US Privacy Notice

General Information

Effective: 4 November 2024

This is the US Privacy Notice for Multiverse Inc ("we", “us”, “our” or “Multiverse”), the controller of your personal data collected over the previous 12 months through https://multiverse.io (“the Platform”) and when accessing our services (“the Services”).

This Notice (“US Privacy Notice”) is for individuals residing in certain US states and is designed to describe how we collect, use and disclose data at Multiverse. References to “you” or “your” relate to end users (“Users”) of our Platform that may access the Services. This Notice sets out the types of personal information we collect when you access and visit or use the Platform or the Services, how we may manage and use that data and how to exercise your rights under US state privacy laws. This Notice includes information on how we may share your personal information with your existing employer (the “Employer”). If we have a negotiated agreement with your Employer governing the sharing of your personal information, the terms of that agreement will prevail over the general terms of this US Privacy Notice. Please contact your Employer if you have questions.

This notice addresses the specific disclosure requirements under the California Consumer Privacy Act of 2018 (as amended by the California Privacy Rights Act of 2020) and its implementing regulations (collectively, “the CCPA”).

Multiverse are committed to protecting and respecting your privacy. It is important that you read this Privacy Notice together with any other privacy notice or fair processing notices that we may provide to you at or around the time that we collect or process personal data about you so that you are fully aware of how and why we are using that data.

This Privacy Notice supplements other notices on our Platform and is not intended to override or replace them.

By visiting or otherwise using our Platform and/or Services, you confirm that you have read and understood this Privacy Notice. If, for any reason, you do not agree to the terms of this Privacy Notice, please stop using our Platform and/or Services.

The Platform and Services are not intended for children (persons under 16) and we do not knowingly collect personal data relating to children.

If you have any questions regarding this Privacy Notice, then please contact the Multiverse team at privacy@multiverse.io.

Notice of Collection and Use of Personal Information

For the purposes of the CCPA, “personal information” means information that identifies, relates to, or could reasonably be linked with you or your household. “Sensitive personal information” means a specific subset of personal information that includes certain government identifiers (such as social security numbers); an account log-in, financial account, debit card, or credit card number with any required security code, password, or credentials allowing access to an account; precise geolocation; contents of mail, email, and text messages; genetic data; biometric information processed to identify a consumer; information concerning a consumer’s health, sex life, or sexual orientation; or information about racial or ethnic origin, religious or philosophical beliefs, or union membership.

During the processes of registering you as a User of the Multiverse Platforms (as explained more fully in our Terms of Use), and/or providing services to you, we may collect (and may have collected during the 12-month period before the last update of this Notice) the following categories of personal information about you:

1. Identifiers: name, personal email address.
2. Other records: application forms, project coursework, progress reviews, assignments and feedback, learner objectives, various types of exam scores, various types of satisfaction ratings, attendance records, your Learner Record. Other personal information covered by the California Civil Code Section 1798.80(e) (which may overlap with other information listed).
3. Commercial information: job title(s), your interaction with the Platform and the Services.
4. Internet or other electronic network activity information: IP address, browser type and version, browser plug-in types and versions, operating system and platform, data from cookies and similar technologies, online log-in frequency, full Uniform Resource Locators (URL) clickstream to, through and from our Platform (including date and time); products you viewed or searched for; page response times, download errors, length of visits to certain pages, page interaction information (such as scrolling, clicks, and mouse-overs) and methods used to browse away from the page.
5. Geolocation data: Country, State, zip code
6. Audio, electronic, visual or similar information: Content posted on the Platform (e.g learning video recordings, messages, comments).
7. Inferences: Information from the categories above that could be used to create a profile about a User reflecting their preferences, characteristics, psychological trends, predispositions, behaviour, attitudes, intelligence, abilities, and aptitudes. We do not use sensitive personal information for the purposes of inferences.
8. Sensitive personal information: Religious or political beliefs, Sex life, Sexual orientation, Health data, Account log-in details. Such information is only collected on a voluntary basis and will always include a ‘Prefer not to say’ option. Where applicable, Multiverse may only collect sensitive personal information with the prior written approval of your Employer.

