MVM Partners LLP Privacy Policy
1. This Policy
This Policy is issued by MVM Partners LLP (“MVM”, “we”, “us” or “our”) and is addressed to individuals outside our organisation with whom we interact, including visitors to our websites (our “Sites”), customers, Personnel of corporate customers, investors and vendors, and other recipients of our services (together, “you”). Defined terms used in this Policy are explained in Section 13 below.
This Policy may be amended or updated from time to time to reflect changes in our practices with respect to the Processing of Personal Data, or changes in applicable law. We encourage you to read this Policy carefully, and to regularly check this page to review any changes we might make in accordance with the terms of this Policy.
2. Processing your Personal Data
Collection of Personal Data: We collect Personal Data about you, subject to applicable law, from a variety of sources as follows:
- We obtain your Personal Data when you provide it to us (e.g., where you contact us via email or telephone, or by any other means).
- We collect your Personal Data in the ordinary course of our relationship with you (e.g., in the course of managing your transactions or your investment in our funds).
- We collect Personal Data that you manifestly choose to make public, including via social media (e.g., we may collect information from your social media profile(s), to the extent that you choose to make your profile publicly visible).
- We receive your Personal Data from third parties who provide it to us (e.g., your employer; credit reference agencies; law enforcement authorities; etc.).
- We receive your Personal Data from third parties, where you purchase any of our products or services through such third parties.
- We may collect or obtain Personal Data when you visit any of our Sites or use any features or resources available on or through a Site. When you visit a Site, your device and browser may automatically disclose certain information (such as device type, operating system, browser type, browser settings, IP address, language settings, dates and times of connecting to a Site and other technical communications information), some of which may constitute Personal Data.
Creation of Personal Data: We may also create Personal Data about you, such as records of your interactions with us, and details of your accounts, subject to applicable law.
Relevant Personal and Sensitive Personal Data: The categories of Personal Data about you that we may Process, subject to applicable law, are as follows:
- Personal details: given name(s); preferred name; nickname(s), gender; date of birth / age; marital status; Social Security Number; Passport number(s); other Government(s) issued numbers (tax identification number, Green Card(s) number(s) including Driving Licence number); nationality; lifestyle and social circumstances; images of Passports; images of Driving Licences; images of signatures; and photograph, visual images, personal appearance and behaviour.
- Family details: names and contact details of family members and dependents.
- Contact details: address; telephone number; fax number; email address; and social media profile details.
- Employment details: industry; role; business activities; names of current and former employers; work address; work telephone number; work fax number; work email address; and work-related social media profile details.
- Education history: details of your education and qualifications.
- Financial details: billing address; bank account numbers; cardholder or accountholder name and details; instruction records; transaction details; and counterparty details.
- Views and opinions: any views and opinions that you choose to send to us, or publish about us on (including on social media platforms).
- Electronic Identifying Data: IP address cookies, logs, online identifiers, device IDs, geolocation.
Processing your Sensitive Personal Data: We do not seek to collect or otherwise Process your Sensitive Personal Data, except where:
- The Processing is necessary for compliance with a legal obligation (e.g., to comply with diversity reporting obligations);
- The Processing is necessary for the detection or prevention of crime (including the prevention of fraud) to the extent permitted by applicable law;
- You have manifestly made those Sensitive Personal Data public;
- The Processing is necessary to protect the vital interests of any individual; or
- We have, in accordance with applicable law, obtained your prior explicit consent prior to Processing your Sensitive Personal Data (as above, this legal basis is only used in relation to Processing that is entirely voluntary – it is not used for Processing that is necessary or obligatory in any way); or
- Processing is necessary for reasons of substantial public interest and occurs on the basis of an applicable law that is proportionate to the aim pursued and provides for suitable and specific measures to safeguard your fundamental rights and interests.
We only Process Criminal Offences Data, and national identification numbers, to the extent required or permitted by applicable law.
Purposes for which we may Process your Personal Data, and legal bases for Processing: The purposes for which we may Process Personal Data, subject to applicable law, and the legal bases on which we may perform such Processing, are:
Processing activity
AML/KYC: fulfilling our regulatory compliance obligations, including ‘Know Your Client’ checks; and confirming and verifying your identity (including by using credit reference agencies); and screening against government, supranational bodies (including but not limited to the European Union and the United Nations Security Council) and/or law enforcement agency sanctions lists as well as internal sanctions lists and other legal restrictions.
