TransparentBusiness Private Debt

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TransparentBusiness Group Privacy Policy (“Privacy Policy”) is effective as of March 29, 2021. Please note that this Privacy Policy will regularly be updated to reflect any changes in the way we handle your personal data or any changes in applicable laws.

1. SCOPE

This Privacy Policy tells you everything you need to know about how TransparentBusiness Inc., Yandiki Inc., Sheworks Inc., and/or its affiliates, subsidiaries and newly acquired companies (indistinctively "TB" or "we") protect the personal data we process and control relating to you (“your personal data”; "your data") and which rights you have in relation to the processing of your personal data.

However, if you are a California resident, please see our specific California-Residents Privacy Policy (“California Privacy Policy”) in this link. If you are a California resident, you have specific privacy rights under the California Consumer Privacy Act (“CCPA”).

2. GENERAL DESCRIPTION OF HOW TB PROTECTS YOUR PERSONAL DATA

It is of great importance to TB, your right to privacy, and the protection of your personal data. We want you to trust that your personal data is secure, and it is in good hands when you deal with TB.

TB protects your personal data in accordance with applicable laws and our Privacy Policy. In addition, TB maintains the best technical and organizational measures to protect your personal data against unauthorized or unlawful processing and/or against accidental loss, alteration, disclosure, or access, or accidental or unlawful destruction of or damage thereto.

2.1. Which categories of personal data do we collect and how do we process such personal data?

The personal data collected comes from, but is not limited to, our employees, potential employees, clients, suppliers, business contacts, partners, ambassadors, shareholders, and website users (the “individuals). If the data we collect is not listed in this Privacy Policy, we will give individuals (when required by law) appropriate notice of which other data will be collected and how they will be used. However, all individuals shall be deemed to have accepted this Privacy Policy by using or entering any of the TB websites.

The personal data we collect includes the categories of personal data referred to in this Privacy Policy or in other statements you have received.

If we learn that any information, we collect has been provided by a child under the age of 13, we will promptly delete that information.

Below is also a chart describing the categories of personal data we collect:

GENERAL CATEGORIES
Category of personal information	Types of personal information captured by category
Personal details, contact details, and identifiers.	Name, pronoun, all types of identifiers and contact details (such as e-mail, phone numbers, physical address), gender, date of birth, age, place of birth.
Commercial information.	History and records of the services and softwares you have obtained from TB.
Marketing and research information	Identifiers – the IP address, social media handle or other online identifiers of a person, e-mail address/mobile number if used for direct marketing, and name and address. Demographic data - (e.g., income, family status, age bracket, gender, interests, pets, home ownership, health, current service providers) Browser/web history data and preferences expressed through selection/viewing/purchase of goods, services, and content. Social media content – blogs, posts and anything posted by an individual online or which mentioned/references an individual. Analytics and profiles of the individuals based on the data collected on them
Sensitive data and biometric information.	TB may also collect certain types of sensitive information when permitted by local law or with your consent, such as health/medical information (including disability status and dietary requirements/allergies in the framework of the events we organize/sponsor) or biometric information, for example as when you elect to use fingerprint authentication.
Audiovisual materials.	Photograph, and images/footage captured/recorded on CCTV or other audio, video and related security monitoring systems or captured during marketing/public filming events/sessions (including recording of virtual or live workshops or similar events/sessions).
Position and professional or employment-related information.	Professional or employment-related information, such as description of current position, job title, employer, location, and TB contact(s).
System and application access data and Internet and electronic network activity information.	Where you are provided with access to TB’s systems, TB may collect information required to access such TB systems and applications such as System ID, LAN ID, e-mail account, instant messaging account, mainframe ID, system passwords, and internet or other electronic network activity information, including access logs, activity logs, and electronic content produced using TB systems.
Cookies and geolocation data	As described below, we also may collect geolocation data in some circumstances. Please see our Cookies Policy for more details regarding our use of cookies.

In addition, for recruitment/employment and vendor selection purposes, TB may process the personal information set out in the below table.

