Privacy Policy

Last updated: April 24, 2024

Your privacy is important. This Privacy Policy explains how Musaffa, LLC and its Affiliates (“Musaffa”, “us”, “we” or “our”) handles your personal information in connection with the website, application (including a mobile application), product, or service that links to this Privacy Policy and administration of the recruiting process through our websites (we call these our “Services”). It applies generally to the following groups:

Customers and users (including prospective customers and users);
Job Applicants for open positions at Musaffa;
Third party business partners; and
Other individuals who interact with us or whose personal information we maintain.

This Privacy Policy does not apply to any website, application, product, or service that links to its own privacy policy or that is offered by third parties, in which clicking on third party links or enabling those connections may allow the third party to collect, use, or share data about you. We encourage you to read their respective privacy policies.

By using our Service, you represent and warrant that you are the legal age of majority under applicable law (generally the age of 18 or older) to form a binding contract with Musaffa and meet the eligibility requirements. If you are under the legal age of majority under applicable law, you represent to Musaffa that you have obtained a parent/guardian’s consent and that your parent/guardian has reviewed and agreed to this Privacy Policy prior to using the Service. If you are an employee of a company or other entity or are acting on behalf of a company or entity, you must be authorized to accept this Privacy Policy on behalf of that employer, company, or entity. If you do not meet these requirements, you must not access or use our Service.

This Privacy Policy is incorporated by reference in our Terms of Use, which is binding on all our customers, prospective customers, our customers’ customers (both direct and indirect), partners, resellers, and visitors to or users of our websites, applications, and Services. Unless otherwise defined in this Privacy Policy, the terms used in this Privacy Policy have the same meanings as in our Terms of Use.

Who is Musaffa and how can you contact us?

Musaffa is a US-based company, and Musaffa’s group of companies is made up of several legal entities with offices located across the globe, including Musaffa, Inc., and Musaffa Financial Solutions LLC (“Affiliates”). Please see the list of locations here.

Musaffa acts as a controller of your personal information where we determine how and why personal information can be used, and Musaffa’s company that provides the specific Service (as identified therein) is the primary controller of your personal information. This Privacy Policy, however, does not apply where we act as a processor or service provider to another controller (such as our customers).

Any comments, complaints, or questions may be emailed to privacy@musaffa.com or mailed to our Chief Legal Officer and Data Protection Officer: One World Trade Center, 285 Fulton St, Suite 8500, New York, NY 10007, United States.

What personal information do we collect and process?

Generally, we collect, use, disclose and process personal information in the following categories:

Mandatory information

Category	Examples
Name & Contact Information	Name, address, phone number, email address
Account Information	Account ID, User ID, account profile, settings and preferences, purchase history, subscriptions, and registrations
Security Information	User credentials (username and password) and similar security information, individual network activity in security and audit logs
Device & Browser Information:	Network and internet service provider (ISP) information, Internet Protocol (IP) addresses, device and browser identifiers, device and browser information, advertising identifiers, cookie/tracker identifiers and related information
Location Data	Region, country, state, and coarse geolocation data

Non-mandatory information

Category	Examples
User Contributions & User Content	Personal information in content and communications uploaded, sent, shared, or inputted through our Services or via our networks and infrastructure, including feedback you provide to us and the content of communications between you and us or sent via our network and Services
Usage and Browsing Information	Usage, search, and browsing history, user journey history (including clicks, navigation, user actions, interactions, and session replays), usage and diagnostics, analytics and metrics, including on our Services and on our internal networks and corporate devices by employees, contractors, and site visitors.
Demographic Information	Age, date of birth, gender
Pictures, audio, video recordings	Pictures, screenshots
Inferences from Personal Information	Profiles reflecting a person’s preferences, interests, psychological trends, psychological behavior,
Additional Information from Job Applicants	Career, education and organization information, including affiliated organizations (such as employer, industry associations, or licensing bodies) and status, position and title, information about colleagues and contacts, career and education history, professional certifications and licenses, employee identification number, employee record (including performance and compensation information), job application information; government identification, governmental identifiers (such as tax identifiers, social security or national insurance numbers, and passport or driver’s license numbers); legal status, immigration status.

A note on children’s online privacy. Our online Services provide solutions primarily intended for professionals engaged in investing activities, who are the age of majority and we do not knowingly collect any personal information from children under the age of eighteen (18). According to the applicable laws, if we become aware that a child under 13 has provided us with personal information for any reason other than being added as an authorized user by their parent or guardian, we will take reasonable steps to delete that information. If you reasonably believe that we might have information from a child under 13 who is not an authorized credit card user or account user of our Services, please contact us at privacy@musaffa.com.

