1. Information Collection

When the User uses the Platform, the User may provide MAELLE with information about the User. This may include but not limit to the User’s name and contact information, address, preferences and answers to questionnaires (which MAELLE is entitled to use at MAELLE’s sole discretion). When the User uses the Platform, MAELLE may also collect information related to the use of the Platform and aggregate this with information about other Users. The User may also provide MAELLE with information about the User’s contacts or friends.

  • Personal Information: In the course of using the Platform whether, MAELLE may require or otherwise collect information and/or documentation that identifies the User as a specific individual and any information and/or documentation concerning an identified or identifiable natural person, and that can be used to contact or identify the User (“Personal Information”). Examples of Personal Information may include the User’s name, email address, company address, billing address, photographs, identification documents and phone number.
  • Biometric Identifiers or Platform Interaction Information: MAELLE may collect Personal Information such as a photograph of the User’s face, a selfie, or data about the User’s interactions with the Platform to verify the User’s identity and to detect fraud, identity theft, or other misuse of the User’s account through the use of facial recognition and other technologies. MAELLE may request documents to verify this information, such as a copy of the User’s government-issued identification. From time to time, MAELLE may require the User to take and submit an additional or updated image of the User’s face for comparison to the User’s government-issued identification. The biometric identifiers or information collected are used only for identity verification and Platform security and use integrity purposes.
  • Non-Identifying Information/Usernames: MAELLE also may collect other information, such as zip codes, demographic data, information regarding the User’s use of the Platform, and general project-related data (“Non-Identifying Information”). MAELLE may aggregate information collected from registered and non-registered Users. In some cases, MAELLE may render Personal Information (generally, email address) into a form of Non-Identifying Information referred to in this Privacy Policy as “Hashed Information.” This is typically accomplished using a mathematical process (commonly known as a hash function) to convert information into a code. The code does not identify the User directly, but it may be used to connect the User’s activity and interests.
  • Combination of Personal and Non-Identifying Information: Certain Non-Identifying Information would be considered a part of the User’s Personal Information if it were combined with other identifiers in a way that enables the User to be identified (for example, combining information with the User’s name). But the same pieces of information are considered Non-Identifying Information when they are taken alone or combined only with other non-identifying information. MAELLE may combine the User’s Personal Information with Non-Identifying Information, but MAELLE will treat the combined information as Personal Information.

2. User Profiles

The User will have a profile, which consists of information about the User, and may include Personal Information, photographs, education, skills, tests taken, test scores, hourly pay rates and earnings information, feedback/rating information and other information, including the User’s username (“Profile”). The information in the User Profile may be visible to all Users and the general public subject to the privacy choices the User make within the Profile. The User may edit certain information in the Profile via the User’s account and may choose to limit who is able to view certain content.

3. Identity Verification

MAELLE may take steps to verify the User’s identity. Before a User can complete registration on the Platform, or at any time thereafter, MAELLE may request or re-request identity verification. Without limiting the manner in which MAELLE request identify verification, MAELLE may require Users to participate in a video call after submitting their government issued ID to enable MAELLE to confirm that the User is indeed the individual in the ID. MAELLE may record such video calls and take screenshots of the user during the call. MAELLE may use the information obtained from Identity Verification for purposes of verifying the User’s identity, enforcing the Terms of Use and other agreements, and preventing fraud.

4. Feedback

MAELLE collect public and private feedback from Users about their experience with the Platform. Please note that any public feedback that the User provide via the Platform about the User’s experience with other Users or that is provided about the User by other Users is publicly viewable via the Platform. MAELLE uses this information to respond to the User’s inquiries, improve the Platform and develop new products and features.

