Privacy & Policy

Last Updated: July 2023

committed to protecting your privacy. This Privacy Policy explains how your Personal Data is collected, used, and disclosed by MUZA. This Privacy Policy explains how your Personal Data is collected, used, and disclosed by MUZA

This Privacy Policy applies to all our Services. By accessing or using our Services, or by otherwise demonstrating your consent to this Privacy Policy, you signify that you have read, understood and agree to our collection, storage, use and disclosure of your Personal Data as described in this Privacy Policy and our Terms of Service. If you are an Administrator, you represent and warrant that you are an authorized representative of Company with the authority to bind Company to this Privacy Policy, and that you agree to this Privacy Policy on Company’s and on each User’s behalf.

1. What Personal Data We Collect

MUZA uses Personal Data we collect to provide the Services, personalize content, remember information to help you efficiently access your Account, analyze how the Services are used, diagnose service or technical problems, maintain security, monitor aggregate metrics such as total number of visitors, traffic, and demographic patterns, and track user content as required to comply with applicable laws, including the Digital Millennium Copyright Act and other relevant regulations. These practices apply to international investors as well.

There are many occasions when you provide information that may enable us to identify you personally ("Personal Data") while using the Services. The Personal Data we may collect from you is outlined in the text below.

  • Identity Data: First name, surname, last name, username or similar identifier, title, date of birth and gender, picture, social security number and/or tax identification number, password, copies of ID cards or other forms of identification.
  • Contact Data: Your home address, work address, billing address, email address and telephone numbers.
  • Professional Background Data: Educational and professional history, interests and accomplishments.
  • Online Presence Data: Links to your public account pages at social media websites, links to personal websites, and other online materials related to you.
  • Financial Data: Your bank account and payment card details, statements about your wealth and financial situation.
  • Transaction Data: Any details about payments to and from you and other details of subscriptions and services you have purchased from us. Data in respect of your transactions with third parties (including your credit history).
  • Content Data: Any content you post to the Services not already included in another category, including without limitation, your profiles, questions, preference settings, answers, messages, comments, and other contributions on the Services, and metadata about them (such as when you posted them) ("Content").
  • Marketing and Communications Data: Your preferences in receiving marketing from us and our third parties and your communication preferences. If you correspond with us by email or messaging through the Services, we may retain the content of such messages and our responses.
  • Behavioral Data: Inferred or assumed information relating to your behavior and interests, based on your online activity. This is most often collated and grouped into "segments."
  • Technical Data: Internet protocol (IP) address, your login data, 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 to access the Site or use our Services.

2. How and Why We Use Your Personal Data

We collect personal information from:

  • Third parties (e.g., banks, agencies, or customer management providers);
  • You, directly (e.g. information form)
  • Cookies and other technologies placed on the devices that you use to access our websites.

When you visit our websites, we collect certain information by automated means, such as cookies and similar technologies. The information we collect in this manner includes IP address, unique device identifier, browser characteristics, device characteristics, operating system, language preferences, referring URLs, information on actions taken, and dates and times of activity.

How We Use Your Personal Data

We generally use Personal Data for the following: to deliver and improve our Services; to manage your Account and provide you with customer support; to perform research and analysis about your use of the Services; to develop, display, and track Content and advertising tailored to your interests on the Services and other sites, including, potentially, providing our advertisements to you when you visit other sites; website or mobile application analytics; to diagnose or fix technology problems; to automatically update the Services on your device; to verify your identity and prevent fraud or other unauthorized or illegal activity; and to enforce or exercise any rights in our Terms.

In respect of each of the purposes for which we use your Personal Data, applicable law may require us to ensure that we have a legal basis for that use. The legal bases depend on the Services you use and how you use them. This means we collect and use your Personal Data only where:

  • We need it to provide you the Services, including to operate the Services, provide customer support and personalized features and to protect the safety and security of the Services;
  • Processing of your Personal Data is necessary for the performance of a contract to which you are a party or to protect your vital interests or that of another person;
  • It satisfies a legitimate interest (which is not overridden by your data protection interests), such as for research and development, to market and promote the Services and to protect our legal rights and interests; or
  • We need to process your data to comply with a legal or regulatory obligation.

We may also rely on your consent as a legal basis for using your Personal Data where we have expressly sought it for a specific purpose. If we rely on your consent to a use of your Personal Data, you have the right to change your mind at any time (but this will not affect any processing that has already taken place). We have set out below, more detailed examples of relevant purposes for which we may use your Personal Data.

