PRIVACY

These principles of Processing of the www.multitude.com website (hereinafter website) visitors Personal Data (hereinafter principles) describe how we, Multitude (hereinafter also we, us or our) process Personal Data of our website visitors and any other Data Subjects (hereinafter also you). These principles apply if you visit our website, or in case you have expressed your wish to receive any information about our products or services.

This policy has been last updated 14 June 2022

1. Definitions
   1. Data Protection Regulations – Any applicable laws and regulations regulating the processing of Personal Data, including but not limited to the GDPR;
   2. Data Subject - an identifiable natural person who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person;
   3. Multitude – Multitude AG, the Company is registered with the Zug Commercial Register in Switzerland, and its registered address is Grafenauweg 8, 6300 Zug;
   4. GDPR – 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, and repealing Directive 95/46/EC (General Data Protection Regulation);
   5. Personal Data – Any information relating to Data Subject. Data which is protected by banking secrecy may also include Personal Data;
   6. Processing – Any operation or set of operations which is performed on Personal Data or on sets of Personal Data, whether by automated means, such as collection, recording, storing, alteration, granting access to, making enquiries, transfer, viewing, etc.
2. Data Controller
   1. Multitude is responsible for the Processing of your Personal Data. These principles apply where Multitude acts as the Data Controller of your Personal Data in terms of the GDPR.
   2. As Multitude is a company established under the laws of Republic of Finland, then the Processing of your Personal Data shall be governed by the laws of Finland.
3. Collecting your Personal Data
   1. Multitude collects your following Personal Data in the following ways:
      1. contact and communication data through communications made to us;
      2. technical logs by automatic means when you use our website. Such Processing is further explained in our Cookies in Section 6.
4. Personal Data Processed
   1. Multitude Processes Personal Data collected for the following purposes:
      1. performance of our obligations arising from law;
      2. safeguarding our rights (establishing, exercising, and defending legal claims). The legal basis for such Processing is Multitude’s legitimate interest;
      3. assessing and developing further the quality of our services and products, e.g., customer support service and quality assurance service. The legal basis for such processing is the legitimate interest of Multitude;
      4. assessing the quality of our (potential) service providers services which enables us to evaluate and develop further the quality of the services and products we offer. The legal basis for such processing is the legitimate interest of Multitude;
      5. internal record and statistics keeping;
      6. security of the website to guarantee a safe consultation and secure interaction with our systems;
      7. to ensure the best user experience;
      8. the purposes you would have requested when providing your Personal Data to us.
5. Disclosing the Personal Data
   1. We do not share your personal data with third parties and do not transfer your Personal Data outside of the European Economic Area.
6. Cookies
   1. A cookie is a small file to be placed on your computer or any other device you use to access our website. Cookies help analyse web traffic or let you know when you visit a particular site. Cookies allow web applications to respond to you as an individual. The web application can tailor its operations to your needs, likes and dislikes by gathering and remembering information about your preferences. A cookie does not give access to the device.
   2. The website uses the following cookies:
      1. Essential Cookies. Essential cookies are a site’s basic form of memory, used to store the settings selected by a visitor. They are essential to a website’s functionality and cannot be disabled by visitor;
      2. Web Analytics and Customization Cookies. Analytics and customization cookies track visitor activity in their browsers, so Multitude can better understand how our website is being accessed and used.

      - Google Analytics. To optimise its internet offer, Multitude uses web analysis services Google Analytics and Google Tag Manager of Google. These cookies are used to collect information about how visitors use the website. Multitude uses the information to compile reports and to improve the website. The cookies collect information in a way that does not directly identify anyone, including the number of visitors to the website, where visitors have come to the website from and the pages they visited. You can find more detailed information about this here https://support.google.com/analytics/answer/6004245.

      To opt out of being tracked by Google Analytics across all websites, visit http://tools.google.com/dlpage/gaoptout.

      - Google Floodlight. Floodlight is an optional feature that allows Multitude to track and report on the onsite actions of visitors to Multitude’s website. You can find more information about this here. https://support.google.com/campaignmanager/answer/2823388?hl=en.

      - Hotjar. Multitude uses Hotjar to better understand your needs and to optimize visitor’s experience. Hotjar is a technology service that helps Multitude better understand visitor’s experience (e.g., how much time you spend on which pages, which links you choose to click, what you do and don’t like, etc.) and this enables Multitude to build and maintain its services with visitors’ feedback. Hotjar uses cookies and other technologies to collect data on visitor’s behaviour and devices. This includes a device's IP address (processed during your session and stored in a de-identified form), device screen size, device type (unique device identifiers), browser information, geographic location (country only), and the preferred language used to display Multitude’s website. Hotjar stores this information on Multitude’s behalf in a pseudonymized user profile.

