MyVox

Privacy Policy

This privacy policy will explain how our organisation, Global Rights Compliance (‘GRC’ and ‘we’ and ‘our’), uses the personal data we collect from you (‘you’ and ‘your’) when you use our MyVox (‘the app’)

About MyVox

Through the MyVox app, users (paralegals) will be able to log in the app using their credentials and report complaints regarding labour rights violations. This includes the collection and processing of personal data of both paralegals and workers on behalf of Global Rights Compliance Foundation, based in the Hague, Netherlands (GRC). The data controller of your personal information is, therefore, GRC.

This Privacy Statement explains our practices, including your choices, regarding the collection, use, and disclosure of certain information, including your personal information in connection with MyVox.

If you have questions about this Privacy Statement, or our use of your personal information, cookies or similar technologies, please contact us by email at [email protected]. Please note that if you contact us to assist you, for your safety and ours we may need to authenticate your identity before fulfilling your request.

Collection of Information

We receive and store information about you such as:

Information you provide to us: We collect information you provide to us which includes:

• your name, email address, telephone number, biometric data, and other identifiers you might use (such as a username). We collect this information in order to set your profile and be able to log into the app.

• information when you enter the details of complaints into the app. These information includes the personal data of workers/interviewees, who voluntarily share their complaints and report any human rights abuses they have suffered. In particular, workers are asked to share some information, such as their hometown, their age group and the factory they work in. They will also have the possibility to provide paralegals with photos, videos and voice recordings, and describe incidents that entail personal and sensitive information, especially in cases of harassment, forced labour etc. This is why it is important that users properly inform interviewees about their data protection, the purpose of the data collection and their rights under the GDPR and give their clear consent for the data collection. GRC has provided users with all the necessary consent and privacy forms for this purpose.

  Information we collect automatically: We collect information about you and your use of our service, your interactions with us, as well as information regarding your network, network devices. This information includes:

• your activity on MyVox app, such as the cases you have filed, including any relevant information;

• your interactions with our emails;

• details of your interactions with our support service, such as the date, time and reason for contacting us, transcripts of any chat conversations, and if you call us, your phone number and call recordings;

  
  

  Information from partners: We collect information from organizations with whom you have a relationship (“Partners”). The information Partners provide us may include:

• your place of operation (city, district, working station);

• service activation information such as your email address or other contact information;

• IP addresses, device IDs or other unique identifiers, user interface information, that support user authentication, and payment processings.

  
  

  Use of Information

  We use information to provide, analyze, administer, enhance and personalize our services, to process your registration, and to communicate with you on these and other topics. For example, we use such information to:

• extract anonymised data of labor human rights violations, in order to use them for advocacy and awareness raising purposes;

• determine your general geographic location (such as your city and state/province);

• help us quickly and efficiently respond to inquiries and requests;

• coordinate with Partners on making MyVox available to users;

• secure our systems, prevent fraud and help us protect the security of MyVox accounts;

• prevent, detect and investigate potentially prohibited or illegal activities, including fraud;

• analyze and understand our audience, improve our service and optimize content selection, recommendation algorithms and delivery.

  
  

  Our legal basis for collecting and using the personal information described in this Privacy Statement will depend on the personal information concerned and the specific context in which we collect and use it.

  We will normally collect personal information from you where we need the personal information to perform a contract with you (for example, to provide our services to you), where the processing is in our legitimate interests and not overridden by your data protection interests or fundamental rights and freedoms, or where we have your consent to do so.

  In some cases, we may also have a legal obligation to collect personal information from you or may otherwise need the personal information to protect your vital interests or those of another person (for example, to prevent payment fraud or confirm your identity).

  Disclosure of Information

  We only share user data with companies that have good privacy practices. In particular, we disclose your information for certain purposes and to third parties, as described below:

  
  

• Service Providers: We use other companies, agents or contractors ("Service Providers") to perform services on our behalf or to assist us with the provision of services to you. For example, we engage Service Providers to provide security, infrastructure and IT services, to customize, personalize and optimize the app, to provide bank account or balance information, to process credit card transactions or other payment methods, to provide user service, to analyze and enhance information (including information about users' interactions with our service), and to process and administer consumer surveys. In the course of providing such services, these Service Providers may have access to your personal or other information. We do not authorize them to use or disclose your personal information except in connection with providing their services (which includes maintaining and improving their services).

• Partners: As described above, you may have a relationship with one or more of our

  Partners, in which case we may share certain information with them in order to coordinate with them on providing the MyVox service to users and paralegals.

