Privacy Policy

1. Introduction

This Privacy Policy describes how MasterA (legal company name “Valandnis”, company address Naugarduko str. 98, Vilnius, Lithuania; [email protected]), and its affiliates will gather, use, and maintain your Personal Information on the MasterA Platform. It will also explain your legal rights with respect to that information.

By using the MasterA Platform, you confirm that you have read and understand this Privacy Policy, and our Terms of Service (together referred to herein as the “Agreement”). The Agreement governs the use of the MasterA Platform. MasterA will collect, use, and maintain information consistent with the Agreement.

If you have any questions or wish to exercise your rights and choices, please contact us as set out in the “Contact Us” section below.

2. General Terms

In this Privacy Policy:

• MasterA, may be referred to as "MasterA," “we,” “our,” or “us.”
• We call a user of the MasterA Platform “User,” “Users,” “you,” “your,” or “Client” and “Master,” as appropriate.
• The community platform that we offer at our website (www.MasterA.com is referred to as the “Site(s).”
• The mobile applications (whether on iOS or Android) are referred to as the “Apps.”
• MasterA’s Sites, Apps and related services, information and communications are collectively referred to as the “MasterA Platform.”
• “Terms of Service” refers to our Terms of Service, which can be found here. This Privacy Policy is incorporated into, and considered a part of, the Terms of Service.

3. Information Collection

Information you provide to MasterA

MasterA collects certain personally identifiable information about you, including information that can identify, relate to, describe, be associated with you, or is reasonably capable of being associated with you (“Personal Information”). Examples of Personal Information that MasterA collects include but are not limited to:

Contact Information.This may include your first and last name, postal address, telephone number, and email address.

Billing Data, including your payment instrument number (such as IBAN number, or a credit or debit card number), expiration date, and security code as necessary to process your payments.

Identity Information. If you are a Master, we may collect Personal Information, such as your date of birth and address, national identification number if applicable, photo, as well as such information as may be needed to validate your identity.

Financial Information. To help Masters set up a payment account and help Clients make payments to Masters and pay fees to MasterA, we may collect financial information, including credit card number, bank routing numbers, tax information, taxpayer identification number, and other payment information, as applicable. We use Financial Information in order to operate the MasterA Platform and to ensure that Masters are paid by Clients. We do this as necessary for our legitimate interests in providing our platform and services and to fulfill our contracts with Users. To keep your financial data secure, we have contracted with a third party to maintain and process your payment information.

Employment Information. We collect employment and education history, transcripts, writing samples, and references as necessary to consider your job application for open positions.

Content Information. You also may choose to send MasterAPersonal Information in an email or chat message containing inquiries about the MasterA Platform and we use this Information in order to help us respond to your inquiry. We also collect content within any messages you exchange with other Users through the MasterA Platform (such as through our chat functionality).

We require that you furnish certain information when you register an account with us in order to provide services through the MasterAPlatform. For example, if you are a Client, we collect your first and last name, email address, and your zip or postal code in order to create and administer your MasterA account. We also collect additional information in order to facilitate your booking request, such as information about the task you are seeking, the time, date and location of the task, and Billing Data. If you are a Master, we collect your first and last name, email address, mobile phone number and zip or postal code in order to create and administer your MasterAaccount and facilitate communications between you and your Clients through the MasterA Platform. We also collect information about your tasks, rates, and skills, as well as Identity Information and Financial Information.

4. Information MasterA Collects Automatically

We automatically collect certain information when you use the MasterAPlatform. The categories of information we automatically collect and have collected, including in the last 12 months, are as follows:

Service Use Data, including data about features you use, pages you visit, emails and advertisements you view, portions of the MasterAPlatform that you view and interact with, the time of day you browse, and your referring and exiting pages.

