Privacy Policy
Last updated on 01.06.2022
1. INTRODUCTION
Welcome to Matrx’s Privacy Policy (the “Policy”).
Matrx (“Matrx”, “Company”, “we”, “us” or “our”) respects your privacy and is committed to protecting your personal data. This Policy will inform you
about how we look after your personal data when you interact with or purchase our products and services on our
website
https://www.matrx.io and our mobile application Matrx (together, the “Site”) regardless of where you visit or access them from and tell you about your privacy rights and how the
law protects you.
By using our Site or any of our services, you agree and consent to the use, collection, sharing and other
processing of your data by the Company under this Policy. If you do not agree to this Policy, please
cease from using our Site or Services in any way.
2. IMPORTANT INFORMATION AND WHO WE ARE
Purpose of this Policy
The nature of our Site requires us to collect user personal data. This Policy aims to give you information on
how we collect and process (which may include collecting, storing, using, or disclosing) your personal data
when you use our Site, regardless of your relationship with us (for example, whether you are a licensed or
unregistered user) including any data you may provide when you purchase a product or service.
We will only collect and process your personal data where you have provided your express consent to the
intended purposes of such collection and processing, to the extent possible and required by personal data
protection laws. It is important that you read this Policy together with any other privacy or fair processing
policy we may provide on specific occasions when we are collecting or processing personal data about you so
that you are fully aware of how and why we are using your data. This Policy supplements other notices and
privacy policies and is not intended to override them. You may withdraw your consent at any time in line with
your rights as detailed
here.
Please note that we may process your personal data without your knowledge or consent where this is required or
permitted by law.
Children
This website is not intended for children aged 16 and below and we do not knowingly collect data relating to
children without consent from their parent or guardian. Should you have reasonable grounds to believe we have
collected personal data from a minor without the appropriate consent, you may reach out to us through the
contact details listed below and we will endeavour to investigate the matter immediately.
Controller
Our Company is made up of different legal entities, details of which can be found on the Group’s website
www.tsi.tech. This Policy is issued on behalf of the TSI Group so when we mention DAYPOP TECHNOLOGY PROJECTS
L.L.C., the “Company”, "we", "us" or
"our" in this Policy, we are referring to the relevant company in our Group responsible for
processing your data. DAYPOP TECHNOLOGY PROJECTS L.L.C. is the controller responsible for this website. Other
companies in the Group may act as joint processors.
We have appointed a data protection officer (DPO) who is responsible for overseeing questions in relation to
this Policy. If you have any questions about this Policy, including any requests to exercise your legal
rights, please contact the DPO using the details set out below.
Contact Details
Full name of legal entity: DAYPOP TECHNOLOGY PROJECTS L.L.C.
Email address:
contact@matrx.io.
Postal address: 38 Beach Road, #17-11 South Beach Tower, Singapore 189767
Telephone number: +65 6272 9924
You also have the right to make a complaint at any time to your local data protection regulator regarding this
Policy and our personal data related practices. You may contact your local data protection authority for more
information. We would, however, appreciate the chance to deal with your concerns before you approach the
relevant authority so please contact us in the first instance.
Changes to the Policy and Your Duty to Inform Us of Changes
We keep our privacy policies under regular review to reflect any changes in our Site and our personal data
processing mechanisms and safeguards. Subsequent updates to this Policy will be available on the Site and will
be indicated as such. You will be notified of any substantial changes to this Policy for your perusal prior to
continuing your engagement with us.
It is important that the personal data we hold about you is accurate and current. Please keep us informed if
your personal data changes during your relationship with us.
Third-Party Links
Although this is currently not the case, our Site may include links to third-party websites, plug-ins and
applications in the future. Clicking on those links or enabling those connections may allow third parties to
collect or share data about you. We do not control these third-party websites and are not responsible for
their privacy statements. When you leave our Site, we encourage you to read the privacy policy of every
website you visit.
3. THE DATA WE COLLECT ABOUT YOU
Personal data, or personal information, means any information about an individual from which that person can
be identified, and in some jurisdictions include information pertaining to deceased individuals. It does not
include data where the identity has been removed (anonymous data).