How do we collect personal information?

Direct Interactions: You provide your personal information when you interact with us, such as when you register for Services, fill in forms, communicate with us, and apply for open positions in Musaffa.

User Contributions: We collect your personal information when you or others upload, share, send, or input that information through our Services or networks, or when you or they communicate with us.

Automatically: We automatically collect personal information about you when you interact with us, such as when you use our Services, visit our offices or events, open emails or view advertisements from us, or communicate with us. We may collect some of this personal information by using cookies and other similar technologies, and we recommend you review our Cookie Notice for more information.

Third Party or Publicly Available Sources: We may receive your personal information from third parties, such as our third party business partners (including data brokers and advertising partners), your organizations, governmental agencies who publish public records, and other publicly or generally available sources (including online websites). For more information on third party service providers, you may refer to Cookie Notice

How do we use personal information?

This section includes details of the purposes for which we use personal information and the different legal reasons (also called legal basis) for processing that personal information.

Purpose	Legal Basis
To fulfil our contractual obligations, including to register your account and provide our Services Communicate with you about our Services and process related transactions For any purpose with your consent or to follow your instructions	Our performance of a contract As outlined in your consents or instructions
To operate, improve, and/or personalize our Services, corporate networks and devices, offices, events, and related infrastructure Develop new products, services, content, and other offerings Monitor the usage of our Services, corporate networks and devices, offices, events, and related infrastructure Audit usage of our Services, corporate networks and devices, offices, events, and related infrastructure, including consumer interactions Ensure the security of our Services, corporate networks and devices, offices, events, and related infrastructur Detect fraud and abuse, including for our Services, corporate networks and devices, offices, events, and related infrastructure Manage our internal operations (such as account administration, corporate asset deployment, billing, troubleshooting, repair)	Our performance of a contract As outlined in your consents or instructions To pursue legitimate interests
Send you personalized and interest-based advertising and marketing Improve and develop new marketing campaigns, segments, and materials To enable you to partake in a prize draw, competition, or complete a survey	As outlined in your consents or instructions To pursue legitimate interests
Exercise our rights and/or protect our or others’ rights or property Effectuate the sale, merger, acquisition, or other disposition of our business Advance our other commercial and economic interests as permitted by law For other purposes as required by or permitted by law	To pursue legitimate interests To comply with our legal obligations To protect your vital interests or those of another person
Additional purposes for the use of personal information collected from Job Applicants
Manage the employee recruiting process (such as for the application process and background checks) Communicate with you regarding recruiting and alumni purposes, as well as human resources administration	Our performance of a contract As outlined in your consents or instructions To pursue legitimate interests

Who do we share personal information with?

Affiliates within Musaffa group of companies.
Third party business partners (also known as “data processors”) that support our business, such as our content and other partners, vendors and subcontractors, analytics providers, advertising and marketing agencies, credit agencies, and other third parties we engage.
With governmental agencies and third parties involved in our sale or purchase of a business or assets, including in connection with a merger, divestiture, restructuring, reorganization, bankruptcy, liquidation, dissolution, or other disposition of assets.
With law enforcement, government agencies, or other third parties in order to comply with any law, court order, legal request, or other legal process, as well as to enforce our agreements or protect the rights, property, or safety of our business, employees, customers, or others (including for the purposes of cybersecurity, fraud protection, and credit risk reduction).
With others when necessary to fulfill your consents or to follow your instructions.

Where do we store personal information?

As described above, we are a global organization so your personal information may be transferred outside of your home country and may be stored in and accessed from multiple countries, including the United States. When you interact with us, you authorize us to transfer your personal information outside of your home country and you acknowledge the risk that we may transfer your personal information to countries that may provide less protection than your home country’s privacy laws and we may not be able to prevent government authorities in some countries from accessing your personal information.
Musaffa will take all the steps reasonably necessary to ensure that your data is treated securely and in accordance with this Privacy Policy.

What steps do we take to secure personal information?

We work to implement technical and organizational measures designed to protect the security of personal information. However, no method of transmission over the Internet or electronic storage is 100% secure, and we cannot guarantee its absolute security. To enhance the security of your personal information, we employ https protocols and ensure the data is encrypted during transmission. The security of your information also depends on you: you are responsible for using unique, strong usernames and passwords for each of your accounts, and for keeping those usernames and passwords confidential. We are not responsible for the circumvention of any privacy settings or cybersecurity measures contained on our Services, and any transmission of personal information is at your own risk. To help us continue to protect your personal information, you should always contact us via email at privacy@musaffa.com if you suspect that your personal information may have been compromised.