RECRUITMENT/EMPLOYMENT/VENDOR SELECTION CATEGORIES
Category of personal information	Types of personal information captured by category
Additional personal details, contact details and identifiers.	In addition to the personal details listed above, TB may collect additional personal details such as, but not limited to, national identification number, social security number, insurance information, marital/civil partnership status, domestic partners, dependents, emergency contact information, and military history.
Education information and professional or employment-related information.	TB may collect information about your education and professional or employment-related information, such as your employment history.
Sensitive data for recruitment purposes.	TB may collect certain types of sensitive information when permitted by local law or with your consent, such as health/medical information (including disability status), trade union membership information, religion, race or ethnicity, minority flag, and information on criminal convictions and offences. TB collects this information for specific purposes, such as health/medical information to accommodate a disability or illness (subject to legal limits on the timing of collection of such information and other applicable limitations) and to provide benefits; background checks and diversity-related personal information (such as race or ethnicity) in order to comply with legal obligations and internal policies relating to diversity and anti-discrimination.
Documentation required under immigration laws.	TB may collect data on citizenship, passport data, and details of residency or work permit (a physical copy and/or an electronic copy).
Financial information for payroll/benefits purposes	Your banking, tax (when applicable), and other relevant financial details we need for payroll/benefits purposes.
Talent management information.	Information necessary to complete a background check, details on performance decisions and outcomes, performance feedback and warnings, e-learning/training programs, performance, and development reviews (including information you provide when asking for/providing feedback, creating priorities, updating your input in relevant tools), driver’s license and car ownership information, and information used to populate biographies.
Requested recruitment information	Information requested to provide during the recruitment process, to the extent allowed by applicable law.
Recruitment information you submit	Information that you submit in résumés/CVs, letters, writing samples, or other written materials (including photographs).
Information generated by us during recruitment	Information generated by interviewers and recruiters related to you, based on their interactions with you or basic Internet searches where allowed under applicable law.
Recruitment information received from third parties	Information related to you provided by third-party placement firms, recruiters, or job-search websites, where applicable.
Audiovisual information processed during recruitment	Photograph, and images/audio/footage captured on CCTV or other video systems when visiting our office or captured during recruitment events or video recruitment interviews.
Recommendations	Recommendations related information provided on your behalf by others.
Employment history and background checks	Information about your prior employment, education, and where applicable and allowed by applicable law, credit history, criminal records or other information revealed during background screenings.
Diversity related information	Information about race / ethnicity / religion / disability / gender and self-identified LGBT status, for purposes of government reporting where required by law, as well as to understand the diversity characteristics of the TB workforce, subject to legal limits.
Assessment information	Information generated by your participation in psychological, technical, or behavioral assessments. You will receive more information about the nature of such assessments before your participation in any of them.

We also may derive inferences about you based on the information described above and collect other information about you as described in this Privacy Policy.

If you provide us with personal information of another person (for instance, a potential employee/referral), you are responsible for ensuring that such person is made aware of the information contained in this Privacy Policy and that the person has given you his/her consent for sharing the information with TB.

The above-mentioned categories of personal data have been obtained either directly from you (for example, when you provide information to be contacted, register as a user or become a partner) or indirectly from certain third parties (for example, through our website’s technology). Such third parties include our affiliates, public authorities, public websites and social media, suppliers, and vendors. Except where certain information is required by law or by TB policies (including management of an employment relationship with TB), your decision to provide any personal data to us is voluntary. Please note that if you do not provide certain information, we may not be able to accomplish some or all of the purposes outlined in this Privacy Policy, and you may not be able to use certain tools and systems which require the use of such personal data.

2.2. For which purposes and on which legal basis do we use your personal data?

TB uses your personal data only where required for specific purposes. Please view the table below for (i) a list of the purposes for which TB uses your personal data and (ii) an overview of the legal basis for each such purpose.

