Personal data we collect and purposes it serves
We may collect:
- Information gathered directly from you. When you register, set up your account (personal profile), request, make use of our services, or communicate with us, you are asked to provide some necessary information about yourself that we use to serve your request or provide our services to you.
- Information collected when you visit our website or use the Mellow Service (including mobile applications). To the extent permitted under applicable laws, we may collect some technical and other information through various means (including cookies) on your interaction with the website and the Mellow Service. This helps us to improve our services, enhance the security of your account (personal profile) and the Mellow Service, and personalize your experience (for more information, refer to the "Cookies and tracking" section).
- Information from publicly available sources and third parties. We may collect information about you from your customers and from open sources, including but not limited to social media, credit risk databases, and ID verification and KYC/KYB/AML web services to verify your identity and prevent fraud and other illegal activities, only doing so in accordance with applicable data protection laws.
Below are the categories of your personal data that we may collect and process, depending on what services you use and how you interact with the Mellow Service, its applications, or its website:
Identification data: Your full name, date of birth, gender, country, webcam photo or video, passport or other national identification documents, driver's license, tax identification number, tax status, a form of doing business/professional activities, and relevant documents.
Contact information: Address of residence or registration, email address, billing or delivery address, work address, telephone number, and documents confirming the address.
Social identification data: Information related to your work experience or profession (specialization, professional and educational background), information about your company, position in the company, ownership/shares in the company, information about recommendations (referrals and referees), information about your related and affiliated parties, your business contacts, behavioral data, compliance data (including risk assessments).
Financial data: Information on bank cards and other payment methods, bank accounts, e-wallets’ and crypto wallets’ IDs and addresses, information on transactions (date and time, TXIDs, etc.), and other related information and documents.
Information generated when you interact with the Mellow Service or related to your activities in your personal profile in the Mellow Service (the "profile data"): Your user identification number, date of registration, date of acceptance of your agreement with Mellow and its number, your customers and/or your collaborators (subcontractors), verification status, invite delivery status, number of invited users, information about tasks and offers, the progress of rendering services/ performing works, materials related to your services/works, your payments or payouts, other information about transactions in the Mellow Service, your texts, voice and speech recordings, documents, requests (including those sent to our support), your requests regarding products, services or other functionality, your preferences, reviews, information from surveys, comments, as well as other information collected and/or generated in the course of your interacting with Mellow or using the Mellow Service.
Technical and usage data: Internet connection data, IP address, login, browser type and version, device type, category and model, location of your device, time zone settings, device language, application or SDK usage, preference settings, diagnostic data, information from cookies, advertising campaign tags, and other data stored or available in relation to your devices when you visit the website or use the Mellow Service, including its applications, as well as other information about how you use the website and applications.
Communication and marketing data: Your communication preferences, your marketing messaging preferences, consumer marketing profile, and other data.
In each case, Mellow makes every effort to collect the minimum possible amount of your personal data, limiting it to what is necessary for the processing purposes.
Below are the processing purposes, categories of personal data that Mellow may process, and corresponding legal bases.
1. Purpose: To arrange and render our services for your benefit, and to enable you to perform under services/works agreements (as a subcontractor or a customer), including:
− Registering with the Mellow Service
− Conducting KYC/KYB procedures
− Using the Mellow Service
− Creating and working with offers
− Handling tasks
− Working on projects as a team
− Saving your orders, services, and projects
− Making payments to subcontractors
− Crediting customers’ advance payments
− Communicating with you (sending notifications related to the Mellow Service, processing your requests, and resolving issues through support)
− Resolving and mediating disputes
− Preparing reports and acts
− Ensuring that our website and the Mellow Service are protected against security threats. − To perform other actions to provide services/ work or obtain their results under your agreements with Mellow.