Where applicable to the product, we may collect and process different kinds of personal data about you which
we have grouped together as follows:
- Identity Data includes first name, last name, username or similar identifier and
title.
- Contact Data includes billing address, delivery address, email address and telephone
numbers.
- Financial Data includes bank account and payment card details.
- Transaction Data includes details about payments to and from you and other details of
products and services you have purchased from us.
- Technical Data includes information regarding the device used to interact with our
Site such as internet protocol (IP) address, WIFI and Bluetooth data, your login details, browser type and
version, time zone setting and location, browser plug-in types and versions, operating system and platform,
and other technology on the devices you use which may include data regarding your microphone, camera and
speakers.
- Settings Data includes preferences set by you on the customisable configurations of
our Site.
- Profile Data includes details collected when you host or join a virtual meeting,
webinar or collaboration such as your username and password, display picture, purchases or orders made by
you, your interests, preferences, feedback and survey responses.
- Contacts Data includes contact information added by users, including those imported
and integrated from third-party apps, to create contact lists on the Site.
- Product Usage Data includes information regarding when and how you use or interact
with our Site, user behavior, meeting metadata and the content generated in virtual meetings conducted on
the Matrx platforms, conversations and chats, responses to polls, files shared, features utilised as well as
any meeting invitation and contextual details which may comprise of your voice and image. This also includes
all user inputs which assist us in maintaining and further developing the features of our Site.
- Marketing and Communications Data wherein marketing data includes your preferences in
receiving marketing materials from us and our third parties, and communications data refers to your
preferences with regards to receiving Site support and updates from us.
- Third-Party Data derived from third-party service providers engaged in market data
enrichment and advertising services includes information such as the nature and size of our individual and
corporate account holders as well as user responses to advertisements presented on the Site, if any.
We also collect, use and share Aggregated Data such as statistical or demographic data
for any purpose. Aggregated Data could be derived from your personal data but is not considered personal data
in law as this data will not directly or indirectly reveal your identity. For example, we may aggregate your
Usage Data to calculate the percentage of users accessing a specific website feature. However, if we combine
or connect Aggregated Data with your personal data so that it can directly or indirectly identify you, we
treat the combined data as personal data which will be used in accordance with this Policy.
We do not collect any Special Categories of Personal Data about you (this includes
details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation,
political opinions, trade union membership, information about your health, and genetic and biometric data).
Nor do we collect any information about criminal convictions and offences.
If You Fail to Provide Personal Data
Where we need to collect personal data by law, or under the terms of a contract we have with you, and you fail
to provide that data when requested, we may not be able to perform the contract we have or are trying to enter
into with you (for example, to provide you with goods or services). In this case, we may have to cancel a
product or service you have with us but we will notify you if this is the case at the time. For more
information, please see our
Terms of Service.
4. HOW IS YOUR PERSONAL DATA COLLECTED?
We use different methods to collect data from and about you including through:
5. HOW WE USE YOUR PERSONAL DATA
We will only collect and use your personal data where the law allows us subject to receiving your express
consent. Most commonly, we will use your personal data in the following circumstances:
-
Where we need to perform the contract we are about to enter into or have entered into with you, which
includes the provision of products and services to you as well as the users you have invited to our Site. In
doing so, we will use personal data to execute the provision of meetings, calls and collaborations with
other users on the platform, customise product features in line with user preferences, extend general
customer support and to notify you regarding any changes to our policies, the agreements between you and us
and any further action required.
-
Where it is necessary for our legitimate interests (or those of a third party) and your interests and
fundamental rights do not override those interests. Legitimate interests have been detailed in the table
below on
Purposes for Which We Will Use Your Personal Data and in the
Glossary.
-
Where it is necessary to fulfil our own marketing purposes and those of our third-party partners for the
promotion of our Site. Cookies, server logs and similar technology may also be used to display third-party
advertisements across our Site should we allow our partners to do so in the future. We do not utilise
content created during your use of our Site such as your webinar content, correspondences between
participants and files shared, for any marketing purposes.
