Multiverse Community Hub - Privacy Policy
Last updated: 09th January 2023
This Privacy Policy is provided by Multiverse Group Limited, a registered company under the number 10027474, with its registered office at 2 Eastbourne Terrace, Floors 5+6, London, W2 6LG (hereafter, the “Company”)
The Company offers this Community Hub (hereafter, the “Community Hub”) to its users which have registered on the Community Hub and as such have a user account (hereafter, the “Users”). The Community Hub is available at the following url address: community.multiverse.io. The Company collects, uses and is responsible for certain personal information about you as a “controller”.
The Company uses a solution called “Hivebrite”, which enables the import and export of user lists and data, the management of content and events, the organisation of emailing campaigns and opportunity research and sharing as well as the management of funds and contributions of any kind.
The Company commits to ensure the compliance with the EU General Data Protection Regulation (GDPR), which came into effect on 25th May 2018.
In order to do so, the Company has put in place this Privacy Policy which provides certain information regarding its processing of Users’ personal data on the Community Hub.
If you have any queries about this privacy policy or the Company’s processing of your personal data please contact the Company at support.multiverse.io or Multiverse Group Limited, 2 Eastbourne Terrace, Floors 5+6, London, W2 6LG.
This Privacy Policy is intended for the Users of the Community Hub of the Company.
1. COLLECTED PERSONAL DATA
1.1 The Registration Process
When registering for the Community Hub or submitting information through our website (https://platform.mutiverse.io), the User is informed that the following (non-exhaustive list of) personal data is collected (together the “Registration Data“):
- First name;
- Surname;
- Email address;
- Location;
- Apprenticeship qualification
This will be collected directly from the User and they will commit to only provide accurate, exhaustive, and regularly updated data regarding their identity, their content and any information in general.
Once the Registration Data has been auto-uploaded, the individual will receive an account activation email. They can then decide whether or not to activate their account.
In some cases, for example if the prospective User is a current apprentice of the Company, the Company may automatically upload that individual’s Registration Data to the Community Hub. This will only happen if the Company already holds the individual’s Registration Data in relation to other services provided by the Company and it is in the Company’s legitimate business interests to use the Registration Data for purpose of auto-uploading it to the Community Hub.
1.2 During the use of the Community Hub
The User may validly publish, at its own initiative, any content on the Community Hub which shall be kept by the Company, including:
- Gender
- Date of birth
- Maiden name
- Skills
- Hobbies and interests
- Social media information
- Apprenticeship start date
- Work experience
- Education
- Payment information
The User is informed that the Company may process special category (sensitive) data within the meaning of applicable legislation and regulations, only if such sensitive personal data is voluntarily shared by the User on the Community Hub. Otherwise the Company will not capture any sensitive personal data, for example it does not capture sensitive personal data during the sign up process or during the completion of a User’s profile.
1.3 Cookie data
The Company informs the User that Hivebrite, as well as its subcontractors, uses a tracking technology on its terminal such as cookies whenever the User navigates on the Community Hub.
A cookie is a message that, subject to the User settings, is sent to its terminal when the User navigates on a website. The aim is to collect data regarding the internet navigation of the User to send tailor-made services to its terminal (computer, mobile phone or tablet).
The cookies that are sent to the User’s terminal, as well as the purpose of the processing of the data collected through the cookies, are detailed under Article 3 of this Privacy Policy.
2. THE COMPANY’S LEGAL BASIS FOR PROCESSING YOUR PERSONAL DATA
When the Company uses your personal information it is required to have a legal basis for doing so. There are various different legal bases on which it may rely, depending on what personal information it processes and why.
The legal bases the Company may rely on when processing your personal data in relation to the Community Hub are as follows:
- Contract: where the Company’s use of your personal information is necessary for a contract it has with you, namely the terms of use in place between you and the Company when you register with the Community Hub, or because you have asked the Company to take specific steps before entering into a contract;
- Legitimate interests: where the Company’s use of your personal information is necessary for its legitimate interests or the legitimate interests of a third party (unless there is a good reason to protect your personal information which overrides its legitimate interests) ; and
- Consent: where you have given the Company clear consent to process your personal information for a specific purpose, for example in relation to the placement of cookies and direct marketing communications.