1.1. Personal data categories:
− Identification data
− Contact information
− Social identification data
− Profile data
− Financial data
− Technical and usage data
− Communication and marketing data
1.2. Legal basis (GDPR):
− Contractual or pre-contractual measures (Art. 6.1 (b) of GDPR)
− Legitimate interests (Art. 6.1 (f) of GDPR)
− Compliance with legal obligations under applicable laws (Art. 6.1 (c) of GDPR)
− Consent (Art. 6.1 (a) of GDPR, if applicable)
2. Purpose: To enable users to create tasks using the voice and speech recognition feature that converts them to texts.
2.1. Personal data categories:
− Voice and speech recordings, texts
2.2. Legal basis (GDPR):
− Consent (Art. 6.1 (a) of GDPR; you can manage consent via your mobile device’s settings)
3. Purpose: To comply with applicable laws and to protect the legal interests of customers, subcontractors, the Mellow Service, and other stakeholders, we may implement measures to prevent and mitigate risks of money laundering and terrorism financing (ML/TF), credit risks, fraud, and other illegal activities, as well as conduct customer due diligence to verify compliance with applicable laws (including checks against sanctions lists).
3.1. Personal data categories:
− Identification data
− Contact information
− Social identification data
− Profile data − Financial data
− Technical and usage data
− Communication and marketing data
− Data from publicly available sources
3.2. Legal basis (GDPR):
− Contractual or pre-contractual measures (Art. 6.1 (b) of GDPR)
− Legitimate interests (Art. 6.1 (f) of GDPR)
− Compliance with legal obligations under applicable laws (Art. 6.1 (c) of GDPR)
− Consent (if applicable)
4. Purpose: To improve your experience with the Mellow Service along with its functionality, efficiency, and usability, and to make it more personalized. Where applicable, automate your interaction with the Mellow Service, provide interactive tips, guides, and notifications regarding the usage of the Mellow Service, and maintain internal services such as referral programs.
4.1. Personal data categories:
− Identification data
− Contact information
− Social identification data
− Profile data
− Technical and usage data
− Communication and marketing data
4.2. Legal basis (GDPR):
− Legitimate interests (Art. 6.1 (f) of GDPR)
− Consent (Art. 6.1 (a) of GDPR, if applicable)
5. Purpose: To improve user experience, website, products, services, marketing, and user and customer relationships by conducting: (i) statistical research based on personal data of customers and subcontractors, including survey data; (ii) troubleshooting of the Mellow Service (analyzing performance and functionality, fixing errors, etc.); (iii) data analysis. Study user behavior in their role as consumers, including user preferences, interests, and Mellow Service usage patterns in order to define marketing and business strategies for business development of Mellow.
5.1. Personal data categories:
− Identification data
− Contact information
− Social identification data
− Profile data
− Technical and usage data
− Communication and marketing data
5.2. Legal basis (GDPR):
− Legitimate interests (Art. 6.1 (f) of GDPR)
− Consent (Art. 6.1 (a) of GDPR, if applicable) Depending on the device, your consent status may be changed in the device settings.
6. Purpose: To inform you about offers on special features, options, products and services of the Mellow Service, including by sending you targeted or personalized advertising through the Mellow Service or otherwise sending you marketing communications about products and services that we believe may be interesting or useful to you or that you have requested to stay updated about. Mellow may also provide you with reports about your activities in the Mellow Service or news of the Mellow Service or inform you about products or services provided by its subsidiaries, affiliates, and partners, including marketing partners.
6.1. Personal data categories:
− Identification data
− Contact information
− Social identification data
− Profile data
− Technical and usage data
− Communication and marketing data
6.2. Legal basis (GDPR):
− Legitimate interests (Art. 6.1 (f) of GDPR)
− Consent (Art. 6.1 (a) of GDPR, if applicable)
7. Purpose: To facilitate business transfers that may include mergers or acquisitions, reorganizations or restructurings, assignments to group companies of Mellow or companies under common control or interest, rebranding, creation and launching of new products, and changes in business models and products.
7.1. Personal data categories:
− Identification data
− Contact information
− Social identification data
− Profile data
− Financial data
− Technical and usage data
− Communication and marketing data
7.2. Legal basis (GDPR):
− Contractual or pre-contractual measures (Art. 6.1 (b) of GDPR)
− Legitimate interests (Art. 6.1 (f) of GDPR)
− Consent (Art. 6.1 (a) of GDPR, if applicable)