-
Where we need to comply with a legal obligation, including but not limited to responding to federal and
local authorities requesting information for the benefit of any legal proceeding regardless of its nature.
Click
here to find out more about the types of lawful bases that we will rely on to process your personal data.
We rely on your clear and express consent as a primary legal basis for processing your personal data,
especially where processing involves sending third-party direct marketing communications to you via email or
text message. You have the right to withdraw consent as listed under
Your Legal Rights at any time by contacting us.
Purposes for Which We Will Use Your Personal Data
We have set out below, in a table format, a description of all the ways we plan to use your personal data and
the legal bases we rely on to do so. We have also identified our legitimate interests where appropriate.
Note that we may process your personal data for more than one lawful ground depending on the specific purpose
for which we are using your data. Please contact us if you need details about the specific legal ground we are
relying on to process your personal data where more than one ground has been set out in the table below.
Purpose/Activity | Type of data | Lawful basis for processing including basis of legitimate interest |
To register you as a new customer | (a) Identity (b) Contact | Performance of a contract with you |
To process and deliver your order including: (a) Manage payments, fees and charges (b) Collect and recover money owed to us | (a) Identity (b) Contact (c) Financial (d) Transaction (e) Marketing and Communications | (a) Performance of a contract with you (b) Necessary for our legitimate interests (to recover debts due to us) |
To manage our relationship with you which will include: (a) Notifying you about changes to our terms or privacy policy (b) Asking you to leave a review or take a survey (c) Responding to your enquiries | (a) Identity (b) Contact (c) Profile (d) Marketing and Communications | (a) Performance of a contract with you (b) Necessary to comply with a legal obligation
(c) Necessary for our legitimate interests (to keep our records updated and to study how customers use
our products/services)
|
To enable you to complete a survey | (a) Identity (b) Contact (c) Profile (d) Usage (e) Marketing and Communications | (a) Performance of a contract with you
(b) Necessary for our legitimate interests (to study how customers use our products/services, to
develop them and grow our business)
|
To administer and protect our business and our Site (including troubleshooting, data analysis,
testing, system maintenance, support, reporting and hosting of data)
| (a) Identity (b) Contact (c) Technical |
(a) Necessary for our legitimate interests (for running our business, provision of administration and
IT services, network security, to prevent fraud and in the context of a business reorganisation or
group restructuring exercise)
(b) Necessary to comply with a legal obligation |
To deliver relevant Site content and advertisements to you and measure or understand the effectiveness
of the advertising we serve to you
| (a) Identity (b) Contact (c) Profile (d) Usage (e) Marketing and Communications (f) Technical |
Necessary for our legitimate interests (to study how customers use our products/services, to develop
them, to grow our business and to inform our marketing strategy)
|
To use data analytics to improve our Site, products/services, marketing, customer relationships and
experiences
| (a) Technical (b) Usage (c) Transaction |
Necessary for our legitimate interests (to define types of customers for our products and services, to
keep our Site updated and relevant, to develop our business and to inform our marketing strategy)
|
To make suggestions and recommendations to you about goods or services that may be of interest to you
| (a) Identity (b) Contact (c) Technical (d) Usage (e) Profile (f) Marketing and Communications (g) Transaction | Necessary for our legitimate interests (to develop our products/services and grow our business) |
Marketing
To the extent required by law, we will obtain your express consent for our (and our third parties’)
marketing purposes. We strive to provide you with choices regarding certain personal data uses, particularly
around marketing and advertising as seen in
Opting Out below.
Promotional Offers from Us
We may use your Identity, Contact, Technical, Usage and Profile Data to form a view on what we think you may
want or need, or what may be of interest to you. This is how we decide which products, services and offers may
be relevant for you (we call this marketing).
You will receive marketing communications from us, including tele-marketing correspondences where permitted by
local regulations, if you have requested information from us and/or purchased products or services from our
Site and have expressly consented to our marketing purposes. Similarly, you will continue to receive marketing
notifications where you have been provided the opportunity to withdraw your consent or unsubscribe and you
have not opted out of receiving such marketing materials.
