Privacy Notice

Version 1.0

 

Multi Dimension Solutions Limited is committed to ensuring that your privacy is protected.

We are the data controller of the App and the Account, namely, Multi Dimension Solutions Limited, a company established under the Laws of Malta, bearing company registration number C 96131 and having its registered address at The Bastions, Office 2, Emvin Cremona Street, Floriana, FRN 1281, Malta.

We recognise Our obligations as data controller and We are committed to comply with all applicable laws, including the Data Protection Act (Cap 586 of the Laws of Malta) and the General Data Protection Regulation (2016/679).

Please note that the defined terms in the HASHTHAT TERMS AND CONDITIONS are to be ascribed the same meaning as ascribed thereto in the HASHTHAT TERMS AND CONDITIONS, when used in this Privacy Notice.

Please read this Privacy Notice carefully to understand your rights and our practices with respect to your personal data.

Please do note that this Privacy Notice applies to your use of Our App and your Account only.

1. What are Personal Data?

“Personal data” refers to all information which can render you personally identifiable, such as your name, surname and email address and includes all information and documentation that can arise or be produced which can identify you personally, either directly or indirectly.

2. How do We Collect your Personal Data?

Please note that We collect your personal data:

  • Through your creation of your Account and any Account related changes you may subsequently undertake through the Account Settings;
  • Through your use of the App, as strictly necessary to enable its intended functionality as set out in the HASHTHAT TERMS AND CONDITIONS;
  • When you purchase or renew any Subscription; and
  • When you correspond with Us.

We do not monitor your personal usage of the App. However, please do note that We have controls in place to ensure that you do not abuse of the Free Trial and may collect and process personal data in your regard to prevent such abuse.

3. What Personal Data do we Process and Why do Process such Information?

Please note that the personal data that We process are the following personal data / datasets:

  • The information required to set-up your Account as set out in the Account Registration Form, including your Username, email address, and any information you may supply when you update your Account Settings. Account related personal data is required in order to enable Us to provide you with Our service as set out in the HASHTHAT TERMS AND CONDITIONS and will be processed by Us to be enable Us to provide you with said service. Please do note that Account related information will also be processed by Us to ensure that you do not abuse of the Free Trial. Furthermore, note that your email address shall be processed for sending you service related communications and updates;
  • Any information which you choose to store within the App, including your Passwords and Password description. This information is processed by Us for storage purposes only, to be able to provide you with the service as described in the HASHTHAT TERMS AND CONDITIONS. As any such information stored within the App is encrypted, We do not have any means of accessing such information. We shall also not otherwise process such personal data, other than to render you with Our service;
  • Your chosen Master Password and Secret Key (if a Secret Key was optionally chosen). Please do note that your Master Password and Secret Key are encrypted within your Device and We have no means to access this information. Your Master Password and Secret Key will be processed by Us (on the client-side) exclusively in order to enable you to access your Account and receive the service as set out in the HASHTHAT TERMS AND CONDITIONS;
  • Your Memory Phrase (if a Memory Phrase was optionally chosen). Please do note that your Memory Phrase is processed by Us exclusively for storing the same to provide it to you, in the event that you need access to your selected Memory Phrase to help you remember your Master Password and/or Secret Key. Your Memory Phrase will otherwise not be processed for any other purpose;
  • The billing related personal data, including your credit card details, which you choose to provide to Us when purchasing or renewing a Subscription. Please do note that this information will be processed by Us and Our payments service provider exclusively for processing your payments and by Us for service provision and compliance with legal obligations; and
  • Any personal data which you may choose to include when you correspond with Us. Please do note any personal data contained within your correspondence shall be processed by Us in order to respond to your message or to otherwise act upon your request.

Please also note that We may also process any personal data necessary for the purpose of enabling Us to comply with any legal obligations that may be imposed on Us.

Lastly, please do note that we do not process any special categories / sensitive personal data in your regard. Note that special categories of personal data include data revealing your racial or ethnic origin, political opinions, religious or philosophical beliefs, trade union membership, genetic, biometric or health data, sexual orientation and data related to your conviction and offences.

4. Cookies

Cookies are small text files containing information which are sent to and stored on a Device, and can have various functionalities. Please do note that We do not make use of any cookies in respect of the App or any matter connected with the Account.