Legal basis for Processing
- The Processing is necessary for compliance with a legal obligation; or
- The Processing is necessary in connection with any contract that you may enter into with us, or to take steps prior to entering into a contract with us; or
- We have a legitimate interest in carrying out the Processing for the purpose of protecting against fraud (to the extent that such legitimate interest is not overridden by your interests, fundamental rights, or freedoms); or
- We have obtained your prior consent to the Processing (this legal basis is only used in relation to Processing that is entirely voluntary – it is not used for Processing that is necessary or obligatory in any way).
Processing activity
Client on-boarding: on-boarding new clients; and compliance with our internal compliance requirements, policies and procedures.
Legal basis for Processing
- The Processing is necessary in connection with any contract that you may enter into with us, or to take steps prior to entering into a contract with us; or
- We have a legitimate interest in carrying out the Processing for the purpose of on-boarding new clients (to the extent that such legitimate interest is not overridden by your interests, fundamental rights, or freedoms).
Processing activity
Credit worthiness: conducting credit reference checks and other financial due diligence
Legal basis for Processing
- We have a legitimate interest in carrying out the Processing for the purpose of conducting financial due diligence (to the extent that such legitimate interest is not overridden by your interests, fundamental rights, or freedoms); or
- We have obtained your prior consent to the Processing (this legal basis is only used in relation to Processing that is entirely voluntary – it is not used for Processing that is necessary or obligatory in any way).
Processing activity
Provision of products and services to you: administering relationships and related services; performance of tasks necessary for the provision of the requested services; communicating with you in relation to those services.
Legal basis for Processing
- The Processing is necessary in connection with any contract that you may enter into with us, or to take steps prior to entering into a contract with us; or
- We have a legitimate interest in carrying out the Processing for the purpose of providing services to you (to the extent that such legitimate interest is not overridden by your interests, fundamental rights, or freedoms); or
- We have obtained your prior consent to the Processing (this legal basis is only used in relation to Processing that is entirely voluntary – it is not used for Processing that is necessary or obligatory in any way).
Processing activity
Marketing / Prospecting: communicating with you via any means (including via email, telephone, text message, social media, post or in person) subject to ensuring that such communications are provided to you in compliance with applicable law; and maintaining and updating your contact information where appropriate.
Legal basis for Processing
- We have a legitimate interest in carrying out the Processing for the purpose of conducting marketing and prospecting (to the extent that such legitimate interest is not overridden by your interests, fundamental rights, or freedoms); or
- We have obtained your prior consent to the Processing (this legal basis is only used in relation to Processing that is entirely voluntary – it is not used for Processing that is necessary or obligatory in any way).
Processing activity
Operation of our Sites: operation and management of our Sites; providing content to you; displaying information to you; and communicating and interacting with you via our Sites.
Legal basis for Processing
- The Processing is necessary in connection with any contract that you may enter into with us, or to take steps prior to entering into a contract with us; or
- We have a legitimate interest in carrying out the Processing for the purpose of providing services to you (to the extent that such legitimate interest is not overridden by your interests, fundamental rights, or freedoms); or
- We have obtained your prior consent to the Processing (this legal basis is only used in relation to Processing that is entirely voluntary – it is not used for Processing that is necessary or obligatory in any way).
Processing activity
IT operations: management of our communications systems; operation of IT security; and IT security audits.
Legal basis for Processing
- The Processing is necessary for compliance with a legal obligation; or
- We have a legitimate interest in carrying out the Processing for the purpose of managing and operating our IT systems and ensuring the security of those systems (to the extent that such legitimate interest is not overridden by your interests, fundamental rights, or freedoms).
Processing activity
Health and safety: health and safety assessments and record keeping; and compliance with related legal obligations.
Legal basis for Processing
- The Processing is necessary for compliance with a legal obligation; or
- We have a legitimate interest in carrying out the Processing for the purpose of providing a safe and secure environment at our premises (to the extent that such legitimate interest is not overridden by your interests, fundamental rights, or freedoms); or
- The Processing is necessary to protect the vital interests of any individual.
Processing activity
Financial management: sales; finance; corporate audit; and vendor management.
Legal basis for Processing
- We have a legitimate interest in carrying out the Processing for the purpose of providing services to you (to the extent that such legitimate interest is not overridden by your interests, fundamental rights, or freedoms); or
- We have obtained your prior consent to the Processing (this legal basis is only used in relation to Processing that is entirely voluntary – it is not used for Processing that is necessary or obligatory in any way).
Processing activity
Research: conducting market or customer satisfaction research; and engaging with you for the purposes of obtaining your views on our products and services.
Legal basis for Processing
- We have a legitimate interest in carrying out the Processing for the purpose of conducting market or customer satisfaction research (to the extent that such legitimate interest is not overridden by your interests, fundamental rights, or freedoms); or
- We have obtained your prior consent to the Processing (this legal basis is only used in relation to Processing that is entirely voluntary – it is not used for Processing that is necessary or obligatory in any way).