Third-Party Marketing
We may use third-party marketing and analytics providers to assist us in the comprehensive evaluation of user
demand in the market for our products and services and accordingly conduct marketing to promote the same to
the public and targeted groups. This is referred to as interest-based marketing. We do not currently permit
our partners to use your personal data to advertise through our Site, although we may do so in the future.
We will get your express opt-in consent before we share your personal data with any third party for marketing
purposes. Nevertheless, we do not disclose your personal data to third parties for the purpose of direct
marketing.
Opting Out
You can ask us or third parties to stop sending you marketing messages at any time by following the opt-out
links on any marketing message sent to you.
Where you opt out of receiving these marketing messages, this will not apply to personal data provided to us
as a result of purchasing our products or services, experience or other any other transactions with
us. Nor does this option apply to necessary messages, alerts and notifications sent regarding our
products and services as outlined in our Terms of Service.
Cookies
You can set your browser to refuse all or some browser cookies, or to alert you when websites set or access
cookies. If you disable or refuse cookies, please note that some parts of our Site may become inaccessible or
not function properly. For more information about the cookies we use, please view our cookie policy below by
clicking
here.
Change of Purpose
We will only use your personal data for the purposes for which we collected it, unless we reasonably consider
that we need to use it for another reason and that reason is compatible with the original purpose. If you wish
to get an explanation as to how the processing for the new purpose is compatible with the original purpose,
please contact us.
If we need to use your personal data for an unrelated purpose, we will notify you and we will explain the
legal basis which allows us to do so.
6. DISCLOSURES OF YOUR PERSONAL DATA
Where you have provided your express consent as required by applicable laws, we may share your personal data
with selected parties as set out below for the purposes addressed in the table
Purposes for Which We Will Use Your Personal Data above.
-
Internal Third Parties as set out in the
Glossary.
-
External Third Parties as set out in the
Glossary.
-
Third parties to whom we may choose to sell, transfer or merge parts of our business or our assets.
Alternatively, we may seek to acquire other businesses or merge with them. If a change happens to our
business, then the new owners may use your personal data in the same way as set out in this Policy.
We require all third parties to respect the security of your personal data and to treat it in accordance with
the law. We do not allow our third-party service providers to use your personal data for their own purposes
and only permit them to process your personal data for specified purposes and in accordance with our
instructions.
7. INTERNATIONAL TRANSFERS
As an international group, our Site is available globally and subject to your express consent we may transfer
your personal data to any of our internal third parties which may be located outside the data’s initial
country of origin for storage and processing as necessary and permitted under this Policy.
We ensure your personal data is protected by requiring all our group of companies to follow the same rules
when processing your personal data. These rules are called "binding corporate rules".
Many of our external third parties operate internationally so their processing of your personal data will
involve a transfer of data outside your country.
The countries to which the international transfers may be made may have different regulations which provide
lesser protection than that of your country. Therefore, where we are legally authorised to transfer your
personal data, we safeguard it by ensuring that a sufficient degree of protection is afforded through the
implementation of at least one of the below rules:
-
We will only transfer your personal data to countries that have been deemed to provide an adequate level of
protection for personal data.
-
Where personal data of users in the European Economic Area, Switzerland and the UK are transferred to
countries outside regions which have not been deemed to provide an adequate level of personal data
protection, we adopt appropriate measures to ensure that the transfer is governed by the European
Commission’s standard contractual clauses.
-
Where we use certain service providers, we may utilise specific contracts approved for use in the country of
data processing which give your personal data adequate protection.
Please contact us if you want further information on the specific mechanism used by us when transferring your
personal data.
8. DATA SECURITY
We have put in place appropriate physical, electronic and administrative security measures to prevent your
personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. Our
security safeguards will be applied depending on the nature of the data (for example, where it is in transit
or at rest). You can find the full details of our security safeguards by visiting our comprehensive data
security page
here.
In addition, we limit access to your personal data to those employees, agents, contractors and other third
parties who have a business need to know. They will only process your personal data on our instructions and
they are subject to a duty of confidentiality.