5. Legal Basis for Processing

We process your personal data on the following legal basis:

  • Entering into and performing a contract: Note that the HASHTHAT TERMS AND CONDITIONS is the contract which regulates Our provision of the App and Account service to you. Providing such personal data is necessary for Our performance of such contract and the consequence for not providing Us with your personal data would be that We would be unable to provide you with the App service;
  • Our legitimate interests: In particular, Our legitimate interest which may arise directly or indirectly in relation to your use of the App, your Account, or a Subscription or Free Trial. When We process your personal data on the basis of Our legitimate interests, We ensure that the legitimate interests pursued by Us are not overridden by your interests, rights and freedoms;
  • Compliance with legal obligations imposed on Us; and
  • We may also process your personal data for the purposes of establishing, exercising or defending legal proceedings on the basis of Our legitimate interests or compliance with legal obligations, as applicable.

The provision of your personal data is not a statutory requirement. As explained above, it is however a contractual requirement in order to enable Us to perform the App service. You are not legally obliged to provide Us your personal data and it is your choice whether to provide Us with your personal data.

6. Recipients of your Personal Data

We do not sell or transfer your personal data to third parties. Your personal data will only be shared with:

  • Our personnel who require access to such personal data on a strict need to know basis, in order to provide you with the App service;
  • Our IT suppliers such as Our internet service providers who may also process your personal data, strictly for technical service provision purposes;
  • Our payment services suppliers who shall process your personal data exclusively to enable your payment of a purchased or renewed Subscription, including any purposes inherently related thereto. Note that our payment services supplier is Stripe, Inc and their Privacy Notice/Policy may be accessed here.

Unless specifically instructed by you, we do not share your personal data with any entity outside of the EU.

Do note that We shall have a right to transfer your personal data to any third party, if the App and/or Our company is sold to a third party. In such case, please do rest assured that any such transfer shall occur in compliance with applicable laws.

7. Automated Decision Making and Profiling

Your personal data will not be processed for the purposes of any decisions taken solely on the basis of profiling methods or algorithmic / automated decision-making without human intervention.

8. Retention

We retain your personal data exclusively for the period which is lawfully permissible to retain your personal data. Thereafter, your personal data shall be immediately and irrevocably destroyed.

In view of Our contractual relationship with you, We typically retain your personal data for up to five (5) years from the end of Our contractual relationship on the basis of Our legitimate interests to protect ourselves in civil cases which you might institute against Us in relation to Our contractual relationship.

Payment information such as invoices and transactional documentation and information, may be kept by Us for up to ten (10) years from the completion of the relevant transaction, on the basis of legal obligations imposed on Us to retain such information.

We may also have a legitimate interest to retain your data for longer periods such as when your personal data is required for exercising or defending legal claims.

9. Your Rights

You enjoy various rights in relation to your personal data.

  • Right of Access – the right to ascertain whether we hold personal data about you and to receive a copy of such personal data;
  • Right to Complain – if you have any complaints regarding our processing of your personal data note that you may contact us at the contact details provided below. You also have a right to lodge a complaint with the Information and Data Protection Commissioner in Malta. The Information and Data Protection Commissioner may be contacted at idpc.gov.mt;
  • Right to Erasure – you have a right to request that we delete your data in certain circumstances;
  • Right to Object – you have a right to object to our processing of your personal data and request that we stop such processing where we rely on our or a third party’s legitimate interest/s;
  • Right to Data Portability – you have a right to request that we port certain personal data in a structured, commonly used and machine-readable format. If technically feasible, you may also request that such data is transmitted by us directly to a third-party controller of your choice;
  • Right to Rectification – you have the right to update, correct and rectify any inaccurate personal data we process about you; and
  • Right to Restriction – you have a right to request that we restrict your personal data in certain circumstances.

Note that if we process personal data which have not been provided to us directly by you, you may also have a right to be informed of the source from which your personal data originates. We however do not envisage situations wherein We process personal data not provided by you.

10. Data Security

We take the protection of your personal data very seriously and are committed to take the appropriate technical and organisation measures to protect your data against unauthorised or unlawful processing. In fact, the App service aims to provide you with added security as a service through the various encryption layers and techniques utilized in Our App.

11. Contact Details

Please do not hesitate to contact us regarding our processing practices at the contact details below:

12. Updates

This Privacy Notice may be updated in our sole discretion including as a result of a change in processing activities or relevant laws. We will communicate changes in this Privacy Notice by email before commencing any relevant processing activity in your regard and will post any such changes on our App. If your consent is required as a result of any change to this Privacy Notice, such change in processing in your regard shall not commence until your consent has been obtained.