Processing activity
Security: physical security of our premises (including records of visits to our premises and CCTV recordings); and electronic security (including login records and access details, where you access our electronic systems).
Legal basis for Processing
- The Processing is necessary for compliance with a legal obligation; or
- We have a legitimate interest in carrying out the Processing for the purpose of ensuring the physical and electronic security of our business and our premises (to the extent that such legitimate interest is not overridden by your interests, fundamental rights, or freedoms).
Processing activity
Investigations: detecting, investigating and preventing breaches of policy, and criminal offences, in accordance with applicable law.
Legal basis for Processing
- The Processing is necessary for compliance with a legal obligation; or
- We have a legitimate interest in carrying out the Processing for the purpose of detecting, and protecting against, breaches of our policies and applicable laws (to the extent that such legitimate interest is not overridden by your interests, fundamental rights, or freedoms).
Processing activity
Legal compliance: compliance with our legal and regulatory obligations under applicable law.
Legal basis for Processing
- The Processing is necessary for compliance with a legal obligation.
Processing activity
Legal proceedings: establishing, exercising and defending legal rights.
Legal basis for Processing
- The Processing is necessary for compliance with a legal obligation; or
- We have a legitimate interest in carrying out the Processing for the purpose of establishing, exercising or defending our legal rights (to the extent that such legitimate interest is not overridden by your interests, fundamental rights, or freedoms).
Processing activity
Improving our products and services: identifying issues with existing products and services; planning improvements to existing products and services; and creating new products and services.
Legal basis for Processing
- We have a legitimate interest in carrying out the Processing for the purpose of improving our products or services (to the extent that such legitimate interest is not overridden by your interests, fundamental rights, or freedoms); or
- We have obtained your prior consent to the Processing (this legal basis is only used in relation to Processing that is entirely voluntary – it is not used for Processing that is necessary or obligatory in any way).
Processing activity
Risk Management: Audit, compliance, controls and other risk management.
Legal basis for Processing
- The Processing is necessary for compliance with a legal obligation; or
- We have a legitimate interest in carrying out the Processing for the purpose of managing the levels of risk to which our business is exposed (to the extent that such legitimate interest is not overridden by your interests, fundamental rights, or freedoms).
Processing activity
Fraud prevention: Detecting, preventing and investigating fraud.
Legal basis for Processing
- The Processing is necessary for compliance with a legal obligation; or
- We have a legitimate interest in carrying out the Processing for the purpose of detecting, and protecting against, fraud (to the extent that such legitimate interest is not overridden by your interests, fundamental rights, or freedoms).
3. Disclosure of Personal Data to third parties
We may disclose your Personal Data to other entities within the MVM group, for legitimate business purposes (including providing services to you and operating our Sites), in accordance with applicable law. In addition, we may disclose your Personal Data to:
- you and, where appropriate, your family, your associates and your representatives;
- clients and customers of our businesses;
- credit reference agencies;
- anti-fraud services;
- Governmental, legal, tax and regulatory, or similar authorities, ombudsmen, and central and/or local government agencies, upon request or where required, including for the purposes of reporting any actual or suspected breach of applicable law or regulation;
- accountants, auditors, financial and tax advisors, lawyers, notaries and other outside professional advisors to MVM or our funds, subject to binding contractual obligations of confidentiality in accordance with applicable law;
- banks, non-bank lenders, company administrators, trade and corporate registries and depositaries;
- general partners of funds we advise or manage;
- debt-collection agencies and tracing agencies;
- data aggregation services;
- accreditation bodies;
- third party Processors (such as payment services providers), located anywhere in the world, subject to the requirements noted below in this Section 3;
- any relevant party, claimant, complainant, enquirer, law enforcement agency or court, to the extent necessary for the establishment, exercise or defence of legal rights in accordance with applicable law;
- any relevant party for the purposes of prevention, investigation, detection or prosecution of criminal offences or the execution of criminal penalties, including safeguarding against and the prevention of threats to public security in accordance with applicable law;
- to any relevant party in connection with AML/KYC requirements; any relevant third party acquirer(s), in the event that we sell or transfer all or any relevant portion of our business or assets (including in the event of a reorganization, dissolution or liquidation) or the assets or business of our funds; and
- the press and the media.
Our Sites may use third party plugins or content. If you choose to interact with any such plugins or content, your Personal Data may be shared with the third party provider of the relevant social media platform. We recommend that you review that third party’s privacy policy before interacting with its plugins or content.
