Moxie Tech Privacy Policy As of 19^th August 2021

Moxie Tech Privacy Policy

Moxie Tech is subject to the EU General Data Protection Regulation (“GDPR”)

This Privacy Statement explains how, applying the applicable data protection principles under the GDPR, we collect and process personal data for third parties (“Moxie Tech Client” or “Moxie Tech Clients”) and for our business. For the purposes of the GDPR Moxie Tech Clients are deemed data controllers.

The Moxie Tech Clients have engaged the services of Moxie Tech to provide identity verification services and assist in the collation of due diligence documentation on the Moxie Tech Clients prospective and existing customers (the “Customer” or “Customers”), when the Moxie Tech Clients’ Customers provide their personal data to us through the submission of information, forms or documents (in whatever format) through an upload to our website, use of our mobile application or otherwise.

Personal Data we process enables us to identify the Customers either directly or indirectly by reference to an identifier. Examples of identifiers we process are name, identification number, location data, an online identifier or one or more factors relating specifically to the economic, cultural or social identity of the natural person (“Personal Data”).

Moxie Tech is a data processor which means that we process Personal Data on behalf of the Moxie Tech Clients. Dependent upon the checks that Moxie Tech has been engaged by the Moxie Tech Client to undertake, Moxie Tech may use sub-processors. Prior to working with any sub-processor, Moxie Tech ensures that they comply with the GDPR, or any other relevant data protection legislation that may be applicable.

The result of the Customer’s verification process, as well as all details and documents provided by Customers to the Moxie Tech Clients via the Moxie Tech website, mobile application or otherwise are available solely to the Moxie Tech Client with whom the Customer is engaging and the Personal Data is provided as part of the Moxie Tech Client’s collation and evaluation of due diligence documentation on potential new and existing Customers to comply with applicable International Anti Money Laundering legislation. Moxie Tech does not have access to any Customer Personal Data.

For the purposes of GDPR, it should be noted that dependent upon the location of the Moxie Tech Client, and the Anti Money Laundering legislation with which they must comply, Personal Data may be transferred or accessed outside the European Economic Area (“EEA”) at the request of the Moxie Tech Client.

For Customers who are not resident within the EEA, you should note that if the Moxie Tech Client you are engaged with is resident in a country other than your country of residence, there is a possibility your Personal Data will be transferred outside your country of residence. You should consult with the relevant contact at the Moxie Tech Client for further details in relation to jurisdictions used for the transfer of your Personal Data.

Individuals (individually a “Subscriber” and collectively the “Subscribers”) may also sign up for news and marketing updates about our business via our website and other marketing tools such as marketing automation platforms. In these instances, Moxie Tech is acting as a data controller and data processor. The Personal Data collected enables us to identify Subscribers through a combination of the information provided during the sign-up process. The Personal Data is stored and retained by us for use as part of our marketing activities.

Dependent upon the marketing tools that we use to facilitate the sign-up process, we may on occasion use a third party data processor to process the Personal Data of Subscribers. In such circumstances, Subscribers will be made aware of this during the sign-up process and asked to provide consent accordingly. Third parties we use for data processing adhere to data protection legislation as applicable.

For the purposes of GDPR, it should be noted that dependent upon the location of the Subscriber, Personal Data may be transferred or accessed outside the EEA as part of marketing activities within the group operating companies of Moxie Tech. For Subscribers who are not resident within the EEA, you should note that there is a probability that your Personal Data will be transferred outside your country of residence. If you have any questions in relation to this, please contact the Data Protection Officer at info@moxitech.net.

Purpose of Collection, Processing and Disclosure

The Personal Data provided by Customers will be used by Moxie Tech for the purposes of processing for any one or more of the following purposes:

• To enable the Moxie Tech Clients to identify and/or verify the identity of the Customers in accordance with applicable International Anti Money Laundering regulations;
• To disclose to the Moxie Tech Clients by way of restricted access to the solution, to enable them to verify the identity of their Customers in accordance with applicable International Anti Money Laundering regulations;
• For any other specific purposes requested by the Moxie Tech Clients; or
• To comply with legal and regulatory obligations applicable to the Moxie Tech Clients.