Sources and Purposes for our Collection of Personal Information

We may collect your information from the following sources:

1. Information you provide to us directly, through usage of the Platform and/or Services.
2. Information from the device(s) used when accessing the Platform and/or Services.
3. Information provided by third parties, such as your Employer.

We use (and may have used during the 12-month period before the last update of this Notice) personal information held about you in the following ways:

Contractual Obligations and Service Provision

1. To carry out our obligations arising from any contracts entered into between you and us, between Multiverse and your Employer, and to provide you with the information, products, and services that you request from us.
2. For you to register for and complete our learning experiences.
3. To assess your eligibility for our learning pathways.
4. To support learning and monitor and report on learner progress. This may include the sharing of session recordings and conversations with other learners and/or your Employer.
5. To notify you about changes to our Services.

Communication and Marketing

1. To provide you with information about other products and services we offer that are similar to those that you have already received or enquired about.
2. To provide you with information about products or services we feel may interest you.
3. To make suggestions and recommendations to you and other Users of our Platform about products or services that may interest you or them.
4. In some instances your Employer may request that we do not send marketing materials to Learners, in which case the communications above will not be received. You can check this directly with your Employer or the Multiverse Privacy team (privacy@multiverse.io).

Data Sharing

1. To provide your personal information to your Employer, and with whom you have permitted us to share your personal information.

User Experience and Platform Improvement

1. To ensure that content from our Platform is presented in the most effective manner for you and for your computer.
2. To improve our Platform to ensure that content is presented in the most effective manner for you and for your computer.
3. To allow you to participate in interactive features of our Services, when you choose to do so.

Administration and Internal Operations

1. To administer our Platform and for internal operations, including troubleshooting, data analysis, testing, research, statistical, and survey purposes.
2. To conduct periodic campaigns, satisfaction or market research surveys, as well as to analyse the results.
3. To assess the quality of our services and ensure continuous internal performance improvement.

Security and Legal Compliance

1. As part of our efforts to keep our Platform safe and secure.
2. To comply with applicable law, for example, in response to a request from a court or regulatory body, where such a request is made in accordance with the law.
3. To resolve any disputes, if you lawfully exercise your rights, or if you wish to dispute any part of our service offering.

Advertising and Analytics

1. To measure or understand the effectiveness of advertising we serve to you and others, and to deliver relevant advertising to you.
   

If you provide us with your email address and / or phone number we may contact you by email, phone or SMS for these services. We may also use this information to send you content and recommendations based on your interests and on opportunities that may be of interest to you. Where we send such communications to you via email or text, this will be because you have: (i) subscribed to receive marketing communications from us; or (ii) subscribed to our Services, and you have not opted out of receiving that marketing when you provide us with your email address and / or phone number. You have the ability to unsubscribe from marketing communications by following the unsubscribe link in each such message. Where we send such communications to you via phone, we ensure that adequate consent is collected from you at the point in which your phone number is provided to us. Where Multiverse has agreed with your Employer not to send marketing materials, you will not receive such communications unless you explicitly subscribe to receive these from us.

We may combine information received from other sources with information you give to us and information we collect about you. We may use this information and the combined information for the purposes set out above (depending on the types of information we receive).

Multiverse shall have the right to monitor you and your Employer's use of the Platform and Service and Multiverse shall retain all right, title and interest in data and data elements collected by the Service which, as applicable, pertains to the usage and performance of the Service (“Performance Data”). Without limiting the foregoing, Multiverse may collect and use Performance Data for the purpose of compiling statistical and performance information, and to improve predictive capabilities related to the provision and operation of the Service. Multiverse may make such Performance Data publicly available, provided that it does not include Personal Data and/or contain Confidential Information of Learners or Employers.

Sharing or Selling of Personal Information

We share data with your Employer throughout your learning experience. We may also share your data with third party suppliers that help deliver the Services. Such suppliers could include business partners, vendors in technical, payment and delivery services, advertising networks, analytics providers, search information providers, credit reference agencies. These types of data sharing may be defined as a “sale” under California law when the personal information is exchanged for non-monetary consideration.

