2. Our Services
To get a better sense on how and from whom we collect data, it is useful to start with a brief overview of our Services. Morgi operates a website www.morgi.org ("Website"), on which individuals ("Rookies") can receive gifts ("Gifts") from other individuals ("Leaders") for gifting purposes (together, "Services"). This Policy applies to the information we collect from any person using or interacting with our Services, including Rookies and Leaders, as well as any person visiting our Website (collectively: “Users”).
3. What types of data we collect?
We collect two types of data from you: Personal Data ("Personal Data") and non-Personal Data. Personal Data means any information which may potentially allow your identification with reasonable means (for example, email address or name). Non-Personal Data, by contrast, can be defined as any information that does not relate to an identified or identifiable natural person. This may include, for example, your aggregated usage information and technical information transmitted by your device (for example, the device you use, the type of browser and operating system your device uses, language preference, access time, etc.). This section sets out how and when we collect those types of data from you.
3.1. All Users
5. Why we collect your Personal Data?
Privacy laws require us to have a valid lawful basis in order to process your Personal Data. The lawful basis for processing are set out in Article 6 of the Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 on the protection of natural persons with regard to the processing of personal data and on the free movement of such data (“GDPR”). This section explains for what purposes we may use your personal data and outlines the legal bases that underlie our usage.
|Consumer services. We use your Personal Data, such as your name and email address, for consumer services purposes. This includes, for example, responding to your inquiries.||The legal basis for processing this data are the performance of our contractual towards you; your consent (for example, when you inputs personal information into the Website); the compliance with our legal obligations; and the protection of our legitimate interests. Our legitimate interests in this case are providing and improving our Services.|
|Facilitating payments. We collect from our third-party Payment Processors certain information about your payment instruments for the purpose of connecting your payment instrument to your account on our Website and enable you to facilitate Gifts.||The legal basis for processing this data are the performance of our contractual towards; the protection of our legitimate interests (in this case provide our Services).|
|Provide our Services. We use your contact information (for example, name and email) to facilitate your registration with our Services. In addition, we use your account data to enable you to open Campaigns and make and receive Gifts via the Website.||The legal basis for processing this data are the performance of our contractual towards you and the protection of our legitimate interests. Our legitimate interests in this case are providing our Services.|
|Improve our Services. We collect and analyze information about you and your usage of our Services to improve the usability and effectiveness of our Services.||The legal basis for processing this data are the performance of our contractual towards you and the protection of our legitimate interests. Our legitimate interests in this case are improving our Services.|
|Tailor our Services. We use connection and usage data (for example, the pages you visited on our website, Campaigns you viewed or searched for, and websites you visited before and after navigating to our Website), your likeness and physical attributes, as provided by you (e.g. by providing your pictures), to tailor our Service to your or others' usage (for example, to suggest you Campaigns that you might be interested in). Face analysis: we will also visually process your image information (e.g your profile picture) to detect and analyze de-identified and general face attributes (such as hair color, mustache or eye color) for the purpose of supporting our indexing feature and allowing Leaders/Rookies to designate their preferences when using the Services. This information would not be used for any other purpose, including for advertising/marketing purposes. For the avoidance of doubt, this information does not involve or allow for the possibility to identify or recognize you.||The legal basis for processing this data is the protection of our legitimate interests. Our legitimate interests in this case are improving our Services.|
|Marketing and Advertising. We may use your Personal Data to provide you with personalized advertisements when visit our Services and to provide you with promotional materials we believe may be relevant for you. If you do not want us to use or share your Personal Data for advertising or marketing purposes, you may opt out of certain cookies by following the instructions provided in our Cookies Policy or unsubscribe from such marketing materials.||The legal basis for processing this data are your consent (when required); the compliance with our legal obligations; and protecting our legitimate interests. Our legitimate interests in this case are providing you with tailored services and advertisements that better correspond with your interests.|
|Compliance with the applicable laws. We may be required to collect, retain, or share your Personal Data under applicable laws.||The legal basis for processing this data is compliance with our legal obligation.|
6.1 The Company may use your Personal Data, such as your name, home address, email address, telephone number etc., ourselves or by using our third party subcontractors for the purpose of providing you with promotional materials, concerning the Services as well as products, services, websites and applications which relate to: (i) affiliated companies or Company's business partners and affiliates (collectively: “Marketing Affiliates”), which we believe may interest you.
6.2 We may also share and disclose Personal Data with our Marketing Affiliates for the purpose of providing you different marketing offers, which we, or our Marketing Affiliates, believe are relevant for you. Our Marketing Affiliates may use this Personal Data for different marketing techniques, such as, but not limited to, direct email, post and SMS.
6.3 You may at any time decline receiving further marketing offers from us or from our business partners and marketing affiliates by contacting us at to DPO@morgi.org.
6.4 Please note that even if you unsubscribe from our marketing mailing list, we may continue to send you service-related updates and notifications.
7. With whom we share your data?
We share your Personal Data as descried below –
8. Data protection rights
This section addresses the specific rights applying to residents of the EU or residents in other jurisdiction that afford the below rights.
8.1. Your rights
You may request to:
Please note that these rights are not absolute and may be subject to our own legitimate interests and regulatory requirements. Users outside the EU are welcome to contact us for any questions or requests at the details below.
8.2. Transfer of data outside the EU
9. How we protect your data?
We have implemented administrative, technical, and physical safeguards to help prevent unauthorized access, use, or disclosure of your Personal Data. While we seek to protect your information to ensure that it is kept confidential, we cannot guarantee the security of any information. You should be aware that there is always some risk involved in transmitting information over the internet and that there is also some risk that others could find a way to thwart our security systems. Therefore, we encourage you to exercise discretion regarding the Personal Data you choose to disclose. If you feel that your privacy was treated not in accordance with our Policy, or if any person attempted to abuse the Services or acted in an inappropriate manner, please contact us directly via DPO@morgi.org.
We do not knowingly collect or solicit Personal Data from anyone under the age of consent (as determined under the applicable laws where the individual resides; “Age of Consent”). By accessing, using or interacting with our Services, you certify to us that you are not under the Age of Consent. In the event that we learn that we have collected Personal Data from an individual under the Age of Consent without verification of parental consent, we will delete that information upon discovery. If you believe that we might have any information from or about an individual under the Age of Consent, then please contact us through the contact details available below.
11. Updates to this Policy
We reserve the right to change this Policy at any time. The most current version will always be posted on our Website (as reflected in the “Last Updated” heading). You are advised to check for updates regularly. By continuing to access or use our Services after any revisions become effective, you agree to be bound by the updated Policy.
12. Data Protection Officer
The Company has a “Data Protection Officer” who is responsible for matters relating to privacy and data protection. This Data Protection Officer can be reached at the following address: DPO@morgi.org
13. Further Information
If you have any further questions regarding the data collects, or how we use it, please contact us via the available chat option.