• Protection of GRC and others: GRC and its Service Providers may disclose and otherwise use your personal and other information where we or they reasonably believe such disclosure is needed to (a) satisfy any applicable law, regulation, legal process, or governmental request, (b) enforce applicable terms of use, including investigation of potential violations thereof, (c) detect, prevent, or otherwise address illegal or suspected illegal activities (including payment fraud), security or technical issues, or (d) protect against harm to the rights, property or safety of GRC, its users or the public, as required or permitted by law.

• Business/Organizational transfers: In connection with any reorganization, restructuring, merger or sale, or other transfer of assets, we will transfer information, including personal information, provided that the receiving party agrees to respect your personal information in a manner that is consistent with our Privacy Statement.

  
  

  Whenever in the course of sharing information we transfer personal information to countries outside of the European Economic Area and other regions with comprehensive data protection laws, we will ensure that the information is transferred in accordance with this Privacy Statement and as permitted by the applicable laws on data protection. Specifically, we use a variety of contractual, organizational and technical protections as appropriate for such transfers, including data protection agreements/standard contractual clauses; technical protections such as encryption, and practices to challenge disproportionate or unlawful government authority requests.

  
  

  Access to Account and Profiles

  Every user has a unique profile on MyVox, and they can access MyVox, by filling their personal emails and a given password which is not to be shared with anyone. Users may also log into the app, using their biometric data, such as face ID and/or fingerprints.

  
  

  Cookies are small data files that are commonly stored on your device when you browse and use websites and online services. We use other technologies such as browser storage and plugins (e.g., HTML5, IndexedDB, and WebSQL). Like cookies, these other technologies may store small amounts of data on your device. Web beacons (also known as clear gifs or pixel tags) often work in conjunction with cookies. In many cases, declining cookies will impair the effectiveness of web beacons associated with those cookies.

  
  

  Your Information and Rights

  We would like to make sure you are fully aware of all of your data protection rights. Every user is entitled to the following:

  
  

• The right to access: you have the right to request GRC for copies of your personal data.

• The right to rectification: you have the right to request that we correct any information you believe is inaccurate. You also have the right to request to complete the information you believe is incomplete.

• The right to erasure: you have the right to request that we erase your personal data, under certain conditions.

• The right to restrict processing: you have the right to request that we restrict the processing of your personal data, under certain conditions.

• The right to object to processing: you have the right to object to the processing of your personal data, under certain conditions.

• The right to data portability: you have the right to request that we transfer the data that we have collected to another organization, or directly to you, under certain conditions.

You can object to processing of your personal information, ask us to restrict processing of your personal information or request portability of your personal information; if we have collected and process your personal information with your consent, then you can withdraw your consent at any time; withdrawing your consent will not affect the lawfulness of any processing we conducted prior to your withdrawal, nor will it affect processing of your personal information conducted in reliance on lawful processing grounds other than consent.

If you would like to exercise any of these rights, please contact us at our email: [email protected]. Please note that if you make a request, we have one month to respond to you.

Security

We use reasonable administrative, logical, physical and managerial measures to safeguard your personal information against loss, theft and unauthorized access, use and modification. These measures are designed to provide a level of security appropriate to the risks of processing your personal information.

How long we store the data

We will keep your data for five years. Once this time period has expired, we will delete your data.

Retention of information: We may retain information as required or permitted by applicable laws and regulations, including to fulfil your choices, for our billing or records purposes and to fulfill the purposes described in this Privacy Statement. Specifically, we retain information for our legitimate interests and essential business purposes, such as operating, maintaining and improving our services; complying with our legal obligations; and exercising our legal rights and remedies, including enforcing our terms of use. Our retention of information is based on many factors such as your relationship with GRC; the nature of the information; compliance with our legal obligations; defending or resolving actual or anticipated legal claims. We take reasonable measures to destroy or de-identify personal information in a secure manner when it is no longer required.

Children

You must be at least 18 years of age or older to subscribe to MyVox app.

Contact

For questions about our use of your personal information (including legal bases and transfer mechanisms we rely on), cookies or similar technologies, please contact us by email at [email protected].

Changes to This Privacy Statement

We will update this Privacy Statement from time to time in response to changing legal, regulatory or operational requirements. We will provide notice of any such changes (including when they will take effect) in accordance with law. Your continued use of MyVox after any such updates take effect will constitute acknowledgement and (as applicable) acceptance of those changes.

Last Updated: August 3, 2023

© 2023 Global Rights Compliance Foundation