Device Data, including data about the type of device or browser you use, your device’s operating system, your internet service provider, your device’s regional and language settings, and device identifiers such as IP address and Ad Id. When you visit and interact with the MasterA Platform, MasterA may collect certain information automatically through cookies or other technologies, including, but not limited to, the type of computer or mobile device you use, your mobile device’s unique device ID, the IP address of your computer or mobile device, your operating system, the type(s) of internet browser(s) you use, and information about the way you use the MasterAPlatform (“Device Information”). We may use Device Information to monitor the geographic regions from which Users navigate theMasterA Platform, and for security and fraud prevention purposes. Use of any IP-masking technologies or similar technologies (like the TOR network) may render portions of the MasterA Platform unavailable and are forbidden on the MasterA Platform.

Location Data, including imprecise location data (such as location derived from an IP address or data that indicates a city or postal code level), and, with your consent, precise location data (such as latitude/longitude data). When you visit the MasterA Platform via a native mobile application, we use, with your consent when required under applicable law, GPS technology (or other similar technology) to determine your current location in order to determine the city you are located in and display a relevant location map. We will not share your current location obtained in this manner with other Users.

Cookies and similar technologies are described in our Cookie Policy, which sets out the different categories of cookies and similar technologies that the MasterA Platform uses and why we use them.

5. MasterA's Use of Information

We collect and use information for business and commercial purposes in accordance with the practices described in this Privacy Policy. Our business purposes for collecting and using information include:

• To operate and make available the MasterA Platform. We use your data to connect you with other Users to enable the posting of, selection for, completion of, and payment for Tasks, in order to fulfill our contracts with Users;
• For billing and fraud prevention, on the basis of our legitimate interests in ensuring a safe and secure environment in which Clients and Masters can meet and conduct business, and in order to comply with our legal obligations;
• To analyze MasterA Platform usage as necessary for our legitimate interest in improving the MasterA Platform to grow our business;
• To contact you and deliver (via email, SMS, push notifications, or otherwise) transactional information, administrative notices, communications relevant to your use of the MasterA Platform, with your consent when required under applicable law, as necessary for our legitimate interests in proper communication and engagement with our Users, and in promoting our business;
• To provide you with customer support in order to fulfill our contracts with Users;
• For internal market research for our legitimate interest in improving the MasterA Platform to grow our business;
• For troubleshooting problems for our legitimate interests in ensuring a safe and secure environment in which Users can meet;
• To assist Users in the resolution of complaints and disputes between them, as necessary for our legitimate interests in facilitating good relations among Users;
• To enforce our Terms of Service and our legitimate interests in ensuring our Agreement is complied with; and
• As otherwise set forth in the Agreement.

Analytics and Market Analysis. MasterA may analyze information (“Market Analysis”) as necessary for our legitimate interests in providing an engaging and relevant experience, and promoting and growing the MasterA Platform.

MasterA uses information to offer services to Users who express an interest in these services, through a poll for example, or to Users who can be presumed to have an interest based on results from our Market Analysis. We do this as necessary for our legitimate interests in providing an engaging and relevant experience, promoting our services, and growing our business.

Cell Phone Numbers. MasterA may use your cell phone number to call or send recurring text messages to you, using an autodialer or prerecorded voice, in order to provide you notifications about Tasks, for marketing purposes (with your consent where required by law), and to administer the MasterA Platform. If you would like more information about our policy, or how to opt out, please review the “Your Rights and Choices” section below or Section 9 of our Terms of Service. You may be liable for standard SMS and per-minute charges by your mobile carrier. MasterA may also message you via push notifications (with your consent when required under applicable law), which you can opt-out of on your mobile device. Data rates may apply.

Call recordings. Calls to or from MasterA or its Third Party Agents may be monitored and recorded for the purposes of quality control and training. Such calls may contain Personal Information.