  • Providing, updating, and maintaining our Services, Site and business
  • To deliver the Services you have requested, including, for example, registering you as a user, managing your account and profile, and authenticating you when you log in.
  • Processing investments and payments
  • To close investments and process payment for any purchases, subscriptions or sales made on our site; to protect against or identify possible money-laundering or other fraudulent transactions, and otherwise as needed to manage our business.
  • Research and development
  • To enable us to improve and add to the Services and better understand our users and the markets in which we operate. For example, we may conduct or facilitate research and use learnings about how people use our Services and feedback provided directly to us to troubleshoot and to identify trends, usage, activity patterns, areas for additional features and services and improvement of the Services and other insights. We also test and analyze certain new features with some Users before introducing the feature to all Users.
  • Communicating with users about the Services
  • To send communications via email and within the Services, including, for example, responding to your comments, questions and requests, providing customer support, and sending you technical notices, product updates, security alerts, and administrative, billing and account management related messages. We may also provide tailored communications based on your activity and interactions with us.
  • Providing customer support
  • To resolve technical issues you encounter, to respond to your requests for assistance, comments and questions, to analyze crash information, to repair and improve the Services and provide other customer support.
  • To deliver our products and services to your location
  • Enhancing security
  • To keep our website, our Services and associated systems operational and secure, including, for example, verifying accounts and activity, monitoring and investigating suspicious or fraudulent activity and to identify violations of our terms and policies.
  • Marketing, promoting and driving engagement with the Services and third-party products and services
  • To send promotional communications that may be of specific interest to you, including, for example, by email and by displaying products, investment offerings, events, promotions and other information on our Site or other companies' websites. These communications may be aimed at driving engagement and maximizing what you get out of the Services or promoting third-party products and services. You generally can control whether you receive these communications as described in this policy under Marketing Communications Preferences.
  • To comply with applicable law, legal process and regulations and protect legitimate business interests
  • As we believe is reasonably necessary to comply with a law, regulation, order, subpoena, rule of a self-regulatory organization or audit or to protect the safety of any person, to address fraud, security or technical issues, or to protect our legal rights, interests and the interests of others, such as, for example, in connection with the acquisition, merger or sale of securities or a business (e.g. due diligence).

3. How We Use Cookies and Other Tracking or Profiling Technologies

MUZA may collect non-personally identifiable information regarding your usage of the Services, including the pages and articles and presentations you viewed, time spent using certain features of the website, demographic data such as server locations, connection speed, and other information that does not identify you. Like most online services, we also use cookies, log files, clear GIFs, tracking pixels, web beacons, and other technologies that may collect Personal Data.

Cookies

  • What are cookies? When you visit the Services, we may send one or more "cookies" – small data files – to your computer to uniquely identify your browser and let MUZA help you log in faster and enhance your navigation through the Site. A cookie may convey anonymous information about how you browse the Services to us so we can provide you with a more personalized experience, but does not collect personal information about you. A persistent cookie remains on your computer after you close your browser so that it can be used by your browser on subsequent visits to the Service. Persistent cookies can be removed by following your web browser's directions. A session cookie is temporary and disappears after you close your browser.
  • What cookies do we use? Our Site uses the following types of cookies for the purposes set out below:
  • Essential Cookies: These cookies are essential to provide you with services available through our Site and to enable you to use some of its features. For example, they allow you to log in to secure areas of our Site and help the content of the pages you request to load quickly. Without these cookies, the Services that you have asked for cannot be provided, and we only use these cookies to provide you with those services.
  • Functionality Cookies: These cookies allow our Site to remember choices you make when you use our Site, such as remembering your login details and remembering the changes you make to other parts of our Site which you can customize. The purpose of these cookies is to provide you with a more personal experience and to avoid you having to re-enter your preferences every time you visit our Site.
  • Analytics and Performance Cookies: These cookies are used to collect information about traffic to our Site and how Users use our Site. The information gathered via these cookies does not "directly" identify any individual visitor. However, it may render such visitors "indirectly identifiable". This is because the information collected is typically linked to a pseudonymous identifier associated with the device you use to access our Site. The information collected is aggregated and anonymous. We use this information to help operate our Site more efficiently, to gather broad demographic information and to monitor the level of activity on our Site. We use a number of different tools including Google Analytics, Segment, Posthog, and Fullstory for this purpose.
  • Targeted and advertising cookies: These cookies track your browsing habits to enable us to show advertising which is more likely to be of interest to you. These cookies use information about your browsing history to group you with other users who have similar interests. Based on that information, and with our permission, third party advertisers can place cookies to enable them to show advertisements which we think will be relevant to your interests while you are on third party websites. Third party advertisers may also use other technologies in addition to cookies placed on the Site (such as JavaScript, or web beacons) to measure the effectiveness of their advertisements and to personalize the advertising content.
  • Social Media Cookies: These cookies are used when you share information using a social media sharing button or "like" button on our Site or you link your account or engage with our content on or through a social networking website such as Facebook, Twitter or Google+. The social network will record that you have done this. These cookies may also include certain code that has been placed on the Site to help track conversions from ads, optimize ads based on collected data, build targeted audiences for future ads, and remarket to qualified leads—users who have already taken certain action on the Site.