We may share the following categories of personal information with your Employer:

1. Identifiers
2. Other records
3. Commercial information
4. Sensitive personal information

The purposes for this exchange of information are as follows:

1. your application form(s) and registrations of interest to assess opportunities to subscribe to our Services;
2. information about your learning performance, any assessment feedback, and your feedback;
3. your views and opinions of our learning pathways;
4. your health information, to inform your Employer of any special health or disability requirements you might have when attending interviews or in order to provide reasonable adjustments to your learning experience; and
5. where we deem it appropriate, any information (which may include Sensitive Personal Information) collected in connection with our Safeguarding role.

We may share the following categories of personal information with our third party suppliers:

1. Identifiers
2. Other records
3. Commercial information
4. Internet or other electronic network activity information
5. Geolocation data
6. Audio, electronic, visual or similar information
7. Professional, employment or education-related information
8. Inferences
9. Sensitive personal information

The purposes for these exchanges of information are as follows:

1. Contractual Obligations and Service Provision - we ensure we have a written contract in place with any third party supplier we use to ensure that the processor only acts on our written instruction and that we are confident in the security of the data we have shared. These third party service providers are required not to use your Personal Information other than to provide the services requested by us.
2. Security and Legal Compliance - If we are under a duty to disclose or share your Personal Information in order to comply with any legal obligation, or in order to enforce or apply our Terms of Use and other agreements, or to protect the rights, property, or safety of Multiverse, our customers and learners. This includes exchanging information with other companies and organisations for the purposes of fraud protection and credit risk reduction.
3. Communication and Marketing.
4. User Experience and Platform Improvement.
5. Administration and Internal Operations.
6. Advertising and Analytics.
   

Our list of third party suppliers is available online via this link.

Other Disclosures:

1. Multiverse may also in limited circumstances share your contact details with other learners on the Platform.
2. As necessary, we may also disclose personal information to law enforcement and government agencies.

Collection, Use or Sharing of Sensitive Personal Information

You may voluntarily provide us with sensitive personal information about yourself (e.g. Religious or political beliefs, Sex life, Sexual orientation, Health data, Account log-in details) by filling in forms on our Platform or when engaging with our Services. We may use this data:

1. to track the diversity of our learners, to demonstrate to your Employer the diversity of learners, to track the success of learners from different ethnic groups, and to ensure that we have no internal biases.
2. to obtain information on any special health or disability requirements you might have whilst learning with Multiverse.
3. to track the wellbeing, welfare and safety of applicants, which may include health and disability data (we call this “Safeguarding”). Such information may also be shared with your coach(es).

Where permitted by law, we may also use sensitive personal information in anonymised datasets, which removes your personal identifiers, for the purposes of understanding our Users, equality monitoring and reporting purposes, and as aggregated data for Employer reporting and for marketing purposes (unless otherwise agreed with your Employer).

Your Privacy rights

1. Right to Know: Residents of California have the right to request information on or obtain the personal information Multiverse collects from them, including information of how it is used and shared.
2. Correction: Residents of California have the right to correct inaccurate personal information that Multiverse holds on them.
3. Deletion: Residents of California have the right to request the deletion of personal information collected from them (with some exceptions).
4. Limit the use and disclosure of sensitive personal information: Residents of California have the right to limit the use and disclosure of sensitive personal information collected about them. We only collect sensitive personal information from Users who submit this information voluntarily and provide their consent, so we do not generally permit the ability to limit the use of such information but would collaborate to ensure the deletion of such information.
5. Opt-out of the sale or sharing of your personal information: Residents of California have the right to opt-out of the sale or sharing of their personal information.
   

We will not discriminate against you for exercising any of your rights, meaning that we will not: deny you of any goods or services, charge you different prices for these, provide a different level or quality of goods or service, suggest that you receive a different price for these.