How long do we retain personal information?

Except as otherwise permitted or required by applicable law or regulation, we will only retain your personal information for as long as necessary to fulfill the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements or until you submit a verifiable request for deletion, in accordance with applicable data protection laws and regulations. Under some circumstances, we may anonymize your information so that it can no longer be associated with you. We reserve the right to use such anonymous and de-identified personal information for any legitimate business purpose without further notice to you or your consent.

What rights do you have over your personal information?

Your local privacy laws may grant you rights with respect to your personal information, and we will not knowingly discriminate against you because you have exercised any of your privacy rights. These rights differ based on the local laws that apply to you, but could include one or more of the following:

Right to confirm we process your personal information and, if so, to access, correct, complete, opt out, object to or restrict the processing of, and delete certain personal information we hold about you, including the rights to receive your personal information in a portable copy. To submit a request, you can contact us via our email: privacy@musaffa.com.
Right to delete your account, for which you may email us at support@musaffa.com requesting for deletion of your account or you may request deletion of your account from within the application (to delete from within the application please go to Profile Details > select Delete Account ). Please note that the Data Protection Officer may require you to verify your identity before proceeding with your request to delete your account. Any identity proof that you may provide shall be stored for a period of 6 months from the date of deletion of the account.
To opt out of marketing emails from us, for which you may click the unsubscribe link at the bottom of each email that you receive from us.
Nevada and Virginia residents and, beginning on July 1, 2023, Colorado and Connecticut residents and, beginning on December 31, 2023, Utah residents may also have the right to opt out of the use of their personal information for targeted advertising (including online behavior advertising) and/or opt-out of the sale of their personal information by emailing us at privacy@musaffa.com.

IMPORTANT: These rights are not absolutely guaranteed and there are several exceptions where we may not have an obligation to fulfill your request. We are only required to honor these rights to the extent we act as a controller of that data and the requested rights have been granted and apply to you under applicable data protection laws. Please consult your local data protection laws to determine what rights may be available to you and when access to these rights is limited. You may appeal an adverse decision on your requests by emailing or writing to us at privacy@musaffa.com; and you have the right to lodge a complaint to your local regulator if you are not satisfied with our responses to your requests or how we manage your personal information. However, we encourage you to first email us at privacy@musaffa.com so we can address your concerns directly.

Additional US State Privacy Rights

This section provides additional details about the personal information we collect about California and Virginia residents and the rights afforded to them under the California Consumer Privacy Act (“CCPA”) and the Virginia Consumer Data Protection Act (“VCDPA”). Please note that the CCPA does not apply to what is referred to as nonpublic personal information collected by financial institutions, as that information is subject instead to other financial privacy laws. Additionally, the VCDPA does not apply to any entities that are financial institutions.

Subject to certain limitations and exceptions, the CCPA and VCDPA provide California and Virginia residents, respectively, with certain rights. Depending on the state in which you are a resident, you may have the right to:

Confirm whether Musaffa processes your personal information;
Correct inaccurate personal information;
Request details (in a readily usable format) about the categories and specific elements of personal information we collect;
Delete your personal information or account (for deleting your account please refer below for more details);
Opt out of any sales, sharing, targeted advertising, or profiling for certain decisions (as these terms are defined in the CCPA and/or VCDPA); and
Not be discriminated against for exercising these rights.

We do not sell information about you to third parties. In order to help Musaffa deliver advertising and marketing on other platforms, we do allow third parties to collect information through our Services. Please see the Cookie Notice for more details, including choices available to you.

We collect the following categories of personal information: identifiers (such as name, email address and IP address), Internet or other electronic network activity information (such as engagement with promotional messages and ads), and inferences (such as gender). For more details about the information we collect (including the categories of sources of this information) as well as the purposes for processing, please see the "What personal information do we collect and process" section above. We disclose this information with the categories of third parties described in the "Who do we share personal information with" section above.

California and Virginia residents may make a request to exercise rights under the CCPA and VCDPA, respectively, that are not otherwise exempt under applicable law. You may also request assistance or exercise your rights according to CCPA and VCDPA by sending an email to privacy@musaffa.com.

If you are a Musaffa app user, you can request to delete your account, for which you may email us at support@musaffa.com requesting for deletion of your account or you may request deletion of your account from within the application (to delete from within the application please go to Profile Details > select Delete Account ). Please note that the Data Protection Officer may require you to verify your identity before proceeding with your request to delete your account. We may verify the request by asking you to provide information that matches information we have on file about you. You can also designate an authorized agent to exercise these rights on your behalf, but we will require proof that the person is authorized to act on your behalf and may also still ask you to verify your identity with us directly. If you are a Virginia resident and Musaffa is unable to satisfy your request to exercise a right available to you under the VCDPA, you are entitled to appeal our decision by emailing privacy@musaffa.com.