How to Disable Cookies?

You can typically reset your web browser to refuse all cookies or to notify you when a cookie is being sent. In order to do this, follow the instructions provided by your browser (usually located within the "settings", "help" "tools" or "edit" facility). Many browsers are set to accept cookies until you change your settings.

If you do not accept our cookies, you may experience some inconvenience in your use of our Services and some features of the Service may not function properly. For example, we may not be able to recognise your computer or mobile device and you may need to log in every time you visit our Services.

4. Promotional Communications.

We may use your personal information to send you updates (e.g., by email, text message, telephone, via our websites) about our products and services, including exclusive offers, promotions or new products and services.

We do not sell your personal information to other organizations for marketing purposes.

You have the right to opt out of receiving promotional communications at any time by:

  • Contacting us through hello@muza.co
  • Using the “unsubscribe” link in emails that you receive from us.

We may ask you to confirm or update your marketing preferences if you instruct us to provide further products or services in the future, or if there are changes in applicable laws and regulations, or the structure of our business.

6. Who We Share Your Personal Information With

We routinely share personal information with:

  • Our affiliates, including our investors
  • Service providers we use to help deliver our products and/or services to you, such as payment service providers and other third party companies;
  • Other third parties we use to help us run our business, such as marketing agencies or website hosts;
  • Our licensors and their agents;
  • Our customers or business partners that integrate with our platform;
  • Third parties approved by you, including social media sites you choose to link your account to or third-party payment providers.

We only allow our service providers to handle your personal information if we are satisfied they take appropriate measures to protect your personal information. We also impose contractual obligations on service providers relating to ensure they can only use your personal information to provide services to us and to you. We may disclose and exchange information with law enforcement agencies and regulatory bodies to comply with our legal and regulatory obligations.

We may also need to share some personal information with other parties, such as potential buyers of some or all of our business or during a restructuring. We will typically anonymize information before sharing it, but where this may not be possible, we make sure that the recipient of the information is bound by confidentiality obligations.

7. How Long Your Personal Information Will Be Kept

We will keep your personal information while you have an account with us or while we are providing products and/or services to you. Thereafter, we will keep your personal information for as long as is necessary:

  • To respond to any questions, complaints or claims made by you or on your behalf;
  • To show that we treated you fairly; or
  • To keep records required by law.

We will not retain your personal information for longer than necessary for the purposes set out in this Privacy Policy. Different retention periods apply for different types of personal information.

8. How Long We Store Your Personal Data

We will retain your information for as long as your account is active or it is reasonably needed for the purposes set out in How we use your Personal Data and Why unless you request that we remove your Personal Data as described in your rights relating to your personal data. We will only retain your personal data for so long as we reasonably need to use it for these purposes unless a longer retention period is required by law. This may include keeping your personal data after you have deactivated your account for the period of time needed for us to pursue legitimate business interests, conduct audits, comply with legal obligations, resolve disputes and enforce our agreements.

9. Where We Store Your Personal Data

The Services are maintained in the United States of America. Personal Data that you provide us may be stored, processed and accessed by us, our staff, sub-contractors and third parties with whom we share Personal Data in Singapore for the purposes described in this policy. We may also store Personal Data in locations outside the direct control of MUZA (for instance, on servers or databases co-located with hosting providers).

Although we welcome users from all over the world, by accessing the Services and providing us with your Personal Data, you consent to and authorize the export of Personal Data to the United States, Singapore, and other locations as specified in this Privacy Policy and use as specified in this Privacy Policy. Please note that the laws in Singapore may not provide the same level of comprehensive protection as the laws in the country where you reside.

10. How We Protect Your Personal Data

MUZA uses industry-standard physical, managerial, and technical safeguards to preserve the integrity and security of your personal information. We limit access to your Personal Data to those employees and other staff who have a business need to have such access. All such people are subject to a contractual duty of confidentiality. We periodically review our policies and procedures to evaluate their effectiveness and ensure that they remain up to date. We cannot, however, ensure or warrant the security of any information you transmit to MUZA or guarantee that your information on the Services may not be accessed, disclosed, altered, or destroyed by a breach of any of our physical, managerial, or technical safeguards.

We have put in place procedures to respond to any actual or suspected Personal Data breach. In the event that personal information is compromised as a result of such a breach of security, MUZA may promptly notify those persons whose personal information has been compromised by posting a notice on the Site, via the functionality of the Services, or by sending an email to you. You may have a legal right to receive this notice in writing.