Exercising your rights

You may exercise your privacy requests in the following ways:

1. Emailing privacy@multiverse.io with the details of your request.
2. Via written correspondence addressed to: The Data Protection Officer, Multiverse Inc, 155 6th Ave, New York, NY 10013, United States
   

When you write to us making a request to exercise your rights, we are entitled to ask you to prove that you are who you say you are. We may ask you to provide copies of relevant ID or residency documents to help us to verify your identity and residence. In some US states, a designated authorised agent can exercise the privacy rights mentioned above on your behalf.

Retention of Personal Information

We will not hold your personal information for any longer than is required by any of the purposes listed above, and once it is no longer required, then we will either permanently delete it or anonymise it to the extent that it is no longer personal information.

Data Security Measures

Multiverse takes the protection of your data seriously. Multiverse uses industry-standard technical and organisational measures to protect information from loss, misuse, and unauthorised access or disclosure. These steps take into account the sensitivity of the information Multiverse collects, processes, and stores, and the current state of technology.

Where we have given you (or where you have selected) a password which enables you to access certain parts of our site, you are responsible for keeping this password secure and confidential. We ask you not to share your password with anyone, as you would be in breach of Multiverse Terms of Use, and we accept no responsibility for any unauthorised access to your personal data that results from you sharing your password or otherwise making your account accessible to a third party. If you suspect that your password has become known to another person or system, then change it and contact us immediately.

Given the nature of communications and information processing technology, Multiverse cannot guarantee that information in our care will be absolutely safe from intrusion by others during transmission through the Internet or while stored on our systems or otherwise. When you click a link to a third-party site, you will be leaving our site and Mutiverse doesn’t control or endorse what is on third-party sites.

International data transfers

We may transfer your personal data outside of the United States. When we do so, we shall ensure that the relevant safeguards are in place to afford adequate protection for your personal data. Further details regarding the relevant safeguards can be obtained from us on request by contacting privacy@multiverse.io.

We may also share your data with processors based outside of the US that contribute to the overall delivery of the Multiverse Services. For each such data transfer, we ensure that relevant safeguards are implemented prior to any data transfer to ensure the protection of your Personal Data. See our Processors page for more information.

Our use of cookies and pixels

Our website and Platform uses cookies and pixels to distinguish you from other Users. This helps us to provide you with a good experience when you browse our website or Platform, and also allows us to improve them. By continuing to browse the site, you are agreeing to our use of cookies and pixels.

A cookie is a small file of letters and numbers that we store on your browser or the hard drive of your computer if you agree. Cookies contain information that is transferred to your computer's hard drive.

We use the following types of cookies:

1. Strictly necessary cookies: Necessary cookies enable core functionality such as security, network management, and accessibility. You may disable these by changing your browser settings, but this may affect how the website functions.
2. Analytics cookies: We'd like to use Google Analytics and Hotjar to help us identify how Users engage with our website. We do this so that we can optimise our web experience for our Users.
3. Functional cookies: These cookies enable the website to provide enhanced functionality and personalisation. They may be set by us or by third-party providers whose services we have added to our pages. If you do not allow these cookies then some or all of these services may not function properly.
4. Targeting cookies: These cookies may be set through our site by our advertising partners. They are based on uniquely identifying your browser and internet device, and may be used by those companies to build a profile of your interests and show you relevant adverts on other sites. If you do not allow these cookies, you will experience less targeted advertising.

Please note that third parties (including, for example, advertising networks and providers of external services like web traffic analysis services) may also use cookies, over which we have no control. These cookies are likely to be analytical/performance cookies or targeting cookies.

You can block cookies by activating the setting on your browser that allows you to refuse the setting of all or some cookies. However, if you use your browser settings to block all cookies (including essential cookies) you may not be able to access all or parts of our site.

Except for Strictly Necessary cookies, all cookies will expire after a period of two years.

How to contact us

If you have any questions about this Privacy Notice, would like to exercise any of your statutory rights, or to make a complaint, please email privacy@multiverse.io or write to: The Data Protection Officer, Multiverse US Inc, 155 6th Ave, New York, NY 10013, United States