Personal Data provided by Subscribers will be used by Moxie Tech to provide marketing information and news updates to the Subscribers about our business and industry news.

Data Security

Moxie Tech undertakes to adhere to best practice in terms of security of the Personal Data collected. All systems use a Role Based Access Control with enforced multi-factor authentication. All data at rest is secured using 256 bit AES encryption as well as SSL/TLS is used for data in transit.

Cookies

A cookie is a piece of information in the form of a very small text file that is placed on an internet user’s hard drive. It is generated by a web page server, which is basically the computer that operates a web site. The information the cookie contains is set by the server and it can be used by that server whenever the user visits the site. A cookie can be thought of as an internet user’s identification card, which tells a web site when the user has returned.

When visiting our website you will be asked to provide consent to the use of cookies. We use cookies for web analytics purposes to understand our website usage by all visitors to our website, to improve the content and offerings on our website.

For the purpose of our identity verification services, when the Customer or Subscriber provides Personal Data to us through the submission of information, forms or documents (in whatever format) through an upload to our website, use of our mobile application or otherwise, cookies that we use enable us to identify the internet protocol address which is classed as pseudonymous identifier and therefore a form of Personal Data. In accepting the content of this Privacy Statement upon the upload of information, you are consenting to the use of cookies for this purpose.

The Customers, Subscribers and all users of our website may at any time withdraw their consent to the use of cookies by sending a request to the Data Protection Officer at info@moxitech.net. Alternatively you may wish to disable cookies on this website. This can be done by consulting the help section of your browser or taking a look at www.aboutcookies.org which offers guidance for all modern browsers.

Rights of the Data Subject

GDPR provides data subjects with the following rights:

• The right to access their own Personal Data;
• The right to have their Personal Data rectified if it is inaccurate or incomplete;
• The right to request deletion or removal of their Personal Data where there is no good reason for processing to continue;
• The right to restrict processing of their Personal Data;
• The right to data portability to enable the moving, copying or transferring of Personal Data from one platform to another;
• The right to object to the processing of their Personal Data in certain circumstances; and
• Rights relating to profiling and automated decision making resulting from the processing of their Personal Data.

For Customers, these rights are exercisable against the Moxie Tech Client and any queries should be directed to the relevant contact as per the privacy statement of the Moxie Tech Client.

Subscribers may exercise these rights by  sending a request to the Data Protection Officer at Moxie Tech at info@moxitech.net.

Subscribers may also unsubscribe from any future communications from Moxie Tech by selecting the unsubscribe option in our email correspondence.

Acceptance of Terms

Please note that by downloading, installing or using our mobile application for the upload of Personal Data, or by uploading Personal Data via a Moxie Tech webpage, or a marketing automation platform, you are accepting the practices described in this Privacy Statement and agree to the processing of your Personal Data by Moxie Tech as described in this document.

For Subscribers who are a resident of the EEA, in acceptance of these terms you are providing explicit consent to Moxie Tech for the processing of the Personal Data to comply with GDPR and that in giving your consent, and uploading the Personal Data, you are agreeing to the processing of the Personal Data by Moxie Tech for the purposes as set out in the sign-up form submitted to Moxie Tech, and that in giving such consent, your Personal Data may be transferred outside of the EEA to other companies within the Moxie Tech group for marketing purposes.

Amendments or Updates to this Privacy Statement

Moxie Tech reserves full rights to amend or update this Privacy Statement unilaterally from time to time as it sees fit or necessary to meet any change in any of the relevant laws or the regulatory environment, or business needs, or to satisfy the needs of stakeholders in the business. Updated versions will be posted to the Moxie Tech website and date stamped so that you are always aware of when the Privacy Statement was last updated. The whole content of this Privacy Statement will then be construed accordingly in conjunction with such amended or updated versions.