Purpose	Legal basis
Managing our contractual and/or employment relationship with you.	Necessary for the performance of a contract to which you are a party.
Facilitating communication with you (including in case of emergencies, and to provide you with requested information).	Justified based on our legitimate interests for ensuring proper communication and emergency handling within the organization.
Operating and managing our business operations.	Justified based on our legitimate interests for ensuring the proper functioning of our business operations.
Complying with legal requirements.	Necessary for the compliance with a legal obligation to which we are subject.
Monitoring your use of our systems (including monitoring the use of our website and any apps and tools you use).	Justified based on our legitimate interests of avoiding non-compliance and protecting our reputation.
Social listening (Identifying and assessing what is being said about TB and our clients on social media (only publicly accessible content) to understand sentiment, intent, mood and market trends and our stakeholders’ needs and thereby improving our services. We do this through key-word searches and our goal is to gain insights in conversation trends over a specified period and not to identify an individual. To achieve this, we analyze and monitor conversation streams and monitor publicly available opinions, statements, or other interactions on social media channels.	Justified based on of our legitimate interest of protecting our assets and our brand on social media.
Improving the security and functioning of our website, networks, and information.	Justified based on our legitimate interests for ensuring that you receive an excellent user experience and our networks and information are secure.
Undertaking data analytics, i.e., applying analytics to business operations and data to describe, predict and improve business performance within TB and/or to provide a better user experience.	Justified based on our legitimate interests for ensuring the proper functioning of our business operations.
Marketing our products and services to you	Justified based on our legitimate interests for ensuring that we can conduct and increase our business.
Specific Recruitment/Employment/Vendor selection Purposes	Legal basis
Assess your suitability for employment for the role for which you are applying, as well as future roles that may become available.	Justified based on TB’s legitimate interests of ensuring that it recruits the appropriate employees.
Manage your application.	Justified based on TB’s legitimate interests of ensuring that it recruits the appropriate employees.
Facilitate communication with you.	Justified based on TB’s legitimate interests of ensuring proper communication within the organization and with you.
Perform administrative functions (e.g., reimburse you for interview-related expenses).	Justified based on TB’s legitimate interests of ensuring that it recruits the appropriate employees.
Perform data analytics, including analysis of our applicant pool to better understand who is applying to positions at TB and how to attract and keep top talent.	Justified based on TB’s legitimate interests of ensuring that it continually improves its recruitment processes.
In some cases, record your online interview for review by additional recruiters and hiring managers.	Justified based on TB’s legitimate interests of ensuring that it recruits the appropriate employees.
If you apply for a position in TB, we may enter you into a database to receive future mailings about TB positions and events. You may also receive personalized job recommendations.	Justified based on TB’s legitimate interests of ensuring that it recruits the appropriate employees.
Transfer your contact information, education data, employment data, application information and the CV, all as supplied by you to us to our HR team in order to notify you about new positions that may be of interest to you.	Justified based on TB’s legitimate interests of ensuring that it recruits the appropriate employees.
Administration of employee benefits	Justified based on TB’s legitimate interests of ensuring that our employees receive the applicable benefits.
Perform any legally required reporting and respond to legal process.	Compliance with a legal obligation.

Legitimate interest means that TB has reasonable grounds to process your personal information. Where the above table states that we rely on our legitimate interests for a given purpose, we are of the opinion that our legitimate interests are not overridden by your interests, rights, or freedoms, given (i) the transparency we provide on the processing activity, (ii) our privacy by design approach, (iii) our regular privacy internal reviews and (iv) the rights you have in relation to the processing activity.

We will process your personal information for the purposes mentioned above based on your prior consent, to the extent such consent is mandatory under applicable laws. To the extent you are asked to click on/check “I accept”, “I agree” or similar buttons/checkboxes/functionalities in relation to one of our privacy policies, doing so will be considered as providing your consent to process your personal information, only where such consent is required by mandatory law.

We will not use your personal information for purposes that are incompatible with the purposes of which you have been informed, unless it is required or authorized by law, or it is in your own vital interest (e.g. in case of a medical emergency) to do so.

2.3. Will we share your personal data with third parties?

We may transfer personal data to our service providers and professional advisors, public and governmental authorities, TB companies/affiliates or third parties in connection with TB’s operation of its business, including any (potential) corporate or commercial transaction. Such third parties may be located in other countries. Before we do so, we shall take the necessary steps to ensure that your personal data will be given adequate protection as required by relevant data privacy laws and TB’s internal policies. TB may also transfer your personal data to any of its global affiliates/partners in furtherance of any visits to our TB locations.

For example, we may disclose personal information to third parties for other business purposes as follows:

We share your information with third-party service providers that provide services to us, including billing, payment processing, customer service, email deployment, advertising and marketing, security and performance monitoring, maintaining or servicing accounts, processing or fulfilling orders and transactions, verifying customer information, research, data hosting, auditing, and data processing;
To protect and defend the legal rights, safety, and security of TB, our affiliates, users, or the public, including to protect against fraud and malicious activity;
For other business purposes described in this Privacy Policy or for any other purpose disclosed to you at the time we collect the information or pursuant to your consent; and
In connection with a substantial corporate transaction, such as the sale of a website, a merger, consolidation, asset sale, initial public offering, or in the unlikely event of a bankruptcy.

Unless you are otherwise notified, any transfers of your personal data from within the European Economic Area (EEA) to third parties outside the EEA will be based on an adequacy decision or are governed by the standard contractual clauses. Any other non-EEA related transfers of your personal data will take place in accordance with the appropriate international data transfer mechanisms and standards.

2.4. What about sensitive data?

We do not generally seek to collect sensitive data (as defined in the second below) (also known as special categories within the EEA). In the limited cases where we do seek to collect such data, we will do this in accordance with data privacy law requirements and/or ask for your consent.