We have put in place procedures to deal with any suspected personal data breach and will notify you and any
applicable regulator of a breach immediately where we are legally required to do so in accordance with the
applicable laws.
9. DATA RETENTION AND DISPOSAL
How Long Will You Use My Personal Data For?
We will only retain your personal data for as long as reasonably necessary to fulfil the purposes we collected
it for, including for the purposes of satisfying any legal, regulatory, tax, accounting or reporting
requirements. We may retain your personal data for a longer period in the event of a complaint or if we
reasonably believe there is a prospect of litigation in respect to our relationship with you.
To determine the appropriate retention period for personal data, we consider its amount, nature and
sensitivity, the potential risk of harm from unauthorised use or disclosure of your personal data, the length
of our relationship with you (such as the period until you cease interacting with or utilising our products
and services or our Site, cancel your account with us and/or terminate your subscription with us), the
purposes for which we process your personal data and whether we can achieve those purposes through other
means, the applicable legal, regulatory, tax and accounting laws as well as other requirements.
In some circumstances, you can ask us to delete your data: see
Your Legal Rights below for further information.
Once the purposes for which your personal data was collected have been achieved, we may anonymise your
personal data (so that it can no longer be associated with you) for research or statistical purposes, in which
case we may use this information indefinitely without further notice to you. Otherwise, where there is no
longer a legitimate interest and legal basis in retaining your personal data, it will be destroyed and deleted
from our data centres.
10. YOUR LEGAL RIGHTS
Under certain circumstances, you have rights under data protection laws in relation to your personal data.
Please click on the links below to find out more about these rights:
If you wish to exercise any of the rights set out above, please contact our PDO. You will not be discriminated
against for doing so.
No Fee Usually Required
You will not have to pay a fee to access your personal data (or to exercise any of the other rights).
Alternatively, we may refuse to comply with your request to the extent allowed by applicable laws if your
request is clearly unfounded, repetitive or excessive.
What We May Need From You
We may need to request specific information from you to help us confirm your identity and ensure your right to
access your personal data (or to exercise any of your other rights). This is a security measure to ensure that
personal data is not disclosed to any person who has no right to receive it. We may also contact you for
further information in relation to your request to speed up our response.
Time Limit to Respond
We try to respond to all legitimate requests within one month. Occasionally, it could take us longer if your
request is particularly complex or you have made a number of requests. In this case, we will notify you and
keep you updated.
11. COOKIE POLICY
What Are Cookies?
Cookies are text files that collect standard internet log and visitor behaviour information placed on your
computer. We may collect such information from you automatically through the use of cookies or similar
technology when you visit our Site.
How Do We Use Cookies?
To improve your experience when using our Site, we use cookies in several ways including:
- Keeping you signed in;
- Understanding your use of our Site; and
- Other reasonable uses.
What Types Of Cookies Do We Use?
Our Site uses different types of cookies such as:
- Strictly necessary cookies: These are cookies that are required for the operation of our
Site. They include, for example, cookies that enable you to log into secure areas of our Site or make use of
e-billing services.
- Analytical or performance cookies: These allow us to recognise and count the number of
visitors and to see how visitors move around our Site when they are using it. This helps us to improve the
way our Site works, for example, by ensuring that users are finding what they are looking for easily.
- Functionality cookies: These allow us to recognize you on our Site and remember your
preferences. They may include your language preferences or your location. A mix of first-party and
third-party cookies may be used.
- Targeting cookies: These cookies record your visit to our Site, the pages you have visited
and the links you have followed. We will use this information to make our Site and the advertising displayed
on it (if any) more relevant to your interests. We may also share this information with third parties for
this purpose when and where applicable.
Please note that third parties may also use cookies, over which we have no control. These may include, for
example, advertising networks and providers of external services like web traffic analysis services. These
third party cookies are likely to be analytical cookies or performance cookies or targeting cookies.
How to Manage Cookies?
You may set your browser to not accept cookies from our Site by adjusting your browser settings. However,
kindly note that disabling cookies may lead you to losing access to certain sections or features of our Site.