3. THE PURPOSE OF THE DATA PROCESSING
The Company and its subcontractors collect, process and host personal data that are freely transferred by the User when accessing the Community Hub.
3.1 Collected Data
When subscribing on the Community Hub:
- First name;
- Surname;
- Email address;
- Location
- Apprenticeship qualification
Purpose of the processing
- Access to the Community Hub;
- Creation of a user account;
- Access for the User to all functionalities of the Community Hub;
- Management of requests to access, amend, delete, limit and oppose.
3.2 Collected Data
When using the Community Hub:
- Gender;
- Date of birth;
- Maiden name;
- Location;
- Skills;
- Hobbies and interests;
- Social media information;
- Apprenticeship start date;
- Work experience;
- Education;
- Payment information;
- Any other personal data that the User chooses to upload to the Community Hub.
Purpose of the processing
- The use and feeding of the Community Hub;
- Management of payments (e.g. for paid for events) through the Community Hub;
- Sending invitations for events or other opportunities organised by the Company or other Users, if the User has consented to receive such invitations.
3.3 Collected Data
When using the Community Hub:
- All data listed above
- Community Hub engagement and usage data
After you’ve completed your apprenticeship or membership of the Community:
- We may ask you to complete non-mandatory surveys about your experiences.
Purpose of the processing
- The Company may combine and compare this data with the same categories of personal data that it has already collected from the User in relation to other programmes that it offers. This is in order to understand the relationships between (a) the User’s Community Hub engagement; and (b) engagement with other programmes, with an ultimate purpose of improving the recruitment, training and Community provision - including to increase grades, apprenticeship completion rates, and the quality of the Company’s algorithmic recruitment services.
- Such data analysis will allow the Company to optimise other user-facing activities and to enhance engagement with Community Hub content (and vice versa).
3.4 Collected Data
Cookies, trackers:
- Add to calendar
- Keep active session
- The user/admin ID
- User first connection
- Stripe
- Identify the user session
- Admin ID
- User search
- Google analytics
Purpose of the processing
- Improve the quality of the services proposed by the Community Hub;
- Improve the usage functionalities of the Community Hub;
- Create statistics regarding the effective use of the Community Hub;
- Enable the User not to have to reconnect to the Community Hub for every new navigation on the Community Hub;
- Invite the User to events organised by the Community Hub;
- Create statistics regarding the different levels of activity on the Community Hub. The cookies cannot allow to identify the User;
- Manage banking transactions.
The Company only collects and processes the User’s personal data for the purpose for the optimal implementation and use of the Community Hub and/or optimisation of the company's other user-facing activities (e.g. candidate recruitment, programme delivery etc).
4. THIRD PARTIES
The Company and its subcontractors commit to a lawful and fair collection of the User’s data, in full transparency and in compliance with the rights conferred to the User pursuant to applicable legislation and regulations. The Company routinely shares your personal information with the following third parties for the following purposes:
- Hivebrite : as provider of the Community Hub. A company registered with the Paris Companies register under the number 75339171300017, having its registered office at 8, rue de la Grande Chaumière, 75008 – Paris (for any additional information on Hivebrite, you can consult the webpage available at the following address: www.hivebrite.com).
- Stripe : as provider of payment services
- Tableau Software UK Limited : as a data visualisation and analytics platform. Tableau is fully compliant with EU, UK and US data privacy regulations and is registered with the Information Commissioner’s Office under the UK Data Protection Act (no. Z2760739). All data processed using Tableau software is stored within the UK on Multiverse-owned servers.
- Aircury Limited : as a provider of data transfer/transformation services. Aircury is fully compliant with EU and UK data privacy regulations and is registered in England under company number 10641335.
- Your employer : where you are employed by a third party that has purchased a Community Hub subscription on your behalf we may share the personal information we collect and process about you with them.