      3. Marketing Cookies. Marketing cookies are used to customize visitors’ ad experience on a website based on their browsing history. Using the data collected from these cookies, Multitude can prevent the same ad from appearing again and again, remember visitor ad preferences, and tailor which ads appear in browsers based on a visitor’s online activities.

         - Google Ads. Google Ads uses the cookies and keywords to allow Multitude to advertise and promote the products and services by reaching interested visitors. You can find more information about this here https://support.google.com/google-ads/answer/6319?hl=en

         - MaxTraffic. With MaxTraffic web push notification, overlays, and promo bars Multitude is able to reach the interested visitors of the products and services available. You can find more information about this here https://maxtraffic.com/.

         - Bing Ads. Bing Ads uses the cookies and keywords to allow Multitude to advertise and promote the products and services by reaching interested visitors. You can find more information about this here https://about.ads.microsoft.com/en-us.

      4. Social Networking Cookies. Social networking tracking cookies allow users to share content on social media platforms and help link activity between a website and third-party sharing platforms.

         -Facebook Plugins are integrated in Multitude website. You can recognize the Facebook plugins from the Facebook logo or the "Like button”. You can find an overview of the Facebook plugins here: http://developers.facebook.com/docs/plugins/. If you visit the website and click on the Facebook plugin, a direct connection will be established between your browser and the Facebook server. Facebook thereby receives the information that you have visited the website with your IP address. If you click on the Facebook "Like button" while you are logged into your Facebook account, you can link the contents of the website pages to your Facebook profile. Thereby, Facebook can associate the visit to the website with your user account. Multitude does not receive any information on the contents of the data transmitted and their use by Facebook. You can find further information about this in Facebook’s Privacy Policy at http://facebook.com/policy.php.

         - Functions of the Twitter service are integrated in the Multitude website. By using Twitter and the "re-tweet" function, the websites visited by you are linked to your Twitter account and announced to other users. Data are thereby also transmitted to Twitter. Multitude does not receive any information on the contents of the data transmitted and their use by Twitter. You can find further information about this in Twitter’s Privacy Policy at http://twitter.com/privacy.

         - Functions of the Instagram service are integrated in the Multitude website. If you are logged into your Instagram account, you can link the contents of the website pages with your Instagram profile by clicking on the Instagram button. Thereby, Instagram can associate the visit to the website with your user account. Multitude does not receive any information on the contents of the data transmitted and their use by Instagram. You can find further information about this in Instagram’s Privacy Policy: http://instagram.com/about/legal/privacy/.

Name	Description	Category	Expiry
ASP.NET_SessionId	General purpose platform session cookie, used by sites written with Miscrosoft .NET based technologies. Usually used to maintain an anonymised user session by the server.	Strictly necessary	1 year
AWSALB	AWS ELB application load balancer	Strictly necessary	6 days
AWSALBCORS	This cookie is managed by AWS and is used for load balancing.	Strictly necessary	6 days
AWSALBTG	AWS Application Load Balancer Cookie: Load Balancing Cookie: Used to encode information about the selected target group.	Strictly necessary	6 days
AWSALBTGCORS	AWS Application Load Balancer Cookie. Load Balancing Cookie: Used to map the session to the instance.	Strictly necessary	6 days
__cf_bm	This is a CloudFoundry cookie.	Strictly necessary	0 days
_cfuvid	The _cfuvid cookie is used by Cloudflare to distinguish individual users who share the same IP address for the purpose of enforcing rate limiting rules.	Strictly necessary	1 year
cf_chl_rc_ni	This is a CloudFoundry cookie.	Strictly necessary	0 day
IRPages2_Session	Cookie used to identify a session instance for the user.	Strictly necessary	1 year
__CookieConsentV300	_Cookieconsent cookie is a plugin used to comply with EU guideline	Strictly necessary	180 days
TS01685b3c, TS#	This is a eqs-cockpit.com cookie. Cookie only collects a session ID to ensure an equal distribution of all requests via our server. Valid until the end of the browser session. Can not be traced to the person visiting a website, as this random session ID is not connected to name, email, IP address or any other person related data.	Strictly necessary	1 year
_ga	This cookie name is associated with Google Universal Analytics - which is a significant update to Google's more commonly used analytics service. This cookie is used to distinguish unique users by assigning a randomly generated number as a client identifier. It is included in each page request in a site and used to calculate visitor, session and campaign data for the sites analytics reports. By default it is set to expire after 2 years, although this is customisable by website owners.	Performance cookies	729 days
_ga_xxxxxxxxxx	A Google Analytics cookie used to persist session state, collect information about how visitors use our site. This information is used to compile reports and to help improve the site. The cookies collect information in an anonymous form, including the number of visitors to the site, marketing performance, where visitors have come to the site from and the pages they visited.	Performance cookies	729 days
_gat	This cookie name is associated with Google Universal Analytics, according to documentation it is used to throttle the request rate - limiting the collection of data on high traffic sites. It expires after 10 minutes.	Performance cookies	End of browser session
_gid	This cookie name is associated with Google Universal Analytics. This appears to be a new cookie and as of Spring 2017 no information is available from Google. It appears to store and update a unique value for each page visited.	Performance cookies	1 day
_gat_INVDSitecore	This cookie name is associated with Google Universal Analytics, according to documentation it is used to throttle the request rate - limiting the collection of data on high traffic sites. It expires after 10 minutes.	Performance cookies	End of browser session
_hjSession_*, _hjAbsoluteSessionInProgress, _hjIncludedInPageviewSample, _hjIncludedInSessionSample ,_hjIncludedInSessionSample_*, _hjFirstSeen, _hjTLDTest	A cookie that holds the current session data. This ensures that subsequent requests within the session window will be attributed to the same Hotjar session.	Performance cookies	End of browser session
_hjSessionUser_*	Hotjar cookie that is set when a user first lands on a page with the Hotjar script. It is used to persist the Hotjar User ID, unique to that site on the browser. This ensures that behavior in subsequent visits to the same site will be attributed to the same user ID.	Performance cookies	365 days
sp_landing	This domain is owned by Spotify, a USA based music streaming service. Spotify provides a number of tools to embed into websites, which enable the tracking of users and non-users across domains.	Performance Cookies	0 day
sp_t	This domain is owned by Spotify, a USA based music streaming service. Spotify provides a number of tools to embed into websites, which enable the tracking of users and non-users across domains.	Performance Cookies	1 year
_fbp	Used by Facebook to deliver a series of advertisement products such as real time bidding from third party advertisers	Marketing cookies	89 days
VISITOR_PRIVACY_METADATA	YouTube is a Google owned platform for hosting and sharing videos. YouTube collects user data through videos embedded in websites, which is aggregated with profile data from other Google services in order to display targeted advertising to web visitors across a broad range of their own and other websites.	Marketing Cookies	5 months
YSC	YouTube is a Google owned platform for hosting and sharing videos. YouTube collects user data through videos embedded in websites, which is aggregated with profile data from other Google services in order to display targeted advertising to web visitors across a broad range of their own and other websites.	Marketing Cookies	1 year
VISITOR_INFO1_LIVE	This cookie is used as a unique identifier to track viewing of videos	Marketing Cookies	5 months