If we engage a third-party Processor to Process your Personal Data, the Processor will be subject to binding contractual obligations to: (i) only Process the Personal Data in accordance with our prior written instructions; and (ii) use measures to protect the confidentiality and security of the Personal Data; together with any additional requirements under applicable law.
4. International transfer of Personal Data
Because of the international nature of our business, we may need to transfer your Personal Data within the MVM group, and to third parties as noted in Section 3 above, in connection with the purposes set out in this Policy. For this reason, we may transfer your Personal Data to other countries that may have different laws and data protection compliance requirements, including data protection laws of a lower standard, to those that apply in the country in which you are located.
Where we transfer your Personal Data to other countries, we do so on the basis of:
- European Commission’s adequacy decisions;
- our binding corporate rules;
- suitable standard contractual clauses; or
- other valid transfer mechanisms.
If you want to receive more information about the safeguards applied to international transfers of personal data, please use the contact details provided in Section 12 below.
5. Data Security
Although it is impossible to guarantee absolute security, we have implemented appropriate technical and organizational security measures designed to protect your Personal Data against accidental or unlawful destruction, loss, alteration, unauthorised disclosure, unauthorised access, and other unlawful or unauthorised forms of Processing, in accordance with applicable law.
You are responsible for ensuring that any Personal Data that you send to us are sent securely.
6. Data Accuracy
We take reasonable steps designed to ensure that:
- your Personal Data that we Process are accurate and, where necessary, kept up to date; and
- any of your Personal Data that we Process that are inaccurate (having regard to the purposes for which they are Processed) are erased or rectified without delay.
From time to time we may ask you to confirm the accuracy of your Personal Data.
7. Data Minimisation
We take reasonable steps designed to ensure that your Personal Data that we Process are limited to the Personal Data reasonably required in connection with the purposes set out in this Policy.
8. Data Retention
We take every reasonable step to ensure that your Personal Data are only Processed for the minimum period necessary for the purposes set out in this Notice. The criteria for determining the duration for which we will retain your Personal Data are as follows:
(1) we will retain copies of your Personal Data in a form that permits identification only for as long as:
a. we maintain an ongoing relationship with you (e.g., where you are a recipient of our services, or you are lawfully included in our mailing list and have not unsubscribed); or
b. your Personal Data are necessary in connection with the lawful purposes set out in this Notice, for which we have a valid legal basis (e.g., where your personal data are included in a contract between us and your employer, and we have a legitimate interest in processing those data for the purposes of operating our business and fulfilling our obligations under that contract; where we have a legal obligation to retain your Personal Data; or where we consider that we may need to contact you in future for legitimate business reasons),
plus:
(2) the duration of:
a. any applicable limitation period under applicable law (i.e., any period during which any person could bring a legal claim against us in connection with your Personal Data, or to which your Personal Data may be relevant); and
b. an additional two (2) month period following the end of such applicable limitation period (so that, if a person brings a claim at the end of the limitation period, we are still afforded a reasonable amount of time in which to identify any Personal Data that are relevant to that claim),
and:
(3) in addition, if any relevant legal claims are brought, we may continue to Process your Personal Data for such additional periods as are necessary in connection with that claim.
During the periods noted in paragraphs (2)a and (2)b above, we will restrict our Processing of your Personal Data to storage of, and maintaining the security of, those data, except to the extent that those data need to be reviewed in connection with any legal claim, or any obligation under applicable law.
Once the periods in paragraphs (1), (2) and (3) above, each to the extent applicable, have concluded, we will either:
- permanently delete or destroy the relevant Personal Data;
- archive your Personal Data so that it is beyond use; or
- anonymize the relevant Personal Data.
9. Your legal rights
Subject to applicable law, you may have a number of rights regarding the Processing of your Personal Data, including:
- the right to request access to, or copies of, your Personal Data that we Process or control, together with information regarding the nature, processing and disclosure of those Personal Data;
- the right to request rectification of any inaccuracies in your Personal Data that we Process or control;
- the right to request, on legitimate grounds:
- erasure of your Personal Data that we Process or control; or
- restriction of Processing of your Personal Data that we Process or control;
- the right to have your Personal Data that we Process or control transferred to another Controller, to the extent applicable;
- restriction of Processing of your Personal Data that we Process or control;
- where we Process your Personal Data on the basis of your consent, the right to withdraw that consent; and
- the right to lodge complaints with a Data Protection Authority regarding the Processing of your Personal Data by us or on our behalf.
This does not affect your statutory rights.
Subject to applicable law, you may also have the following additional rights regarding the Processing of your Personal Data:
- the right to object, on grounds relating to your particular situation, to the Processing of your Personal Data by us or on our behalf; and
- the right to object to the Processing of your Personal Data by us or on our behalf for direct marketing purposes.
