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:

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:

Processing your Sensitive Personal Data: We do not seek to collect or otherwise Process your Sensitive Personal Data, except where:

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


Processing activity
Client on-boarding: on-boarding new clients; and compliance with our internal compliance requirements, policies and procedures.

Legal basis for Processing


Processing activity
Credit worthiness: conducting credit reference checks and other financial due diligence

Legal basis for Processing

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


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


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


Processing activity
IT operations: management of our communications systems; operation of IT security; and IT security audits.

Legal basis for Processing


Processing activity
Health and safety: health and safety assessments and record keeping; and compliance with related legal obligations.

Legal basis for Processing


Processing activity
Financial management: sales; finance; corporate audit; and vendor management.

Legal basis for Processing


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


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


Processing activity
Investigations: detecting, investigating and preventing breaches of policy, and criminal offences, in accordance with applicable law.

Legal basis for Processing


Processing activity
Legal compliance: compliance with our legal and regulatory obligations under applicable law.

Legal basis for Processing


Processing activity
Legal proceedings: establishing, exercising and defending legal rights.

Legal basis for Processing


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


Processing activity
Risk Management: Audit, compliance, controls and other risk management.

Legal basis for Processing


Processing activity
Fraud prevention: Detecting, preventing and investigating fraud.

Legal basis for Processing


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:

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:

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:

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:

9. Your legal rights

Subject to applicable law, you may have a number of rights regarding the Processing of your Personal Data, including:

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:

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

30 St. George Street

London W1S 2FH

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.