The term "sensitive data" refers to the various categories of personal data identified by data privacy laws as requiring special treatment, including in some circumstances the need to obtain explicit consent from you. These categories include racial or ethnic origin, political opinions, religious, philosophical or other similar beliefs, membership of a trade union, physical or mental health, biometric or genetic data, sexual life or orientation, or criminal convictions and offences (including information about suspected criminal activities).

2.5. What about data security?

We maintain organizational, physical, and technical security arrangements for all the personal data we hold. We have protocols, controls and relevant policies, procedures, and guidance to maintain these arrangements considering the risks associated with the categories of personal data and the processing we undertake.

2.6. Where will your personal data be processed?

As a global organization with offices and operations throughout the world, personal data we collect may be transferred or be accessible internationally throughout TB's global business and between its entities and affiliates.

Any such transfers throughout TB’s global business take place in accordance with applicable data privacy laws.

2.7. What are the sources we get your personal information from?

If we do not obtain your personal information directly from you, we may obtain it from the following sources: publicly available sources (registers or the internet), TB’s actual and potential employees, contractors, partners, investors, members of board of directors, shareholders, TB’s affiliates, subsidiaries and newly acquired businesses, employers of our contractors, public authorities, public websites and social media, previous employers, educational institutions, suppliers and vendors (including third party data providers).

2.8. How long will your personal data be retained by us?

We will retain your personal data only for as long as is necessary. We maintain specific records management and retention policies and procedures, so that personal data are deleted after a reasonable time according to the following retention criteria:

We retain your data if we have an ongoing relationship with you. This includes, for example, TB’s actual and potential employees, contractors, partners, investors, members of board of directors, shareholders, TB’s affiliates, subsidiaries and newly acquired businesses, employers of our contractors.
If you have a user account with us, we will only keep the data while your account is active or for as long as needed to provide services to you.
We retain your data for as long as needed to comply with applicable law and with our global legal and contractual obligations.

2.9. Which rights do you have with respect to the processing of your personal data?

You are entitled (in the circumstances and under the conditions, and subject to the exceptions, set out in applicable law) to:

Request access to the personal data we process about you: this right entitles you to know whether we hold personal data about you and, if we do, to obtain information on and a copy of that personal data.
Request a rectification of your personal data: this right entitles you to have your personal data be corrected if it is inaccurate or incomplete.
Object to the processing of your personal data: this right entitles you to request that TB no longer processes your personal data.
Request the erasure of your personal data: this right entitles you to request the erasure of your personal data, including where such personal data would no longer be necessary to achieve the purposes.
Request the restriction of the processing of your personal data: this right entitles you to request that TB only processes your personal data in limited circumstances, including with your consent.
Request portability of your personal data: this right entitles you to receive a copy (in a structured, commonly used and machine-readable format) of personal data that you have provided to TB, or request TB to transmit such personal data to another data controller.
To the extent that the processing of your personal data is based on your consent, request the withdrawal of such consent at any time. Please note that this will not affect TB’s right to process personal data obtained prior to the withdrawal of your consent, or its right to continue parts of the processing based on other legal bases than your consent.

If, despite our commitment and efforts to protect your personal data, you believe that your data privacy rights have been violated, we encourage and welcome individuals to come to TB first to seek resolution of any complaint. You always have the right to register a complaint directly with the relevant supervisory authority or to make a claim against TB with a competent court (either in the country where you live, the country where you work or the country where you deem that data privacy law has been infringed).

3. HOW DO WE USE PERSONAL DATA WHEN YOU VISIT TB’S WEBSITE?

In addition to the information set out above, this section describes how we use personal data when you visit TB’s website:

3.1. Which personal data do we gather?

TB collects personal data at its websites in two ways: (1) directly (for example, when you provide personal data to sign up as a user, register as an investor or as an ambassador or provide contact information); and (2) indirectly (for example, through our website's technology).

We may collect and process the following personal data:

Personal data that you provide by filling in forms on our website. This includes registering to use the website, subscribing to services, registering as an investor, registering as an ambassador, newsletters, and alerts, or requesting further information. It is completely up to you whether you want to provide it.
If you contact us, we may keep a record of that correspondence.
We may ask you to complete surveys that we use for research purposes, although you do not have to respond to them.
Any postings, comments, or other content that you upload or post to a TB website.
Our website collects personal data about your computer, including (where available) your IP address, operating system, and browser type, for system administration, to filter traffic, to look up user domains and to report on statistics.
Details of your visits to our website, the pages you view and resources you access or download, including but not limited to, traffic data, location data, web logs and other communication data. Please see the Cookies Policy for more information.