To exercise one or more of these rights, or to ask a question about these rights or any other provision of this Policy, or about our Processing of your Personal Data, please use the contact details provided in Section 12 below.
10. Cookies
A cookie is a small file that is placed on your device when you visit a website (potentially including our Sites). It records information about your device, your browser and, in some cases, your preferences and browsing habits. We may Process your Personal Data through cookie technology, in accordance with our Cookie Policy.
11. Direct Marketing
We may Process your Personal Data to contact you, primarily by email and also on occasion by mail or by telephone, so that we can provide you with information concerning products and services that may be of interest, in accordance with applicable law.
If you do not wish to receive marketing communications from us you can opt out at any time by contacting your regular MVM contact. After you unsubscribe, we will not send you further promotional emails, but we may continue to contact you to the extent necessary for the purposes of any Services you have requested.
12. Contact details
If you have any comments, questions or concerns about any of the information in this Policy, or any other issues relating to the Processing of Personal Data by MVM, please contact your regular MVM contact, or:
020 7557 7500
info@mvm.com
MVM Partners LLP
38 Wigmore Street
London W1U 2RU
United Kingdom
13. Defined terms
Controller
The entity that decides how and why Personal Data is Processed. In many jurisdictions, the Controller has primary responsibility for complying with applicable data protection laws.
Data Protection Authority
An independent public authority that is legally tasked with overseeing compliance with applicable data protection laws.
Personal Data
Information that is about any individual, or from which any individual is identifiable.
Process or Processed or Processing
Anything that is done with any Personal Data, whether or not by automated means, such as collection, recording, organisation, structuring, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, alignment or combination, restriction, erasure or destruction.
Personnel
Any current, former and prospective directors, officers, consultants, employees, temporary staff, individual contractors, interns, secondees and other personnel.
Processor
Any person or entity that Processes Personal Data on behalf of the Controller (other than employees of the Controller).
Sensitive Personal Data
Personal Data about race or ethnicity, political opinions, religious or philosophical beliefs, trade union membership, physical or mental health, sexual life, or any other information that may be deemed to be sensitive under applicable law.
Criminal Offences Data
Personal data about any actual or alleged criminal offences or penalties.
Cookies
We use cookies to ensure you get the best experience on our website. They are listed below:
ARRAffinity
Used for load balancing to make sure page requests are routed to the same server in any browsing session. This cookie is deemed Strictly Necessary.
__AntiXsrfToken
A security cookie used to prevent cross-scripting attacks – this cookie is anonymous.
_ga and _gat
Google Universal Analytics – 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 site’s analytics reports.
MVM Partners, LLC Privacy Policy
We respect your privacy and are committed to protecting it through our compliance with this privacy policy (“Policy”). This Policy describes the types of information we may collect from you or that you may provide (“Personal Information”) on the mvm.com website (“Website” or “Service”) or elsewhere and any related products and services (collectively, “Services”), and our practices for collecting, using, maintaining, protecting, and disclosing that Personal Information. It also describes the choices available to you regarding our use of your Personal Information and how you can access and update it.
This Policy is a legally binding agreement between you (“User”, “you” or “your”) and MVM Partners, LLC (“MVM Partners, LLC”, “we”, “us” or “our”). If you are entering into this Policy on behalf of a business or other legal entity, you represent that you have the authority to bind such entity to this Policy, in which case the terms “User”, “you” or “your” shall refer to such entity. If you do not have such authority, or if you do not agree with the terms of this Policy, you must not accept this Policy and may not access and use the Website and Services. By accessing and using the Website and Services, you acknowledge that you have read, understood, and agree to be bound by the terms of this Policy. This Policy does not apply to the practices of companies that we do not own or control, or to individuals that we do not employ or manage.
Collection of information
We collect Personal Information about you, subject to applicable law, from a variety of sources as follows:
- We obtain your Personal Information when you provide it to us (e.g., where you contact us via email or telephone, or by any other means).
- We collect your Personal Information in the ordinary course of our relationship with you (e.g., in the course of managing your transactions or your investment in our funds).
- We collect Personal Information that you manifestly choose to make public, including via social media (e.g., we may collect information from your social media profile(s), to the extent that you choose to make your profile publicly visible).
- We receive your Personal Information from third parties who provide it to us (e.g., your employer; credit reference agencies; law enforcement authorities; etc.).
- We receive your Personal Information from third parties, where you purchase any of our products or services through such third parties.
- We may collect or obtain Personal Information when you visit our Website or use any features or resources available on or through the Website. When you visit the Website, your device and browser may automatically disclose certain information (such as device type, operating system, browser type, browser settings, IP address, language settings, dates and times of connecting to the Website and other technical communications information), some of which may constitute Personal Information.