The personal data collected by the Company is hosted by the following service providers:
Host - Microsoft Azure Cloud
Privacy policy: https://privacy.microsoft.com/en-gb/privacystatement
https://www.microsoft.com/en-us/TrustCenter/Privacy/gdpr/default.aspx
Nature of the hosting - Hosting of all data and content produced / provided by the User, as well as images, profile pictures and backups
Host - AmazonAWS
Privacy policy:
https://aws.amazon.com/compliance/gdpr-center/
Nature of the hosting - Hosting of all data and content produced / provided by the User, as well as images, profile pictures and backups
Host - OVH
Privacy policy: https://www.ovh.co.uk/personal-data-protection/security.xml
Nature of the hosting - Hosting of some user data (e.g. event participation data) for analysis purposes
Host - G Suite provided by Google Cloud
Privacy policy: https://support.google.com/googlecloud/answer/6056650?hl=en
Nature of the hosting - Hosting of some user data (e.g. event participation data) for analysis purposes
Some of the above listed third party recipients may be based outside the European Economic Area, for further information including on how the Company safeguards your personal data when this occurs, see ‘Transfer of your information out of the EEA’.
The Company will share personal information with law enforcement or other authorities if required by applicable law.
The Company will not share your personal information with any other third party.
5. TRANSFER OF YOUR INFORMATION OUT OF THE EEA
Although the Company is located within the UK, its third parties are located globally, including outside of the EEA.
Whenever the Company transfers your personal data outside of the EEA it ensures that appropriate safeguards are in place, for example ensuring that parties in the US are Privacy Shield certified. This is in order to safeguard your privacy rights and give you remedies in the unlikely event of a misuse of your personal information.
6. MARKETING AND COMMUNICATIONS
The Company strives to provide you with choices regarding certain personal data uses, particularly around marketing and advertising.
We will always treat your personal information with the utmost respect and you have the right to opt out of receiving marketing communications at any time by contacting us at: support.multiverse.io.
We may use your personal information to send you updates about our services, including information about your apprenticeship or events you’ve chosen to attend. Such communications are part of our service and we therefore have a legitimate interest in processing your personal information for these purposes (see section 2 above). This means we do not usually need your consent to send you such communications. However, where consent is needed, we will ask for this consent separately and clearly.
We may ask you to confirm or update your marketing preferences if you instruct us to provide further services in the future, or if there are changes in the law, regulation, or the structure of our business.
7. LENGTH OF DATA RETENTION
In accordance with application legislation, cookie data will be automatically deleted thirteen (13) months following their placing on the User’s terminal.
The Company will only retain your personal data for as long as necessary to fulfil the purposes it collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements. This will typically be the duration for which you hold an account on the Community Hub.
To determine the appropriate retention period for personal data, the Company considers the amount, nature, and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which the Company processes your personal data and whether it can achieve those purposes through other means, and the applicable legal requirements.
8. EXERCISE OF THE USERS’ RIGHTS
Under the General Data Protection Regulation you have a number of important rights free of charge. In summary, those include rights to:
- Access to your personal information and to certain other supplementary information that this Privacy Notice is already designed to address
- Require the Company to correct any mistakes in your information which it holds
- Require the erasure of personal information concerning you in certain situations
- Receive the personal information concerning you which you have provided to the Company, in a structured, commonly used and machine-readable format and have the right to transmit those data to a third party in certain situations
- Object at any time to processing of personal information concerning you for direct marketing
- Object to decisions being taken by automated means which produce legal effects concerning you or similarly significantly affect you
- Object in certain other situations to the Company’s continued processing of your personal information
- Otherwise restrict the Company’s processing of your personal information in certain circumstances
The User can exercise its rights by raising a ticket at support.multiverse.io or by mail at the following address 2 Eastbourne Terrace, Floors 5+6, London, W2 6LG provided that the User justifies its identity.
The Company hopes that it can resolve any query or concern you raise about its use of your information. However, the General Data Protection Regulation also gives you the right to lodge a complaint with a supervisory authority, in particular in the European Union (or European Economic Area) state where you work, normally live or where any alleged infringement of data protection laws occurred. The supervisory authority in the UK is the Information Commissioner who may be contacted at https://ico.org.uk/concerns/.
9. KEEPING YOUR DATA SECURE
The Company has appropriate security measures in place to prevent personal information from being accidentally lost, or used or accessed in an unauthorised way. It limits access to your personal information to those who have a genuine business need to know it. Those processing your information will do so only in an authorised manner and are subject to a duty of confidentiality.