3.2. Do we include (links to) websites and programs of third parties?

Our websites may include:

Links to and from the sites of our partner networks, advertisers, and affiliates.
Certain programs (widgets and apps) of third parties. Where this is the case, note that such third parties may process your personal data collected through such programs for their own purposes. We do not accept any responsibility or liability for such third parties’ sites or programs. Please check such third parties’ terms of use and privacy statements before using and providing any information to such third parties’ sites and programs.

3.3. How do we use personal data that we collect from our websites?

We use personal data for the purposes described in section 2.2 above, as well as to provide you with information you request, process user accounts, create investor and partners profiles.

We also analyze your IP and browser information to determine what is most effective about our website, to help us identify ways to improve it, make it more effective and, eventually, to determine how we can tailor our website to make it a more positive and relevant user experience.

By using our website, you agree that we can place cookies and other similar technologies on your device as explained in our Cookies policy.

4. HOW DO WE USE PERSONAL DATA FOR MARKETING PURPOSES?

In addition to the information set out above, this section describes how we use personal data for marketing purposes:

4.1. Do we send targeted e-mails?

We send commercial e-mail to individuals at our client or other companies with whom we want to develop or maintain a business relationship in accordance with applicable marketing laws. Our targeted e-mail messages typically include web beacons, cookies, and similar technologies that allow us to know whether you open, read, or delete the message, and links you may click. When you click a link in a marketing e-mail you receive from TB, we will also use a cookie to log what pages you view and what content you download from our websites, even if you are not registered at or signed into our site.

Targeted e-mails from TB may include additional data privacy information, as required by applicable laws.

4.2. Do we maintain Customer Relationship Management (CRM) databases?

Like most companies, TB uses customer relationship management (CRM) database technology to manage and track our marketing efforts. Our CRM databases include personal data belonging to individuals at our client and other companies with whom we already have a business relationship or want to develop one. The personal data used for these purposes includes relevant business information, such as: contact data, publicly available information (e.g. board membership, published articles, press releases, your public posts on social media sites if relevant for business purpose), your responses to targeted e-mail (including web activity following links from our e-mails), website activity of registered users of our website, and other business information included by TB professionals based on their personal interactions with you.

4.3. Do we combine and analyze personal data?

We may combine data from publicly available sources, and from our different e-mail, website, and personal interactions with you (this includes information collected across our different websites and information collected when you sign-up or log on to our sites or connect to our sites using your social media credentials (such as LinkedIn). We combine this data to better assess your experience with TB and to perform the other activities described throughout our privacy policy.

4.4. Do we share personal data with third parties?

In addition to the third parties mentioned in section 2.3. above, we may share your personal data with marketing agencies and service providers.

4.5. What are your rights regarding marketing communications?

You can exercise your right to prevent marketing communications to you by not checking certain boxes on the forms we use to collect your personal data, or by utilizing opt-out mechanisms in e-mails we send to you.

You can exercise the right to discontinue marketing communications to you, or to have your personal data removed from our customer relationship management (CRM) databases at any time by communicating to the link indicated in section “6. CONTACT” below. In such cases, we will retain minimum personal data to note that you opted out to avoid contacting you again.

5. HOW DO WE USE PERSONAL DATA FOR PRODUCTION ACTIVITIES?

In addition to the information set out above, this section describes how we use personal data in connection with content creation/production purposes.

Some TB entities are in the business of content production. We may process your personal data for these TV, film, marketing, advertising or other related content creation, production, and distribution activities.

The personal data that we process for production purposes include images and footage of you and may include your location at the time of filming.

If you are a member of public, we will diligently attempt to make you aware of our location and filming activities in advance and will give you an opportunity not to enter the location where filming is taking place and participate in them.

If you are a focus of our filming activities (i.e. a contributor or talent such as an interviewee, extra or actor, as opposed to a member of public) we will also collect and process your name, contact information and any other information provided in any pre-filming questionnaires and/or release forms, such as next of kin details.

We may also collect and process special categories of data a such as health or disability information to the extent that this is necessary to enable us to make any necessary adjustments to our filming arrangements to assist or support you.

6. CONTACT US

Please send an email to [email protected] if:

You have a general question about how TB protects your personal data.
You wish to exercise your rights in relation to your personal data rights.
You wish to make a complaint about TB’s use of your data.

LAST UPDATED: March 29, 2021

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