Our Privacy Policy

Your privacy is important to Skuad Pte Ltd. and its subsidiaries and affiliates, including Boundless Technologies Limited, a wholly owned subsidiary of Skuad (“Skuad”, “our”, “we,” or “us”). It is Skuad’s policy to respect your privacy and comply with all applicable laws and regulations regarding any personal information we may collect about you. Personal information is any information about you which can be used to identify you, e.g. your name, email address, and in some circumstances, information about your device such as your IP address.

This Privacy Policy (“Policy”) describes our data protection practices when we collect, use, process, disclose and transfer personal information through your use of our websites, mobile applications and the Payoneer Workforce Management (WFM) Platform (together “Services”).

Information we collect and when we collect it

We may collect your personal information in a number of circumstances, such as when:

• You use our Services
• You register for an account through our website
• You sign up to receive updates from us via email or social media channels
• You use a mobile device or web browser to access our content
• You contact us via email, social media, or any similar technologies
• You mention us on social media
• You opt in for marketing messages or participate in promoted events
• You become a platform user

Information we collect falls into one of two categories: “voluntarily provided” information and “automatically collected” information.
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“Voluntarily provided” information refers to any information you knowingly and actively provide us when using or participating in any of our Services and promotions.

“Automatically collected” information refers to any information automatically sent by your devices while accessing our Services.

Automatically collected information

Log data

When you use our Services, our servers may automatically log the standard data provided by your web browser. This may include your device’s Internet Protocol (IP) address, your browser type and version, the pages you visit, the time and date of your visit, the time spent on each page, and other details about your visit.

Additionally, if you encounter certain errors while using the Services, we may automatically collect data about the error and the circumstances surrounding its occurrence. This data may include technical details about your device, what you were trying to do when the error happened, and other technical information relating to the problem. You may or may not receive notice of such errors, even in the moment they occur, that they have occurred, or what the nature of the error is.

‍Please be aware that while this information may not be personally identifiable by itself, it may be possible to combine it with other data to personally identify individual people.

Device data

When you visit our website or interact with our Services, we may automatically collect data about your device, such as:

• Device type
• Operating system
• Geo-location data

The data we collect can depend on the individual settings of your device and software. We recommend checking the policies of your device manufacturer or software provider to learn what information they make available to us.

Voluntarily provided information

We may ask for personal information — for example, when you subscribe to our newsletter, contact us, or use or Services — which may include one or more of the following:

• Email address
• Social media profiles
• Phone/mobile number
• ‍Date of birth
• Gender
• Nationality
• Address
• Marital Status
• Financial information
• Government IDs (Health ID, Social Security, etc)
• Username and password used to access our platform

How we use your personal information

We may collect, hold, use, and disclose personal information for the following purposes:

• To provide you with our Services in accordance with the legal & contractual obligations.
• To enable you to customise or personalise your experience of our Services
• To contact and communicate with you and manage our relationship with you
• To consider your employment application
• Testing new products
• Improving our products and services, including data analytics to understand and improve effectiveness
• Managing our operations with other companies that provide services to our customers and us
• Developing new ways to meet our customers’ needs and grow our business
• Delivering relevant content via our Services and online advertisements to you, including measuring and understanding the effectiveness of advertisements served to you
• Marketing and events-related communications
• Making and managing payments and payrolls
• Managing fees and charges due on user accounts and collecting/recovering money owed to us
• Managing taxes and compliance requirements
• Administering and protecting our business and Services
• Identifying, investigating, reporting and preventing fraud, money laundering and other crimes
• Managing risk for our users and ourselves
• Complying with laws and regulations
• Investigating and responding to complaints and feedback

We may combine personal information with general information or research data we receive from other trusted sources. For example, our marketing and market research activities may uncover data and insights, which we may combine with information about how visitors use our Services to improve our Services and your experience.