The Company also has procedures in place to deal with any suspected data security breach. The Company will notify you and any applicable regulator of a suspected data security breach where it is legally required to do so.
10. COOKIE MANAGEMENT CONFIGURATION AND OTHER DATA
The User’s consent to the placement of cookies is requested through a banner at the bottom of the Community Hub homepage.
In case of consent, the User’s internet navigator shall automatically transmit to the Company the data collected and detailed under Article 1.2 above.
The User is informed that the cookies and trackers will be automatically deleted following a period of thirteen (13) months.
The User may at all times configure its navigator in order to prevent the creation of cookie files.
However, certain functionalities of the services proposed by the Community Hub may not function properly without cookies (sometimes known as strictly necessary cookies). In addition, even if most navigators are configured by default and accept the creation of cookie files, the User has the possibility to choose to accept the creation of all cookies other than the functional cookies or to systematically decline them or to choose the cookies it accepts depending on the issuer by configuring the following settings:
Internet Explorer:
- Click on the settings menu, followed by “Internet Options”;
- Under the “General” tab on the upper-left hand side, scroll down to “Browsing history”;
- Check the "Temporary Internet files and website files," "Cookies and website data," "History," and "Download History" boxes;
- Click on “Delete”;
- Close out of Internet Explorer and reopen it for changes to take effect.
Firefox:
- Click on your Tools bar;
- Click on “Preferences”;
- On the menu to the right, select "Privacy";
- Under the “history option”, there is a shortcut titled "clear your recent history", click on that;
- Select only the top four options and hit clear now.
Safari:
- Click on “Safari” in the top left corner of the finer bar;
- Click on “Preferences”;
- Click on the “Privacy” tab;
- Click on “Manage Website Data”;
- Click on “Remove All”;
- Click “Remove Now”.
Google Chrome:
- Click the Tools menu;
- Click on “More tools”;
- Clear browsing data;
- At the top, choose a time range.
- To delete everything, select “All time”;
- Next to "Cookies and other site data" and "Cached images and files", check the boxes;
- Click on “Clear data”.
In order to configure the data settings, please find below the recommendations of the Company:
Data collected for the following purpose: General data enabling the proper functioning of the Community Hub and the improvement of the services proposed by the Community Hub.
Settings: Data that is essential for the provision of services by the Company.
Data collected for the following purpose: Data regarding the management of payment services proposed by the Community Hub, delinquencies and litigation.
Settings: Data that is essential for the provision of services by the Company.
Data collected for the following purpose:
- Data enabling the creation of User files;
- Mailing of commercial offers, advertisements or newsletters of the Company and/or its commercial partners if this has been accepted by the User.
Settings:
- Management by the User in its login area;
- Unsubscribing to newsletters / commercial offers by clicking on the appropriate link;
- Request for deletion of the data base of the Company by writing to the following address 2 Eastbourne Terrace, Floors 5+6, London, W2 6LG and subject to providing a proof of identity.
Data collected for the following purpose: Compilation of statistics with the purpose of improving the functioning of the Community Hub notably by analysing the traffic of the Community Hub (modules which are more or less consulted, preferred routes, level of activity depending on the day of the week and hour of the day, etc.) and by adapting the Community Hub according to the needs and tastes of the Users (recognition of the User when it accesses the Community Hub).
Settings:
- Clearance of cookie history in the navigator pursuant to the above instructions;
- Using the “incognito mode” whilst navigating;
- Request for deletion of the data base of the Company by writing to the following address 2 Eastbourne Terrace, Floors 5+6, London, W2 6LG and subject to providing a proof of identity.
Data collected for the following purpose: Management of requests to access, rectify, delete, limit and oppose.
Settings: Request for deletion of the data base of the Company by writing to the following address 2 Eastbourne Terrace, Floors 5+6, London, W2 6LG and subject to providing a proof of identity.
11. CHANGES TO THIS PRIVACY POLICY
Especially in light of any future developments of the applicable legislation and regulations, the Company reserves its right to proceed with any modification of its Privacy Policy and commits to duly inform you if any such modification occurs.