6. Information Sharing

We only share the Information we collect about you as described in this Privacy Policy or as described at the time of collection or sharing, including as follows:

Third Party Agents. We share information, including Identity Information, with entities that process information on our behalf for our business purposes. We contractually prohibit our Third-Party Agents from retaining, using, or disclosing information about you for any purposes other than performing the services for us, although we may permit them to use information that does not identify you (including information that has been aggregated or de-identified) for any purpose except as prohibited by applicable law.

To operate the MasterA Platform, including processing your transactions, we may share your Personal Information with our agents, representatives, vendors and service providers (“Third Party Agents”) so they can provide us with support services as follows:

• Email origination;
• Receipt, invoice, or support services;
• Customer relationship management services;
• Data analytics;
• Marketing and advertising;
• Website hosting;
• Communications services;
• Technical support;
• Financial transaction fulfillment and related chargeback and collection services; and
• To otherwise help us provide the MasterA Platform.

Other Users. MasterA facilitates contact between Clients and Masters and reserves the right to share one User’s contact information (e.g., name, phone number, email, or postal address) with other Users, or with the recipient User’s legal or other authorized representative, in order to: (1) facilitate or communicate the resolution of an investigation or dispute related to or arising from an interaction between two or more Users of the MasterA Platform; or (2) facilitate the performance of a Task. This exchange of information is essential to the operation of the MasterA Platform.

Legal Obligations. MasterA and our Third Party Agents may disclose your Personal Information or User Generated Content to courts, law enforcement, governmental or public authorities, tax authorities or authorised third parties, if and to the extent required or permitted to do so by law or where disclosure is reasonably necessary to: (i) comply with MasterA’s legal or regulatory obligations; (ii) respond to a court order, warrant or subpoena; (iii) respond to a valid legal request relating to an investigation into alleged criminal or illegal activity; or (iv) respond to or address any other activity that may expose us to legal or regulatory liability.

In jurisdictions where MasterA is, according to applicable law, required to collect or remit information about Users’ permits, licences, tax, or social security registrations, MasterA and our Third Party Agents may disclose information, including but not limited to, User contact details, identification information, transaction dates and amounts, license and permit status, and tax identification number(s) to applicable governmental authorities.

MasterA reserves the right to disclose Personal Information from both private and public areas of the MasterA Platform in the absence of a court order, warrant, or subpoena, to the extent permitted by applicable law, if we are given reason to believe, in our sole discretion, that someone is causing injury to or interfering with the rights of Users, the general public, or MasterA or its partners, parents or affiliates.

It is our policy to provide notice to Users before producing their information in response to law enforcement requests unless (i) we are prohibited or otherwise constrained by law or court order from doing so, (ii) we have reason to believe the User’s account has been compromised such that the notice would go to the wrong person, or notice would otherwise be counterproductive or would create a risk to safety, or (iii) it is an emergency request and prior notice would be impractical (in which case we may provide notice after the fact).

Merger or Acquisition. MasterA reserves the right to share information in connection with, or during negotiations of, any proposed or actual merger, purchase, sale, or any other type of acquisition or business combination of all or any portion of our assets, or transfer of all or a portion of our business to another business.

Public Areas. Your profile on the MasterA Platform consists of information about you and your business, and may include information such as photographs, your years in business, skills and expertise, hourly pay rates, feedback/rating information, and other information, including your username (“Profile”). The information in your User Profile may be visible to all Users and the general public.

7. Your Rights and Choices

You may opt-out of receiving promotional communications from us, including promotional communications related to the MasterA Platform, and request the removal of your Personal Information from our databases, or deactivate your account, by contacting us.

Push Notifications. You have the option to receive updates and relevant offers via push notifications in your app. These notifications can be configured in the settings of your mobile device at any time.

Corrections to Profile. You have the right to access, update, and correct inaccuracies in your MasterA Profile at any time by logging in and clicking on the “Account” tab. There, you can view, update, and correct your Account information.

So that we may protect the integrity of the MasterA Platform, there are certain pieces of information, such as your age, that you cannot alter yourself. You may contact us if there is a need to make a correction to such data.