MUZA cannot ensure that your Personal Data will be protected, controlled or otherwise managed pursuant to this Privacy Policy if you share your login and password information with any third party, including any third party operating a website or providing other services.

11. Our Policy on Children's Privacy

Protecting the privacy of young children is especially important. The Services are not intended for children under the age of 18 and MUZA does not knowingly collect or solicit personal information from anyone under the age of 18 or knowingly allow such persons to register with the Services. If you are under the age of 18, please do not submit any personal information through the Site. We encourage parents and legal guardians to monitor their children's Internet usage and to help enforce our Privacy Policy by instructing their children never to provide personal information on this Site. If we become aware that we have collected personal information from a child under the age 18, we will take steps to remove that information.

12. Your Rights Relating to Your Personal Data

You have the right under this Privacy and Cookies Policy, and by law in certain jurisdictions, to:

  • Request access to your Personal Data: If you are in certain jurisdictions, you have the right to receive a copy of the Personal Data we hold about you in a portable and, to the extent technically feasible, readily usable format, and to check that we are lawfully processing it. As applicable, you may have the right to request that we disclose to you the following information covering the 12 months preceding your request:
  • The categories of Personal Data we have collected about you and the categories of sources from which we collected such Personal Data;
  • The business or commercial purpose for collecting Personal Data about you;
  • The categories of Personal Data about you that we otherwise disclosed, and the categories of third parties to whom we disclosed such Personal Data (if applicable).
  • Request correction of the Personal Data that we hold about you: This enables you to have any incomplete or inaccurate information we hold about you corrected.
  • Request deletion of your Personal Data: This allows you to request the deletion or removal of your Personal Data when there is no legitimate reason for us to continue processing it. If you are an international investor, you also have the right to request the deletion or removal of your Personal Data if you have exercised your right to object to the processing, in accordance with applicable international privacy laws and regulations.
  • Object to processing of your Personal Data: This right exists where we are relying on a legitimate interest as the legal basis for our processing and there is something about your particular situation, which makes you want to object to the processing of your Personal Data on this ground. You also have the right to object where we are processing your Personal Data for direct marketing purposes.
  • Request the restriction of processing of your Personal Data: This enables you to ask us to suspend the processing of Personal Data about you in certain scenarios (for example if you want us to establish its accuracy or the reason for processing it).
  • Request the transfer of your Personal Data: If you are in certain jurisdictions, 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.
  • Request to limit use and disclosure of your Sensitive Personal Data: If you are in certain jurisdictions, you have the right to ask that we limit our use and disclosure of your “Sensitive Personal Data” to certain purposes permitted by law. For purposes of this Privacy Policy, Sensitive Personal Data may include information such as social security number, driver license number, state identification card, passport number, financial data, etc.
  • Request to stop selling your Personal Data or sharing your Personal Data for cross-context behavioral advertising: MUZA does not sell your Personal Data and we have not engaged in such activities in the 12 months preceding the date this Privacy Policy was last updated. If you are in certain jurisdictions, you have the right to ask that we limit the sharing of your Personal Data for cross-context behavioral advertising.
  • Opt out of targeted advertising: If you are in certain jurisdictions, you have the right to opt out of targeted advertising based on your Personal Data obtained from your activities over time and across websites or applications.
  • Opt out of profiling: MUZA does not process Personal Data for the purpose of profiling in furtherance of decisions that produce legal or similarly significant effects concerning consumers. To the extent that we were to engage in these activities and depending on your jurisdiction, you have the right to request that we stop doing so.
  • Withdraw consent: This right only exists where we are relying on consent to process your Personal Data ("Consent Withdrawal"). If you withdraw your consent, we may not be able to provide you with access to certain specific functionalities of our Site. We will advise you if this is the case at the time you withdraw your consent.

13. How to Exercise Your Rights

If you want to exercise any of the rights described above, please contact us using the contact details in Section “Who we are and how to contact us” herein.

Typically, you will not have to pay a fee to access your Personal Data (or to exercise any of the other rights). However, except in relation to Consent Withdrawal, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive, or, we may refuse to comply with your request in these circumstances.

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 to ask you for further information in relation to your request to speed up our response.

We try to respond to all legitimate requests within one month. Occasionally it may take us longer than a month 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. If we decline to take action on one of your rights outlined above, you can request an appeal by contacting us at hello@muza.co

MUZA will not discriminate against an individual because the individual exercised any of the rights described above.

14. Changes to Our Privacy Policy

We reserve the right, in our sole discretion, to change, modify, add, or remove portions of this Privacy Policy at any time. Any changes or updates will be effective immediately upon posting to this page. You should review this Privacy Policy regularly for changes. You can determine if changes have been made by checking the Effective Date below. Your continued use of our Site following the posting of any changes to this Privacy Policy means you consent to such changes.

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.

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