Changes to this Privacy Policy

This Privacy Policy is expected to change over time. We reserve the right to update it at any time, for any reason. We will notify you of changes to our Privacy Policy by updating the “Last Updated” date and posting the updated Privacy Policy on this page and, in some cases, we provide additional notice (such as adding a statement to our website or sending you a notification). Changes to this Privacy Policy are effective when they are posted on this page and your continued engagement with our Services after any such revisions indicates that you accept and consent to them, so please check our Privacy Policy periodically for updates.

If there are any differences between the English version of our Privacy Policy and a version translated in another language, the English version controls.

Supplementals to Privacy Policy

Depending on the specific Service you are using or specific interactions you have with us (such as when you apply for a job or work for us), we may provide different or supplemental privacy statements or notices that describe and govern how we use your personal information. When we do so, those different or supplemental privacy statements or notices apply to that specific Service or those specific interactions. Of note, please review these supplemental privacy statements

For more information on our use of cookies and other automated technologies as well as interest-based advertising, please review our Cookie Notice

Cookie Notice

About Us

Our website musaffa.com ("Website"), any associated Musaffa mobile applications, present or future, (“Application”), are operated by, and the services available on Website and Application from time to time (“Services”) are provided by, Musaffa LLC and its Affiliates (“Musaffa”, “we”, “our” or “us”).

What is the Scope of this Cookie Notice?

This Cookie Notice supplements our Privacy Policy and specifically explains the types of cookies and other tracking technologies that we may place on your device, either when you are visiting our Website or Application or if you are using our Services through the Website or Application. Unless otherwise defined in this Cookie Notice, the terms used in this Cookie Notice have the same meanings as in our Privacy Policy and our Terms of Use.

Can our Cookie Notice change?

This notice may change from time to time. Changes to this Notice are effective when they are posted on this page and your continued engagement with our Services after any such revisions indicates that you accept and consent to them, so please check our Cookie Notice periodically for updates.

What are Cookies?

A cookie is a small amount of information that is downloaded to your computer or device when you visit certain websites. A cookie allows applications to distinguish your device from other users’ devices. Cookies make your browsing experience better by allowing the website to remember your actions and preferences (such as login and region selection). This means you do not have to re-enter this information each time you return to the site or browse from one page to another. Cookies also provide information on how people use the website, for instance whether it is their first time visiting or if they are a frequent visitor. Read more about how we use the data collected through these technologies, in our Privacy Policy.

Do Cookies hold your Personal Information?

Generally, cookies do not contain personal information unless you have already given this information to us through our Website, our Application, or Services.

What are our Main Principles and Purposes in using Cookies?

We always respect our customers’ privacy and personal information, and we take this matter very seriously. We have worked very hard to earn our customers’ trust and keeping it is our top priority. Our Website or Application uses cookies or other automatic data collection technologies to distinguish you from other Website or Application users. This helps us deliver better and more personalized Services when you browse our Website or Application. It also allows us to improve our Website and Application by enabling us to:

Estimate our audience size and usage patterns.
Store your preferences so we may customize our Website or Application according to your individual interests.
Speed up your searches.
Recognize you when you return to our Service.
Ensure a quality, consistent, and efficient experience for our users.
Analyze your usage of our Services and interactions with content (including emails).

What are the Categories of Cookies we use:

Essential Cookies are required so our Website and Application work in the way you expect. Examples of these types of cookies are login cookies which keep you logged in and move around the Website and Application and use their features.
Analytics Cookies which are used for internal analytics and include cookies from providers like Google Analytics.
Functional Cookies for customizing content and for helping to provide you with a better experience while using the Website or Applications.
Marketing Cookies which are used for advertising to you of our Services.
Third-Party tracking technologies which may use cookies to collect information about you when you use our Website or Application.

What Do We Do with the Cookies in Each Category?

Essential Cookies

We use essential cookies to remember your settings and preferences, like the language you prefer and your privacy settings.

Essential cookies let you log in and out of our Website and Application. These cookies allow you to remain logged in for the duration of your current visit to our Website or Application and enable you to take actions without having to login again.

Essential cookies are just one way we protect you from security risks. For example, we use them to detect when someone might be trying to hack your account.