7. Protection of Personal Data
   1. Multitude endeavours to maintain physical, technical, and procedural safeguards appropriate to the sensitivity of the Personal Data in question. These safeguards are designed to protect your Personal Data from loss and unauthorized access, copying, use, modification, or disclosure. Despite these safeguards, please note that no method of transmission over the internet or data storage is fully secure. Should we be required by law to inform you of a breach to your Personal Data we may notify you electronically, in writing, or by phone.
8. Data retention
   1. Multitude retains your Personal Data in accordance with industry guidelines for as long as necessary for the purposes for which they were collected, or for as long as necessary to safeguard our rights, or for as long as required by applicable legal acts. Kindly note that if the same Personal Data is Processed for several purposes, we will retain the Personal Data for the longest retention period applicable.
9. Your rights
   1. To the extent required by applicable Data Protection Regulations, you have all the rights of a Data Subject as regards your Personal Data. This includes the right to:
      1. request access to your Personal Data;
      2. obtain a copy of your Personal Data;
      3. rectify inaccurate or incomplete Personal Data relating to you;
      4. erase your Personal Data;
      5. restrict the Processing of your Personal Data;
      6. be informed of the source from which your Personal Data originates where the Personal Data we hold about you was not provided to us directly by you;
      7. should you believe that your rights have been violated, you have the right to lodge a complaint with:

         - Multitude data protection officer at email [email protected]; or

         - Office of the Data Protection Ombudsman, Postal address: P.O. Box 800, 00531 Helsinki, Finland, E-mail: [email protected]; or

         - Data Protection Supervisory Authority of your country.

   2. When requesting access to, or rectification or deletion of your Personal Data, please note that we shall request specific information from you to enable us to confirm your identity and right to access, rectify or delete, as well as to search for and provide you with the Personal Data that we hold about you.
   3. Kindly note that your right to access, rectify, or delete your Personal Data we hold about you is not absolute. There are instances where applicable law or regulatory requirements allow or require us to refuse your request. In addition, the Personal Data may have already been destroyed, erased, or made anonymous in accordance with our record retention obligations and practices.
   4. If we cannot provide you with access to, or rectification or deletion of your Personal Data, we will inform you of the reasons why, subject to any legal or regulatory restrictions. We can assure you we will not discriminate you for exercising any of your rights described in these Principles.
10.   Amending these principles
    1. Should our Personal Data Processing practices change or there shall be a need to amend these principles under the applicable law, case-law or guidelines issued by competent authorities, we are entitled to unilaterally amend these principles at any time. Our most recent principles will always be published on our website, and we urge you to check this at least once a month.