5. Use of Information

MAELLE uses information collected through the Platform to:

  1. Provide and improve the Platform, process the User’s requests, prevent fraud, provide the User with information and advertising that may interest the User, comply with the law, and as otherwise permitted with the User’s consent.
  2. Provide and improve the Platform, complete the User’s transactions, address the User’s inquiries, process the User’s registration, verify the information the User provide is valid, and for compliance and internal business purposes.
  3. To administer and develop business relationship with the User and, if applicable, the corporation or other legal entity the User represent.
  4. To enforce and comply with the law, including to conduct an investigation, to protect the property and rights of MAELLE or a third party, to protect the safety of the public or any person, or to prevent or stop activity MAELLE may consider to be, or to pose a risk of being, illegal, fraudulent, unethical or legally actionable activity.
  5. Transmit, in any way and by any means, whether onerous or not (including the sale of certain information pursuant to any applicable laws), to whom MAELLE deems appropriate, ensuring that it is done safely, certain information collected, avoiding transmitting Personal Information.

7. Data Retention

Unless the User requests that MAELLE deletes certain information, MAELLE retains government-issued identification documents the User submit to verify the User’s identity for 30 days, selfies the User submit to verify the User’s identity for 180 days, a copy of the headshot image from the User’s identity document for 3 years, and other information MAELLE collects for at least 5 years. The User’s information may persist in copies made for backup and business continuity purposes for additional time. If the User chooses to provide MAELLE with Personal Information, MAELLE encourages the User to routinely update the data to ensure that MAELLE has accurate and up-to-date information about the User.

The User can review and change the User’s Personal Information by logging into the Platform and visiting the User’s account profile page.

MAELLE will not be obliged to delete the Personal Information when:

  • It refers to the parties of a private, social or administrative contract and it is necessary for its development and compliance;
  • It must be treated by legal provision;
  • It obstructs judicial or administrative actions related to tax obligations, the investigation and prosecution of crimes or the updating of administrative sanctions;
  • Is necessary to protect the legally protected interests of its owner;
  • Is necessary to carry out an action based on the public interest;

8. Legal and Investigative Purposes

MAELLE will share information with government agencies as required by law in response to lawful requests by public authorities, including to meet national security or law enforcement requirements and, including without limitation, in connection with reporting earnings. MAELLE cooperates with government and law enforcement officials and private parties to enforce and comply with the law. MAELLE will disclose information about the User to government or law enforcement officials or private parties as MAELLE, in its sole discretion, believes necessary or appropriate to respond to claims and legal process (including but not limited to subpoenas), or, at the request of governmental authorities or other third parties conducting an investigation where MAELLE determines in its sole discretion the disclosure is necessary to (a) protect the property and rights of MAELLE or a third party, (b) protect the safety of the public or any person, or (c) prevent or stop activity MAELLE may consider to be, or pose a risk of being, illegal, fraudulent, unethical or legally actionable activity. These provisions will remain in effect even if MAELLE sells or assigns its rights to the Platform.

9. Changes To This Policy

MAELLE may change this Privacy Policy. If MAELLE makes substantial changes, MAELLE will provide notice.

MAELLE may update this Privacy Policy at any time and any changes will be effective upon posting. In the event that there are substantial changes to the way MAELLE treat the User’s Personal Information, MAELLE will display a notice through the Platform prior to the change becoming effective. MAELLE may also notify the User by email. However, MAELLE will use the User’s Personal Information in a manner consistent with the Privacy Policy in effect at the time the User submitted the information, unless the User consents to the new or revised policy.

10. User’s Rights

Under the General Data Protection Regulation and the UK GDPR, the User has a number of important rights free of charge. In summary, those include rights to:

  • access to the User’s personal data and to certain other supplementary information that this Privacy Policy is already designed to address;
  • require MAELLE to correct any mistakes in the User’s information which MAELLE holds;
  • require the erasure of personal data concerning the User in certain situations;
  • receive the personal data concerning the User which the User has provided to MAELLE, in a structured, commonly used and machine-readable format and have the right to transmit those data to a third party in certain situations;
  • object at any time to processing of personal data concerning the User for direct marketing;
  • object to decisions being taken by automated means which produce legal effects concerning the User or similarly significantly affect the User;
  • object in certain other situations to MAELLE continued processing of User’s personal data;
  • otherwise restrict MAELLE from processing the User’s personal data in certain circumstances;
  • claim compensation for damages caused by MAELLE’s breach of any data protection laws.