Analytics Cookies

We use analytics cookies to make our Website and Application better. For example, these cookies tell us how many people use a certain feature and how popular it is, or whether people open an email we send. These cookies also inform us about crash analytics, performance analytics, and click events when a user interacts with our Website and Application

We also use cookies to help advertisers understand who sees and interacts with their ads, and who visits our Website or Application or uses our Services. These cookies collect information in an anonymous form, including the number of visitors to the Website or Application. They also allow us to calculate how long you spend on the Website or Application and to see how you arrived at them.

Sometimes we hire security vendors or use third-party analytics providers to help us understand how people are using our Website or Application. Just like we do, these providers may use cookies.

Functional Cookies

These cookies help to provide you with a better experience while using the Applications. These cookies allow the Website or Application to remember certain details about the choices you make, including: the language with which you are using the Website or Application; remembering your past visit logins (using the ‘Remember Me’ option); and browser and device description information used for fraud prevention purposes.

Marketing Cookies

These cookies allow us to display our promotional material that we think will interest you on other sites you visit across the Internet. We may also share information about your behavior on the Website or Application with third parties (including operators of third-party websites and/or social networking sites) in order to show you content that has been customized for you. We also use cookies to determine which ads users have seen, and how many times users have seen a particular ad.

Third Party Use of Cookies and other tracking technologies

Some content or applications, including advertisements, on the Website or Application are served by third parties, including advertisers, ad networks and servers, content providers, and application providers. These third parties may use cookies to collect information about you when you use our Website or Application. They may associate the information collected with your personal information or they may collect information, including personal information, about your online activities over time and across different websites or other online services. They may use this information to provide you with interest-based (behavioral) advertising or other targeted content.

We do not control how these third-party tracking technologies operate or how they may use the collected data. If you have any questions about an advertisement or other targeted content, you should contact the responsible provider directly.

Additionally, we use pixels and tags from the following third parties, which may in turn place cookies. Although we may update these tables periodically, please be advised that the names of cookies, pixels and other technologies are subject to change and the below tables may not reflect all of the third-party cookies that we use

Third Party Analytics Tracking Technology:

Third Party	Description	Privacy Policy
Microsoft Clarity	We use Microsoft Clarity to collect analytics and click events	https://privacy.microsoft.com/en-us/privacystatement
Google Analytics	We use Google Analytics to collect analytics and click events	https://policies.google.com/privacy?hl=en&gl=uk
Facebook Analytics	We use Facebook Analytics to collect analytics and click events	https://www.facebook.com/privacy/policy/
Branch	We use Branch to collect analytics data	https://legal.branch.io/#branchio-privacypolicy
MixPanel	We use MixPanel to collect analytics and click events	https://mixpanel.com/legal/privacy-policy/
MoEngage	We use MoEngage to collect analytics and click events	https://www.moengage.com/privacy-policy/

What Are Your Options to Manage Cookies?

There are a few ways you can choose how cookies are used on our Website or Application.

You may refuse to accept browser cookies by activating the appropriate setting on your browser or mobile device. However, if you select this setting, certain parts of our Website or Application may become inaccessible and certain features may not work correctly. Unless you adjust your browser settings to refuse cookies, our system will issue them.

There are also online tools such as Digital Advertising Alliance's Browser Check and European Interactive Digital Advertising Alliance's Your Online Choices site which allow you to choose how cookies are used throughout the web based on the device and browser you are using.

Your browser probably gives you cookie choices. For example, most browsers let you block “third-party cookies,” which are cookies from sites other than the one you are visiting. Those options vary from browser to browser, so check your browser settings for more info. For more information on how to modify your browser settings or how to block, manage or filter cookies can be found in your browser’s help file or through such sites as: www.aboutcookies.org.uk.

If you do not want these cookies on your device, you can change your cookie settings at any time through your web browser settings. We have supplied links to several of the more popular browsers for procedures on how to view and disable cookies.

You may opt-out of Google Analytics including AdWords and opt-out of customized Google Display Network ads by visiting the Google Ads Preferences Manager. To provide you with more choice on how your data is collected you should install the “Google Analytics Opt-out Browser Add-on” provided by Google and available from https://tools.google.com/dlpage/gaoptout.

Finally, your mobile device has settings that allow you to control whether ad partners can use information about your use of mobile applications to show ads to you. On iOS devices, this setting is called “Limit Ad Tracking” and on Android devices, this setting is called “Opt out of Ads Personalization.”

Many of the third-party advertising and other tracking services listed above offer you the opportunity to opt out of their tracking systems. You can read more about the information they collect and how to opt out through the privacy policy links listed above.

How can you contact us?

If you have any questions about this Cookie Notice or any other queries or complaints, we are here to help – please contact us via the following email: privacy@musaffa.com