Legal Bases for Processing your Personal Information

Some countries’ laws require us to identify a legal basis for our processing of your personal information. Where these laws apply, we process your personal information on the following legal bases:

• Contractual necessity: Skuad may process personal information based on contractual necessity when it is necessary for the performance of a contract to which you are a party, or for taking pre-contractual steps at your request. This means that we process your personal information to fulfil our contractual obligations to you or to establish a contract with you. For example, if you engage our Services, we need to process your personal information to provide the requested services, manage the client relationship, and handle related administrative tasks.
• Compliance with legal obligations: Skuad may process personal information when it is necessary to comply with a legal obligation imposed on us. This legal basis requires us to process personal information to meet our legal responsibilities, such as fulfilling obligations under applicable laws, regulations, or court orders. For instance, if we are legally required to retain certain records, conduct due diligence checks, or report information to regulatory authorities, we will process the necessary personal information to fulfil these obligations.
• Legitimate interests: Skuad relies on legitimate interests as a legal basis for processing personal information, provided that such interests are not overridden by your rights and interests. Our legitimate interests may include various business purposes, such as improving our Services, developing new features, conducting research and analysis, ensuring the security of our systems, and promoting our business. When relying on this legal basis, we carefully consider the impact on your privacy rights and only proceed with processing if it is reasonably expected and does not unduly infringe on your rights and freedoms.In some cases, Skuad may process personal information based on the legitimate interests of a third party, provided that such interests are not overridden by your rights and interests. This means that we may process personal information if it is necessary for a third party’s legitimate interests and does not disproportionately affect your rights. For example, when Skuad provides Services to a client, we may process personal information to support the client’s legitimate business purposes, such as when we provide HR or project management services.
• Consent: In some cases, for example, if you agree to receive marketing emails from us, or if you consent to the use of cookies on our website, we process your personal information based on your consent. You can withdraw your consent at any time.

When do we disclose your personal information

We may share your personal information where necessary with the parties and in the circumstances set out below for the purposes described in this policy.

• Our other group companies.
• Third-party service providers for the purpose of enabling them to provide their services, including (without limitation) IT service providers, data storage, hosting and server providers, analytics, error loggers, debt collectors, maintenance or problem-solving providers, professional advisors, and payment systems operators.
• 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 information in the same way as set out in this Policy.
• Our existing or potential agents or business partners.
• Credit reporting agencies, courts, tribunals, and regulatory authorities, in the event you fail to pay for goods or services we have provided to you.
• Courts, tribunals, regulatory authorities, and law enforcement officers, as required by law, in connection with any actual or prospective legal proceedings, or in order to establish, exercise, or defend our legal rights.

Security of your personal information

At Skuad, the security of your personal information is of utmost importance. We take extensive measures to safeguard the information you provide, aimed at protecting against loss, unauthorised access, disclosure, and misuse. These measures are designed to align with the sensitivity of the data we collect, process, and store, as well as the current advancements in technology. Skuad has obtained internationally recognised security certifications, reflecting our commitment to maintaining robust security practices.

However, it is important to note that due to the inherent nature of communication and information processing technology, we cannot guarantee absolute security against external intrusions while transmitting data over the internet or when it is stored in our systems. Additionally, when you click on a link leading to a third-party website, please be aware that you will be leaving our site, and we do not have control over or endorse the content found on such third-party sites.

You are responsible for selecting any password and its overall security strength, ensuring the security of your own information within the bounds of our services. For example, ensuring that any passwords associated with accessing your personal information and accounts are secure and confidential.

How long we keep your personal information

We keep your personal information only for as long as we need to fulfil the purposes mentioned in this Policy. This time period may depend on what we are using your information for, and as required by applicable law, in accordance with our data retention policy. For instance, if you have provided personal information while creating an account, we may retain this data as long as your account remains active on our system. If your personal information is no longer required for such purposes, we will promptly delete it or anonymise it by removing any identifiable details.

Nevertheless, there are certain circumstances where we may need to retain your personal information for legitimate business or legal reasons. These may include obligations related to compliance with applicable laws, accounting or reporting requirements, or the need for archiving in the public interest, scientific research, historical research, or statistical analysis. Additionally, certain data may be retained for extended periods to fulfil purposes such as ensuring security, preventing fraud and abuse, or maintaining financial records.

To ensure the safe and thorough management of your personal information, we adhere to a deletion process that aims to either completely remove your data from our servers or retain it solely in anonymised form. Our Services are designed to protect against accidental or malicious deletion of information. However, it’s important to note that there may be occasional delays between the time you initiate a deletion and when copies are effectively removed from both our active and backup systems.