Use and processing of collected information
We act as a data controller and a data processor when handling Personal Information, unless we have entered into a data processing agreement with you in which case you would be the data controller and we would be the data processor.
Our role may also differ depending on the specific situation involving Personal Information. We act in the capacity of a data controller when we ask you to submit your Personal Information that is necessary to ensure your access and use of the Website and Services. In such instances, we are a data controller because we determine the purposes and means of the processing of Personal Information.
We act in the capacity of a data processor in situations when you submit Personal Information through the Website and Services. We do not own, control, or make decisions about the submitted Personal Information, and such Personal Information is processed only in accordance with your instructions. In such instances, the User providing Personal Information acts as a data controller.
In order to make the Website and Services available to you, or to meet a legal obligation, we may need to collect and use certain Personal Information. If you do not provide the information that we request, we may not be able to provide you with the requested products or services. Any of the information we collect from you may be used for the following purposes:
- Create and manage user accounts
- Deliver products or services
- Send administrative information
- Send marketing and promotional communications
- Send product and service updates
- Respond to inquiries and offer support
- Respond to legal requests and prevent harm
- Run and operate the Website and Services
Processing your Personal Information depends on how you interact with the Website and Services, where you are located in the world and if one of the following applies: (a) you have given your consent for one or more specific purposes; (b) provision of information is necessary for the performance of this Policy with you and/or for any pre-contractual obligations thereof; (c) processing is necessary for compliance with a legal obligation to which you are subject; (d) processing is related to a task that is carried out in the public interest or in the exercise of official authority vested in us; (e) processing is necessary for the purposes of the legitimate interests pursued by us or by a third party.
Note that under some legislations we may be allowed to process information until you object to such processing by opting out, without having to rely on consent or any other of the legal bases. In any case, we will be happy to clarify the specific legal basis that applies to the processing, and in particular whether the provision of Personal Information is a statutory or contractual requirement, or a requirement necessary to enter into a contract.
Disclosure of information
Depending on the requested Services or as necessary to complete any transaction or provide any Service you have requested, we may share your non-personally identifiable information with our trusted subsidiaries, affiliates and joint venture partners, contracted companies, and service providers (collectively, “Service Providers”) we rely upon to assist in the operation of the Website and Services available to you and whose privacy policies are consistent with ours or who agree to abide by our policies with respect to your information. We will not share any information with unaffiliated third parties.
Service Providers are not authorized to use or disclose your information except as necessary to perform services on our behalf or comply with legal requirements. Service Providers are given the information they need only in order to perform their designated functions, and we do not authorize them to use or disclose any of the provided information for their own marketing or other purposes.
We may also disclose any Personal Information we collect, use or receive if required or permitted by law, such as to comply with a subpoena or similar legal process, and when we believe in good faith that disclosure is necessary to protect our rights, protect your safety or the safety of others, investigate fraud, or respond to a government request.
In the event we go through a business transition, such as a merger or acquisition by another company, or sale of all or a portion of its assets, your Personal Information will likely be among the assets transferred.
Retention of information
We will retain and use your Personal Information for the period necessary to comply with our legal obligations, as long as your user account remains active, until the purchase order or Services are fulfilled, to enforce our Policy, resolve disputes, and unless a longer retention period is required or permitted by law.
We may use any aggregated data derived from or incorporating your Personal Information after you update or delete it, but not in a manner that would identify you personally. Once the retention period expires, Personal Information shall be deleted. Therefore, the right to access, the right to erasure, the right to rectification, and the right to data portability cannot be enforced after the expiration of the retention period.
Transfer of information
Depending on your location, data transfers may involve transferring and storing your Personal Information in a country other than your own, including the United Kingdom and the European Union. Where required by applicable laws, we will ensure that such transfers are based on appropriate legal grounds, including obtaining your explicit consent or implementing necessary safeguards to protect your Personal Information.
You are entitled to learn about the legal basis of such transfers and the measures we take to ensure the security of your Personal Information. If you would like more details, please refer to the relevant sections of this policy or contact us using the information provided. We are committed to protecting your Personal Information and complying with applicable data protection laws when processing personal information across different jurisdictions.
Region specific notices
Out of respect for your privacy, we have implemented additional measures to comply with the obligations and rights associated with the collection of Personal Information as dictated by the laws governing the regions of our users.