12. GLOSSARY
Lawful Basis
We strive to limit the processing of personal data to the extent you have expressly authorized us and where we
have a lawful basis to do so. These lawful bases include but are not limited to the following:
Legitimate Interest means the interest of our Company in conducting and managing our business
to enable us to give you the best service/product and the most secure experience. We make sure we consider and
balance any potential impact on you (both positive and negative) and your rights before we process your
personal data for our legitimate interests. We do not use your personal data for activities where our
interests are overridden by the impact on you (unless we have your consent or are otherwise required or
permitted to by law). Legitimate interests may include monitoring, testing, improving and developing our
products and services through the analysis of user data in line with our business needs; overseeing product
usage and conducting safety and compliance analysis on accounts where required to safeguard public safety, us
and our Site. We may also conduct automatic scans across personal data in this regard.
You can obtain further information about how we assess our legitimate interests against any potential impact
on you in respect of specific activities by contacting us.
Performance of Contract means processing your data where it is necessary for the
execution of an agreement to which you are a party or to take steps at your request before entering into such
a contract.
Comply with a Legal Obligation means processing your personal data where it is necessary
for compliance with a legal obligation that we are subject to.
Third Parties
Internal Third Parties means other companies in our Group acting as joint processors.
External Third Parties refer to the below selected parties based in the relevant
jurisdictions:
- Service providers acting as processors who provide IT and system administration services;
-
Professional advisers acting as processors including lawyers, bankers, auditors and insurers who provide
consultancy, banking, legal, insurance and accounting services;
-
Relevant regulators and authorities acting as processors who require reporting of processing activities in
certain circumstances; and
- Other third-party researchers, fraud prevention agencies and price comparison sites.
Your Legal Rights
Subject to local data protection laws, the right to enforce the following legal rights may be limited to you
and your authorized representative, and serving us written notice may be a pre-requisite. Regardless, we may
have to verify your identity to facilitate any request.
Request Access to Your Personal Data (commonly known as a "data subject access
request"). This enables you to receive a copy of the personal data we hold about you, its
sources and to check that we are lawfully processing it.
California-based users may request on an annual basis to see how their personal data has been shared to third
parties for direct marketing purposes in the previous year under the California Civil Code Section 1798.83.
Nevertheless, personal data is not shared with third parties for such purposes. Additionally, while we do not
sell the personal data of Californian users, interest-based marketing may be construed locally as selling. For
more information, please see
Third-Party Marketing.
Request Correction of the Personal Data That We Hold About You. This enables you to have any
incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the
new data you provide to us.
Request Erasure of Your Personal Data. This enables you to ask us to delete or remove
personal data where there is no good reason for us continuing to process it. You also have the right to ask us
to delete or remove your personal data where you have successfully exercised your right to object to
processing (see below), where we may have processed your information unlawfully or where we are required to
erase your personal data to comply with local law. Note, however, that we may not always be able to comply
with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the
time of your request.
Object to Processing of your personal data where we are relying on a legitimate interest (or
those of a third party) and there is something about your particular situation which makes you want to object
to processing on this ground as you feel it impacts your fundamental rights and freedoms. You also have the
right to object where we are processing your personal data for direct marketing purposes. In some cases, we
may demonstrate that we have compelling legitimate grounds to process your information which override your
rights and freedoms.
Request Restriction of Processing of Your Personal Data. This enables you to ask us to
suspend the processing of your personal data in the following scenarios:
- If you want us to establish the data's accuracy;
- Where our use of the data is unlawful but you do not want us to erase it;
-
Where you need us to hold the data even if we no longer require it as you need it to establish, exercise or
defend legal claims;
-
You have objected to our use of your data but we need to verify whether we have overriding legitimate
grounds to use it.
Request the Transfer of Your Personal Data to You or to a Third Party. We will provide
to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable
format. Note that this right only applies to automated information which you initially provided consent for us
to use or where we used the information to perform a contract with you.
Withdraw Consent at any time where we are relying on consent to process your personal
data.However, this will not affect the lawfulness of any processing carried out before you withdraw your
consent. If you withdraw your consent, we may not be able to provide certain products or services to you. We
will advise you if this is the case at the time you withdraw your consent.