Your Rights. You also have the following rights under certain circumstances:

• A right of access: you have the right to obtain confirmation as to whether personal data concerning you are processed or not and, if processed, to obtain access to such data and a copy thereof;
• A right to rectification: you have the right to obtain the rectification of any inaccurate personal data concerning you. You also have the right to have incomplete personal data completed, including by means of providing a supplementary statement;
• A right to erasure: in some cases, you have the right to obtain the erasure of personal data concerning you. However, this is not an absolute right and MasterA may have legal or legitimate grounds for keeping such data;
• A right to restriction of processing: in some cases, you have the right to restrict the processing of your personal data;
• A right to data portability: you have the right to receive the personal data concerning you which you have provided to MasterA, in a structured, commonly used and machine-readable format, and you have the right to transmit those data to another controller without hindrance from MasterA. This right only applies when the processing of your personal data is based on your consent or on a contract and such processing is carried out by automated means.
• A right to object to processing: you have the right to object at any time, on grounds relating to your particular situation, to processing of personal data concerning you when such processing is based on the legitimate interest of MasterA. MasterA may, however, invoke compelling legitimate grounds for continued processing. When your personal data are processed for direct marketing purposes, you have the right to object at any time to the processing of such data. You can change your marketing preferences at any time as described in Section 7, Your Rights and Choices.
• A right to lodge a complaint with the supervisory authority: if your request or concern is not satisfactorily resolved by us, you may approach your local data protection authority. The Information Commissioner is the supervisory authority in the UK and can provide further information about your rights and our obligations in relation to your personal data, as well as deal with any complaints that you have about our processing of your personal data (https://ico.org.uk/). The CNIL is the supervisory authority in France. The Spanish Data Protection Agency is the supervisory authority in Spain. This list identifies the supervisory authorities for the 16 states in Germany. The CNPD (“Comissão Nacional de Proteção de Dados”) is the supervisory authority for Portugal. The Garante per la protezione dei dati personali is the supervisory authority in Italy.

You can exercise your rights by contacting us.

8. MasterA's Information Retention Policy

We retain personal data for as long as you are a User in order to meet our contractual obligations to you, and for such longer period as may be in our legitimate interests and to comply with our legal obligations. We may also retain data from which you cannot directly be identified, for example where stored against a randomly-generated identifier so we know the data relates to a single User, but we cannot tell who that User is. We use this kind of data for research purposes and to help us develop and improve our services, and we take appropriate measures to ensure you cannot be re-identified from this data.

9. MasterA’s Security of Collected Information

Your MasterA account is password-protected so that only you and authorized MasterA staff have access to your account information. In order to maintain this protection, do not give your password to anyone. Also, if you share a computer, you should sign out of yourMasterA account and close the browser window before someone else logs on. This will help protect your information entered on public terminals from disclosure to third parties.

MasterA implements and maintains reasonable administrative, physical, and technical security safeguards to help protect information about you from loss, theft, misuse and unauthorized access, disclosure, alteration and destruction. MasterA has staff dedicated to maintaining this Privacy Policy and other privacy initiatives, periodically reviewing security, and making sure that every MasterA employee is aware of our security practices. Nevertheless, transmission via the internet is not completely secure and we cannot guarantee the security of information about you.

10. Notification of Changes

MasterA's Privacy Policy is periodically reviewed and enhanced as necessary. This Privacy Policy might change as MasterA updates and expands the MasterA Platform. MasterA will endeavor to notify you of any material changes by email. MasterA also encourages you to review this Privacy Policy periodically.

11. Contacting Us

If you have any questions about this Privacy Policy or the manner in which we or our Third-Party Agents treat your Personal Information, the practices of the Site, your dealings with the MasterA Platform, or if you have technical problems, you may contact us.

MasterA's staff will respond to all mail or email from Users with questions about privacy, including the types of Personal Information stored on the MasterA databases, and requests to know, delete or rectify such Personal Information.