right to have certain personal data erased where it is no longer necessary for us to process it, where you have withdrawn your consent pursuant to paragraph 6.4, where you have objected pursuant to paragraph 6.5, where your personal data has been unlawfully processed, or where erasing your personal data is required in accordance with a legal obligation.
However, there are exclusions of the right to erasure. The general exclusions include where processing is necessary: for exercising the right of freedom of expression and information; for compliance with a legal obligation; or for the establishment, exercise or defence of legal claims.
Withdrawing consent and restriction of processing
Where we have specifically requested your consent to process your personal data and have no other lawful conditions to rely on, you have the right to withdraw this consent at any time by changing your Account settings or by sending a communication to dpo@everymatrix.com specifying which consent you are withdrawing. Please note that the withdrawal of your consent does not affect the lawfulness of any processing activities based on such consent before its withdrawal.
Additionally, applicable law may give you the right to limit the ways in which we use your personal information, in particular where (i) you contest the accuracy of your personal information; (ii) the processing is unlawful and you oppose the erasure of your personal information; (iii) we no longer need your personal information for the purposes of the processing, but you require the information for the establishment, exercise or defence of legal claims; or (iv) you have objected to the processing pursuant to next section and pending the verification whether the legitimate grounds of the Data Controller override your own.
Objection to processing
You have the right to object to processing where lawful basis is that it is in our legitimate interests. Furthermore, you have the right to withdraw consent in the event we are processing your personal data on the basis of your consent. However, please note that we may still process your personal data where there are other relevant lawful bases or where we have compelling grounds to continue processing your personal data in our interests which are not overridden by your rights, interests or freedoms;
You also have the right to object to direct marketing, which can be done by opting-out of direct marketing either via your Account settings or by opting out via the communication itself. You also have a right to object to any profiling to the extent that it relates to direct marketing only.
Lodging complaints
You have the right to lodge complaints about the data processing activities carried out by the Data Controller before the competent data protection authorities. Please refer to Section 9 for further information.
Overseas transfer of your information
To facilitate our global operations, we may transfer, store, and process your information within our family of companies or share it with service providers based outside Europe for the purposes described in this Privacy Policy.
If we do transfer your Personal Data outside of the EEA, within the group or to our business partners, we will take all reasonable steps to ensure that adequate measures are in place to keep your personal data as secure as it is within the EEA and in accordance with this Privacy Policy, by relying on the use of standard contractual clauses or binding corporate rules or any other acceptable method that ensures a protection of your data to the standard required within the EEA.
You can always contact us to receive the full list of our service providers outside of the EEA which processes your data.
Contact us
If you have questions about this Policy or our information handling practices, or If you are seeking to exercise any of your rights under Data Protection Laws, please contact our Data Protection Officer at: dpo@everymatrix.com. Below you can find the details of the Data Controllers that you can contact by post or online through our website “Contact Us” form”.
EveryMatrix Software Ltd
Reg. no: C51832
Address: St Julian’s Business Centre, Level 3, 3 Triq Elija Zammit, STJ 3155, Malta
EveryMatrix Development Ltd.
Reg. no. C 56332
Address: St Julian’s Business Centre, Level 3, 3 Triq Elija Zammit, STJ 3155, Malta
EveryMatrix SRL
Reg.no. 16866918
Address: Bucuresti Sectorul, 3 Lipiscani Street, no. 102, Floor 1, 4 SI POD, Bucharest, Romania
EveryMatrix Limited
Reg no. C44411
Address: St Julian’s Business Centre, Level 3, 3 Triq Elija Zammit, STJ 3155, Malta
EveryMatrix N.V.
Reg no. 108354. Its representative inside the EU is EveryMatrix Limited
Filing a complaint
If you are not satisfied with how we manage your personal data, you also have the right to lodge a complaint with your local Data Protection Authority.