Disclosures for residents of the USA
If you are a resident of certain states, you may have certain additional rights and we aim to take reasonable steps to allow you to correct, amend, delete, or limit the use of your Personal Information. This supplemental section, together with other relevant sections of the Policy, provides information about your rights and how to exercise them under the California Consumer Privacy Act and the California Privacy Rights Act (collectively, “CCPA”), the Colorado Privacy Act (“CPA”), the Connecticut Data Privacy Act (“CDPA”), the Delaware Online Privacy and Protection Act (“DOPPA”), the Iowa Consumer Data Protection Act (“ICDPA”), the Maryland Personal Information Protection Act (“PIPA”), the Utah Consumer Privacy Act (“UCPA”), the Virginia Consumer Data Protection Act (“VCDPA”), and any and all regulations arising therefrom. Unless otherwise expressly stated, all terms in this section have the same meaning as defined in the related state laws.
In addition to the rights as explained in this Policy, if you provide Personal Information as defined in the statute to obtain Services for personal, family, or household use, you have the right to submit requests related to your Personal Information once a calendar year. Note that there are circumstances when we may not be able to comply with your request such as when we are not able to verify your request or find that providing a full response conflicts with other legal obligations or regulatory requirements. You will be notified if it’s the case.
(a) Right to know and right to access: You have the right to request certain information we have collected about you. Once we receive and confirm a verifiable request from you, we will disclose to you, to the extent permitted by law:
- The specific pieces of Personal Information we hold about you.
- The categories of sources from which Information about you is collected.
- The purposes for collecting, selling, or sharing your Personal Information.
You have the right to request that the Personal Information is delivered in a format that is both portable and easily usable, as long as it is technically possible to do so.
(b) Right to correct: You have the right to request that we correct your inaccurate Personal Information taking into account the nature of the Personal Information and the purposes of the processing of the Personal Information.
(c) Right to delete: You have the right to request deletion of your Personal Information.
(d) Right to opt-out of the sale and sharing: You have the right to opt-out of the sale of your Personal Information which may include selling, disclosing, or transferring Personal Information to another business or a third party for monetary or other valuable consideration.
(e) Right to consent to or limit the use of your sensitive personal information: You have the right to consent to the use of your Sensitive Personal information and to direct us to restrict its use and disclosure solely to what is essential for carrying out or delivering the Services in a manner reasonably anticipated by an average user, or for certain business objectives as specified by law. However, we do not use Sensitive Personal Information for any purposes other than those legally permitted or beyond the scope of your consent.
(f) Right to non-discrimination: You have the right to not be discriminated against in the Services or quality of Services you receive from us for exercising your rights. We may not, and will not, treat you differently because of your data subject request activity, and we may not and will not deny goods or Services to you, charge different rates for goods or Services, provide a different level quality of goods or Services, or suggest that we would treat you differently because of your data subject request activity.
To exercise any of your rights, simply contact us using the details below. After we receive and verify your request, we will process it to the extent possible within our capabilities.
Other countries and general privacy rights
If you reside in a country other than the United States, we are committed to protecting your personal data in accordance with internationally recognized privacy principles. Users from other regions may have rights similar to those outlined above and other data protection laws. These rights may include:
- The right to access, correct, or delete your personal data.
- The right to restrict or object to certain types of processing.
- The right to withdraw consent for data processing.
- The right to data portability, where applicable.
- The right to opt out of targeted advertising and data sales, where required by law.
- The right to file a grievance with a relevant data protection authority.
- The right to nominate a representative to exercise your privacy rights on your behalf, if permitted by applicable regulations.
How to exercise your rights
Any requests to exercise your rights can be directed to us through the contact details provided in this document. Please note that we may ask you to verify your identity before responding to such requests. Your request must provide sufficient information that allows us to verify that you are the person you are claiming to be or that you are the authorized representative of such person. If we receive your request from an authorized representative, we may request evidence that you have provided such an authorized representative with power of attorney or that the authorized representative otherwise has valid written authority to submit requests on your behalf.
You must include sufficient details to allow us to properly understand the request and respond to it. We cannot respond to your request or provide you with Personal Information unless we first verify your identity or authority to make such a request and confirm that the Personal Information relates to you.
Cookies
Our Website and Services use “cookies” to help personalize your online experience. A cookie is a text file that is placed on your hard disk by a web page server. Cookies cannot be used to run programs or deliver viruses to your computer. Cookies are uniquely assigned to you, and can only be read by a web server in the domain that issued the cookie to you.
We may use cookies to collect, store, and track information for security and personalization, and for statistical purposes. Please note that you have the ability to accept or decline cookies. Most web browsers automatically accept cookies by default, but you can modify your browser settings to decline cookies if you prefer.