Children’s privacy

We do not aim any of our products or services directly at children under the age of 16, and we do not knowingly collect personal information about children under 16. If you become aware that someone under the age of 16 has unlawfully provided us with personal information, please reach out to us, and we will promptly take measures to delete such information.

International data transfers

To the extent permitted by applicable laws, by providing us with your personal information and using our Services, you acknowledge and consent to Skuad receiving and processing your personal information and to your personal information being transferred to other countries where our affiliates and service providers are situated. It is important to note that some of these countries may have different data protection laws from those in your own country, and in some cases, these laws may not offer the same level of protection.

If you are in the EEA or the UK, and we transfer your information to a third-party located outside of the EEA/UK or a country without an adequacy decision by the European Commission/UK government, we will ensure that these third parties enter into an agreement that includes appropriate safeguards for your information. This will be achieved through the use of EU Model Clauses (SCCs) and the UK International Data Transfer Addendum.

Your rights and controlling your personal information

Depending on where you are located, you may have certain rights in relation to your personal information:

• Right to be informed: The right to be informed about the processing of personal information, including the purposes, recipients, and legal basis for the processing
• Right to access: The right to obtain confirmation of whether personal information is being processed and, if so, to access that information
• Right to data portability: The right to receive a copy of personal information in a structured, commonly used, and machine-readable format, and to transmit that personal information to another data controller
• Right to correction: The right to request the correction or amendment of inaccurate or incomplete personal information.
• Right to erasure: The right to request the deletion or removal of personal information under certain circumstances
• Right to restrict processing: The right to request the limitation of processing personal information under specific conditions.
• Right to object: The right to object to the processing of personal information based on specific grounds, such as legitimate interests or direct marketing.
• Right to non-discrimination: The right to be free from discriminatory practices or treatment based on the exercise of one’s data protection rights.
• Right to additional information: The right to request additional information about the processing of personal information beyond what is typically provided in privacy notices or disclosures.
• Right to withdraw consent: The right to withdraw consent given for the processing of personal information at any time.
• Right to make complaints: The right to lodge a complaint with a data protection authority
• Right to opt-out of sale: The right to opt out of the sale or disclosure of personal information to third parties for monetary or other valuable consideration.
• Right to object to automated decision-making: The right to object to decisions made solely based on automated processing, including profiling, that significantly affect you.
• Unsubscribe: To unsubscribe from our email database or opt-out of communications (including marketing communications), please contact us using the details provided in this Policy, or opt-out using the opt-out facilities provided in the communication. We may need to request specific information from you to help us confirm your identity.

‍To find out which rights apply to you, or to exercise these rights under the applicable regulations, please contact privacy@skuad.io. To ensure the security of your request, we will verify it using the information associated with your account, including your email address. In certain cases, we may request government identification as part of the verification process. If you prefer, you can also designate an authorised agent to act on your behalf to exercise these rights. To do so, the authorised agent must provide proof of authorisation.

Use of cookies

We use “cookies” to collect information about you and your activity across our site. A cookie isa small piece of data that our website stores on your computer, and accesses each time you visit, so we can understand how you use our site. This helps us serve you content based on the preferences you have specified.

‍Please refer to our Cookie Policy for more information.

Limits of our policy

Our website may link to external sites that are not operated by us. Please be aware that we have no control over the content and policies of those sites and cannot accept responsibility or liability for their respective privacy practices.

Changes to this policy

At our discretion, we may change this Policy to reflect updates to our business processes, current acceptable practices, or legislative or regulatory changes. If we decide to change this Policy, we will post the changes here at the same link by which you are accessing this Policy.

If the changes are significant, or if required by applicable law, we will contact you (based on your selected preferences for communications from us) and all our registered users with the new details and links to the updated or changed policy.

If required by law, we will get your permission or give you the opportunity to opt in to or opt out of, as applicable, any new uses of your personal information.

If you would like to exercise any of the rights listed above or if you have any questions about this Privacy Statement, please contact our Data Privacy Office at: privacy@skuad.io