Data analytics
Our Website and Services may use third-party analytics tools that use cookies, web beacons, or other similar information-gathering technologies to collect standard internet activity and usage information. The information gathered is may be used to compile statistical reports on User activity such as how often Users visit our Website and Services, what pages they visit and for how long, etc. We may use the information obtained from these analytics tools to monitor the performance and improve our Website and Services.
Privacy of children
We recognize the need to provide further privacy protections with respect to Personal Information we may collect from children and take special precautions to protect their privacy. We may require a child to disclose some Personal Information to use the Services. All of the information created or submitted by a child will be treated as private by default, meaning it will not be made publicly available and access will be restricted within MVM’s systems. Parents and legal guardians can review their child’s Personal Information, delete it, and refuse to allow any further collection or use of such information.
Do Not Track signals
Some browsers incorporate a Do Not Track feature that signals to websites you visit that you do not want to have your online activity tracked. Tracking is not the same as using or collecting information in connection with a website. For these purposes, tracking refers to collecting personally identifiable information from users who use or visit a website or online service as they move across different websites over time. How browsers communicate the Do Not Track signal is not yet uniform. As a result, the Website and Services are not yet set up to interpret or respond to Do Not Track signals communicated by your browser. Even so, as described in more detail throughout this Policy, we limit our use and collection of your Personal Information. For a description of Do Not Track protocols for browsers and mobile devices or to learn more about the choices available to you, visit internetcookies.com
Email marketing
We offer electronic newsletters to certain Users. We are committed to keeping your email address confidential and will not disclose your email address to any third parties except as allowed in the information use and processing section or for the purposes of utilizing a third-party provider to send such emails. We will maintain the information sent via email in accordance with applicable laws and regulations.
In compliance with the CAN-SPAM Act, all emails sent from us will clearly state who the email is from and provide clear information on how to contact the sender. You may choose to stop receiving our newsletter by following the unsubscribe instructions included in these emails or by contacting us.
Links to other resources
The Website and Services contain links to other resources that are not owned or controlled by us. Please be aware that we are not responsible for the privacy practices of such other resources or third parties. We encourage you to be aware when you leave the Website and Services and to read the privacy statements of each and every resource that may collect Personal Information.
Information security
We secure information you provide on computer servers in a controlled, secure environment, protected from unauthorized access, use, or disclosure. We maintain reasonable administrative, technical, and physical safeguards in an effort to protect against unauthorized access, use, modification, and disclosure of Personal Information in our control and custody. However, no data transmission over the Internet or wireless network can be guaranteed.
Therefore, while we strive to protect your Personal Information, you acknowledge that (a) there are security and privacy limitations of the Internet which are beyond our control; (b) the security, integrity, and privacy of any and all information and data exchanged between you and the Website and Services cannot be guaranteed; and (c) any such information and data may be viewed or tampered with in transit by a third party, despite best efforts.
Data breach
In the event we become aware that the security of the Website and Services has been compromised or Users’ Personal Information has been disclosed to unrelated third parties as a result of external activity, including, but not limited to, security attacks or fraud, we reserve the right to take reasonably appropriate measures, including, but not limited to, investigation and reporting, as well as notification to and cooperation with law enforcement authorities.
In the event of a data breach, we will make reasonable efforts to notify affected individuals if we believe that there is a reasonable risk of harm to the User as a result of the breach or if notice is otherwise required by law. In jurisdictions where required, we may also report the breach to relevant authorities in accordance with applicable data protection regulations.
Changes and amendments
We reserve the right to modify this Policy or its terms related to the Website and Services at any time at our discretion. When we do, we will revise the updated date at the bottom of this page. We may also provide notice to you in other ways at our discretion, such as through the contact information you have provided.
An updated version of this Policy will be effective immediately upon the posting of the revised Policy unless otherwise specified. Your continued use of the Website and Services after the effective date of the revised Policy (or such other act specified at that time) will constitute your consent to those changes. However, we will not, without your consent, use your Personal Information in a manner materially different than what was stated at the time your Personal Information was collected.
Acceptance of this policy
You acknowledge that you have read this Policy and agree to all its terms and conditions. By accessing and using the Website and Services and submitting your information you agree to be bound by this Policy. If you do not agree to abide by the terms of this Policy, you are not authorized to access or use the Website and Services.
Contacting us
If you have any questions, concerns, or complaints regarding this Policy, the information we hold about you, or if you wish to exercise your rights, we encourage you to contact us using the details below:
info@mvm.com
We will attempt to resolve complaints and disputes and make every reasonable effort to honor your wish to exercise your rights as quickly as possible and in any event, within the timescales provided by applicable data protection laws.
If you believe your concerns have not been adequately addressed, you may escalate the matter to the appropriate data protection authority in your region, in accordance with applicable privacy laws.